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Category:INTERVENTION PETITIONS
MONTHYEARML20106D3131992-10-0505 October 1992 Suppl to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SM Hasan.* Board Should Admit Petitioner Contention 1 for Listed Reasons.W/Certificate of Svc ML20099J8751992-08-14014 August 1992 TU Electric Answer to Petition for Intervention & Request for Hearings by Dows.* Petition to Intervene Should Not Be Accepted for Filing Because Petition Contains Untrue & Scandalous Allegations.Certificate of Svc & Other Info Encl ML20099H1071992-08-0606 August 1992 TU Electric Answer to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SMA Hasan.* Petition Should Be Denied Re Macktal & Hasan Since Neither Showed Standing to Intervene.W/Notices & Certificate of Svc ML20114A9331992-07-28028 July 1992 Petition of SL Dow Dba Disposable Workers of Comanche Peak Ses & RM Dow for Intervention & Request for Hearings.* Licensee Seeks to Extend Expiration Date of CP for Period of Addl 3 Yrs.W/Certificate of Svc ML20099H0921992-07-27027 July 1992 Petition to Intervene & Request for Hearing of Bi Orr, Di Orr,Jj Macktal & SMA Hasan.* Requests That Hearing Be Convened to Determine Whether Good Cause Exists for Extension of CP Completion Date.Certificate of Svc Encl ML19325D6381989-10-20020 October 1989 Request to Continue Proceedings & Petition to Intervene by Citizens for Fair Util Regulation & Greater Fort Worth Group of Lone Star Chapter of Sierra Club.* Petitioners Have Requisite Interest to Establish Standing ML20154G7591988-09-12012 September 1988 Citizen for Fair Util Regulation (Cfur) First Suppl to 880811 Request for Hearing & Petition for Leave to Intervene.* Cfur 880811 Request for Hearing & Petition for Leave to Intervene Should Be Granted.W/Certificate of Svc ML20153D1361988-08-26026 August 1988 Applicant Answer to Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* Request Should Be Denied Based on Inability to Develop Allegations. Certificate of Svc Encl ML20207E5261988-08-11011 August 1988 Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* ML20150E2131988-07-13013 July 1988 Citizens Audit Motion for Stay & Motion for Sua Sponte Relief.* Requests Time to Review Concerns of J Doe & for Relief for Listed Items in Order to Act as Intervenor in Proceeding.W/Certificate of Svc ML20150E2071988-07-11011 July 1988 Second Group of Individual Residents Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released.W/Certificate of Svc ML20150E3301988-07-11011 July 1988 Greater Fort Worth Sierra Club Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That Relief for Listed Items Be Granted Sua Sponte to Address Complex safety-related Issues.W/Certificate of Svc ML20150D5141988-07-0808 July 1988 Citizens for Fair Util Regulation Motion to Intervene & for Sua Sponte Relief.* Petitioner Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released & That 880713 Hearing Be Continued for 60 Days ML20150D5371988-07-0808 July 1988 Individual Residents Motion to Intervene & for Sua Sponte Relief.* Listed Petitioners Request Relief That All Settlement Agreements Re Joint Stipulation Be Publicly Released & 880713 Hearing Be Extended.W/Certificate of Svc ML20211H3921986-10-31031 October 1986 Consolidated Intervenors Motion to Dismiss Pending Appeal as Moot &/Or for Lack of Jurisdiction & to Immediately Dissolve Order Staying Discovery.Certificate of Svc Encl ML20210N2811986-09-30030 September 1986 Consolidated Intervenors Amended Contentions 1 & 2 Re Reinsp Efforts & Const Delay.Certificate of Svc Encl ML20203G4731986-04-18018 April 1986 Answer Opposing M Gregory & Case 860407 Petition for Leave to Intervene Re NRC 860210 Order Extending Completion Date for CPPR-126 to 880801.Contentions Fail to Satisfy 10CFR2.714(b) Criteria.W/Certificate of Svc ML20203D5681986-04-17017 April 1986 Permittees Answer to Petitions to Intervene of Case & M Gregory.Certificate of Svc Encl ML20202G4751986-04-0707 April 1986 Petition of Case for Leave to Intervene & Request for Hearing.Certificate of Svc & Jl Howard Affidavit Encl ML20199K7401986-04-0707 April 1986 Petition of M Gregory for Leave to Intervene Re Improper Const & Invalid Util Justification for Delay.Affidavit of M Gregory & Certificate of Svc Encl.Served on 860409 ML20151U6791986-02-0505 February 1986 Response to Ha Stiner Request to Intervene late.Late-filed Petition Should Be Denied.W/Certificate of Svc ML20137Q0151985-12-0202 December 1985 Answer Supporting Applicant 851105 Petition for Directed Certification of ASLB 851031 Order for Review.Order Adversely Affects Basic Structure of OL