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| bl10.82(b)(1) and (4). | | bl10.82(b)(1) and (4). |
| 1/ The attached affidavit of Heherson Alvarez more fully details MFP and its members and activities. | | 1/ The attached affidavit of Heherson Alvarez more fully details MFP and its members and activities. |
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| The International Secretary General of MFP, Heherson Alvarez, is empowered to authorized participation in this matter in MFP's name. Mr. Alvarez, after polling of the members of the organization at their annual convention, has done so. | | The International Secretary General of MFP, Heherson Alvarez, is empowered to authorized participation in this matter in MFP's name. Mr. Alvarez, after polling of the members of the organization at their annual convention, has done so. |
| The International President of MFP is Raoul S. | | The International President of MFP is Raoul S. |
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| As shown in the attached Sixth Annual Convention Program, MFP has devoted large amounts of time, effort and resources to studying and discussing this project. In evaluating this project as well as trying to understana the impact of U.S. foreign aid and international export programs upon the Philippines, MFP has placed great reliance and worked closely with the Center for Development Policy (" CDP"), a proposed intervenor in this matter. CDP has supplied MFP with the technical and scientific knowledge necessary to understand the effect of this reactor upon MFP's members. | | As shown in the attached Sixth Annual Convention Program, MFP has devoted large amounts of time, effort and resources to studying and discussing this project. In evaluating this project as well as trying to understana the impact of U.S. foreign aid and international export programs upon the Philippines, MFP has placed great reliance and worked closely with the Center for Development Policy (" CDP"), a proposed intervenor in this matter. CDP has supplied MFP with the technical and scientific knowledge necessary to understand the effect of this reactor upon MFP's members. |
| III. RELIEF REQUESTED MFP respectfully requests that the Commission allow it to join with the Center for Development Folicy as an intervenor in the above-captioned matters and allow MFP to participate in any and all hearings to be held on this reactor. | | III. RELIEF REQUESTED MFP respectfully requests that the Commission allow it to join with the Center for Development Folicy as an intervenor in the above-captioned matters and allow MFP to participate in any and all hearings to be held on this reactor. |
| Resp l l y s u bru i t t e a , | | Resp l l y s u bru i t t e a , |
| f ( udW Thomas R. Asher | | f ( udW Thomas R. Asher |
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| Mattnew B. Bogin Thomas R. Asher, P.C. | | Mattnew B. Bogin Thomas R. Asher, P.C. |
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| Third Floor Washington, D.C. 20036 (202) 452-1540 Attorneys for Petitioners f/'if / h 3 | | Third Floor Washington, D.C. 20036 (202) 452-1540 Attorneys for Petitioners f/'if / h 3 |
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| UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ) | | UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ) |
| ) Application No. XR-120 WESTINGHOUSE ELECTRIC CORP. ) Docket No. 50-574 (Exports to the Pbilippines) Application No. XCOM 0013 | | ) Application No. XR-120 WESTINGHOUSE ELECTRIC CORP. ) Docket No. 50-574 (Exports to the Pbilippines) Application No. XCOM 0013 |
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| Eckert, Seamons, Cherin & Mellott 42nd Floor, 600 Grant Street Pittsburgh, Pennsylvania 15230 Thomas M. Daugherty, Esq. | | Eckert, Seamons, Cherin & Mellott 42nd Floor, 600 Grant Street Pittsburgh, Pennsylvania 15230 Thomas M. Daugherty, Esq. |
