|
|---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20039E9551982-01-0606 January 1982
Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 821222 Petition for Review.Request Untimely & Unsupported.Matters Should Have Been Raised Before Aslab.Certificate of Svc Encl
ML20039D8371981-12-29029 December 1981
Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc.811218 Petition for Stay of Aslab 811207 Decision.Intervenors Failed to Seek Stay of ALAB-622 from Aslab.Certificate of Svc Encl
ML20039C6971981-12-22022 December 1981
Petition for Review.Commission Should Remand Case to ASLB for ASLB to Delineate & Impose Conditions Upon Applicant for Granting Dismissal of CP Application W/O Prejudice. Certificate of Svc
ML20069A9931981-12-18018 December 1981
Petition for Stay of Aslab 811207 decision,ALAB-622, Dismissing Proceeding W/O Prejudice.Certificate of Svc Encl
ML20010D1621981-08-0303 August 1981
Request for Consolidation W/Fulton Proceeding & for 15-day Extension to File Brief.Instant Case & Fulton Proceeding Present Common Question of Law & Fact.Certificate of Svc Encl
ML20010B2831981-08-0303 August 1981
Motion to Consolidate Fulton Case & for Extension of 15 Days to File Brief.Cases Present Common Question of Law & Fact. Intervenor Illness Necessitates Extension of Time
ML20009E4291981-07-21021 July 1981
Petition for Reconsideration & Request for Extension of Time to File Brief.Belated Mailing of Microfiche Collection & NRC Issuances Adversely Affects Intervenor Opportunity to Conduct Necessary Research
ML19352B3371981-06-29029 June 1981
Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 810613 Motion to File Sworn Statements.Intervenors Failed to Justify Reopening of Record
ML20005A9051981-06-29029 June 1981
Notice of Appearance Re Facility.Certificate of Svc Encl
ML19351A1671981-06-16016 June 1981
Comments on Various Matters in Proceeding.Intervenors Concerned That Aslab 810611 Order Does Not Mention Compelling ASLB to Keep Record Open on Applicant Past Performance.Certificate of Svc Encl
ML20004F7621981-06-13013 June 1981
Motion for Leave to File Encl Sworn Statements as Evidence of Damage to Public Interest Which Would Be Caused & Remain If Application Dismissal W/O Prejudice Were Sustained on Appeal.Certificate of Svc Encl
ML20004E8961981-06-0606 June 1981
Petition to Reconsider Aslab 810601 Order Denying Intervenors' 810512 Request for Extension of Time to File Brief.Requests Aslab Investigation Into NRC Failure to Serve NRC Response to Intervenors' Request.W/Certificate of Svc
ML20004B6321981-05-21021 May 1981
Response to G Fernos & Citizens for Conservation of Natural Resources Notice of Appeal & Request for Extension of Time to File Brief.Opposes Delay in Filing.Leave to File Appeal Granted Earlier.Certificate of Svc Encl
ML19347F6291981-05-12012 May 1981
Notice of Appeal of ASLB 810218 Memorandum & Order. Intervenors Take Exception to Granting Applicant Motion to Terminate Proceeding & Granting Withdrawal of Application W/O Prejudice.Certificate of Svc Encl
ML20003J3821981-04-25025 April 1981
Response Opposing Applicant 810417 Response to Intervenor Petition for Temporary Stay & Extension of Time.Applicant Motion Lacks Support & Time to File Appeal Has Not Expired. Certificate of Svc Encl
ML17328B0611981-04-17017 April 1981
Response Opposing G Fernos & Citizens for Conservation of Natural Resources 810406 Request for Stay of ASLB 810218 & 0326 Decisions & Petition for Extension of Time to File Appeal.Certificate of Svc Encl
ML19347D9201981-04-0606 April 1981
Request for Extension Until 810515 to File Appeal & for Stay of ASLB 810218 & 0326 Orders Granting Applicant Withdrawal of Application W/O Prejudice & Denying Intervenor Petition for Reconsideration,Respectively.Certificate of Svc Encl
ML19350B5271981-03-12012 March 1981
Answer Opposing G Fernos 810303 Request for Reconsideration of ASLB 810218 Order Granting Withdrawal W/O Prejudice of Util Application.Also Opposes Request to Stay Decision.No New Info Presented.Certificate of Svc Encl