Proceeding. Certificate of Svc Encl ML20081G7771983-11-0303 November 1983 Answer Opposing Citizens Assoc for Sound Energy (Case) 831024 Motions to Add New Contention & for Discovery Re Hot Functional Test Results.Case Should Have Begun to Pursue Subj Matter by 830513 ML20080S3261983-10-13013 October 1983 Motion to Add Proposed Contention 26 Re Hot Functional Test, Motion for Discovery & Offer of Proof.Certificate of Svc Encl ML20024A5251983-06-12012 June 1983 Answer Opposing State of Tx 830609 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Proposed Contention Lacks Requisite Specificity & Bases for late-filed Contentions.Certificate of Svc Encl ML20024A0311983-06-0909 June 1983 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Somervell County & Hood County Commitment,Expertise & Resources Inadequate to Adopt & Implement Emergency Plans.Certificate of Svc Encl ML20063H0351982-08-26026 August 1982 Motion to Add New Contention 26 Re Apparent Applicant Violation of 10CFR50,App A,Criterion 1,requiring Possession of Design Criteria for Pipe Support Sys & Components at Site.Certificate of Svc Encl ML19340D3001980-11-25025 November 1980 Supplemental Response,Submitted to Ferc,On DOJ 800917 Petition to Intervene.Doj Position Is Irrelevant to Approval of Supplemental Offer of Settlement & Should Be Denied W/O Prejudice.Supporting Info & Certificate of Svc Encl ML19338E9471980-09-17017 September 1980 Petition for Leave to Intervene ML19338C4101980-08-13013 August 1980 Response in Support of Tx Border Cooperatives Petition to Intervene.Nexus Requirement for Util Operations Affected by Dc Interconnection Satisfied.Untimeliness Is Measured by Necessity to Preserve Rights.Certificate of Svc Encl ML19331C5331980-08-13013 August 1980 Answer in Support of Tx Border Cooperatives 800731 Petition to Intervene.Good Cause Shown for Late Filing.No Other Means Exist to Protect Interests.Intervention Would Assist in Development of Sound Record.Certificate of Svc Encl ML19330C5831980-08-0707 August 1980 Response in Opposition to Tx Border Cooperative Petition to Intervene.Good Cause Not Shown.Cooperative Interests Can Be Protected in Pending FERC Hearing.Petitioners Failed to Show Participation Would Assist in Development of Record ML19330B5911980-07-31031 July 1980 Petition for Untimely Intervention.Petitioners Had Reason to Believe That Interests Would Be Adequately Protected by Other Utils,But Significant Developments Created Concerns Re Dc Interconnections.Certificate of Svc Encl ML19331D9051980-07-31031 July 1980 Response to Applicants,Central & South West Corp & City of Austin,Tx Objections to Tx Border Cooperative Petition to Intervene.Asserts Interests Under LBP-74-13.Urges Full Party Participation.W/Certificate of Svc ML19323B5551980-04-10010 April 1980 Statement of Position in Opposition to Tx Association of Community Organizations for Reform Now Proposed Contentions. Intervenor Failed to Submit Allegations Warranting Admission in Proceeding.Certificate of Svc Encl ML19309H6591980-04-10010 April 1980 Statement of Position in Opposition to Citizens Association for Sound Energy Proposed Contentions.Intervenor Failed to Submit Allegations Warranting Admission in Proceeding. Proposed Contentions & Certificate of Svc Encl ML19344D5751980-03-25025 March 1980 Response in Opposition to Public Utils Board of City of Brownsville,Tx 800317 Comments Requesting Admittance as Party in Consolidated Proceeding.Statement of Interest Untimely & Vague.Certificate of Svc Encl 1992-08-06
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20106D3131992-10-0505 October 1992 Suppl to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SM Hasan.* Board Should Admit Petitioner Contention 1 for Listed Reasons.W/Certificate of Svc ML20099J8751992-08-14014 August 1992 TU Electric Answer to Petition for Intervention & Request for Hearings by Dows.* Petition to Intervene Should Not Be Accepted for Filing Because Petition Contains Untrue & Scandalous Allegations.Certificate of Svc & Other Info Encl ML20099H1071992-08-0606 August 1992 TU Electric Answer to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SMA Hasan.* Petition Should Be Denied Re Macktal & Hasan Since Neither Showed Standing to Intervene.W/Notices & Certificate of Svc ML20114A9331992-07-28028 July 1992 Petition of SL Dow Dba Disposable Workers of Comanche Peak Ses & RM Dow for Intervention & Request for Hearings.* Licensee Seeks to Extend Expiration Date of CP for Period of Addl 3 Yrs.W/Certificate of Svc ML20099H0921992-07-27027 July 1992 Petition to Intervene & Request for Hearing of Bi Orr, Di Orr,Jj Macktal & SMA Hasan.