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| {{#Wiki_filter:UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION ARIZONA PUBLIC SERVICE COMPANY DOCKET NOS.STN 50-528, 50-529, and 50-530 PETITION TO INTERVENE OF PUBLIC UTILITY COMMISSION OF TEXAS The Public Utility Commission of Texas (PUCT), pursuant to 10 C.F.R.$2.714, hereby files its petition to intervene in the above proceeding. | | {{#Wiki_filter:UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION ARIZONAPUBLIC SERVICE DOCKET NOS. STN 50-528, COMPANY 50-529, and 50-530 PETITION TO INTERVENE OF PUBLIC UTILITYCOMMISSION OF TEXAS The Public UtilityCommission of Texas (PUCT), pursuant to 10 C.F.R. $ 2.714, hereby files its petition to intervene in the above proceeding. |
| 1.Nature of proceeding. | | : 1. Nature of proceeding. Pursuant to the terms of an agreement between El Paso Electric Company (EPEC) and Central and So'uth West Corporation (CSW) to merge, Arizona Public Service Company and EPEC have filed the above proceedings. |
| Pursuant to the terms of an agreement between El Paso Electric Company (EPEC)and Central and So'uth West Corporation (CSW)to merge, Arizona Public Service Company and EPEC have filed the above proceedings. | | They are requests that the Nuclear Regulatory Commission (NRC): (1) consent to the indirect transfer of control of EPEC's interest in certain operating licenses; and (2) amend two of those operating licenses to delete provisions relating to previous sale-leaseback arrangements. By notice published March 14, 1994 at page 11S13, Volume 59, No. 49, of the Federal Register, the NRC has requested comment on the proposed transfer of control and the staff has requested comment on the antitrust issues raised by the proposed transactions. |
| They are requests that the Nuclear Regulatory Commission (NRC): (1)consent to the indirect transfer of control of EPEC's interest in certain operating licenses;and (2)amend two of those operating licenses to delete provisions relating to previous sale-leaseback arrangements. | | : 2. Representative. The Attorney General of Texas is authorized to represent the PUCT before federal agencies that regulate public utilities. Public Utility 9404iS02iS 9404i2 PDR ADOCK OS000528 P PDR |
| By notice published March 14, 1994 at page 11S13, Volume 59, No.49, of the Federal Register, the NRC has requested comment on the proposed transfer of control and the staff has requested comment on the antitrust issues raised by the proposed transactions. | |
| 2.Representative. | |
| The Attorney General of Texas is authorized to represent the PUCT before federal agencies that regulate public utilities. | |
| Public Utility 9404iS02iS 9404i2 PDR ADOCK OS000528 P PDR | |
| ,~I n l~~V Regulatory Act (PURA), Tex.Rev.Civ.Stat.Ann.art.1446c, g 15 (Vernon Supp.1994).Service can be made on the following assistant attorneys general appearing on behalf of the PUCT: Norma K.Scogin Liz Bills Steven Baron Administrative Law Section Energy Division P.O.Box 12548, Capitol Station Austin, Texas 78711-2548 (512)463-2003 Telecopier:
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| (512)320-0911 3.Interested party.The above counsel appear on behalf of: Public Utility Commission of Texas 7800 Shoal Creek Blvd., Suite 400-N Austin, Texas 78757 (512)458-0213 Telecopier:
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| (512)458-8340 4.Interest.The above proceedings are a prerequisite to the proposed merger of EPEC and CSW.The PUCT regulates public utilities in Texas to assure rates, operations, and services that are just'and reasonable to consumers and utilities.
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| PURA$2.The PUCT is charged with protecting the public interest inherent in the rates and services of public utilities in Texas.Id.Five public utilities that provide electricity to retail customers in Texas will be directly affected by the proposed merger.
