ML20198Q852
| ML20198Q852 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 01/16/1998 |
| From: | Kennedy J AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| CON-#198-18741 ISFSI, NUDOCS 9801230155 | |
| Download: ML20198Q852 (5) | |
Text
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NUCLEAR REGULATORY COhihilSSION Of p
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Docket No. 72-22-ISFSIWM
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CLASSIFICATION OF CONTENTIONS ON BEllALF OF Tile CONFEDERATED TRIBES OF Tile GOSilUTE RESERVATION AND DAVIJ) PETE By Order d1ted January 6,1998, the Board directed the Goshute Tribe to classify its contentions and to state whether it has any objections to the suggestions of PFS for redrafling those contentions. In response to that order the Goshute Tribe (and David Pete), by and through their counsel, John Paul Kennedy,1385 Yale Avenue, Salt Lake City, Utah 84105, hereby submit the following:
ClassincAllonsf_ Contentions A.
Decommissioning Plan Deficiencies. This contention potentially impacts safety, environmental, emergency planning, and may fall into the "other" category as well.
B.
Lack of protection against worst case accidents. This contention potentially impacts safety, environmental, emergency planning, and may fall into the "other" category as well.
C.
Inadequate Assessment of Costs under NEPA. This contention impacts emironmental and "other" issues.
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Inadequate Discussion ofNo-Action Alternative. This contention impacts environmental and "other" issues.
E.
Failure to Give Adequate consideration to Adverse Impacts on the Historic District. This contention impacts environmental and "other" issues.
F.
Failure to Adequately Establish Financial Qualifications. This contention potentially impacts safety, environmental, emergency planning, and may fall into the "other" category as well.
G.
With respect to the contentions incorporated by reference, The Goshute Tribe hereby adopts and incorporates by reference the clasifications designed by the initial proponents of those contentions. (Absence of NRC Authority, Non-Compliance with Regulations, Application for Permanent Repositoty, Inadequate Financial Qualifications, Regional and Cumulative Environmental Impacts, Statutory Authority, License Needed for Intermodal Transfer Facility.)
hopssed3cdrding by PFS:
Generally speaking, the Goshute Tribe objects to the redrafling of any ofits contentions to the extent that such proposed redrafling would have the effect ornarrowing the scope of those contentions. The Goshute Tribe assens that the Application in this matter is in part broad and vague. Until all of the concerns regarding the scope and detail of the application have been fully resolved, the Goshute Tribe wishes to stand by its statements. To the extent, however, the proposed restatement of the contentions serves to provide additional clarity or any required
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Dated: January 16,1998.
j Respectfully sub 't r
Jein Paul K edy
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A tomey for Petitioners Goshute Tribe and ~
David Pete e
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Certificate of Senice
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nem I hereby certify that copies of the above Statement of 4
persons indicated below in the manner stated on the date stated:
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, gT Attn: Docketing & Service Branch Dr. Jerry R. Kline 3ccretary of the Commission Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Mail Stop Ol6G15 U.S. Nuclear Regulatory Commission 11555 Rockville Pike One White Flint North Washington, D.C. 20555 Rockville, MD 20852 2738 emailjrk2@nrc. gov (original and two copies -- Fed Ex. On!))
G. Paul Ilollwerk,111, Chairman Dr. Peter S. Lam Administrative Judge Administrative Judge Atomic Safety and Licensing Board Nanic 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@nre gov Oflice of the Secretary Shenvin E. Turk, Esq.
Attn: Rulemakings and Adjudication Staff Catherine L. Marco, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C. 20555 U.S. Nuclear Regulator Commission (Fed I&. On/j)
Mail Stop: 0-15 B18 Washington, D.C. 20555 Fax: 301-415-3725 email SET @nrc. gov Jay E. Silberg, Esq Jean Belille, Esq.
Shaw, Pittman, Potts & Trowbridge Land and 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 jay _silberg@shawplttmansom landwater@lawfund.org Danny Quintana, Esq.
Diane Curran, Esq.
50 W. Broadway, Founh Floor 1larmon, Curran & Spielberg Salt Lake City, Utah 84101 2001 S Street, N.W., Suite 430 Fax: 801521-4625 Washington, D.C. 20009 quintana @Xmission.com Fax: 202 328-6918 dicurran@aol.com
-5 Denise Chancellor Utah Attorney General's Office P.O. Box 140873 Salt Lake City, Utah 84114-4810 Fax: 801-366-0292 dchancel@ state.ut.us Connie Nakahara, Esq.
Utah Dep. Of Environmental Quality 168 North 1950 West P.O. Box 144810 Salt Lake City, Utah 84114-4810 Fax: 801-536-0061
. cnakahar@ state.UT,US Clayton J. Parr, Esq.
Michael Later, Esq.
Parr, Waddoups, Brown, Gee & Loveless 185 S. State #1300 Salt Lake City, Utah 84147 0019 Fax: 801-532 7751 kjohnson@.kimballparr.com Dated: January 16,1998, I
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