* Requests That Hearing Be Convened to Determine Whether Good Cause Exists for Extension of CP Completion Date.Certificate of Svc Encl ML19325D6381989-10-20020 October 1989 Request to Continue Proceedings & Petition to Intervene by Citizens for Fair Util Regulation & Greater Fort Worth Group of Lone Star Chapter of Sierra Club.* Petitioners Have Requisite Interest to Establish Standing ML20154G7591988-09-12012 September 1988 Citizen for Fair Util Regulation (Cfur) First Suppl to 880811 Request for Hearing & Petition for Leave to Intervene.* Cfur 880811 Request for Hearing & Petition for Leave to Intervene Should Be Granted.W/Certificate of Svc ML20153D1361988-08-26026 August 1988 Applicant Answer to Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* Request Should Be Denied Based on Inability to Develop Allegations. Certificate of Svc Encl ML20207E5261988-08-11011 August 1988 Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* ML20150E2131988-07-13013 July 1988 Citizens Audit Motion for Stay & Motion for Sua Sponte Relief.* Requests Time to Review Concerns of J Doe & for Relief for Listed Items in Order to Act as Intervenor in Proceeding.W/Certificate of Svc ML20150E2071988-07-11011 July 1988 Second Group of Individual Residents Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released.W/Certificate of Svc ML20150E3301988-07-11011 July 1988 Greater Fort Worth Sierra Club Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That Relief for Listed Items Be Granted Sua Sponte to Address Complex safety-related Issues.W/Certificate of Svc ML20150D5141988-07-0808 July 1988 Citizens for Fair Util Regulation Motion to Intervene & for Sua Sponte Relief.* Petitioner Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released & That 880713 Hearing Be Continued for 60 Days ML20150D5371988-07-0808 July 1988 Individual Residents Motion to Intervene & for Sua Sponte Relief.* Listed Petitioners Request Relief That All Settlement Agreements Re Joint Stipulation Be Publicly Released & 880713 Hearing Be Extended.W/Certificate of Svc ML20211H3921986-10-31031 October 1986 Consolidated Intervenors Motion to Dismiss Pending Appeal as Moot &/Or for Lack of Jurisdiction & to Immediately Dissolve Order Staying Discovery.Certificate of Svc Encl ML20210N2811986-09-30030 September 1986 Consolidated Intervenors Amended Contentions 1 & 2 Re Reinsp Efforts & Const Delay.Certificate of Svc Encl ML20203G4731986-04-18018 April 1986 Answer Opposing M Gregory & Case 860407 Petition for Leave to Intervene Re NRC 860210 Order Extending Completion Date for CPPR-126 to 880801.Contentions Fail to Satisfy 10CFR2.714(b) Criteria.W/Certificate of Svc ML20203D5681986-04-17017 April 1986 Permittees Answer to Petitions to Intervene of Case & M Gregory.Certificate of Svc Encl ML20202G4751986-04-0707 April 1986 Petition of Case for Leave to Intervene & Request for Hearing.Certificate of Svc & Jl Howard Affidavit Encl ML20199K7401986-04-0707 April 1986 Petition of M Gregory for Leave to Intervene Re Improper Const & Invalid Util Justification for Delay.Affidavit of M Gregory & Certificate of Svc Encl.Served on 860409 ML20151U6791986-02-0505 February 1986 Response to Ha Stiner Request to Intervene late.Late-filed Petition Should Be Denied.W/Certificate of Svc ML20137Q0151985-12-0202 December 1985 Answer Supporting Applicant 851105 Petition for Directed Certification of ASLB 851031 Order for Review.Order Adversely Affects Basic Structure of OL Proceeding. Certificate of Svc Encl ML20081G7771983-11-0303 November 1983 Answer Opposing Citizens Assoc for Sound Energy (Case) 831024 Motions to Add New Contention & for Discovery Re Hot Functional Test Results.Case Should Have Begun to Pursue Subj Matter by 830513 ML20080S3261983-10-13013 October 1983 Motion to Add Proposed Contention 26 Re Hot Functional Test, Motion for Discovery & Offer of Proof.Certificate of Svc Encl ML20024A5251983-06-12012 June 1983 Answer Opposing State of Tx 830609 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Proposed Contention Lacks Requisite Specificity & Bases for late-filed Contentions.Certificate of Svc Encl ML20024A0311983-06-0909 June 1983 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Somervell County & Hood County Commitment,Expertise & Resources Inadequate to Adopt & Implement Emergency Plans.Certificate of Svc Encl ML20063H0351982-08-26026 August 1982 Motion to Add New Contention 26 Re Apparent Applicant Violation of 10CFR50,App A,Criterion 1,requiring Possession of Design Criteria for Pipe Support Sys & Components at Site.Certificate of Svc Encl ML19340D3001980-11-25025 November 1980 