ML19347D2291981-03-0303 March 1981
Request for Reconsideration of ASLB 810218 Order Granting Application Withdrawal W/O Prejudice.Applicant Actions & Clear Lack of Necessity for Plant Demand That Dismissal Be W/Prejudice.Certificate of Svc Encl
ML20002C0871980-12-31031 December 1980
Reply to Intervenor 801203 Submittal Stating Withdrawal Application Should Be Dismissed W/Prejudice.Accusation of Hidden,Deceitful Action Is Unsubstantiated.Proceeding Should Be Terminated W/O Prejudice.W/Certificate of Svc
ML19351F1431980-12-0303 December 1980
Reply to Applicant & NRC Contention That Withdrawn Application Should Not Be Dismissed W/Prejudice.Urges That Application Be Dismissed W/Prejudice.Certificate of Svc Encl
ML19351C8811980-10-0303 October 1980
Response in Opposition to Citizens for Conservation of Natural Resources Motion for Direct Certification Urging Dismissal of Application W/Prejudice.Future Applications May Not Be Barred Unless Public Harmed.Certificate of Svc Encl
ML19332B4051980-09-18018 September 1980
Motion for Stay of Proceeding Until Commission Rules Upon Direct Certification Seeking Dismissal of Application W/ Prejudice.Certificate of Svc Encl
ML19332B4041980-09-18018 September 1980
Addendum to 800917 Motion for Direct Certification Which Requested That CP Application Be Dismissed W/Prejudice. Applicant Withdrawal Evading Direct Confrontation W/Issues Raised & Litigated for 5 Yrs Is Unfair.W/Certificate of Svc
ML19332B3971980-09-17017 September 1980
Motion for Direct Certification Requesting That CP Application Be Dismissed W/Prejudice Rather than Accepting Applicant Withdrawal Terminating Proceeding.Certificate of Svc Encl
ML19332A9111980-09-13013 September 1980
Requests Commission Take No Action Re ALAB-605.Intervenor Must Present Case to ASLB Before Commission Acts to Review ALAB-605.Intervenor Counsel in Hosp Until After Commission Action Deadline of 800919.Certificate of Svc Encl
ML19332A4911980-09-11011 September 1980
Motion for Termination of Proceeding Due to Encl Withdrawal of Application.Certificate of Svc Encl
ML19332A4891980-09-11011 September 1980
Motion for Withdrawal of Application for CP
ML19332A1801980-09-0303 September 1980
Motion Advising of Temporary Substitution of Author.Requests Incorporation of T Morales on Svc List in Absence. W/Certificate of Svc
ML19332A1931980-09-0303 September 1980
Interrogatories & Request for Production of Documents Directed to Applicant.Questions Applicant Financial Statement Re Past & Future Total Investment in Project. Certificate of Svc Encl
ML19331D9091980-08-27027 August 1980
Motion for Ruling on Intervenor 800718 Submission Seeking Legal Assistance During Hearings Plus Round Trip Travel & Lodging Expenses for Counsel.Certificate of Svc Encl
ML19331D9071980-08-27027 August 1980
Motion for Clarification of Scope of Single Issue to Be Tried in ASLB 800819 Order Re Intervenor 800430 Petition on Lack of Intention to Build.Draws Attention to Util Inaction & Contradictory Actions.W/Certificate of Svc
ML19331B7341980-08-0404 August 1980
Response to Applicants' 800718 Memorandum Alleging That ASLB Has No Jurisdiction to Dismiss CP Application as Moot.Urges Reversal of ASLB 800529 Order in Order to Address Merits of Intervenors' 800430 Request.W/Certification of Svc
ML19321A5071980-07-18018 July 1980
Response to NRC 800627 Memorandum,In Reply to Aslab 800630 Order.Interlocutory Review of ASLB Order Re Dismissal of CP Application W/O Hearing on Health,Safety & Environ Is Not Warranted.Certificate of Svc Encl
ML19321A6281980-07-18018 July 1980
Memorandum in Response to Aslab 800604 Order Re Validity of ASLB 800529 Order Denying Petition to Intervene.Urges Reversal of ASLB Order & Institution of Hearings. Certificate of Svc Encl
ML19320C2721980-07-0909 July 1980
Motion Seeking Option to Respond to Applicant by 800808,if Applicant Responds to NRC 800627 Memorandum by 800718,re Aslab 800630 Order.Certificate of Svc Encl
ML19320A7771980-06-27027 June 1980
