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Category:INTERVENTION PETITIONS
MONTHYEARML20059L9391993-11-12012 November 1993 Petitioners Supplemental Petition for Leave to Intervene.* Court Held That NRC May Not Eliminate Public Participation on Matl Issue in Interest of Making Process More Efficient. W/Certificate of Svc ML20101M7061992-06-30030 June 1992 Applicant Answer in Opposition to Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Untimely Intervention Petition Should Be Denied.W/Certificate of Svc ML20101E1261992-06-15015 June 1992 Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Should Be Granted Discretionary Intervention & Amended Petition for Leave to Intervene Granted for Listed Reasons.W/Certificate of Svc ML20086G6401991-11-22022 November 1991 Petitioners Amended Petition for Leave to Intervene.* Amended Petition of Ohio Citizens for Responsible Energy,Inc for Leave to Intervene to Respond to Arguments Made in Licensee & NRC Intervention Petition.W/Certificate of Svc ML20083B7981991-09-16016 September 1991 Answer of Util to City of Brook Park,Oh Suppl to Petition for Leave to Intervene.* Concluded That City Petition Failed to Satisfy Any of Three Criteria for Intervention,Therefore Leave to Intervene Should Be Denied.W/Certificate of Svc ML20083B7901991-09-16016 September 1991 Answer of Util to Petition of City of Brook Park,Oh for Leave to Intervene & Suppl Thereto.* Petition Should Be Denied Based on Listed Reasons.W/Certificate of Svc ML20083B3581991-09-0404 September 1991 City of Brook Park Suppl to Petition for Leave to Intervene.* in Consideration of Foregoing,Petition of City of Brook Park,Oh for Leave to Intervene Should Be Granted. W/Certificate of Svc & Svc List ML20082P1611991-08-23023 August 1991 Petition for Leave to Intervene & Request for Hearing.* Petitioners Have Demonstrated Right to Be Made Parties to Proceeding and Instant Petition for Leave to Intervene Should Be Granted & Proposed Contention Admitted ML20082G8921991-07-31031 July 1991 Petition of City of Brook Park,Oh for Leave to Intervene.* City Requests That NRC & ASLB Deny Applicant Request for Hearing.W/Svc List & Certificate of Svc ML20082D4411991-07-10010 July 1991 Supple by American Municipal Power-Ohio,Inc to Petition for Leave to Intervene.* Facility Requests Addl Time to Mod Suppl.W/Certificate of Svc ML20082B5111991-07-10010 July 1991 10CFR2.714(b)(1) Suppl to Conditional Petition to Intervene of City of Cleveland,Oh Submitted in Connection w/910725 Prehearing Conference.W/Certificate of Svc & Svc List ML20082B2511991-07-0303 July 1991 Petition of Util for Leave to Intervene.* If License Conditions Can Disappear & Reappear W/Shifting Economics of Electric generation,AMP-Ohio Future Will Be Seriously Jeopardized.W/Certificate of Svc ML20077G2661991-05-30030 May 1991 Petition of Alabama Electric Cooperative,Inc for Leave to Intervene.* Util Requests Intervention in Further Proceedings on Applications of Ohio Edison & Other Applicants.W/Certificate of Svc ML20043D6751990-06-0101 June 1990 Ocre Response to Licensee & NRC Staff Answers to Ocre Contention.* Ocre Contention Should Be Granted Since NRC Has No Valid Argument to Preclude Admission of Contention & 10CFR2.714(b)(2) Requirements Met.W/Certificate of Svc ML20012E6901990-03-23023 March 1990 Licensee Answer to Ocre Petition for Leave to Intervene & Request for Hearing.* Concludes That Ocre Lacks Requisite Interest in License Amend Proceeding & Requests That ASLB Rule on Ocre Petition.W/Certificate of Svc & Svc List ML20012E6771990-03-0808 March 1990 Petition for Leave to Intervene & Request for Hearing.* Ocre Requests Hearing on Util 891219 Amend Request & Submits Petition W/Intention of Becoming Full Party.Petition Should Be Granted Since Ocre Demonstrated Right to Be Made Party ML20148D0511988-01-0707 January 1988 Petition for Leave to Intervene & Request for Formal Adjudicatory Hearing.* Ocre Demonstrated Right to Be Made Party in Proceeding & Petition Should Be Granted ML20214W6371987-06-0505 June 1987 Petition of Toledo Coalition for Safe Energy,Sunflower Alliance,Inc,S Sass & SB Carter for Revocation,Mod or Suspention of OL Per 10CFR2.206.