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| II L'J<<I I h P' The PUCT has jurisdiction over the utilities'exas retail rates and services.PURA$g 2, 16.There is currently pending before the PUCT an application under PURA g 63 for a finding that the merger is in the public interest and a request to increase EPEC's rates.As stated above, the NRC has requested public comment on possible antitrust implications of the proposed merger.If the NRC denies the requested relief, the merger'!will not take place.If the NRC conditions approval on some change in the terms of the merger, the PUCT's evaluation of the public interest question may be affected.The PUCT has a duty to participate in the above proceeding to ensure that the public interest is served.5.Request for Notice.The PUCT hereby requests that copies of notices in this matter be provided to the its attorneys and that they be included on the official service list of this proceeding.
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| Respectfully submitted, DAN MORALES Attorney General of Texas JORGE VEGA First Assistant Attorney General JAMES M.PHILLIPS Chief, Energy Division
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| Dated: April 12, 1994 NORMA K.SCOG LIZ BILLS STEVEN BARON Assistant Attorney General Administrative Law Section Energy Division P.O.Box 12548, Capitol Station Austin, Texas 78711-2548 (512)463-2003 Telecopier:
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| (512)320-0911 ATTORNEYS FOR PUBLIC UTILITY COMMISSION OF TEXAS 0 a~~C I II II ,F 1 I certify that on this 12th day of April, 1994, a true and correct copy of the foregoing Notice of Appearance of Public Utility Commission of Texas has been sent by United States mail, postage prepaid, to all persons listed on the attached service list.N RMAK.SCOGIN | | I n |
| ~g~, I Steve Olea Arizona Corporation Commission 1200 W.Washington Street Phoenix, Arizona 85007 Jack R.Newman Newman&Holtzinger 1615 L Street, N.W., Suite 1000 Washington, D.C.20036 James A.Beoletto Southern California Edison Company P.O.Box 800 Rosemead, California 91770 Senior Resident Inspector Palo Verde Nuclear Generating Station 5951 S.Wintersburg Road Tonopah, Arizona 85354-7537 Regional Administrator, Region V U.S.Nuclear Regulatory commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Charles B.Brinkman, Manager Washington Nuclear Operations ABB Combustion Engineering Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Aubrey V.Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, Arizona 85040 Mark D.Roberson Federal Case Director El Paso Transition Team Central and South West Corp.P.O.Box 660164.Dallas, Texas 75266-0164 Curtis Hoskins Executive Vice President and Chief Executive Operating Officer El Paso Electric Company 303 North Oregon Street El Paso, Texas 79901 Roy P.Lessy, Jr.Akin, Gump, Strauss, Hauer and Feld 1333 New Hampshire Ave., Ste.400 Washington, D,C.20036 Ronald J.Stevens, Director Nuclear Regulatory Affairs Arizona Public Service Company P.O.Box 52034 Phoenix, Arizona 85072-2034 Eduardo A.Rodriguez Vice President, Secretary and General Counsel El Paso Electric Company 303 North Oregon Street EI Paso, Texas 79901 Chairman Maricopa County Board of Supervisors 111 South Third Ave.Phoenix, Arizona 85003 Clark Evans Downs Jones, Day Reavis&Pogue 1450 G Street, N.W.Washington, D.C.20005-2088 | | l |
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| | Regulatory Act (PURA), Tex. Rev. Civ. Stat. Ann. art. 1446c, g 15 (Vernon Supp. |
| | 1994). Service can be made on the following assistant attorneys general appearing on behalf of the PUCT: |
| | Norma K. Scogin Liz Bills Steven Baron Administrative Law Section Energy Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 (512) 463-2003 Telecopier: (512) 320-0911 |
| | : 3. Interested party. The above counsel appear on behalf of: |
| | Public UtilityCommission of Texas 7800 Shoal Creek Blvd., Suite 400-N Austin, Texas 78757 (512) 458-0213 Telecopier: (512) 458-8340 |