| Westinghouse Nuclear Energy Systems P. O. Box 355 Pittsburgh, Pennsylvania 15230 Peter Tarnoff Executive Secretary U.S. Department of State Washington, D. C. 20520 , | | Westinghouse Nuclear Energy Systems P. O. Box 355 Pittsburgh, Pennsylvania 15230 Peter Tarnoff Executive Secretary U.S. Department of State Washington, D. C. 20520 , |
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| .: l f Matthew B. | | .: l f Matthew B. |
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| UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ) | | UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ) |
| ) Application No. XR-120 WESTINGHOUSE ELECTRIC CORP. ) Docket No. 50-574 (Exports to the Philippines) Application No. XCOM 0013 | | ) Application No. XR-120 WESTINGHOUSE ELECTRIC CORP. ) Docket No. 50-574 (Exports to the Philippines) Application No. XCOM 0013 |
| ) Application No. XSNM0 1471 CERTIFICATE OF SERVICE I hereby certify that copies of " Supplemental Memorandum" and accompanying Affidavit f postage prepaid, were mailed,7 to the following individuals this [rst-class | | ) Application No. XSNM0 1471 CERTIFICATE OF SERVICE I hereby certify that copies of " Supplemental Memorandum" and accompanying Affidavit f postage prepaid, were mailed,7 to the following individuals this [rst-class day of October, 1979. |
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| Howard K. Shapar, Esq. | | Howard K. Shapar, Esq. |
| Joanna Becker, Esq. | | Joanna Becker, Esq. |
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| Barton Z. Cowan, Esq. g 4.g Eckert, Seamons, Cherin & Mellott se _,, | | Barton Z. Cowan, Esq. g 4.g Eckert, Seamons, Cherin & Mellott se _,, |
| 42nd Floor, 600 Grant Street Pittsburgh, Pennsylvania 15230 ( | | 42nd Floor, 600 Grant Street Pittsburgh, Pennsylvania 15230 ( |
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| OCI .31373 C #'3 Thomas M. Daugherty, Esq. ,{d g ,,, fjg | | OCI .31373 C #'3 Thomas M. Daugherty, Esq. ,{d g ,,, fjg Westinghouse Nuclear Energy Systems CCLc. ,,1,w* |
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| Pittsburgh, Pennsylvania 15230 91 , | | Pittsburgh, Pennsylvania 15230 91 , |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML19310A6271980-06-10010 June 1980 Brief on Appeal Before Us Court of Appeals,Dc Circuit,From Commission 800506 Orders.Case Must Be Remanded to Examine Us Common Defense & Security Under Atomic Energy Act,Nuclear Non-Proliferation Act & Nepa.Certificate of Svc Encl ML19305D4561980-04-0303 April 1980 Motion to Stay Effectiveness of Final Order,Pending Appeal & Judicial Review Re Nuclear Reactor Export to Philippines. Delay in Shipment Will Not Injure Interests of Exporter or Parties.Certificate of Svc Encl ML19294C1251980-02-29029 February 1980 Comments in Response to Commission 800208 Order Requesting Further Views on Proposed Reactor Export to Philippines. Effects on Global Commons Subminimal Per Apr 1976 Fes on Us Nuclear Power Export process,ERDA-1542.W/Certificate of Svc ML19290E3061980-02-29029 February 1980 Statement of Views in Response to Commission 800208 Order Requesting Further Submittals Re Nuclear Reactor Export to Philippines.Urges Preparation of EIS Updating ERDA-1542 & Addressing Possible Environ Impacts on Us & Global Commons ML19294C1191980-02-29029 February 1980 Comments in Response to Commission 800208 Order Requesting Further Views on Proposed Reactor Export to Philippines. Impact on Clark Air Force Base & Subic Bay Naval Station Sufficient to Pose Threat.W/Certificate of Svc ML19294C1071980-02-29029 February 1980 Response to Commission 800208 Order Requesting Further Views on Proposed Reactor Export to Philippines.Apr 1976 Fes on Us Nuclear Power Export activities,ERDA-1542,should Be Applied.Effects on Global Commons Not Related to Us Defense ML19322E2601980-02-28028 February 1980 Statement Opposing Proposed Export of Reactor & Matls to Philippines by Westinghouse.Nrc Should Not Approve Export of Reactor & Matls