ML20198C227
| ML20198C227 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 12/29/1997 |
| From: | Kennedy J AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#198-18700 ISFSI, NUDOCS 9801070228 | |
| Download: ML20198C227 (6) | |
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N.hr 29,1997 VI EC 301 P5.:16 UNITED STATES OF AMERICA:
NUCLEAR REGULATORY COMMISSION OFFICF2 OF S! Cw,.....Y ru i 4
BEFORE THE ATOMIC SAFETY AND LICENSINab kbh F
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In the Matter oft
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. PRIVATE FUEL STORAGE; LLC
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Docket No. 22-ISFSI
)
(Independent Spent
)
Fuel Storage Installation)
)
. FURTHER SUPPLEMENTAL MEMORANDUM IN SUPPORT OF THE PETITION OF THE CONFEDERATED TRIBES OF THE GOSHUTE RESERVATION AND DAVID PETE TO INTERVENE AND FOR A HEARING In response to the supplemental memorandum and declarations submitted by the Goshute Tribe, Applicant in turn submitted a declaration by Arlene Walsh. That declaration and the memorandum failed to fully reflect the facts, which are supplemented by the attached second supplemental declaration of Chrissandra Reed.
Ms. Reed notes the following points: (1) she herself visits the Skull Valley Reservation from 8 to 10 times per year, not just once a year as asserted by Ms. Walsh; and (2) Ms. Reed is Michaela's
. legal guardian.
- The Applicant has not denied that Michaela has been frequently present on the Skull Valley Reservation or that Michaela is a member of the Goshute Tribe.
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9001070229 971229 PDR ADOCK 07200022 C
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- . 2 Conclusion Based upon the foregoing and the materials previously submitted, it is respectfully submitted 1
that the Petition of the Goshiste Tribe and David Pete to intervene in this matter should be granted.
Dated: December 29,1997.
Respectfully submitted J hn Paul Kennedy ttorney for Petitioners Goshute Tribe and David Pete 4
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' i Certificate of Senice -
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i hereby certify that copies of the above Further Supplemental Agrandup W3hssecond supplemental declaration of Chrissandra Reed were served upon the persenihdkisisd Gloylg' e ADJUD'CMM O manner stated on the date rad:
Attn: Docketing & Service Branch Dr. Jerry R. Kline Secretary of the Commission '
Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Mail Stop 016G15 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Washington, D.C. 20555 Rockville, MD 20852-2738 emailjrk2@nrc. gov (original and two copies - Fed. Ex. Only)
G. Paul Bollwerk, Ill, Chairman
- Dr. Peter S. Lam Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 email gpb@nrc. gov email psl@nrc. gov Office of the Secretary Sherwin E. Turk, Esq.
Attn: Rulemakings and Adjudication Staff Catherine L. Marco, Esq.
U.S. Nuclear Regulatory Commission Office ofGeneral Counsel
- Washington, D.C. 20555 U.S. Nuclear Regulator Commission (Fed Er. Only)
Mail Stop: 0-15 B18 Washington, D.C. 20555 Fax: 301-415-3725 email SE1@nrc. gov Jay E. Silberg, Esq Jean Belille, Esq.
. Shaw, Pittman, Potts & Trowbridge Land anu Water Fund of the Rockies 2300 N Street N.W.
2260 Baseline Road, Suite 200 Washington, D.C. 20037-8007 Boulder, Colorado 80302 Fax: 202 663-8007 Fax: 303-786-8054
- Danny Quintana, Esq.
Diane Curran, Esq.
50 W. Broadway, Fourth Floor Harmon, Curran & Spielberg Salt Lake City, Utah 84101 2001 S Street, N.W., Suite 430 Fax: 801-521-4625 Washington, D.C. 20009 1
Fax: 202-328-6918
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- Denise Chancellor Utah Attorney General's Office P.O. Box 140873 _
Salt Lake City, Utah 84114-4810-Fax: 801-366-0292
- Connie Nakahara, Esq.
R dtah Dep. Of Environmental Quality j 168 North 1950 West P.O. Box 144810 Salt Lake City, Utah 84114-4810 Fax: 801-536-0061 -
= Clayton i Parr, Esq.
Kimball, Parr, Waddoups, Brown & Gee
.185 S. State #1300 Salt Lake City, Utah 84147-0019
~ Fax: 801532-7751 Dated: December 29,1997 JoEPaul Renh6 I
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-j December 29,1997 -
j UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~
'In the Matter of
)
)
PRIVATE FUEL STORAGE, LLC
)
Docket No. 72-22-ISFSI
)
(Independent Spent
)
Fuel Storage Installation)
)-
- SECOND SUPPLEMENTAL DECLARATION OF CHRISSANDRA M. REED IN SUPPORT OF THE PETITION OF THE CONFEDERATED TRIBES OF THE GOSHUTE RESERVATION TO INTERVENE CHRISS ANDRA M. REED, hereby declares under penalty of perjury:
1.
She is an enrolled member of the Confederated Tribes of the Goshute Reservation (herein the Goshute Tribe) and curr:ntly serves as a member of the Tribal Business Council, which is the governing body of said Indian Tribe. She has previously submitted a declaration in support of the Petition of the Confederated Tribes of the Goshute Reservation to Intervene in this matter.
2.
With respect to her three-year old granddaughter, Michaela, Declarant is the legal guardian of that granddaughter. Michaela resides on a full-time basis with Declarant except for times when she is under the care of Declarant's cousins on the Skull Valley _
Reservation.
3.
. As noted, Michaela is an enrolled member of the Goshute Tribe.
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4 The dwation otsuch stays on the Skull Va!!ey Reservation by Mehacle ce frm to periods orup to two weeks.' puring her stays on the skull Valley Reservation,
.\\lichaela resides in the home ofher cousins and plays with be cousins and has acunI horse-back riding there on the St.ull Valley Reservation Also, during such stays, she dnnks local water and eats the food proposed and served by her cousins, Much food inchb rutural foods gathered irt the Skull Valley area.
5.
Declarant usually drops off her granddaughter at the I-80 truck viop (Rowley Junction) through which junction Applicant propcses to tranship nuclear waste.
6.
Declarant picks up her grandchild either at Salt 14ke City or at the Skull Valley Reservation. About onefourth of the pick.ups are on the Skull Valley Reservation. Only occasionally does she pick up her grandchild at the truck stop.
7.
On the average, Declarant visits the Skull Valley Reservation about 8-10 times each year.
I declare under penalty of perjury that the foregoing is true and conect.
Dated: Deceber 29,1997, 2
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