| | : 4. Interest. The above proceedings are a prerequisite to the proposed merger of EPEC and CSW. The PUCT regulates public utilities in Texas to assure rates, operations, and services that are just'and reasonable to consumers and utilities. |
| | PURA $ 2. The PUCT is charged with protecting the public interest inherent in the rates and services of public utilities in Texas. Id. Five public utilities that provide electricity to retail customers in Texas will be directly affected by the proposed merger. |
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| | The PUCT has jurisdiction over the utilities'exas retail rates and services. PURA $g 2, 16. |
| | There is currently pending before the PUCT an application under PURA g 63 for a finding that the merger is in the public interest and a request to increase EPEC's rates. |
| | As stated above, the NRC has requested public comment on possible antitrust implications of the proposed merger. Ifthe NRC denies the requested relief, the merger will not take place. Ifthe NRC conditions approval on some change in the terms of the merger, the PUCT's evaluation of the public interest question may be affected. The PUCT has a duty to participate in the above proceeding to ensure that the public interest is served. |
| | : 5. Request for Notice. The PUCT hereby requests that copies of notices in this matter be provided to the its attorneys and that they be included on the official service list of this proceeding. |
| | Respectfully submitted, DAN MORALES Attorney General of Texas JORGE VEGA First Assistant Attorney General JAMES M. PHILLIPS Chief, Energy Division |
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| | NORMA K. SCOG LIZ BILLS STEVEN BARON Assistant Attorney General Administrative Law Section Energy Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 (512) 463-2003 Telecopier: (512) 320-0911 ATTORNEYS FOR PUBLIC UTILITY COMMISSION OF TEXAS Dated: April 12, 1994 |
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| | I certify that on this 12th day of April, 1994, a true and correct copy of the foregoing Notice of Appearance of Public Utility Commission of Texas has been sent by United States mail, postage prepaid, to all persons listed on the attached service list. |
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| | Steve Olea Jack R. Newman Arizona Corporation Commission Newman & Holtzinger 1200 W. Washington Street 1615 L Street, N.W., Suite 1000 Phoenix, Arizona 85007 Washington, D.C. 20036 James A. Beoletto Curtis Hoskins Southern California Edison Company Executive Vice President and P. O. Box 800 Chief Executive Operating Officer Rosemead, California 91770 El Paso Electric Company 303 North Oregon Street Senior Resident Inspector El Paso, Texas 79901 Palo Verde Nuclear Generating Station Roy P. Lessy, Jr. |
| | 5951 S. Wintersburg Road Akin, Gump, Strauss, Hauer and Feld Tonopah, Arizona 85354-7537 1333 New Hampshire Ave., Ste. 400 Washington, D,C. 20036 Regional Administrator, Region V U.S. Nuclear Regulatory commission Ronald J. Stevens, Director 1450 Maria Lane, Suite 210 Nuclear Regulatory Affairs Walnut Creek, California 94596 Arizona Public Service Company P. O. Box 52034 Charles B. Brinkman, Manager Phoenix, Arizona 85072-2034 Washington Nuclear Operations ABB Combustion Engineering Eduardo A. Rodriguez Nuclear Power Vice President, Secretary and 12300 Twinbrook Parkway, Suite 330 General Counsel Rockville, Maryland 20852 El Paso Electric Company 303 North Oregon Street Aubrey V. Godwin, Director EI Paso, Texas 79901 Arizona Radiation Regulatory Agency 4814 South 40 Street Chairman Phoenix, Arizona 85040 Maricopa County Board of Supervisors 111 South Third Ave. |
| | Mark D. Roberson Phoenix, Arizona 85003 Federal Case Director El Paso Transition Team Clark Evans Downs Central and South West Corp. Jones, Day Reavis & Pogue P. O. Box 660164. 1450 G Street, N.W. |
| | Dallas, Texas 75266-0164 Washington, D.C. 20005-2088 |
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Category:INTERVENTION PETITIONS