for Power Plant to Be Constructed on Slope of Volcano ML19294B6441980-02-28028 February 1980 Comments in Response to Commission 800208 Order Re Reactor Export to Philippines.License Should Be Issued Immediately. NRC Already Adequately Addressed Health Safety & Environ Effects ML19290E7051980-02-27027 February 1980 Comments & Argument in Response to Commission 800208 Order Inviting Further Views Re Nuclear Reactor Export to Philippines.Adopts Wl Cummings 800129 Encl Affidavit Re Health,Safety & Environ Effects on Global Commons or Us Land ML19294B6041980-02-26026 February 1980 Comments in Response to Commission 791019 & 800208 Orders Re Reactor Export to Philippines.Steps Taken by Philippine Govt Assure No Adverse Health & Environ Effects on Us Global Commons.Certificate of Svc Encl ML19290E7081980-01-29029 January 1980 Affidavit Urging Denial of Nuclear Reactor Export to Philippines.Export Threaten Philippine Sovereignity, Jeopardizes Global Commons & Affects Us Natl Security. Certificate of Svc Encl ML19211C6621979-12-27027 December 1979 Comments on NRC 791119 Position Per Commission 791019 Order. Urges Compliance w/1954 Atomic Energy Act Re Limitation of NRC Jurisdiction to Common Defense & Security of Us ML19211C6241979-12-27027 December 1979 Comments by National Power Corp of Philippines on NRC 791119 Submittal in Response to Commission 791019 Order.Urges Compliance W/Us 1954 Atomic Energy Act Limiting NRC Jurisdiction to Common Defense & Security of Us ML19257A3961979-12-19019 December 1979 Response to Westinghouse Objection to Friends of the Filipino People Request to Intervene.No Delay or Prejudice Will Arise from Granting of Request.No Other Group Can Represent Interests of Petitioners ML19257A6591979-12-19019 December 1979 Response in Opposition to Westinghouse Answer Objecting to Friends of the Filipino People Request to Intervene.Adopts Ctr for Development Policy,Movement for Environ Protection & Jn Perlas 790604 Consolidated Reply.W/Certificate of Svc ML19260C6721979-12-18018 December 1979 Reply to Applicant Response to Petitioner Motion to Intervene.Urges Commission to Grant Intervention.Affidavit of Support & Certificate of Svc Encl ML19260B6141979-11-29029 November 1979 Response in Opposition to Ctr for Development Policy, Philippine Movement for Environ Protection,Movement for Free Philippines & Nj Perias 791119 Pleading.Waiver of Export Rules Will Create Uncertainty Among Importing Countries ML19210E5401979-11-21021 November 1979 Response to NRC 791019 Request for Views on Philippine Export Proceedings.Hearing on Seven Items Outlined in 790419 Petition to Intervene Requested ML19210E5831979-11-19019 November 1979 Affidavit of C Planas on 791119 Re Westinghouse Application to Export Nuclear Reactor to Philippines.Application Should Be Denied Due to Health & Safety Risks & High Cost of Maint ML19260A6281979-11-19019 November 1979 Response to Commission 791019 Order Requesting Views on Nuclear Reactor Export to Philippines.Requests Hearing on Issues Presented in 790419 Petition to Intervene.Supporting Documentation Encl ML19262A9881979-11-19019 November 1979 Brief in Lieu of Pleading,Re Nuclear Reactor Export to Philippines.Questions Ability of Less Developed Nations to Deal W/Nuclear Technology Issues.Supporting Documentation Encl ML19253C3591979-11-19019 November 1979 Memorandum Stating Position Re Export of Nuclear Reactor to Philippines in Response to NRC 791019 Order.Nrc Has No Jurisdiction Over Matters Affecting Health & Safety in Foreign Countries.Certificate of Svc & Exhibits Encl ML19210E4861979-11-19019 November 1979 Comments in Response to Commission 791019 Order Requesting Views on Commission Jurisdiction to Consider Nuclear Reactor Effects in Foreign Country.Proceeding Affects Foreign Policy Which NRC Cannot Formulate ML19210E6181979-11-15015 November 1979 Statement of Views by Natl Power Corp,Agency of Govt of Philippines,In Response to Commission 791019 