ML20126L553

Clarifies Citizens for Conservation of Natural Resources, Inc 810512 Pleading.Related Correspondence

ML20126L553
Person / Time
Site:	05000376
Issue date:	05/27/1981
From:	Fernos G CITIZENS FOR THE CONSERVATION OF NATURAL RESOURCES, IN
To:	Shea K LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
References
NUDOCS 8106040472
Download: ML20126L553 (1)

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,o ClUDADANOS PRO CONSERVACION DE RECURSOS NATUR ALES,INC.

CITIZEN S FOR THE CONSERVATION OF N AT UR A L R E S O U R CE S, INC.

CALLE BARBE NUM.503 SANTURCE, PUERTO RtCO 00912 T E LS. : (809) 7-2 +ns 727-0087 M-4M 727-2287 27 Wy,1981 CABLES: CON R E N A Ms. Kathleen H. Sheo Lowenstein, Newrnan, Reis & Axelrod 1025 Connecticut Avenue, N.W.

Re : NRC Docket No. 50-376 Washington, D.C. 20036 North Coast Nuclear Plant Islote Ward, Arecibo, P.R.

Dear Ms. Sheo :

In Applicant's Response of Wy 21, 1 981, submitted by you *, your concern olleged lack of understanding of several issues raised in Intervenors' pleading of Wy 12,1981. For your benefit I wish to clarify as follows :

1.-

Intervenors pray the Appeal Board to acknowledge its iurisdiction to deal e

with the Appeal in cuestion because Applicant hed beforehand untirnely r=ised colection to the granting of an extension of time until. Wy 15, 1981 to file the Apoecl. Fbd the ASLAB reversed and revised its order granting until Wy 15, 1981 to file the Appeal, obviously it would bsve lacked jurisdiction to resolve the controversy. That is so because ivrisdiction

~ is concomitant with the timing of acting some way permissible or taking some proceeding

~

within a prescribed period.

e 2.- Your allegotion that the connection between the Investigation of Applicant's operations and the question on oppect is "too attenuated" whstever you mean by that--

to merit consideration is in and of itself a premature unsupported allegation. Perhaps you l

i overlook the fact that the Reports of the Investigations, already underway by the Department l

of.lustice as ordered by the Governor of Puerto Rico and by the Legislature sua sponte, is unprecedented in any NRC licensing proceeding, and the least to say, of utmost importance l

to the granting of a withdrawsl of an application without prejudice. Further, bribery has i

already been proven in Applicant's declings with contracts. The conaaction is clear: NRC supposedly will not leave the door open to o prospective opolicant who hos been proven corrupt or let it sin no more by forbiddingitto resubmit in a near future opplications for licenses to build nuclear plants In Puerto Rico.

If you, presurnably a lawyer, have some further doubts on fog.d.krwswith regard to I

the instant cose which need clarification, please do not hesitate t 11 onM is ' eyrnon and we will be most happy to set the record straight again for you.

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e xe : All concerned.

Gor u o rernes Chairren, CCNR i

' intervenors have not received any copy of NoticeAf Appearance from you to ASLAB as Applicant's additional counsel.

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