MONTHYEARML17310B1911994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Texas. W/Certificate of Svc ML17310B2041994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Tx ML20086J3841991-11-25025 November 1991 Petition for Leave to Intervene & Request for Hearing.* Petitioners Request Listed Relief.W/Certificate of Svc & Notices of Appearance ML20070M2911991-03-13013 March 1991 Supplemental & Amended Petition to Intervene of ML Scott, Bs Bush & Coalition for Responsible Energy Education.* Petitioners Should Be Allowed to Intervene & Contentions Admitted.W/Certificate of Svc ML20070M5281991-03-0909 March 1991 Supplemental Petition of Mitchell Petitioners for Leave to Intervene.* Petitioners Submit for Consideration Proposed Contentions Per 10CFR2.714(b).W/Certificate of Svc ML20066H0421991-02-0606 February 1991 Licensee Answer in Oposition to Petition for Leave to Intervene & Request for Hearing.* W/Notice of Appearance of Counsel & Certificate of Svc ML20067C9081990-01-28028 January 1990 Petition for Leave to Intervene & Request for Hearing.* Petitioners Seek Intervention & Request Hearing on Application for 901113 Amend to License.W/Certificate of Svc ML20215K5521986-10-20020 October 1986 Petition of Coalition for Responsible Energy Educ for Public Hearing & Order to Show Cause Why OLs Should Not Be Lifted Based on Apparent Falsification of Util Documents by Ee Van Brunt.Van Brunt Polygraph Exam Encl ML17299B0751986-03-0404 March 1986 Views & Comments on 2.206 Petition Re Containment Leak Rate Testing Filed by Coalition for Responsible Energy Educ on 860131.Petition Has No Merit & Should Be Denied ML20128B6841985-05-17017 May 1985 Withdrawal of 821014 Petition of West Valley Agricultural Protection Council,Inc for Leave to Intervene & Request for Hearing.Issuance of OLs Consented To.Certificate of Svc Encl ML20071E4991983-03-0707 March 1983 Response in Opposition to Pl Hourihan 830323 Motion for Leave to File Response to West Valley Agricultural Protection Council 830202 Motion for Ruling on Contentions. No Good Cause Shown for Late Filing.Certificate of Svc Encl ML20071A0611983-02-14014 February 1983 Answer Opposing West Valley Agricultural Protection Council, Inc Motion for Ruling on Contentions,For Declaration That NEPA Analysis Inadequate & for Continuance of Proceeding.No Basis/Need to Admit Contentions Shown.W/Certificate of Svc ML20028G2891983-02-0202 February 1983 Motion for Ruling on Contentions I,Ii,Iv(A),Iv(C),V & VI Re Salt Deposition,For Declaration That NEPA Analysis Inadequate & for Continuance of Proceeding.Certificate of Svc Encl ML20028A4381982-11-18018 November 1982 Supplemental Memorandum of West Valley Agricultural Protection Council,Inc in Support of Petition to Intervene. Certificate of Svc Encl ML20027E4701982-11-0909 November 1982 Response Opposing West Valley Agricultural Protection Council,Inc 821014 Petition to Intervene.No Good Cause Exists for Untimely Filing & Standing Requirements Not Met. Two Aperture Cards Available in Pdr.Certificate of Svc Encl ML17297B7151982-10-13013 October 1982 Petition of West Valley Agricultural Protection Council,Inc to Intervene,Request for Preparation of Supplemental or Revised Eia & Request for Reopening Record.Certificate of Svc Encl ML20027C4111982-10-13013 October 1982 Memorandum of Law Supporting West Valley Agricultural Protection Council,Inc Petition to Intervene.Substantial New Info Only Recently Discovered.Certificate of Svc Encl ML17296A9181980-08-11011 August 1980 Petition to Intervene & Request for Hearing.Explains Interests Adversely Affected by Operation 1994-04-12
