ML20217K962
| ML20217K962 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 10/14/1997 |
| From: | Quintana D SKULL VALLEY BAND OF GOSHUTE INDIANS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#497-18592 ISFSI, NUDOCS 9710300156 | |
| Download: ML20217K962 (4) | |
Text
1) /15?L DOCKETED-USNRC UNITED STATES OF AMERICA NUCLEAR REOULATORY COMMISSION W DCT 22 P5:15 BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD OFFICE f Dlir i HY
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R U LlJ,1*.1 U.c A N D in the Matter of
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ADJUDCAT0NL. iiiAFF
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PRIVATE FUEL STORAGE, LLC
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Docket No. 72 221SFSI
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(Independent Spend
)
Fuel Storage Installation
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SKULL VALLEY BAND OF OOSHUTES' RESPONSa TO STATE OF UTAIPS MOTION TO SUSPEND LICENSING PROCEEDINGS AND TO REQUIRE RENOTICE OF Ti1E APPLICATION The Band objects to th; State of Utah's motion seeking suspension of the license proceeding and renotice of the proceeding in the Federal Register. The suspension is sought for purely political purposes. The Governor has a personal dislike for this project, lie has publicly stated that this project would go forward,"over his dead body". The
- Band has not ins':ted this be part of the license application and NRC proceedings.
The State of Utah does not he.vejurisdiction over the Skull Valley Goshute Reservation. They are completely separate sovereigns. The proceedings need to move forward in the interest of time and judicial economy. The State of Utah has appealed the -
refusal of the Bureau ofIndian Affairs to disclose the confidential portions of the lease with Private Fuel Storage, LLC When this frivolous appeal fails they will next bore the Federal Court with litigation.- All of these proceedings need to be consolidated and heard before this judicial body. A protective order is necessary to stop this proposed disclosure as this information is confidential. The pretext of an incomplete Private Fuel Storage, LLC application is not grounds for suspending the entire licensing proceeding.
y$A c
O For the reasons set forth and based upon the law cited in Private Fuel Storage's brief, the Band respectfully requests that this Motion to suspend the proceedings and other relief prayed for by the State of Utah be denied.
tfully su ed, v
D General Counsel Skull Valley Band ofGoshutes Dated at Salt Lake City, Utah this 14* day of October,1997 CERTIFICATE OF SERVICE 1 hereby certify that copies of the foregoing Skull Valley Band of Goshute's Response to the State of Utah's Motion to Suspend the licensing Proceedings was served on the following through via the United States Mail, postage prepaid and by fax and e-mail this 14* day of October,1997 to the following:
Office of the Secretary G. Paul Bollwerk,Ill, Esq. Chahnnan f *,.,
ATTN: Rulemakings and Adjudications Administre.!ve Judge Staff Atomic Safety and L! censing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 (E Mail copy to GPB@.NRC.OOV)
Dr. Peter S. Lam
- AdministrativeJudge Dr. Jeny R. Kline Atomic Safety and Licensing Board Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board l
Washington, DC 20555 U.S. Nuclear Regulatory Commission (E Mail copy to PSL@NRC.OOV)
Washington, DC 20555 -
(E-Mail copy to JRK@NRC.OOV)
Jart 41. Cutchin, V Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Panel Washington, DC 20555 U.S. Nuclear Regulatory Commission (by E Mail to JMC3@NRC.OOV)
Washington, DC 20555 j
_ _ _ _ + _ _ _ _.
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Office of the Commission Appellate Adjudication Mail Stop: 16 015 OWFN U.S. Nuclear Regulatory Commission Washington, DC 20555 Jay E. Silberg, Esq.
Denise Chancellor, Esq.
SilAW, PITTMAN, POTTS &
Fred O. Nelson, Etiq.
TROWDBIDGE 160 East 300 South, $* Floor 2300 N. Street, NW P.O. Box 140873 Washington, DC 20037 8007 -
Sah Lake City, Utah 84114-0873 Jean Belille, Esq.
Connie Nakahara, Esq.
Land and Water Fund of the Rockles Utah Dept. ofEnvironmental Quality 2260 Baseline Road, Suite 200 168 North 1950 West Boulder, CO 80302 Salt Lake City, UT 84114-4810 Clayton J. Parr, Esq.
KIMBALL, PARR, WADDOUPS, Diane Curran, Esq.
-BROWN & OEE 11armon, Curran & Spielberg t85 S. State St., Suite 1300 2001 "S" Street, N.W.
P.O. Box 11019 Suite 430 Salt Lake City, UT 84147-0019 Washington, DC 20009 John Paul Kennedy, SR.,
1385 Yale Ave.
Salt Lake City, Utah 84105 k
N Danny Qbui a"
Counsel for Skull Valley Band of Goshutes
l?\\
DANNY QUINTANA & ASSOCIATES, P.c.
Attornep at 1.aw I'ourth I'loor 50 Went llroadway Salt 1.ake City,lf tah H4101 (Hol)464??J6 Ias(kol)S214624 October 15,1997 Office of the Secretary A1TN: Rulemakings and Adjudications Staff U.S. Regulatory Commission Washington, D.C. 20555 Re: The matter of Private Fuel Storage, LLC.
Dear Sir or Madame; Please find enclosed the Skull Valley Band of Goshutes' Response to State of Utah's Motion regarding the matter mentioned above.
If you have any questions or need more information please feel free to contact this office. Thank you.
S ncerely, Wynnt arry Secretary IN/wp enc.
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