Supplemental Response,Submitted to Ferc,On DOJ 800917 Petition to Intervene.Doj Position Is Irrelevant to Approval of Supplemental Offer of Settlement & Should Be Denied W/O Prejudice.Supporting Info & Certificate of Svc Encl ML19338E9471980-09-17017 September 1980 Petition for Leave to Intervene ML19338C4101980-08-13013 August 1980 Response in Support of Tx Border Cooperatives Petition to Intervene.Nexus Requirement for Util Operations Affected by Dc Interconnection Satisfied.Untimeliness Is Measured by Necessity to Preserve Rights.Certificate of Svc Encl ML19331C5331980-08-13013 August 1980 Answer in Support of Tx Border Cooperatives 800731 Petition to Intervene.Good Cause Shown for Late Filing.No Other Means Exist to Protect Interests.Intervention Would Assist in Development of Sound Record.Certificate of Svc Encl ML19330C5831980-08-0707 August 1980 Response in Opposition to Tx Border Cooperative Petition to Intervene.Good Cause Not Shown.Cooperative Interests Can Be Protected in Pending FERC Hearing.Petitioners Failed to Show Participation Would Assist in Development of Record ML19330B5911980-07-31031 July 1980 Petition for Untimely Intervention.Petitioners Had Reason to Believe That Interests Would Be Adequately Protected by Other Utils,But Significant Developments Created Concerns Re Dc Interconnections.Certificate of Svc Encl ML19331D9051980-07-31031 July 1980 Response to Applicants,Central & South West Corp & City of Austin,Tx Objections to Tx Border Cooperative Petition to Intervene.Asserts Interests Under LBP-74-13.Urges Full Party Participation.W/Certificate of Svc ML19323B5551980-04-10010 April 1980 Statement of Position in Opposition to Tx Association of Community Organizations for Reform Now Proposed Contentions. Intervenor Failed to Submit Allegations Warranting Admission in Proceeding.Certificate of Svc Encl ML19309H6591980-04-10010 April 1980 Statement of Position in Opposition to Citizens Association for Sound Energy Proposed Contentions.Intervenor Failed to Submit Allegations Warranting Admission in Proceeding. Proposed Contentions & Certificate of Svc Encl ML19344D5751980-03-25025 March 1980 Response in Opposition to Public Utils Board of City of Brownsville,Tx 800317 Comments Requesting Admittance as Party in Consolidated Proceeding.Statement of Interest Untimely & Vague.Certificate of Svc Encl 1992-08-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
[Table view] |
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s ; // 9, UNITED STATES OF AMERICA Ol pc'~ ,o NUCLEAR REGULATORY COMMISSION 2 9 g Y,#q7Y$
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BEFORE THE ATOMIC SAFETY AND LICENSING BOAR -o- ^
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In the Matter of )
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s TEXAS UTILITIES ELECTRIC ) Docket No. 50-445-CPA COMPANY, et --
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(Comanche . Peak Steam Electric )
Station, Unit 1)
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NRC STAFF'S ANSWL3 TO PETITIONS FOR LEAVE TO INTERVENE FILED B y CASE AND MEDDIE GREGORY I. INTIdgDUCTION On April 7,1986, petitions for inve to intervene were filed by Citi-zens Association for Sound Energy (OASE) and Meddie Gregory in con-nection with the NRC Staff's Februar}( 10, 1986 Order extending the completion date for Construction Permit by. CPPR-126 for Comanche Peak Unit 1. See, 51 F. R . 5622, February 1., 1986. CASE's petition was filed pursuant to the direction of the Atomik Safety and Licensing Board.
Petitioner Gregory's petition, on the other Mand, is presumably filed in response to the Order itself. q For the reasons discussed below , the NRC Staff opposes the petitions.
II. BACKGROUND After evaluation of the Applicants' request of January 20,1986, the NRC staff, on-February 10, 1986, issued an Order extending Construction Permit No. CPPR-126 for, Comanche Peak Unit I until August 1, 1988.
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8604290111 860418 .
gDR ADOCK 05000445' PDR DESw alTED CRI0ixs c*l,titied 3 , yye y
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Following submissions by CASE, on January 31 and February 11, 1986, of requests for, among other things , a hearing, the Commission, on March 13,1986,, issued a Memorandum and Order, CLI-96-04, which, inter alia, referred CASE's hearing request to the Chairman of the Atomic s Safety and Licensing Board k)anel for appointment of an Atomic Safety and Licensing Board to consider the request and conduct any necessary hear-ing. On March 20, 1986, a Licensing Board was appointed. 51 F.R.
10480.