* No Regulatory Review Has Taken Place at Plant in Response to Reed Rept.W/Svc List ML20215N2451986-10-29029 October 1986 Second Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State Emergency Evacuation Review Team Not Convinced Plan Adequate.Certificate of Svc Encl ML20215H6861986-10-21021 October 1986 Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State of Oh Emergency Plan Should Be Reviewed Before Full Operation Granted.Certificate of Svc Encl ML20214U9901986-09-29029 September 1986 Reply to Licensee Response to State of Oh 860904 Petition for Leave to Intervene.State Seeking Opportunity to Advise Commission as to Serious Safety Concern Re Eventual Full Power Licensing.W/Certificate of Svc ML20214R3381986-09-23023 September 1986 Response Granting State of Oh Petition to Intervene as Interested State,To Allow Entering Proceeding to Advise Commission on Pending Immediate Effectiveness Review.W/ Certificate of Svc ML20214R5671986-09-19019 September 1986 Response to State of Oh 860904 Petition for Leave to Intervene & Request That Petition Be Denied.Certificate of Svc Encl ML20212Q8461986-09-0404 September 1986 Petition of State of Oh for Leave to Intervene.Requests Participation in Evaluating Adequacy of Licensee Offsite Evacuation Plans.Certificate of Svc Encl ML20115A5681985-03-0808 March 1985 Petition for Suspension of CPs & Nuclear Fuel Shipments & Conduct of Investigation to Ascertain Whether Central Area Power Coordinating Group Financially Qualified to Design & Construct Facility ML20078K3501983-10-14014 October 1983 Response to Util & NRC 831003 & 06 Answers,Respectively,To Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2.NRC Misunderstood Thrust of Motion. Contention Should Be Admitted.W/Certificate of Svc ML20078E5161983-10-0303 October 1983 Answer Opposing Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2 Re Diesel Generator Reliability.Motion Fails to Meet Criteria of Adequate Basis & Specificity.Certificate of Svc Encl ML20080H2651983-09-16016 September 1983 Motion to Resubmit Contention 2 on Diesel Generator Reliability.Good Cause Contained in Recent Documents Describing Generator Failure of Type to Be Used at Plant. Certificate of Svc Encl ML20024B7491983-07-0505 July 1983 Reply Opposing Util & NRC Responses Opposing Ohio Citizens for Responsible Energy 830510 Motion to File Contentions on SNM License Application.Certificate of Svc Encl ML20024A2871983-06-13013 June 1983 Answer Opposing Ohio Citizens for Responsible Energy 830510 Motion to Admit Five New Contentions on SNM License Application.Contentions Unjustifiably Late,Outside ASLB Jurisdiction or Moot.Certificate of Svc Encl ML20066B9791982-11-0404 November 1982 Answer to Sunflower Alliance 821019 Reply Brief to NRC & Util Answers to Sunflower Motion to Submit Addl Contention on Shift Rotation.No Support Exists for Sunflower Untimeliness Argument.Certificate of Svc Encl ML20069J9811982-10-19019 October 1982 Reply Brief Supporting Motion to Submit Addl Contention.Good Cause for Late Filing Demonstrated.Applicant Shift Rotation Plans May Not Be Incorporating Circadian Principles ML20027C5851982-10-12012 October 1982 Reply Opposing NRC & Applicant Responses to Oh Citizens for Responsible Energy Motion for Leave to File Contentions 21-26.Good Cause,Specificity & Basis Requirements Met. Certificate of Svc Encl ML20069G0481982-09-24024 September 1982 Answer Opposing Sunflower Alliance 820910 Motion to Submit Addl Contention.Good Cause for Late Filing,Basis for Contention & Nexus Between Contention & Facility Not Shown. Certificate of Svc Encl ML20027B5751982-09-16016 September 1982 Answer Opposing Oh Citizens for Responsible Energy 820818 Motion for Leave to File Contentions 21-26.Adequate Basis, Specificity or Good Cause Not Demonstrated.Certificate of Svc Encl ML20063M6271982-09-10010 September 1982 Motion to Submit Addl Contention Re Unnatural Shift Rotations.Good Cause Shown for Late Filing as Basis of Contention Is Recently Published Research.Certificate of Svc Encl ML20063J4651982-08-31031 August 1982 Answer Opposing Oh Citizens for Responsible Energy 820809 