Order.Atomic Energy & Nuclear Nonproliferation Acts Were Not Promulgated to Dictate Policies on Foreign Nations ML19210D9251979-11-14014 November 1979 Response to Commission 791019 Order for Views on Procedural & Jurisdictional Issues.Relevant Legal Considerations Discussed May Justify Different NRC Health,Safety & Environ Reviews for Some Export License Applications ML19253C1351979-11-12012 November 1979 Affidavit Alleging That Philippine Govt Has Not Carefully Considered Impacts of Proposed Reactor.Nrc Should Conduct Thorough Health,Safety & Environ Review.Reactor Would Be Unsafe.Exhibits Encl ML19253C1231979-11-12012 November 1979 Petition to Intervene in Form of Brief Requesting License Denial.Urges Review of Commission 791019 Order Re Seismic & Geological Risks,Design Adequacy,Environ Impact,Spent Fuel Disposition & Other Issues.Hearings Requested ML19210D9791979-11-12012 November 1979 Responds to 791019 Order Requesting Views on Jurisdictional & Procedural Issues.Nrc Failed to Comply w/791004 Deadline for Implementation of Executive Order 12114.NRC Is Restrained from Action on Westinghouse Application ML19250C6581979-11-0808 November 1979 Natl Power Corp Statement of Views Re Pending Westinghouse Export Application.Export License Should Be Granted W/O Further Proceedings ML19268B9901979-11-0606 November 1979 Affidavit Stating Observation of Commission 790623-0810 & 0913-14 Hearing in Philadelphia,Pa.Objects to Scope of Hearing & Limited Opportunity Given to Participants ML19256F0671979-11-0202 November 1979 Brief in Lieu of Pleading Per Commission 791019 Order Inviting Submittal of Questions Re Scope of Commission Jurisdiction Over Foreign Environ.Alleges That Environ Impacts in Philippines May Be Connected W/Us Security ML19256F0731979-10-19019 October 1979 Affidavit Alleging That Westinghouse Has Been Bribed by Marcos Govt.Contends That Location of Reactor on Slope of Volcano Believed to Be Active Will Cause Harm to Us Military Personnel Located in Adjacent Areas ML19256F0721979-10-19019 October 1979 Affidavit Alleging That Philippine Environmental Matters Will Be Aggravated by Allowing Exportation of Nuclear Reactor from Us.Urges Commission to Disapprove Proposal ML19209D2001979-10-10010 October 1979 Notice of Friends of Filipino People Intention to File 791016 Petition to Intervene,Along W/Opposition & Request for Participation.States Experience Gained in Representing Us Citizens Concerned About US-Philippines Relations ML19254C8261979-10-0909 October 1979 Supplemental Memorandum in Response to NRC Supplemental Answer.Psar & Other Primary Evidence Were Prepared by Members of Group Applying for Full Participation in Proceeding.Certificate of Svc & Affidavits Encl ML19261F1541979-10-0909 October 1979 Answer in Opposition to Movement for Free Philippines Motion to Amend 791003 Petition to Intervene & Request for Hearing. Petition Is Untimely & Does Not Satisfy Requirements. Separate Intervention Status Should Not Be Granted ML19254F0231979-10-0303 October 1979 Motion That Ctr for Development Policy 790419 Petition to Intervenor Be Amended to Add Movement for Free Philippines as Petitioner.Members Are Political Refugees.Affidavit of H Alvarez & Certificate of Svc Encl ML19254F0261979-10-0303 October 1979 Supplemental Memorandum in Support of 790420 Petition to Intervene & Request for Adjudicatory Public Hearing.Asserts Vital Interest in Export Proceeding ML19254C8511979-10-0303 October 1979 Supplemental Memorandum in Support of Ctr for Development 790420 Petition to Intervene & Request for Hearing.Alleges Discovery of Contradicting Applicant Submittal ML19254C8451979-10-0303 October 1979 Motion to Amend 790419 Petition to Intervene & Request for Hearing.Participation Will Draw Filipino Attention to Risks & Hazards Created by Reactor.Certificate of Svc Encl ML19254F0271979-09-28028 September 1979 Affidavit of L Mattison on 791003 Re Supplemental Memorandum to 790420 Petition to