On March 21, 1986, the Licensing Board, by telephone calls to each of the participants individually, directed that CASE file a petition for leave to intervene and contentions in regard to the extension granted by the Staff's Order. To the best of the Staff's knowledge, the petition later submitted by Petitioner Gregory was not discussed during the call.
III. DISCUSSION A. The Standards for Intervention
- 1. Petitioners Must Meet the " Interest" Requirements of 10 C.F.R.I 2.714 Section 189a of the Atomic Energy Act of 1954, as amended, 42 U.S.C. I 2239(a), provides that:
In any proceeding under (tho] Act , for the granting, sus-pending, revoking, or amending of any license ... the
, Commission shall grant a hearing upon the request of any person whose interest may be affected by the proceeding, and shall admit any such person as a party to such proceeding.
Section 2.714(a)(2) of the Commission's Rules of Practice, 10 C.F.R.
I 2.714(a)(2), requires that a petition to intervene in a Commission pro-4 ceeding set forth with particularity:
(1) the interest of the petitioner in the proceeding;
l (2) how that interest may be affected by the results of the proceeding; and (3) the specific aspect or aspects of the subject matter of the proceeding as to which petitioner wishes to intervene.
In order for intervention to be granted, the Atomic Safety and Licensing s Board designated to rule oht petitions to intervene and/or requests for hearing must 13nd that the petition satisfies these standards.1_/
In determ!ning whether the requisite interest prescribed by both Section 189a of the Atomic Energy Act and Section 2.714 of the Commis-sion's Rules of Practice is present, the Commission has held that contem-poraneous judicial concepts of standing are controlling. Portland General Electric Co. (Pebble Springs Nuclear Plant, Units 1 and 2), CLI-76-27, 4 NRC 610, 613-14 (1976). Thus, there must be a showing (1) that the action being challenged could cause " injury-in-fact" to the person seeking to intervene - and (2) that such injury is arguably within the " zone of
-1/ Intervention may also be granted as a matter of discretion to a peti-tioner who is not entitled to intervention as a matter of right if the petitioner can show that the Commission's specific criteria weigh in favor of discretionary intervention. See Portland General Electric
' Company, et al. (Pebble Springs Nuclear Plant, Units 1 and 2),
CLI-76-27, DRC 610, 616 (1976). Since , the instant petitioners have not addressed these criteria, which is their burden (Nuclear i
Engineering Company (Sheffield, Illinois, Low-Level Radiation Waste Disposal Site) , ALAB-473, 7 NRC 737, 745 (1978)), discretionary intervention will not be discussed further.
-2/ " Abstract concerns" or a " mere academic interest" in the matter which are not accompanied by some real impact on a petitioner will i not confer standing. See In the Matter of Ten Applications for l Low-Enriched Uranium ~Eiports to EURATOM Member Nations ,
l CLI-77-24, 6 NRC 525, 531 (1977); Pebble Springs, CLI-76-27, su-p_ra, 4 NRC at 613. Rather the asserted harm must have some pH-ticular effect on a petitioner, Ten Applications, CLI-77-24, supra, l
(FOOTNOTE CONTINUED ON NEXT PAGE) l
interests" protected by the Atomic Energy Act 3,/ of the National Environmental Policy Act. S Id. See also Warth v. Seldin, 422 U.S. 490 (1975); Sierra Club v. Morton, 405 U.S. 727 (1972); Association of Data Processing Service Organizations, Inc. v. Camp, 397 U.S. 150, 153 s (1970). Close proximity of a petitioner's residence, standing alone, is sufficient to satisfy the interest requirements. Virginia Electric and Power Company (North Anna Nuclear Power Station, Units 1 and 2),
ALAB-522, 9 NRC 54, 56 (1979).
An organization may gain standing to intervene based on injury to itself. Edlow International Company, CLI-76-6, 3 NRC 563, 572-74 (1976). If the organization seeks standing on its own behalf, it must establish that it will be injured and that the injury is not a generalized grievance shared in substantially equal measure by all or a large class of citizens. Ten Applications, CLI-77-24, supra, at 531. On the other hand, an organization may establish standing through members of the organization who have an interest which may be affected by the outcome of the proceeding. Public Service Co. of Indiana Inc. (Marble Hill Nu-clear Generating Station, Units 1 and 2), ALAB-322, 3 NRC 328, 330 (1976). When an organization claims that its standing is based on the (FOOTNOTE CONTINUED FROM PREVIOUS PAGE) and a petitioner must have some direct stake in the outcome of the proceeding. See Allied-Generel Nuclear Services, et al. (Barnwell Fuel Receiving and Storage Station) , ALAB-328, 37C 420, 422 (1976). .
3_/ 4% U.S.C. I 2011 g seq.