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML17310B1911994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Texas. W/Certificate of Svc ML17310B2041994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Tx ML20086J3841991-11-25025 November 1991 Petition for Leave to Intervene & Request for Hearing.* Petitioners Request Listed Relief.W/Certificate of Svc & Notices of Appearance ML20070M2911991-03-13013 March 1991 Supplemental & Amended Petition to Intervene of ML Scott, Bs Bush & Coalition for Responsible Energy Education.* Petitioners Should Be Allowed to Intervene & Contentions Admitted.W/Certificate of Svc ML20070M5281991-03-0909 March 1991 Supplemental Petition of Mitchell Petitioners for Leave to Intervene.* Petitioners Submit for Consideration Proposed Contentions Per 10CFR2.714(b).W/Certificate of Svc ML20066H0421991-02-0606 February 1991 Licensee Answer in Oposition to Petition for Leave to Intervene & Request for Hearing.* W/Notice of Appearance of Counsel & Certificate of Svc ML20067C9081990-01-28028 January 1990 Petition for Leave to Intervene & Request for Hearing.* Petitioners Seek Intervention & Request Hearing on Application for 901113 Amend to License.W/Certificate of Svc ML20215K5521986-10-20020 October 1986 Petition of Coalition for Responsible Energy Educ for Public Hearing & Order to Show Cause Why OLs Should Not Be Lifted Based on Apparent Falsification of Util Documents by Ee Van Brunt.Van Brunt Polygraph Exam Encl ML17299B0751986-03-0404 March 1986 Views & Comments on 2.206 Petition Re Containment Leak Rate Testing Filed by Coalition for Responsible Energy Educ on 860131.Petition Has No Merit & Should Be Denied ML20128B6841985-05-17017 May 1985 Withdrawal of 821014 Petition of West Valley Agricultural Protection Council,Inc for Leave to Intervene & Request for Hearing.Issuance of OLs Consented To.Certificate of Svc Encl ML20071E4991983-03-0707 March 1983 Response in Opposition to Pl Hourihan 830323 Motion for Leave to File Response to West Valley Agricultural Protection Council 830202 Motion for Ruling on Contentions. No Good Cause Shown for Late Filing.Certificate of Svc Encl ML20071A0611983-02-14014 February 1983 Answer Opposing West Valley Agricultural Protection Council, Inc Motion for Ruling on Contentions,For Declaration That NEPA Analysis Inadequate & for Continuance of Proceeding.No Basis/Need to Admit Contentions Shown.W/Certificate of Svc ML20028G2891983-02-0202 February 1983 Motion for Ruling on Contentions I,Ii,Iv(A),Iv(C),V & VI Re Salt Deposition,For Declaration That NEPA Analysis Inadequate & for Continuance of Proceeding.Certificate of Svc Encl ML20028A4381982-11-18018 November 1982 Supplemental Memorandum of West Valley Agricultural Protection Council,Inc in Support of Petition to Intervene. Certificate of Svc Encl ML20027E4701982-11-0909 November 1982 Response Opposing West Valley Agricultural Protection Council,Inc 821014 Petition to Intervene.No Good Cause Exists for Untimely Filing & Standing Requirements Not Met. Two Aperture Cards Available in Pdr.Certificate of Svc Encl ML17297B7151982-10-13013 October 1982 Petition of West Valley Agricultural Protection Council,Inc to Intervene,Request for Preparation of Supplemental or Revised Eia & Request for Reopening Record.Certificate of Svc Encl ML20027C4111982-10-13013 October 1982 Memorandum of Law Supporting West Valley Agricultural Protection Council,Inc Petition to Intervene.Substantial New Info Only Recently Discovered.Certificate of Svc Encl ML17296A9181980-08-11011 August 1980 Petition to Intervene & Request for Hearing.Explains Interests Adversely Affected by Operation 1994-04-12
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217E1551999-09-28028 September 1999 Comment Supporting Pr 10CFR50 Re Elimination of Requirement for Licensees to Revise ISI & IST Programs Beyond Baseline Edition & Addenda of ASME B&PV Code ML17313B0651999-07-30030 July 1999 Comment on Draft Rg DG-1076, Service Level I,Ii & III Protective Coatings Applied to Npps. ML17313B0161999-07-0101 July 1999 Comment on Draft Rg DG-1074, SG Tube Integrity. ML20196K5631999-06-29029 June 1999 Comment Supporting Proposed Rule 10CFR50.55a Re Elimination of 120-month Requirement to Update ASME Code ISI & Inservice Testing Program ML20207D1591999-05-20020 May 1999 Comment on Proposed Rules 10CFR21,50 & 54 Re Use of Alternative Source Terms at Operating Reactors ML17313A9791999-05-20020 