Intervene.Intervention Is in Public Interest & Would Assist NRC in Making Required Determinations.Certificate of Svc Encl ML19254C8521979-09-28028 September 1979 Affidavit Attesting That Ctr for Development Policy Conducts Independent,Nonpartisan Research of Us Development Programs, W/Primary Attention Focused on Nanot Point Reactor Project. Requests Intervention to Present Evidence ML19254C8501979-08-31031 August 1979 Affidavit Attesting Authorization to Intervene on Behalf of Movement of Free Philippines.Certificate of Svc Encl ML19254D4891979-07-11011 July 1979 Transcript of Republic of Philippines Commission on Nuclear Power Plants 790711-13 Hearings in Manila,Philippines. Transcript Divided Into Sections by Stenographer ML19261D6981979-06-0404 June 1979 Joint Reply of Petitioners to NRC & Westinghouse Request for Denial of Intervenor Status.Petitioners Have Standing Under All Applicable Tests.Consolidation of Licenses Will Aid Proceedings.Certificate of Svc Encl ML19257A2541979-05-23023 May 1979 Answer in Opposition to Friends of the Filipino People & Coalition Against Reactor Exports 791106 & 15 Briefs. Petitioners Failed to Demonstrate Standing & Raised Questions Outside NRC Jurisdiction.Certificate of Svc Encl ML19269D9811979-05-23023 May 1979 Applicant Answer to 790419 Petition to Intervene.Joint Intervenors Are Untimely,Lack Standing,Raise Issues Outside Jurisdiction of NRC & Fail to Demonstrate That Hearing Is in Public Interest.Certificate of Svc Encl ML19263E2461979-04-19019 April 1979 Petition to Intervene & Request for Hearing Per 10CFR110 by Ctr for Development Policy,Jn Perlas & Philippine Movement for Environ Protection.Supporting Documentation Encl 1980-06-10
[Table view] Category:PLEADINGS
MONTHYEARML19305D4561980-04-0303 April 1980 Motion to Stay Effectiveness of Final Order,Pending Appeal & Judicial Review Re Nuclear Reactor Export to Philippines. Delay in Shipment Will Not Injure Interests of Exporter or Parties.Certificate of Svc Encl ML19290E3061980-02-29029 February 1980 Statement of Views in Response to Commission 800208 Order Requesting Further Submittals Re Nuclear Reactor Export to Philippines.Urges Preparation of EIS Updating ERDA-1542 & Addressing Possible Environ Impacts on Us & Global Commons ML19294C1071980-02-29029 February 1980 Response to Commission 800208 Order Requesting Further Views on Proposed Reactor Export to Philippines.Apr 1976 Fes on Us Nuclear Power Export activities,ERDA-1542,should Be Applied.Effects on Global Commons Not Related to Us Defense ML19294C1191980-02-29029 February 1980 Comments in Response to Commission 800208 Order Requesting Further Views on Proposed Reactor Export to Philippines. Impact on Clark Air Force Base & Subic Bay Naval Station Sufficient to Pose Threat.W/Certificate of Svc ML19294C1251980-02-29029 February 1980 Comments in Response to Commission 800208 Order Requesting Further Views on Proposed Reactor Export to Philippines. Effects on Global Commons Subminimal Per Apr 1976 Fes on Us Nuclear Power Export process,ERDA-1542.W/Certificate of Svc ML19322E2601980-02-28028 February 1980 Statement Opposing Proposed Export of Reactor & Matls to Philippines by Westinghouse.Nrc Should Not Approve Export of Reactor & Matls for Power Plant to Be Constructed on Slope of Volcano ML19294B6441980-02-28028 February 1980 Comments in Response to Commission 800208 Order Re Reactor Export to Philippines.License Should Be Issued Immediately. NRC Already Adequately Addressed Health Safety & Environ Effects ML19290E7051980-02-27027 February 1980 Comments & Argument in Response to Commission 800208 Order Inviting Further Views Re Nuclear Reactor Export to Philippines.Adopts Wl Cummings 800129 Encl Affidavit Re Health,Safety & Environ Effects on Global Commons or Us Land ML19294B6041980-02-26026 February 1980 Comments in Response to Commission 791019 & 800208 Orders Re Reactor Export to Philippines.Steps Taken by Philippine Govt Assure No