Memorandum in Response to Aslab 800604 Order.Interlocutory Review of ASLB Order Denying G Fernos Petition to Dismiss Application Not Warranted Unless Legal Boundaries Are Not Explored.W/Certificate of Svc
ML19312E9181980-05-19019 May 1980
Response in Opposition to Intervenor G Fernos 800430 Request for Issuance of Order to Show Cause Why Application Should Not Be Dismissed.No Time Frame Requirememts Exist for License Processing.W/Certificate of Svc
ML19318A2771980-04-30030 April 1980
Petition Urging ASLB to Hold Evidentiary Hearings to Request Applicant to Show Cause Why Application Should Not Be Dismissed Due to Lack of Intention to Build.Requests Costs & Damages.W/Certificate of Svc & Supporting Documents
ML19209B8361979-08-31031 August 1979
Status Rept as of 790831.Natl Academy of Sciences Is Studying Overall Energy Situation in Pr.Portion of Study Is Being Prepared by Electric Power Sys Subcommittee. Certificate of Svc Encl
ML20076B1551979-04-30030 April 1979
Status Rept by Puerto Rico Water Resources Authority Re Facility Application,As of 790430.Electric Power Sys Will Issue Rept by Late May.Certificate of Svc Encl
ML19263B6711978-12-29029 December 1978
Status Rept as of 781229 Re Puerto Rico Water Resources Authority'S Application.Internal Review of Generation Expansion Not Yet Completed.Westinghouse Contract Re Nuclear Steam Supply Sys Cancelled.W/Certificate of Svc
ML20148C4311978-10-16016 October 1978
Discovery Status Rept as of 781016.Internal Review Incomplete.Requests That NRC Issue Site Safety Review Re Seismicity & Geology.Applicant Does Not Expect to File Motions in Near Future.Certificate of Svc Encl
1982-01-06
[Table view]
Category:PLEADINGS
MONTHYEARML20039E9551982-01-0606 January 1982
Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 821222 Petition for Review.Request Untimely & Unsupported.Matters Should Have Been Raised Before Aslab.Certificate of Svc Encl
ML20039D8371981-12-29029 December 1981
Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc.811218 Petition for Stay of Aslab 811207 Decision.Intervenors Failed to Seek Stay of ALAB-622 from Aslab.Certificate of Svc Encl
ML20039C6971981-12-22022 December 1981
Petition for Review.Commission Should Remand Case to ASLB for ASLB to Delineate & Impose Conditions Upon Applicant for Granting Dismissal of CP Application W/O Prejudice. Certificate of Svc
ML20069A9931981-12-18018 December 1981
Petition for Stay of Aslab 811207 decision,ALAB-622, Dismissing Proceeding W/O Prejudice.Certificate of Svc Encl
ML20010D1621981-08-0303 August 1981
Request for Consolidation W/Fulton Proceeding & for 15-day Extension to File Brief.Instant Case & Fulton Proceeding Present Common Question of Law & Fact.Certificate of Svc Encl
ML20010B2831981-08-0303 August 1981
Motion to Consolidate Fulton Case & for Extension of 15 Days to File Brief.Cases Present Common Question of Law & Fact. Intervenor Illness Necessitates Extension of Time
ML20009E4291981-07-21021 July 1981
Petition for Reconsideration & Request for Extension of Time to File Brief.Belated Mailing of Microfiche Collection & NRC Issuances Adversely Affects Intervenor Opportunity to Conduct Necessary Research
ML19352B3371981-06-29029 June 1981
Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 810613 Motion to File Sworn Statements.Intervenors Failed to Justify Reopening of Record
ML19351A1671981-06-16016 June 1981
Comments on Various Matters in Proceeding.Intervenors Concerned That Aslab 810611 Order Does Not Mention Compelling ASLB to Keep Record Open on Applicant Past Performance.Certificate of Svc Encl
ML20004F7621981-06-13013 June 1981
Motion for Leave to File Encl Sworn Statements as Evidence of Damage to Public Interest Which Would Be Caused & Remain If Application Dismissal W/O Prejudice Were Sustained on Appeal.Certificate of Svc Encl
ML20004E8961981-06-0606 June 1981
Petition to Reconsider Aslab 810601 Order Denying Intervenors' 810512 Request for Extension of Time to File Brief.Requests Aslab Investigation Into NRC Failure to Serve NRC Response to Intervenors' Request.W/Certificate of Svc
