ML20150D558
| ML20150D558 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/07/1988 |
| From: | Colapinto D, Kohn M, Kohn S AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20150D512 | List: |
| References | |
| CPA, OL, NUDOCS 8807140047 | |
| Download: ML20150D558 (3) | |
Text
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'JUL 111988*
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' UNITED STATES OF AMERICA Q
m ac NUCLEAR REGULATORY. COMMISSION vf\\
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD U
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In the Matter of,
)
)
Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC
)
50-446-OL COMPANY, et al.,
)
(Application for an
)
Operating License)
)
(Comanche Peak Steam Electric
)
Docket No. 50-445 CPA Station, Units 1 and 2)
)
(Construction Permit
)
Amendment)
)
l'.OTION TO PROCEED AS JOHN DOE Comes now petitioner,.through counsel, who hereby moves this Honorable Court to proceed as a John Doe in the above-captioned proceeding for the reasons set forth hereinafter:
1.
John Doe is a former senior engineer at the Comanche Peak Steam Electric Station (hereinafter, "CPSES") who has first-hand knowledge of matters currently pending before this licensing proceeding.
Upon inf'rmation and belief, John Doe is listed as 2.
o a pending witness for the intervenor Citizens Association for Sound Energy (hereinafter, "CASE"), and he fully expected that CASE would represent his concerns to the U.S. Nuclear Reculatory Commission (hereinafter, "NRC"), the Atomic Safety and Licensing Board (hereinafter, "ASLB") and the public.
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3.
To date, John Doe's concerns have not been adequately addressed by CASE or the NRC and, upon information and belief, will not be addressed under the terms of the proposed "Joint Stipulation" signed by the parties in the above-captioned proceeding and submitted to this Court 4on or about-July 1, 1988.
4.
John Doe is presently an employee in the nuclear '
industry and has a reasonable fear of harassment, intimidation or termination based on filing these pleadings.
If this Court desires that the identity of petitioner be revealed either in camera or on the record, petitioner will furnish his identity if failure to do so would prejudice his motion requesting a substitution of parties, motion to intervene, or motion to make public all settlement agreements enacted by the parties.
Respectfully submitted, f
f MICHAEL D.
KOHN STEPHEN M.
KOHN DAVID K. COLAPINTO 526 U Street, N.W.
Washington, D.C.
20001 (202) 234-4663 Attorneys for Petitioner July 1988 l
l I i
i b^
+
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
,In the Matter of,
)
)
Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC
)
50-446-OL COMPANY, et al.,
)
(Application for an
)
Operating License)
)
(Comanche Peak Steam Electric
)
Docket No. 50-445 CPA Station, Units 1 and 2)
)
(Construction Permit
)
Amendment)
)
9EDEg UPON CONSIDERATION of petitioner's motion to proceed as John Doe, all papers in opposition thereto, and it appearing to the Court that the motion should be granted, it is this day of 1988; ORDERED that petitioner's motion to proceed as John Doe be, and it hereby is, GRANTED.
s, Administrative Law Judge