Adverse Health & Environ Effects on Us Global Commons.Certificate of Svc Encl ML19211C6621979-12-27027 December 1979 Comments on NRC 791119 Position Per Commission 791019 Order. Urges Compliance w/1954 Atomic Energy Act Re Limitation of NRC Jurisdiction to Common Defense & Security of Us ML19211C6241979-12-27027 December 1979 Comments by National Power Corp of Philippines on NRC 791119 Submittal in Response to Commission 791019 Order.Urges Compliance W/Us 1954 Atomic Energy Act Limiting NRC Jurisdiction to Common Defense & Security of Us ML19257A6591979-12-19019 December 1979 Response in Opposition to Westinghouse Answer Objecting to Friends of the Filipino People Request to Intervene.Adopts Ctr for Development Policy,Movement for Environ Protection & Jn Perlas 790604 Consolidated Reply.W/Certificate of Svc ML19257A3961979-12-19019 December 1979 Response to Westinghouse Objection to Friends of the Filipino People Request to Intervene.No Delay or Prejudice Will Arise from Granting of Request.No Other Group Can Represent Interests of Petitioners ML19260C6721979-12-18018 December 1979 Reply to Applicant Response to Petitioner Motion to Intervene.Urges Commission to Grant Intervention.Affidavit of Support & Certificate of Svc Encl ML19260B6141979-11-29029 November 1979 Response in Opposition to Ctr for Development Policy, Philippine Movement for Environ Protection,Movement for Free Philippines & Nj Perias 791119 Pleading.Waiver of Export Rules Will Create Uncertainty Among Importing Countries ML19210E5401979-11-21021 November 1979 Response to NRC 791019 Request for Views on Philippine Export Proceedings.Hearing on Seven Items Outlined in 790419 Petition to Intervene Requested ML19210E4861979-11-19019 November 1979 Comments in Response to Commission 791019 Order Requesting Views on Commission Jurisdiction to Consider Nuclear Reactor Effects in Foreign Country.Proceeding Affects Foreign Policy Which NRC Cannot Formulate ML19262A9881979-11-19019 November 1979 Brief in Lieu of Pleading,Re Nuclear Reactor Export to Philippines.Questions Ability of Less Developed Nations to Deal W/Nuclear Technology Issues.Supporting Documentation Encl ML19260A6281979-11-19019 November 1979 Response to Commission 791019 Order Requesting Views on Nuclear Reactor Export to Philippines.Requests Hearing on Issues Presented in 790419 Petition to Intervene.Supporting Documentation Encl ML19253C3591979-11-19019 November 1979 Memorandum Stating Position Re Export of Nuclear Reactor to Philippines in Response to NRC 791019 Order.Nrc Has No Jurisdiction Over Matters Affecting Health & Safety in Foreign Countries.Certificate of Svc & Exhibits Encl ML19210E6181979-11-15015 November 1979 Statement of Views by Natl Power Corp,Agency of Govt of Philippines,In Response to Commission 791019 Order.Atomic Energy & Nuclear Nonproliferation Acts Were Not Promulgated to Dictate Policies on Foreign Nations ML19210D9251979-11-14014 November 1979 Response to Commission 791019 Order for Views on Procedural & Jurisdictional Issues.Relevant Legal Considerations Discussed May Justify Different NRC Health,Safety & Environ Reviews for Some Export License Applications ML19210D9791979-11-12012 November 1979 Responds to 791019 Order Requesting Views on Jurisdictional & Procedural Issues.Nrc Failed to Comply w/791004 Deadline for Implementation of Executive Order 12114.NRC Is Restrained from Action on Westinghouse Application ML19250C6581979-11-0808 November 1979 Natl Power Corp Statement of Views Re Pending Westinghouse Export Application.Export License Should Be Granted W/O Further Proceedings ML19256F0671979-11-0202 November 1979 Brief in Lieu of Pleading Per Commission 791019 Order Inviting Submittal of Questions Re Scope of Commission Jurisdiction Over Foreign Environ.Alleges That Environ Impacts in Philippines May Be Connected W/Us Security ML19261F1541979-10-0909 October 1979 Answer in Opposition to Movement for Free Philippines Motion to