ML19254C845

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

ML19254C845
Person / Time
Site:	05000574
Issue date:	10/03/1979
From:	Asher T, Bogin M MOVEMENT FOR A FREE PHILIPPINES
To:
Shared Package
ML19254C846	List: ML19254C845 ML19254C850 ML19254C851 ML19254C852
References
NUDOCS 7910180010
Download: ML19254C845 (4)

Text

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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.

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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 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.

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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.

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

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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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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

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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 (

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OCI .31373 C #'3 Thomas M. Daugherty, Esq. ,{d g ,,, fjg

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Westinghouse Nuclear Energy Systems CCLc. ,,1,w*

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"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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