Motion for Leave to File Contention 20 Re Inadequate Consideration of Economic Consequences of Accidents.No Basis for Assertion of Deficiency Shown.Certificate of Svc Encl ML20063D0551982-08-18018 August 1982 Motion for Leave to File Contentions 21-26 Re Turbine Missiles,New Mark III Containment Concerns,Seismic Evaluation of BWR Core Thermal Hydraulics & in-core Thermocouples.W/Certificate of Svc ML20058J8551982-08-0909 August 1982 Motion for Leave to File Contention 20 Re Adequacy of Consideration of Economic Consequences of Accidents.Des (NUREG-0884) Deficient Due to Failure to Include Assessment of Disruption Caused by Accident.Certificate of Svc Encl ML20055A3641982-07-13013 July 1982 Response Opposing Conservation Council of Nc Additions to Suppl to Petition to Intervene.Opposes Contentions Under Same Rationale Identical Contentions of W Eddleman Opposed. Certificate of Svc Encl ML20052A2821982-04-22022 April 1982 Motion for Leave to File Contentions 17,18 & 19.Certificate of Svc Encl ML20004E8381981-06-0808 June 1981 Amended Contention of T Kenney.Facility Evacuation Plan Fatally Defective Since Applicant Definitions of Affected Persons,Contaminated Area,Dose Projection & Emergency Action Levels Are Deficient.Certificate of Svc Encl ML20008G1571981-05-0808 May 1981 Amended Sunflower Alliance,Inc,North Shore Alert & Citizens for Safe Energy Petition for Intervenor Status.Contentions Set Forth in Original Petition Are Adopted by Ref.Svc List Encl ML20003H5211981-04-30030 April 1981 Suppl to Oh Citizens for Responsible Energy 810311 Petition to Intervene,Enumerating Contentions to Be Litigated. Contentions Concern Clam Biofouling,Steam Generator Reliability,Radiation Blocking Agent & Steam Injury ML19345G5941981-03-20020 March 1981 Response in Opposition to Oh Citizens for Responsible Energy 810306 Petition to Intervene in OL Proceeding.Petition Fails to Establish Organizational Interest Required by 10CFR2.714.Certificate of Svc Encl ML19345G5471981-03-20020 March 1981 Response in Opposition to Sunflower Alliance,Inc Et Al 810315 Petition to Intervene in OL Proceeding.Individual Petitioners Satisfy Interest Requirements But Organization Petitioners Do Not.Certificate of Svc Encl ML19343C7791981-03-16016 March 1981 Petition to Intervene in Proceeding ML19350B9871981-03-16016 March 1981 Petition to Intervene in Licensing Proceeding.W/Certificate of Svc ML20126F5351981-03-0606 March 1981 Petition for Leave to Intervene.Util May Not Be Financially Capable to Operate Plant Safely.Requests Fes & Info Re Prehearing Conference ML20126F5291981-03-0505 March 1981 Petition to Intervene in Licensing Proceeding & Request for Hearing.Proof of Svc Encl 1993-11-12
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20059L9391993-11-12012 November 1993 Petitioners Supplemental Petition for Leave to Intervene.* Court Held That NRC May Not Eliminate Public Participation on Matl Issue in Interest of Making Process More Efficient. W/Certificate of Svc ML20101M7061992-06-30030 June 1992 Applicant Answer in Opposition to Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Untimely Intervention Petition Should Be Denied.W/Certificate of Svc ML20101E1261992-06-15015 June 1992 Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Should Be Granted Discretionary Intervention & Amended Petition for Leave to Intervene Granted for Listed Reasons.W/Certificate of Svc ML20086G6401991-11-22022 November 1991 Petitioners Amended Petition for Leave to Intervene.* Amended Petition of Ohio Citizens for Responsible Energy,Inc for Leave to Intervene to Respond to Arguments Made in Licensee & NRC Intervention Petition.W/Certificate of Svc ML20083B7981991-09-16016 September 1991 Answer of Util to City of Brook Park,Oh Suppl to Petition for Leave to Intervene.* Concluded That City Petition Failed to Satisfy Any of Three Criteria for Intervention,Therefore Leave to Intervene Should Be Denied.W/Certificate of Svc ML20083B7901991-09-16016 September 1991 Answer of Util to Petition of City of Brook Park,Oh for Leave to Intervene & Suppl Thereto.