4/ 42 U.S.C. I 4321 et seq.
t
s interests of its members, the organization must identify one or more indi-vidual members (by name and address) whose interests may be affected and give some concrete indication that such members have authorized the organization to represent their interests in the proceeding. Jiouston ,
s- Lighting and Power Company (Allens Creek Nuclear Generating Station, Unit 1), ALAB-535, 9 NRC 377, 393-97 (1979); Public Service Electric and Gas Company (Salem Nuclear Generating Station , Units 1 and 2),
ALAB-136, 6 AEC 487, 488-89 (1973); Duquesne Light Company, et al.
(Beaver Valley Power Station, Unit No.1), ALAB-109, 6 AEC 243, 244 at n.2 (1973). Specific representational authorization of a member with personal standing is not required where the sole or primary purpose of e i the petitioning organization is to oppose nuclear power in general or the particular facility at bar. Allens Creek, ALAB-535, supra, at 396. -
- 2. Petitioners Nst Meet the " Aspect" Requirenents of 10 C.F.R. I 2.714
-5/ Further, under Section 2.713 of the Commission's Rules of Practice, a " partnership , corporation or unincorporated association . may be represented by a duly authorized member or officer, or by an attor-ney-st-law . " 10 C.F.R. I 2.713(b) (emphasis added). Thus, where an organization is represented by one of its members, the member must demonstrate authorization by that organization to represent it.
It is clear that groups may not represent persons other than their own members, and individuals may not assert the interest of other persons. Long Island Lighting Co. (Shoreham Nuclear Power Sta-tion , Unit 1), LBP-77-11, 5 NRC 481, 483 (1977); Watts Bar, ALAB-413, s lu ra at 1421; Detroit Edison Company (Enrico Fermi
. Atomic Power Plant, Unit No. 2), ALAB-470, 7 NRC 473, 474 n.1 (1978). There is, under the Atomic Energy Act and the Commis-sion's regulations, no provision for private attorneys general. Port-4 land Geri~e ral Electric Company (Pebble Springs Nuclear Plant, Units 1 and 2), ALAB-333, 3 NRC 804, 806 n.6 (1976); Long Island Lighting Company, LBP-77-11, supra, at 483, 1
In addition to demonstrating " interest", a petitioner must set forth "the specific aspect or aspects of the subject matter of the proceeding as to which petitioner wishes to intervene." 10 C.F.R. I 2.714(a)(2). 6_/
While there is little guidance in NRC case law as to the meaning of "as-
, s. pect" as the term is used in 10 C.F.R. I 2.714, it appears that a peti-tioner may satisfy this requirement by identifying general potential effects 4
of the ;icensing action or areas of concern which are within the scope of matters that may be considered in the proceeding. I- See North Anna, ALAB-146, supra, at 633; Metropolitan Edison Co.. (Three Mile Island Nu-clear Station, Unit 1), Licensing Board " Memorandum and Order Ruling on Petitions and Setting Special Prehearing Conference", dated September 21, 1979, slip. op. at 6 (unpublished Order).
The Petidons B.
With respect to CASE's petition, the Staff does not contest its stand-ing to intervene in this proceeding. Furthermore, the Staff believes that
} -6/
10 C.F.R. I 2.714 also requires the petitioner to file " . . . a sup-plement to his petition to intervene which must include a list of the 4
contentions which petitioner seeks to have litigated in the matter, and the bases for each contention set forth with reasonable specific-ity . " This section further provides: "A petitioner who fails to file such a supplement which satisfies the requirements of this paragraph with respect to at least one contention will not be permitted to par-4 ticipate as a party." The NRC staff will respond to the contentions set forth in the petitions in Section C below.
7_/
The subject matter of the proceeding, for purposes of identification of " aspects" relates to the question of public health and safety of the proposed action (issuance of the amendments) and not the proce-dural determination made by the Commission staff concerning whether or not the proposed action involves a "significant hazards consider-ation . " See 48 Fed. Reg. 14864,14805 ( April 6,1983).
i
.- , . . . _ , _ _ _ _ - . _ . . _ , _ _ . _ _ , _ _, . . . . , _ . _ _ , , _ . . . . _ _ , _ _ , _ _ , , _ . , , _ , , . , , . . , _ __,m.,_____ _
i CASE, by its contentions, 8_/ has adequately set forth the " aspects" of the procce, ding on which it wishes to participate, i.e. , whether " good cause" has begn shown, although the Staff does' not agree that the contentions are properly within the scope of a construction permit s extension proceeding, as defined by the Commission's decision in Washingtor - Public Power Supply System (WPPSS Nuclear Projects Nos. 1 and 2), CLI-82-29,16 NRC 1221 (1982); see Comanche Peak, CLI-86-04, slip op , at 11,14. CASE's contentions are discussed in Section C below.
