ML20150E330
| ML20150E330 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/11/1988 |
| From: | Kohn M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#388-6707 CPA, OL, NUDOCS 8807150085 | |
| Download: ML20150E330 (6) | |
Text
j;YOY 1
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"" 13
d:"O Te r:
UNITED STATES OF AMERICA NUCLEAR RFGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.
)
In the Matter of,
)
)
TEXAS UTILITIES ELECTRIC
)
Docket Nos. 50-445-OL COMPANY, et al.,
)
50-446-OL
)
(Application for an
)
Operating License)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
Docket ho. 50-445-CPA
)
(Construction Permit
)
Amendment)
)
GREATER FORT WORTH SIERRA CLUB'S MOTION FOR LEAVE TO INTERVENE AND MOTION FOR SUA SPONTE RELIEF Comes now Petitioner Greater Fort Worth Sierra Club, through counsel, to hereby move this Atomic Safety and Licensing Board (hereinafter, "ASLB" or "Board") for leave to intervene in the l
above-captioned proceeding for the limited purposes stated herein.
l Petitioner Greater Fort Worth Sierra Club's current address is P.O.
Box 1057, Fort Worth, Texas 76101 and is located within a fifty mile radius of the Comanche Peak Steam Electric Station (CPSES).
The Greater Forth Worth Sierra Club represents 1250 members who reside in the area near CPSES.
The Greater Fort Worth Sierra Club, which is a local chapter of the Texas Sierra l
Club, has given emergency approval to file this petition pending l
g5 ADO O 00 9603
g-final authority from the Texas state chapter to move this Board for ' intervention.
Petitioner did not know that settlement negotiations were being conducted between CASE and the utility; petitioner was never consulted directly or indirectly to any of the terms contained in the "Joint Stipulation", dated July 1, 1988; petitioner first learned of the proposed settlement on or about July 5, 1988 through the' news media; and petitioner has not seen a copy of any-settlement agreement, secret or otherwise, including the Joint Stipulation.
Upon information and belief, petitioner understands that numerous confidential settlements exist relating to the dissolution of these ASLB proceedings.
Petitioner needs time to review the concerns of John Doe, a comanche Peak whistleblower who has requested anonymity during this proceeding and desires to testify at ASLB hearings in the above-captioned matter.
Due to the public rights implicated and affected by the l
proposed settlement and dissolution of these proceedings, and the i
l impact of'the settlement on our lives, property, health and well-being, petitioner hereby prays for the following relief:
(1)
That all settlement agreements which in any way relate to the Joint Stipulation be ordered publicly released; (2)
That the hearing scheduled for Wednesday, July 13, 1988 be continued for a period of 60 days from release of all
s-1 settlement agreements; (3). That petitioner shall be allowed to review all settlement agreements and the public record filed in this case, and shall file within the 60 day period:
(a) any objections to the proposed settlement; (b) a formal motion for late intervention in these proceedings as provided for by 10 C.F.R.
s.
2.714; (c) a motion for substitution of the. parties; and (d) any other motions, objections or comment which may be required.
Given the reasonable nature of this request and the impossibility for petitioner to adequately address the complex public policy issues involved, the substantive safety-related technical concerns about CPSES, and pose objections to the proposed settlement by the date of hearing in this matter, Wednesday, July 13, 1988, petitioner requests that this relief be granted ssua sponte.
Petitioner is pleased to inform the Board that petitioners l
CFUR, the Comanche Peak Citizens Audit, the "Individual Residents," and the "Second Group of Individual Residents" consent to this request.
l h
l
Respec fully submitte MICHAEL D. KOHN, ESQ.
STEPHEN M. KOHN, ESQ.
DAVID K.
COLAPINTO, ESQ..
Kohn and Associates 526 U Street, N.W.
Washington, D.C.
20001 (202) 234-4663 Attorneys for Petitioner Greater Fort Worth Sierra Club
- July 11, 1988
/005/
J f
.y 4
CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of the foregoing document was hand-delivered to Administrative Law Judge Peter B.
B ch, 4350 Eastwest Highway, 4th Floor, Bethesda, MD, on the
//
day of July, 1988; and by first class mail, postage prepaid, except wh9re
- denotes that service was accomplished by hand, on the //rAday of July, 1988 to the.following parties:
Office of the' Secretary Attention: Docketing & Service Branch M
~~
U.S. Nuclear Regulatory Commission L
Uashington, D.C.
20555 p.
?"
(3 copies)
Chairman ASLB Panel U.S. Nuclear Regulatory Commission 2(
Washington, D.C.
20555 (4 copies)
[
Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, TN 37830 I
Dr. Kenneth A. McCollom 1107 West Knapp Street Stillwater, OK 74075 ALJ Elizabeth B. Johnson Oak Ridge National Labratory P.O.
Boy X, Building 3500 Oak Ridge, TN 37830 Janice Moore, Esq.
Office of General Counsel U.S. Nuclear Regulatory Commission Mail Stop 15B18 Washington, D.C.
20555 Mr. Victor Stello U.S. Nuclear Regulatory Commission Mail Stop 15B18 Washington, D.C.
20555 Jack R. Newman, Esq.
George Edgar, Esq.
Newman & Holtzinger 1615 L Street, N.W.,
Suite 1000 Washington, D.C.
20036 g-e
Robert A. Woolridge, Esq.
- Worsham, Forsythe, Samples & Woolridge 2001 Bryan Tower, Suite 3200 Dallas, TX 75201 Mr. William G. Counsil Texas Utilities Electric Co.,
Skyway Tower 400 North Olive Street, L.B.
81 Dallas, TX 75201 Ms.-Billie Pirner Garde GAP-Midwest Office
~~
104 E. Wisconsin - B Appleton, WI 54911 Anthony Roisman, Esq.
1401 New York Ave, N.W.,
Suite 600 Washington, D.C.
20005 Mrs. Juanita Ellis 1426 S.
Polk Dallas, TX 75224 By:
h David 7. Colapin l
l l
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