* Petition Should Be Denied Based on Listed Reasons.W/Certificate of Svc ML20083B3581991-09-0404 September 1991 City of Brook Park Suppl to Petition for Leave to Intervene.* in Consideration of Foregoing,Petition of City of Brook Park,Oh for Leave to Intervene Should Be Granted. W/Certificate of Svc & Svc List ML20082P1611991-08-23023 August 1991 Petition for Leave to Intervene & Request for Hearing.* Petitioners Have Demonstrated Right to Be Made Parties to Proceeding and Instant Petition for Leave to Intervene Should Be Granted & Proposed Contention Admitted ML20082G8921991-07-31031 July 1991 Petition of City of Brook Park,Oh for Leave to Intervene.* City Requests That NRC & ASLB Deny Applicant Request for Hearing.W/Svc List & Certificate of Svc ML20082D4411991-07-10010 July 1991 Supple by American Municipal Power-Ohio,Inc to Petition for Leave to Intervene.* Facility Requests Addl Time to Mod Suppl.W/Certificate of Svc ML20082B5111991-07-10010 July 1991 10CFR2.714(b)(1) Suppl to Conditional Petition to Intervene of City of Cleveland,Oh Submitted in Connection w/910725 Prehearing Conference.W/Certificate of Svc & Svc List ML20082B2511991-07-0303 July 1991 Petition of Util for Leave to Intervene.* If License Conditions Can Disappear & Reappear W/Shifting Economics of Electric generation,AMP-Ohio Future Will Be Seriously Jeopardized.W/Certificate of Svc ML20077G2661991-05-30030 May 1991 Petition of Alabama Electric Cooperative,Inc for Leave to Intervene.* Util Requests Intervention in Further Proceedings on Applications of Ohio Edison & Other Applicants.W/Certificate of Svc ML20043D6751990-06-0101 June 1990 Ocre Response to Licensee & NRC Staff Answers to Ocre Contention.* Ocre Contention Should Be Granted Since NRC Has No Valid Argument to Preclude Admission of Contention & 10CFR2.714(b)(2) Requirements Met.W/Certificate of Svc ML20012E6901990-03-23023 March 1990 Licensee Answer to Ocre Petition for Leave to Intervene & Request for Hearing.* Concludes That Ocre Lacks Requisite Interest in License Amend Proceeding & Requests That ASLB Rule on Ocre Petition.W/Certificate of Svc & Svc List ML20012E6771990-03-0808 March 1990 Petition for Leave to Intervene & Request for Hearing.* Ocre Requests Hearing on Util 891219 Amend Request & Submits Petition W/Intention of Becoming Full Party.Petition Should Be Granted Since Ocre Demonstrated Right to Be Made Party ML20148D0511988-01-0707 January 1988 Petition for Leave to Intervene & Request for Formal Adjudicatory Hearing.* Ocre Demonstrated Right to Be Made Party in Proceeding & Petition Should Be Granted ML20214W6371987-06-0505 June 1987 Petition of Toledo Coalition for Safe Energy,Sunflower Alliance,Inc,S Sass & SB Carter for Revocation,Mod or Suspention of OL Per 10CFR2.206.* No Regulatory Review Has Taken Place at Plant in Response to Reed Rept.W/Svc List ML20215N2451986-10-29029 October 1986 Second Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State Emergency Evacuation Review Team Not Convinced Plan Adequate.Certificate of Svc Encl ML20215H6861986-10-21021 October 1986 Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State of Oh Emergency Plan Should Be Reviewed Before Full Operation Granted.Certificate of Svc Encl ML20214U9901986-09-29029 September 1986 Reply to Licensee Response to State of Oh 860904 Petition for Leave to Intervene.State Seeking Opportunity to Advise Commission as to Serious Safety Concern Re Eventual Full Power Licensing.W/Certificate of Svc ML20214R3381986-09-23023 September 1986 Response Granting State of Oh Petition to Intervene as Interested State,To Allow Entering Proceeding to Advise Commission on Pending Immediate Effectiveness Review.W/ Certificate of Svc ML20214R5671986-09-19019 September 1986 Response to State of Oh 860904 Petition for Leave to Intervene & Request That Petition Be Denied.Certificate of Svc Encl ML20212Q8461986-09-0404 September 1986 Petition of State of Oh for Leave to Intervene.Requests Participation in Evaluating Adequacy of Licensee Offsite Evacuation Plans.Certificate of Svc Encl ML20115A5681985-03-0808 March 1985 Petition for Suspension of CPs & Nuclear Fuel Shipments & Conduct of Investigation to Ascertain Whether Central Area Power Coordinating Group