Subject to the same reservations noted above with respect to aspects and contentions, the Staff does not contest the standing of Meddie Greg-ory to participate in the construction permit amendment proceeding.
Ms. Gregory's contentions are also discussed in Section C below.
C. Contentions The scope of contentions properly considered in the context of a construction permit extension proceeding is narrow. Contentions must be limited to issues regarding whether the applicant has shown " good cause" for the delay in completion of the facility. WPPSS, CLI-82-29, supra; Public Service Co. of New Hampshire (Seabrook Station , Unit 2),
CLI-84-6,19 NRC 975 (1974). A contention must seek to " challenge the reasons for the delay [or) ... to show that other reasons, not constituting good cause, are the principal reasons for the delay."
8/
Consistent with the date set for the prehearing conference, both CASE and Ms. Gregory have, as part of their respective petitions, submitted contentions. See,10 C.F.R. I 2.714(b).
i
. WPPSS, CLI-82-20, supra,10 NRC at 1230. As explained by the Appeal Board: .
We refined the Commission's guidance into a two-pronged test for determining whether a contention is within the scope of a permit extension proceeding. "First, the construction delays at issue have to be traceable to the applicant. Second, the A delays must be ' dilatory'." We defined ' dilatory' for such -
purposes as the " intentional delay of construction without a valid purpose." The Commission endorsed our promulgation of this test in its Seabrook opinion. In doing so, it noted that delay for financial reasons constitutes a valid business purpose. Applying the test, the Commission ruled out
" questions about the need for power cost of completion and financial consequences to both the utility and to the ratepayers."
Washington Public Power Supply System (WPPSS Nuclear Project No . 1) ,
ALAB-771, 19 NRC 1183, 1189-1190 (1984; footnotes omitted); see also.
Washington Public Power Suppiv System (WPPSS Nuclear Project No. 2, ALAB-722,17 NRC 546, 551-553 (1983).
With respect to issues going beyond " good cause", the Commission has determined that "the avenue afforded for the expression of health, safety, and environmental concerns in any pending operating license pro-ceeding, or, in the absence of such a proceeding, in a petition under 10 C.F.R. I 2.206, would be exclusive despite the pendancy of a con-struction permit extension request." WPPSS, CL1-82-29, supra, 16 NRC at 1229, (footnote omitted) . It has been emphasized that " permit extension proceedings are not intended to permit " periodic relitigation of health , safety , or environmental questions ... between the time a construction permit is issued and the time the facility is authorized to operate." WPPSS , ALAB-771, s'1pra, 19 NRC at 1189 (footnote omitted).
Viewed in light of the forego:ng, we address CASE's contentions.
The first five contentions raised (Petition at 2-4) are conceded by CASE
, itself, to go beyond the scope of issues properly admitted in a con-
- struction permit proceeding, Petition at 2. Thus, no further discussion is required here.
Contention 6 (Petition at 4-5), which alleges that the Applicants
% were dilatory and, for that reason, failed to complete Unit 1 within the time provided by the construction permit, superficially might appear to raise issues which are admissible in a construction permit extension proceeding. But the Commission has concluded that the admission of contentions of the type asserted by CASE here:
would be contrary to the overall intent of the Atomic Energy Act and the Commission's regulations. If the permit holder were to construct portions of a facility in violation of NRC regulations, when those violations are detected and corrections ordered or voluntarily undertaken, there is likely to be some delay in the construction caused by the revisions. Nonethekss, such delay, as with delay caused by design changes, must give " good cause" for an extension.
To consider it otherwise would discourage permit holders from ' disclosing and correcting improper construction for fear that corrections would cause delays that would result in a refusal to extend a construction permit, a result obviously inconsistent with the Commission's efforts to ensure the protection of the public health and safety. This contention thus is not litigible.
WPPSS, CLI-82-29, supra,16 NRC at 1230-1231. CASE presents no basis for distinguishing its proposed Contention 6 from the foregoing holding, and, consequently, it should be refacted.
Contention 7 (Petition at 5-8) seeks to raise issues going to the Applicants' ability to properly complete the facility in conformance with the Commission's regulations, in particular, challenging the sufficiency of the ongoing CPRT efforts. This issue relates principally to matters more appropriately considered in the context of the operating license
, a proceeding rather than to the Applicants' " good cause" showing in support of its construction permit extension request. Accordingly, Contention 7 shpuld be rejected. -
Contention 8 similarly should be rejected. That additional time be-
- s. yond the extension recently granted may be required to complete the fa-cility is not properly at issue in this proceeding; CASE makes no claim that the extension requested and granted will in any way frustrate the NR C's " regulatory oversight ." WPPSS, AB AB-771, supra, 19 NRC at 1191-1192. At most , this contention speculates, without basis, on the outcome of the ongoing activities of the Applicants and CPRT, issues which may be addressed in the operating license proceeding but not in a construction permit extension proceeding.