May 1999 Comment Opposing Draft Reg Guide DG-1084, Qualification & Training of Personnel for Nuclear Power Plants. as General Comment,Util Believes That Many of Proposed Changes Will Limit Ability to cross-train Mgt Level Personnel ML20205A4271999-03-18018 March 1999 Comment on Petition for Rulemaking PRM-50-64 Which Requested Greater Clarification by NRC Re Possible Financial Obligations of NPP Licensees as Reflected in NRC Final Policy Statement on Restructuring & Economic Deregulation ML17313A8521999-03-0505 March 1999 Comment Supporting Proposed Change to NRC Enforcement Policy.Suggested Rewording of Sections Provided ML17313A8191999-02-24024 February 1999 Comment Supporting Secy 99-007, Recommendation for Reactor Oversight Process Improvements, & Comments Provided by NEI & Regional Utility Group Iv.Offers Comments on NRC Approach to Using Performance Indicators in Assessment Process ML20198J4031998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirement for Monitoring Effectiveness of Maint at NPPs ML20217B9761998-04-0909 April 1998 Comment Re Draft RG DG-1029, Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safey-Related Instrumentation & Control Sys ML20216A9091998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50.55a Re Industry Codes & Stds ML17313A3361998-03-27027 March 1998 Comment Opposing Proposed GL Re Lab Testing on Nuclear-Grade Activated Charcoal. Believes That Proposed 60 Day Implementation Schedule Would Severely Challenge Resources of Limited Number of Qualified Vendors ML20217E8781998-03-27027 March 1998 Comment Supporting Proposed GL, Lab Testing of Nuclear- Grade Activated Charcoal ML17313A2511998-03-0303 March 1998 Comment on Proposed GL 98-XX Re Yr 2000 Readiness of Computer Sys at Npps. ML20203L5521998-02-25025 February 1998 Forwards Comments on Draft Reg Guide DG-5008, Reporting of Safeguards Events ML20202E4251998-01-30030 January 1998 Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. Draft RG Should Be Revised to Clarify That Alloy Analyzer Can Be Used Consistent W/Guidance in EPRI NP-5652 ML20199E0871998-01-17017 January 1998 Comment Opposing PRM 50-63A by Pg Crane Re Amending Emergency Planning Regulations to Require Consideration of Prophylactic Use of Potassium Iodide for General Public ML20202G4461997-12-0101 December 1997 Comment on Proposed Final Rule 10CFR50.Licensee Requests That Effective Date Be Delayed from 980101 to 0601,in Order to Provide Enough Time to Request & Obtain NRC Review of Exemption from Rule ML20212D1391997-10-17017 October 1997 Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power Reactors ML17312B4241997-04-23023 April 1997 Comment Supporting Draft Rg DG-1068 (Proposed Rev 3 to Rg 1.134, Medical Evaluation of Licensing Personnel at Npps) ML20134J9671997-02-0606 February 1997 Comment Supporting Proposed Rule 10CFR50, Draft Policy Statement on Restructuring & Economic Deregulation of Electric Util Industry ML20134N2521996-11-14014 November 1996 Comment on Draft RG DG-1012,proposed Rev 3 to RG 1.8, Qualification & Training of Personnel for Npp ML20117E3871996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements ML20113C6981996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Cautions NRC Not to Adopt Rules That Are Too Restrictive & Could Lead to Premature Decommissioning ML20117P1261996-06-24024 June 1996 Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Urges NRC to Approach Rulemaking Re Decommissioning Costs in Manner That Will Facilitate Federal Legislative Solution ML20095A8461995-11-28028 November 1995 Comment on Petition for Rulemaking PRM-50-62 Re Proposed Changes to 10CFR50.54.Util Endorses Industry Petition & Response Provided by NEI ML17311B2931995-11-27027 November 1995 Comment Opposing Draft NUREG/CR-6354, Performance Testing of Electronic Personnel Dosimeters. ML17311B1601995-08-31031 August 1995 Comment Opposing Review of Revised NRC SALP ML20087H7241995-08-16016 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy ML20087H7501995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design