ML19270F265
| ML19270F265 | |
| Person / Time | |
|---|---|
| Site: | 05000477, 05000478 |
| Issue date: | 12/29/1978 |
| From: | Valore C ATLANTIC COUNTY, NJ |
| To: | |
| References | |
| NUDOCS 7902060080 | |
| Download: ML19270F265 (5) | |
Text
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- fr ni . in . ;< t avvM Ng pnry, STATES OF AMERICA UNITED NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF )
Docket Nos. STN 50-477 PUBLIC SERVICE ELECTRIC ) & STN 50-478 AND GAS COMPANY
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(Atlantic Generating Station Units #1 and 62) )
S 4p NOTICE OF MOTION TO IMPOSE TERMS oT AND CONDITIONS PUBSUANT
- ib33 I TO 10 CFR, SECTION 2.107 I -12
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TO: Sheldon J. Wolfe , Chairman p Atomic Safety & Licensing Board A @
U.-S. Nuclear Regulatory Commission Washington ,D.C., 20555 SIR:
PLEASE TAKE NOTICE, that the Intervenor, Atlantic County, moves the Board to impose terms and conditions upon the Applicant's withdrawal of application to wit:
- 1. Applicant should pay to the Intervencr, County of Atlantic, the cos. of intervention incurred by the County of Atlantic. An itemized bill of said costs to be submitted upon an Order being entered directing the Applicant to pay said costs.
- 2. Applicant should post a bond or cash in lieu of bond in an amount of $250,000 to cover legal costs and expert costs that will be incurred by Intervenors in the event a substantially similar application is filed in the future. Said bond or cash deposit should be for a term of ten (10) ye ars .
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- 3. The Order of Dismissal should be with prejudice.
- 4. That an order be entered precluding the Applicant from filing a substantially similar application for the next ten (10) yeais or such other reasonable period of time.
- 5. That an order be entered precluding the Anglicant from filing an application to site a floating nuclear power plant or plants in the coastal or bay waters of New Jersey for the next 10 years or such other reasonable period of time.
- 6. For such other relief as may be just and appropriate.
A brief in support of this Motion will be filed by the Intervenor Atlantic County before January 15, 1979.
Re $ectful D b itted,
,n (D ,
AL , JR., Special clear Ccunsel for the Intervenor A ic County December 29, 1978
UNITED STATES OF AMERICA NUCLEAR REGULATORY CO?D1ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
PUBLIC SERVICE ELECTRIC ) Docket Nos. STN 50-477 AND GAS COMPANY & STN 50-478 (Atlantic Generating Station, )
Units #1 and #2)
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s'$ EAQ ,x AFFIDAVIT IN SUPPORT OF MorION ef g TO IMPOSE TERMS AND CONDITIONS PURSUANT TO 10 CFR, SECTION 2.107 g
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STATE OF NEW JERSEY b .
COUNTY OF ATLANTIC: A RICHARD E. SQUIRES, of full age, duly sworn according to law upon his oath deposes and says:
- 1. I am the Chairman of the Atlantic County Board of Chosen Freeholders, an intervenor in these proceedings.
- 2. Atlantic County has spent both real costs and time costs for legal counsel, experts, county staff and county officials - an itemization of these costs can be provided upon request. f
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RICHARD E. SQUIRES, Chqirman 3 Atlantic County Board Mf Chosen Freeholders Sworn to and subscribed to before me this 29th day of December, 1978.
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UNITED STATES OF AMERICA (h. 'y~.
g NUCLEAR REGULATORY COMMISSION 2 $\ hay @1
}. S6b In the Matter of )
1CUI (f A 9 l PUBLIC SERVICE ELECTRIC ) Docket Nos. STN 50- l 9
& GAS COMPANY and STN 50-478 (Atlantic Generating Station )
Units #1 and #2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of Atlantic County's Motion to impose terms and condtions pursuant to 10 CFR, Section 2.107 dated December 29, 1978, in the captioned matter, have been served upon the following by deposit in the United States mail this 29th day of December, 1978:
Sheldon J. Wolfe, Esq. Trof B. Conner, Esq.
Chairman, Atomic Safety Conner, Moore & Corber
& Licensing Board 1747 Pennsylvania Ave. N.W.
U.S. Nuclear Regulatory Commission Washington, D.C., 20006 washington, D.C,, 20555 Franklin H. Berry, Jr., Esq.
Mr. Lester Kornblith, Jr. County of Ocean Atomic Safety & Licensing Board P.O. Box 757 Panel 34 Washington Street U.S. Nuclear Regulatory Commission Toms River, N.J., 08753 Washington, D.C., 20555 Chairman, Atomic Safety &
Dr. David R. Schink Licensing Board Panel Department of Oceano9raphy U.S. Nuclear Regulatory Commission Texas A&M University Washington, D.C., 20555 College Station, Texas, 77840 Chairman, Atomic Safety &
John J. Degnan, Esq. Licensing Board Appeal Panel Attorney General of New Jersey U.S. Nuclear Regulatory Commission Department of Law and Washington, D.C., 20555 Public Safety Division of Law Stephen M. Schinki, Esq.
1100 Raymond Boulevard Counsel for NRC Regulatory Staff Newark, N.J., 07102 office of the Executive Legal Directc U.S. Nuclear Regulatory Commission Mr. Chase R. Stephens Washington, D.C., 20555 Docketing & Service Section Office of the Secretary MarkiL. First, Esq.
U.S. Nuclear Regulatory Deputy Attorney General Commission State of New Jersey Washington, D.C., 20555 State House Annex Trenton, N.J., 08625 Anthony Roisman, Esq.
Natural Resources Defense Council Harold P. Green, Esq.
917 15th Street, N.W. Suite 1000, The Watergate 600 Washington, D.C., 20005 600 New Hampshire Avenue, N.W.
Washington, D.C., 20037
Page 2 4
Dr. Glenn L. Paulson Assistant Commission, State of New Jersey Department of Environmental Protection Labor & Industry Building John Fitch Plaza Trenton, N.J., 08625 Richard Fryling, Jr., Esq.
Assistant General Solictor Public Service Electric & Gas Co.
80 Park Place Newark, N.J., 07101 R. William Potter, Esq.
Assistant Deputy Public Advocate Department of Public Advocate Division of Public Interest P.O. Box 141 520 East State Street Trenton, N.J., 08625 Richard S. Salzman, Esq.
Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C., 20555 Dr. Joh.' H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C., 20555 Michael C. Farrar, Esq.
Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C., 205555