Contention 9 (Petition at 9-10) seeks to raise environmental issues.
This contention should be rejected for lack of basis and specificity as well as on grounds that it exceeds the scope of matters coming within the am-bit of a construction permit extension proceeding. The issues raised by CASE do not encompass environmental concerns associated with the exten-sion of the construction permit but, rather, speculate on impacts which might result from the ultimate failure to obtain an operating license for the unit, or which go to the censideration of alternatives assessed at the initial construction permit stage and which, therefore, are more appropri-ately raised by a petition filed pursuant to 10 C.F.R. I 2.206. See, WPPSS, ALAB-771, supra, at 1189-1191.
The contentions put forward by Ms. Gregory are virtually identical 4
to CASE's contentions 6, 7, 8 and 9. Accordingly, the Staff's response
to CASE's contentions , above, sufficiently addresses Ms. Gregory's contentions, as well, and will not be reiterated at this point.
In sum, both CASE's and Ms. Gregory's petitions fail to set forth at least one contention within the scope of this proceeding which satisfies the requirements of 10 C.F.R. I 2.714(b).
IV. CONCLUSION For the foregoing reasons, the Staff opposes the petitions for leave to intervene filed by CASE and Meddie Gregory and urges that they be denied.
Respectful 1y subnitted,
/
hLawrence wa+J. 01andler -
Special Litigation Counsel Dated at Bethesda, W ryland this 18th day of April,1986 i
h h
o UNITED STATES.OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of- )
)
TEXAS UTILITIES ELECTRTC' ) Docket No. 5G-445-CPA COMPANY, e_t t al. )
)
(Comanche Peak Steam Electric )
Station, Unit 1 ) )
. CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF ANSWER TO PETITIONS FOR LEAVE TO INTERVENE FILED BY CASE AND MEDDIE GREGORY" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, or as indicated by two asterisks (**) by express mail or hand delivery, this 18th day of April,1986:
Peter B. Bloch, Esq. , Chairman
Administrative fudge President, CASF Atomic Safety arid Licensing Board 1426 South Polk Street U.S. Nuclear Regulatory Commission Dallas, TX 75224 Washington, DC 20555 ,
Dr. Kenneth A. McCollom v& Nicholas S. Reynolds, Esq.**
Administrative Judge William A. Horin, Esq.
1107 West Knapp Bishop, Liberman, Cook, Stillwater, OK 74075 Purcell & Reynolds 1200 17th Street, N.W.
Washington, DC 20036 Elizabeth B. Johnson 14 Administrative Judge r Mr. W. G. Counsil Oak Ridge National Laboratory Executive Vice President P.O. Box X, Building 3500 Texas. Utilities Generating Company Oak Ridge, TN 37830 400 North Olive Stree,t, L.B. 81 Dallas, TX '7520F' ' #-
^
Dr. Walter H. Jordan v& Robert A. Wooldrid'ge, Eso.
, Administrative Judge Worsham, Forsythe, Samples
! 881 W. Outer Drive a Wooldridge Oak Ridge, TN 37830 2001 Bryan Tower, Suite 2500 Dallas, TX 75201 l
l
__ m , _ _ _ _ _ , . _ . _ . - _ _ _ . - . _ - - . .
Ellen Ginsberg, Esq.* Wil!iam L. Brown, Esq.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Washington, DC 20555 Arlington, TX 76011 Mr. James E. Cummins Resident inspec' tor / Comanche Peak Steam Electric Station clo U.S. Nuclear Regulatory. Commission Atomic Safety and Licensing Board s P.O. Box 38 Panel
- Glen Rose, TX 76043 U.S. Nuclear Regulatory Commission Washington, DC 20555 William H. Burchette, Esq.
Merk D. Nozette, Esq. Atomic Safety and Licensing Appeal Heron, Burchette, Ruckert Board Panel
- a Rothwell U.S. Nuclear Regulatory Commission Suite 700 Washington, DC 20555 1025 Thomas Jefferson Street, N.W.
Washington, DC 20007 Docketing and Service Section*
Office of the Secretary Robert D. Martin U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Roy P. Lessy, Jr . , Esq.
Morgan, Lewis & Bockius Robert A. Jablon, Esq. 1800 M Street, N.W.
Spiegel & McDiarmid Suite 700, North Tower 1350 New York Avenue, N.W. Washington, DC 20036 Washington, DC 20005-4798 Thomas G. Dignan, Esq.**
Anthony Z. Roisman, Esq.** Ropes & Gray Trial Lawyers for Public Justice 225 Franklin Street 2000 P Street, N.W. , Suite 611 Boston, MA 02110 hasidngton, DC 20036 e
S. zuno Co sel NRC Staff t