ML20087H7331995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations ML17311B0071995-06-27027 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Insp Detail Should Be Brief & Ref Previous Rept by Section or at Min IR Number ML20083N5031995-05-0505 May 1995 Comment on Proposed Rev to 10CFR50,app J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Proposed Rev Will Result in Highly Efficient Regulation ML20082P7461995-04-19019 April 1995 Comment Supporting Proposed Rules 10CFR170 & 171 Re Proposed Revs of NRC Fee Schedule for FY95 in Fr ML20082H0971995-04-10010 April 1995 Draft Policy Statement Re Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation ML20081B5721995-03-0808 March 1995 Motion of Plains Electric Generation & Transmission Cooperative,Inc to Withdraw,W/Prejudice,Petition for Leave to Intervene,Request for Finding of Significant Change & for Antitrust Hearing & Comments.* W/Certificate of Svc ML17311A6691995-02-0202 February 1995 Comment Supporting Draft Rg DG-8014 (Proposed Rev 3 to Rg 8.13, Instruction Concerning Prenatal Radiation Exposure) ML20078H0671995-01-20020 January 1995 Comment Supporting NUMARC Position on Proposed Rules 10CFR20,30,40,50,51,70 & 72 Re Radiological Criteria for Decommissioning of Lands & Structures ML20077M5471995-01-0404 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactor Proposed Rule ML17311A2461994-08-25025 August 1994 Comment on Draft Reg Guide (DG-1031), Monitoring Effectiveness of Maint at Npps. Term Maint Preventable Failure Needs to Be Defined & Compared to Term Maint Preventable Functional Failure. ML17310B1911994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Texas. W/Certificate of Svc ML17310B2041994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Tx ML20062M4141993-12-27027 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Procurement of Commercial Grade Items ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML17306B2461993-01-15015 January 1993 Comment Supporting in Part,Draft Reg Guide DG-1020, Monitoring Effectiveness of Maint at Npps. ML17306A9571992-09-0808 September 1992 Comments on Proposed Rev to Staff Technical Position on Radwaste Classification.Supports Rev ML20099E0621992-07-29029 July 1992 Comment Opposing Proposed Rule 10CFR50.63, Loss of All AC Power ML20090F9661992-03-0909 March 1992 Comment Supporting Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel ML17306A4501992-02-0404 February 1992 Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data 1999-09-28
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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION ARIZONAPUBLIC SERVICE DOCKET NOS. STN 50-528, COMPANY 50-529, and 50-530 PETITION TO INTERVENE OF PUBLIC UTILITYCOMMISSION OF TEXAS The Public UtilityCommission of Texas (PUCT), pursuant to 10 C.F.R. $ 2.714, hereby files its petition to intervene in the above proceeding.
- 1. Nature of proceeding. Pursuant to the terms of an agreement between El Paso Electric Company (EPEC) and Central and So'uth West Corporation (CSW) to merge, Arizona Public Service Company and EPEC have filed the above proceedings.
They are requests that the Nuclear Regulatory Commission (NRC): (1) consent to the indirect transfer of control of EPEC's interest in certain operating licenses; and (2) amend two of those operating licenses to delete provisions relating to previous sale-leaseback arrangements. By notice published March 14, 1994 at page 11S13, Volume 59, No. 49, of the Federal Register, the NRC has requested comment on the proposed transfer of control and the staff has requested comment on the antitrust issues raised by the proposed transactions.
- 2. Representative. The Attorney General of Texas is authorized to represent the PUCT before federal agencies that regulate public utilities. Public Utility 9404iS02iS 9404i2 PDR ADOCK OS000528 P PDR
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Regulatory Act (PURA), Tex. Rev. Civ. Stat. Ann. art. 1446c, g 15 (Vernon Supp.
