ML20063H114

Motion for Admission of Second Suppl to Petition to Intervene

ML20063H114
Person / Time
Site:	Skagit
Issue date:	07/16/1982
From:	Wapato S COLUMBIA RIVER INTER-TRIBAL FISH COMMISSION
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20063H109	List: ML20063H108 ML20063H111 ML20063H114 ML20063H119 ML20063H122 ML20063H127
References
NUDOCS 8209010332
Download: ML20063H114 (2)

Text

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UNITED STATES OF AMERICA >

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter of Puget Sound Power and Light, et al.

Docket Nos.

Amended Application for Construction STN 50-522, 50-523 Permits and Facility Licenses, SKAGIT/HANFORD NUCLEAR PROJECT COLUMBIA RIVER INTER-TRIBAL FISH COMMISSION'S MOTION FOR ADMISSION OF SECOND SUPPLEMENT l0 PETITION TO INTERVENE On May 5,1982, Petitioner Columbia River Inter-Tribal Fish Coninission (CRITFC) filed its Petition to Intervene in the above-captioned proceeding together with a Supplement to Petition to Intervene. On May 19, 1982, applicant, Puget. Sound Power and Light Company, filed its Response in Opposition to Untimely Petition to Intervene objecting to the timeliness of the CRITFC petition and to the specificity and basis for petitioner's contention but concluding that CRITFC's Petition to Intervene satisfied the standing requirements of commission regula-tions 10 C.F.R. 2.714(a)(2). On June 14, 1982, the NRC staff served its Response to Untimely Petition to Intervene by CRITFC and the Yakima Inif an Nation. The NRC staff concluded that Petitioner, CRITFC, satisfied the stand-ing requirements and that the balance of the five factors set out in 10 C.F.R. 2.714(a)(1) weighed in favor of CRITFC being permitted to Intervene in this proceeding. The NRC staff, however, objected to certain contentions.

, In light of the objections specified by the NRC staff and the applicant, and I

certain recent changes in the conmission's regulatory scheme, Petitioner CRITFC, 8209010332 820716

. PDR ADOCK 05000S22 G PDR l

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has prepared a Second Supplement to Petition to Intervene, which amends the ,

original supplement in certain respects, while retaining contentions 1,2, and I

3 essentially unchanged. Pursuant to commission regulation 10 C.F.R. 2.714(a)

(3) Petitioner,CRITFC,hereby moves the Board to admit its amended contentions and bases, as set forth in its Second Supplement, and to reject the objections raised by applicants and staff to CRITFC contentions.

In support of this motion, CRITFC has filed a memorandum justifying the amend-ments contained in its Second Supplement, pursuant to 10 C.F.R. 2.714 (a).

In addition, the Memorandum discusses CRITFC position on its consolidation with other parties.

Respectfully Submitted, bw S. Timothy Wapato/

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Dated this /hday'kof July,1982.

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