ML20004B6321981-05-21021 May 1981
Response to G Fernos & Citizens for Conservation of Natural Resources Notice of Appeal & Request for Extension of Time to File Brief.Opposes Delay in Filing.Leave to File Appeal Granted Earlier.Certificate of Svc Encl
ML20003J3821981-04-25025 April 1981
Response Opposing Applicant 810417 Response to Intervenor Petition for Temporary Stay & Extension of Time.Applicant Motion Lacks Support & Time to File Appeal Has Not Expired. Certificate of Svc Encl
ML17328B0611981-04-17017 April 1981
Response Opposing G Fernos & Citizens for Conservation of Natural Resources 810406 Request for Stay of ASLB 810218 & 0326 Decisions & Petition for Extension of Time to File Appeal.Certificate of Svc Encl
ML19347D9201981-04-0606 April 1981
Request for Extension Until 810515 to File Appeal & for Stay of ASLB 810218 & 0326 Orders Granting Applicant Withdrawal of Application W/O Prejudice & Denying Intervenor Petition for Reconsideration,Respectively.Certificate of Svc Encl
ML19350B5271981-03-12012 March 1981
Answer Opposing G Fernos 810303 Request for Reconsideration of ASLB 810218 Order Granting Withdrawal W/O Prejudice of Util Application.Also Opposes Request to Stay Decision.No New Info Presented.Certificate of Svc Encl
ML19347D2291981-03-0303 March 1981
Request for Reconsideration of ASLB 810218 Order Granting Application Withdrawal W/O Prejudice.Applicant Actions & Clear Lack of Necessity for Plant Demand That Dismissal Be W/Prejudice.Certificate of Svc Encl
ML20002C0871980-12-31031 December 1980
Reply to Intervenor 801203 Submittal Stating Withdrawal Application Should Be Dismissed W/Prejudice.Accusation of Hidden,Deceitful Action Is Unsubstantiated.Proceeding Should Be Terminated W/O Prejudice.W/Certificate of Svc
ML19351F1431980-12-0303 December 1980
Reply to Applicant & NRC Contention That Withdrawn Application Should Not Be Dismissed W/Prejudice.Urges That Application Be Dismissed W/Prejudice.Certificate of Svc Encl
ML19351C8811980-10-0303 October 1980
Response in Opposition to Citizens for Conservation of Natural Resources Motion for Direct Certification Urging Dismissal of Application W/Prejudice.Future Applications May Not Be Barred Unless Public Harmed.Certificate of Svc Encl
ML19332B4051980-09-18018 September 1980
Motion for Stay of Proceeding Until Commission Rules Upon Direct Certification Seeking Dismissal of Application W/ Prejudice.Certificate of Svc Encl
ML19332B4041980-09-18018 September 1980
Addendum to 800917 Motion for Direct Certification Which Requested That CP Application Be Dismissed W/Prejudice. Applicant Withdrawal Evading Direct Confrontation W/Issues Raised & Litigated for 5 Yrs Is Unfair.W/Certificate of Svc
ML19332B3971980-09-17017 September 1980
Motion for Direct Certification Requesting That CP Application Be Dismissed W/Prejudice Rather than Accepting Applicant Withdrawal Terminating Proceeding.Certificate of Svc Encl
ML19332A9111980-09-13013 September 1980
Requests Commission Take No Action Re ALAB-605.Intervenor Must Present Case to ASLB Before Commission Acts to Review ALAB-605.Intervenor Counsel in Hosp Until After Commission Action Deadline of 800919.Certificate of Svc Encl
ML19332A4911980-09-11011 September 1980
Motion for Termination of Proceeding Due to Encl Withdrawal of Application.Certificate of Svc Encl
ML19332A4891980-09-11011 September 1980
Motion for Withdrawal of Application for CP
ML19332A1801980-09-0303 September 1980
Motion Advising of Temporary Substitution of Author.Requests Incorporation of T Morales on Svc List in Absence. W/Certificate of Svc
ML19331D9071980-08-27027 August 1980
Motion for Clarification of Scope of Single Issue to Be Tried in ASLB 800819 Order Re Intervenor 800430 Petition on Lack of Intention to Build.Draws Attention to Util Inaction & Contradictory Actions.W/Certificate of Svc
ML19331D9091980-08-27027 August 1980
Motion for Ruling on Intervenor 800718 Submission Seeking Legal Assistance During Hearings Plus Round Trip Travel & Lodging Expenses for Counsel.Certificate of Svc Encl