Amend 791003 Petition to Intervene & Request for Hearing. Petition Is Untimely & Does Not Satisfy Requirements. Separate Intervention Status Should Not Be Granted ML19254C8261979-10-0909 October 1979 Supplemental Memorandum in Response to NRC Supplemental Answer.Psar & Other Primary Evidence Were Prepared by Members of Group Applying for Full Participation in Proceeding.Certificate of Svc & Affidavits Encl ML19254F0231979-10-0303 October 1979 Motion That Ctr for Development Policy 790419 Petition to Intervenor Be Amended to Add Movement for Free Philippines as Petitioner.Members Are Political Refugees.Affidavit of H Alvarez & Certificate of Svc Encl ML19254F0261979-10-0303 October 1979 Supplemental Memorandum in Support of 790420 Petition to Intervene & Request for Adjudicatory Public Hearing.Asserts Vital Interest in Export Proceeding ML19254C8451979-10-0303 October 1979 Motion to Amend 790419 Petition to Intervene & Request for Hearing.Participation Will Draw Filipino Attention to Risks & Hazards Created by Reactor.Certificate of Svc Encl ML19261D6981979-06-0404 June 1979 Joint Reply of Petitioners to NRC & Westinghouse Request for Denial of Intervenor Status.Petitioners Have Standing Under All Applicable Tests.Consolidation of Licenses Will Aid Proceedings.Certificate of Svc Encl ML19257A2541979-05-23023 May 1979 Answer in Opposition to Friends of the Filipino People & Coalition Against Reactor Exports 791106 & 15 Briefs. Petitioners Failed to Demonstrate Standing & Raised Questions Outside NRC Jurisdiction.Certificate of Svc Encl ML19269D9811979-05-23023 May 1979 Applicant Answer to 790419 Petition to Intervene.Joint Intervenors Are Untimely,Lack Standing,Raise Issues Outside Jurisdiction of NRC & Fail to Demonstrate That Hearing Is in Public Interest.Certificate of Svc Encl ML19263E2461979-04-19019 April 1979 Petition to Intervene & Request for Hearing Per 10CFR110 by Ctr for Development Policy,Jn Perlas & Philippine Movement for Environ Protection.Supporting Documentation Encl 1980-04-03
[Table view] |
Text
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. mo.ng In the matter of
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) Application No. XR-120 WESTINGHOUSE ELECTRIC CORP. ) Docket No. 50-574
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(Exports to the Philippines) ) Application No. XCOM 0013
) Application No. XSNM0 1471 MOTION TO AMEND PETITION FOR LEAVE i0 INTERVENE AND REQUEST FOR HEARING The Movement for a Free Philippines ( "M F P '~ ) respectfully requests that this Commission allow amendment of the Petition for Leave to Intervene and Request for Hearing filed in the above-captioned matters on April 19, 1979 to allow MFP to join in that Petition.
I. IDENTIFICATION OF PETITIONER 1/
MFP is an unincorporated association of Filipino political refugees with 39 chapters in the United States and a membership comprised of both American citizens and Filipinos currently residing in the United States.S/
MFP has thousands of memoers in the Philippines who, due to the political climate, must remain secret. Many reside and/or own property within 40 miles of the site of the proposed reactor.
In addition, many of the MFP members in the United States own real property located within the same radial distance from the reactor.
1/ This information is submitted pursuant to 10 C.F.R.
bl10.82(b)(1) and (4).
1/ The attached affidavit of Heherson Alvarez more fully details MFP and its members and activities.
t 7910180 O [ O G
The International Secretary General of MFP, Heherson Alvarez, is empowered to authorized participation in this matter in MFP's name. Mr. Alvarez, after polling of the members of the organization at their annual convention, has done so.
The International President of MFP is Raoul S.
Manglapus. He has served as Undersecretary of Foreign Affairs and Secretary of Foreign Affairs in the Philippine government and was additionally a member of the Filipino Senate.