1994). Service can be made on the following assistant attorneys general appearing on behalf of the PUCT:
Norma K. Scogin Liz Bills Steven Baron Administrative Law Section Energy Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 (512) 463-2003 Telecopier: (512) 320-0911
- 3. Interested party. The above counsel appear on behalf of:
Public UtilityCommission of Texas 7800 Shoal Creek Blvd., Suite 400-N Austin, Texas 78757 (512) 458-0213 Telecopier: (512) 458-8340
- 4. Interest. The above proceedings are a prerequisite to the proposed merger of EPEC and CSW. The PUCT regulates public utilities in Texas to assure rates, operations, and services that are just'and reasonable to consumers and utilities.
PURA $ 2. The PUCT is charged with protecting the public interest inherent in the rates and services of public utilities in Texas. Id. Five public utilities that provide electricity to retail customers in Texas will be directly affected by the proposed merger.
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The PUCT has jurisdiction over the utilities'exas retail rates and services. PURA $g 2, 16.
There is currently pending before the PUCT an application under PURA g 63 for a finding that the merger is in the public interest and a request to increase EPEC's rates.
As stated above, the NRC has requested public comment on possible antitrust implications of the proposed merger. Ifthe NRC denies the requested relief, the merger will not take place. Ifthe NRC conditions approval on some change in the terms of the merger, the PUCT's evaluation of the public interest question may be affected. The PUCT has a duty to participate in the above proceeding to ensure that the public interest is served.
- 5. Request for Notice. The PUCT hereby requests that copies of notices in this matter be provided to the its attorneys and that they be included on the official service list of this proceeding.
Respectfully submitted, DAN MORALES Attorney General of Texas JORGE VEGA First Assistant Attorney General JAMES M. PHILLIPS Chief, Energy Division
NORMA K. SCOG LIZ BILLS STEVEN BARON Assistant Attorney General Administrative Law Section Energy Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 (512) 463-2003 Telecopier: (512) 320-0911 ATTORNEYS FOR PUBLIC UTILITY COMMISSION OF TEXAS Dated: April 12, 1994
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I certify that on this 12th day of April, 1994, a true and correct copy of the foregoing Notice of Appearance of Public Utility Commission of Texas has been sent by United States mail, postage prepaid, to all persons listed on the attached service list.
N RMAK. SCOGIN
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Steve Olea Jack R. Newman Arizona Corporation Commission Newman & Holtzinger 1200 W. Washington Street 1615 L Street, N.W., Suite 1000 Phoenix, Arizona 85007 Washington, D.C. 20036 James A. Beoletto Curtis Hoskins Southern California Edison Company Executive Vice President and P. O. Box 800 Chief Executive Operating Officer Rosemead, California 91770 El Paso Electric Company 303 North Oregon Street Senior Resident Inspector El Paso, Texas 79901 Palo Verde Nuclear Generating Station Roy P. Lessy, Jr.
5951 S. Wintersburg Road Akin, Gump, Strauss, Hauer and Feld Tonopah, Arizona 85354-7537 1333 New Hampshire Ave., Ste. 400 Washington, D,C. 20036 Regional Administrator, Region V U.S. Nuclear Regulatory commission Ronald J. Stevens, Director 1450 Maria Lane, Suite 210 Nuclear Regulatory Affairs Walnut Creek, California 94596 Arizona Public Service Company P. O. Box 52034 Charles B. Brinkman, Manager Phoenix, Arizona 85072-2034 Washington Nuclear Operations ABB Combustion Engineering Eduardo A. Rodriguez Nuclear Power Vice President, Secretary and 12300 Twinbrook Parkway, Suite 330 General Counsel Rockville, Maryland 20852 El Paso Electric Company 303 North Oregon Street Aubrey V. Godwin, Director EI Paso, Texas 79901 Arizona Radiation Regulatory Agency 4814 South 40 Street Chairman Phoenix, Arizona 85040 Maricopa County Board of Supervisors 111 South Third Ave.
Mark D. Roberson Phoenix, Arizona 85003 Federal Case Director El Paso Transition Team Clark Evans Downs Central and South West Corp. Jones, Day Reavis & Pogue P. O. Box 660164. 1450 G Street, N.W.
Dallas, Texas 75266-0164 Washington, D.C. 20005-2088
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