ML19331B7341980-08-0404 August 1980
Response to Applicants' 800718 Memorandum Alleging That ASLB Has No Jurisdiction to Dismiss CP Application as Moot.Urges Reversal of ASLB 800529 Order in Order to Address Merits of Intervenors' 800430 Request.W/Certification of Svc
ML19321A5071980-07-18018 July 1980
Response to NRC 800627 Memorandum,In Reply to Aslab 800630 Order.Interlocutory Review of ASLB Order Re Dismissal of CP Application W/O Hearing on Health,Safety & Environ Is Not Warranted.Certificate of Svc Encl
ML19321A6281980-07-18018 July 1980
Memorandum in Response to Aslab 800604 Order Re Validity of ASLB 800529 Order Denying Petition to Intervene.Urges Reversal of ASLB Order & Institution of Hearings. Certificate of Svc Encl
ML19320C2721980-07-0909 July 1980
Motion Seeking Option to Respond to Applicant by 800808,if Applicant Responds to NRC 800627 Memorandum by 800718,re Aslab 800630 Order.Certificate of Svc Encl
ML19320A7771980-06-27027 June 1980
Memorandum in Response to Aslab 800604 Order.Interlocutory Review of ASLB Order Denying G Fernos Petition to Dismiss Application Not Warranted Unless Legal Boundaries Are Not Explored.W/Certificate of Svc
ML19312E9181980-05-19019 May 1980
Response in Opposition to Intervenor G Fernos 800430 Request for Issuance of Order to Show Cause Why Application Should Not Be Dismissed.No Time Frame Requirememts Exist for License Processing.W/Certificate of Svc
ML19318A2771980-04-30030 April 1980
Petition Urging ASLB to Hold Evidentiary Hearings to Request Applicant to Show Cause Why Application Should Not Be Dismissed Due to Lack of Intention to Build.Requests Costs & Damages.W/Certificate of Svc & Supporting Documents
1982-01-06
[Table view] |
Text
,
6 D0 t 18 December,1981 3
U N IT E Db Tb 5'5 Ch b E RIC A BEFORE THE NUCLEAR REGULATORY COMMISSION 0:1. J OF jay DC :',T W '!!CE in the Matter of 3R PUERTO RICO ELECTRIC DOCKET N 6 POWER AUTHORITY ( PREPA )
Applicant g
' c'y ( -
Propos ' N o r thCC o a~'s t.
GONZALO FERNOS, ET AL. NucIe r'4 I og U'n i t"1 .h -
Intervenors Islote Wo'rdj Arec$oS@JG6);Ri
f Q &
PETITION FOR A STAY OF APPEAL BOARD'S DECISION OF DEC- , 1 981 .
NYiTI)
TO THE HONORABLE COMMISSION :
e COMES NOW the undersigned Intervenor, Pro Se, and on behalf of Members of Citizens For The Conservation Of Natural Resources, In. ( CCNR ), collectively referred to os the Intervenors, and respectfully request a stay of the effectiveness of the Appeal Board's Decision of December 7,1981, served on December 8,1981, and as grounds thereof states, alleges and prays :
e 1.- That on December 7,1981, the Atomic Safety and Licensing Appeal Board issued Decision ALAB-662 by which it offirmed the Licensing Board's Memorandum and Order of February 18th,1981 granting without prejudice Applicant's Motion of September 11, 1980 requesting termination of proceeding.
. 2.- That the intervenors will be filing a Petition For Review before the Commission within the prescribed term of 15 days.
e 3.- That although Intervenors have made a strong showing to prevail on the merits, the Appeal Board have selected those arguments that support Applicant's position while omitting the most crucial one adverse to the letter. That is, the corruptive climate within Applicant's operations, o nationally known fact which lead to o grand jury indictment and further conviction.
. 4.- That ofter ossessing this matter further, Intervenors may concede that the public interest lies in a compromise adjudication by which a conditional dismissal is granted without prejudice, thus sparing to continue litigating this case in the U.S. Court of Appeals and sub -
sequently in the Supreme Court of the United States, if deemed necessary.
. WHEREFORE, Intervenors request pursuant to 10 CFR i 2.788 that a stay of the afore-mentioned Decision be granted pending the outcome of the forthcoming Petiton For Review.
8112240061 011218" PDR ADOCK 05000376 G
f f PDR s
, - __ - - - _ ___ _ - , _ _ . . _ _ . - __ __