MFP's offices are Suite 804, National Press Building, Washington, D.C. 20045, and its telephone number is 630-0400.
II. INTEREST OF MFP MFP's interests in this matter are wide and variea. It seeks to prevent the radioactive contamination of the homes and farms of many of its members. Additionally, it is seriously concerned about the threat to the security of the Philippines, which is inexorably intertwined with that of the United States, posed by this reactor.
MFP seeks to bring to the attention of Filipino citizens and their government the attendant risks and hazards of this project but because of the political conditions there and the exile status of its public members it has been unable to do 50.
Participation by MFP at the NRC is the only avenue by which MFP can share its information and concerns about this project.
i18% 108 2
As shown in the attached Sixth Annual Convention Program, MFP has devoted large amounts of time, effort and resources to studying and discussing this project. In evaluating this project as well as trying to understana the impact of U.S. foreign aid and international export programs upon the Philippines, MFP has placed great reliance and worked closely with the Center for Development Policy (" CDP"), a proposed intervenor in this matter. CDP has supplied MFP with the technical and scientific knowledge necessary to understand the effect of this reactor upon MFP's members.
III. RELIEF REQUESTED MFP respectfully requests that the Commission allow it to join with the Center for Development Folicy as an intervenor in the above-captioned matters and allow MFP to participate in any and all hearings to be held on this reactor.
Resp l l y s u bru i t t e a ,
f ( udW Thomas R. Asher
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Mattnew B. Bogin Thomas R. Asher, P.C.
1232 Seventeenth Street, N.W.
Third Floor Washington, D.C. 20036 (202) 452-1540 Attorneys for Petitioners f/'if / h 3
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )
) Application No. XR-120 WESTINGHOUSE ELECTRIC CORP. ) Docket No. 50-574 (Exports to the Pbilippines) Application No. XCOM 0013
) Application No. XSNM0 1471 CERTIFICATE OF SERVICE I hereby certify that copies of " Motion to Amend Petition for Leave to Intervene and Request for Hearing" were mailed, first-class postage prepaid, to the following individuals this > ,t / day of October, 1979:
Howard K. Shapar, Esq.
Joanna Becker, Esq.
U.S. Nuclear Regulatory Commission Room 10604 Maryland National Bank Suilding Washington, D. C. 20555 Barton Z. Cowan, Esq.
Eckert, Seamons, Cherin & Mellott 42nd Floor, 600 Grant Street Pittsburgh, Pennsylvania 15230 Thomas M. Daugherty, Esq.
Westinghouse Nuclear Energy Systems P. O. Box 355 Pittsburgh, Pennsylvania 15230 Peter Tarnoff Executive Secretary U.S. Department of State Washington, D. C. 20520 ,
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.: l f Matthew B.
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Bogin 1184 0 4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )
) Application No. XR-120 WESTINGHOUSE ELECTRIC CORP. ) Docket No. 50-574 (Exports to the Philippines) Application No. XCOM 0013
) Application No. XSNM0 1471 CERTIFICATE OF SERVICE I hereby certify that copies of " Supplemental Memorandum" and accompanying Affidavit f postage prepaid, were mailed,7 to the following individuals this [rst-class day of October, 1979.
Howard K. Shapar, Esq.
Joanna Becker, Esq.
U.S. Nuclear Regulatory Commission Roon 10604 Maryland National Bank Building Washington, D. C. 20555 m ' o.
Barton Z. Cowan, Esq. g 4.g Eckert, Seamons, Cherin & Mellott se _,,
42nd Floor, 600 Grant Street Pittsburgh, Pennsylvania 15230 (
'55_.A:
OCI .31373 C #'3 Thomas M. Daugherty, Esq. ,{d g ,,, fjg Westinghouse Nuclear Energy Systems CCLc. ,,1,w*
"d" P. O. Box 355 #
Pittsburgh, Pennsylvania 15230 91 ,
co Peter Tarnoff Executive Secretary ,
U.S. Department of State Washington, D. C. 20520 '
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Matthew B .' B o g i n ilbk 5