Financially Qualified to Design & Construct Facility ML20078K3501983-10-14014 October 1983 Response to Util & NRC 831003 & 06 Answers,Respectively,To Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2.NRC Misunderstood Thrust of Motion. Contention Should Be Admitted.W/Certificate of Svc ML20078E5161983-10-0303 October 1983 Answer Opposing Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2 Re Diesel Generator Reliability.Motion Fails to Meet Criteria of Adequate Basis & Specificity.Certificate of Svc Encl ML20080H2651983-09-16016 September 1983 Motion to Resubmit Contention 2 on Diesel Generator Reliability.Good Cause Contained in Recent Documents Describing Generator Failure of Type to Be Used at Plant. Certificate of Svc Encl ML20024B7491983-07-0505 July 1983 Reply Opposing Util & NRC Responses Opposing Ohio Citizens for Responsible Energy 830510 Motion to File Contentions on SNM License Application.Certificate of Svc Encl ML20024A2871983-06-13013 June 1983 Answer Opposing Ohio Citizens for Responsible Energy 830510 Motion to Admit Five New Contentions on SNM License Application.Contentions Unjustifiably Late,Outside ASLB Jurisdiction or Moot.Certificate of Svc Encl ML20066B9791982-11-0404 November 1982 Answer to Sunflower Alliance 821019 Reply Brief to NRC & Util Answers to Sunflower Motion to Submit Addl Contention on Shift Rotation.No Support Exists for Sunflower Untimeliness Argument.Certificate of Svc Encl ML20069J9811982-10-19019 October 1982 Reply Brief Supporting Motion to Submit Addl Contention.Good Cause for Late Filing Demonstrated.Applicant Shift Rotation Plans May Not Be Incorporating Circadian Principles ML20027C5851982-10-12012 October 1982 Reply Opposing NRC & Applicant Responses to Oh Citizens for Responsible Energy Motion for Leave to File Contentions 21-26.Good Cause,Specificity & Basis Requirements Met. Certificate of Svc Encl ML20069G0481982-09-24024 September 1982 Answer Opposing Sunflower Alliance 820910 Motion to Submit Addl Contention.Good Cause for Late Filing,Basis for Contention & Nexus Between Contention & Facility Not Shown. Certificate of Svc Encl ML20027B5751982-09-16016 September 1982 Answer Opposing Oh Citizens for Responsible Energy 820818 Motion for Leave to File Contentions 21-26.Adequate Basis, Specificity or Good Cause Not Demonstrated.Certificate of Svc Encl ML20063M6271982-09-10010 September 1982 Motion to Submit Addl Contention Re Unnatural Shift Rotations.Good Cause Shown for Late Filing as Basis of Contention Is Recently Published Research.Certificate of Svc Encl ML20063J4651982-08-31031 August 1982 Answer Opposing Oh Citizens for Responsible Energy 820809 Motion for Leave to File Contention 20 Re Inadequate Consideration of Economic Consequences of Accidents.No Basis for Assertion of Deficiency Shown.Certificate of Svc Encl ML20063D0551982-08-18018 August 1982 Motion for Leave to File Contentions 21-26 Re Turbine Missiles,New Mark III Containment Concerns,Seismic Evaluation of BWR Core Thermal Hydraulics & in-core Thermocouples.W/Certificate of Svc ML20058J8551982-08-0909 August 1982 Motion for Leave to File Contention 20 Re Adequacy of Consideration of Economic Consequences of Accidents.Des (NUREG-0884) Deficient Due to Failure to Include Assessment of Disruption Caused by Accident.Certificate of Svc Encl ML20055A3641982-07-13013 July 1982 Response Opposing Conservation Council of Nc Additions to Suppl to Petition to Intervene.Opposes Contentions Under Same Rationale Identical Contentions of W Eddleman Opposed. Certificate of Svc Encl ML20052A2821982-04-22022 April 1982 Motion for Leave to File Contentions 17,18 & 19.Certificate of Svc Encl ML20004E8381981-06-0808 June 1981 Amended Contention of T Kenney.Facility Evacuation Plan Fatally Defective Since Applicant Definitions of Affected Persons,Contaminated Area,Dose Projection & Emergency Action Levels Are Deficient.Certificate of Svc Encl ML20008G1571981-05-0808 May 1981 Amended Sunflower Alliance,Inc,North Shore Alert & Citizens for Safe Energy Petition for Intervenor Status.Contentions Set Forth in Original Petition Are Adopted by Ref.Svc List Encl ML20003H5211981-04-30030 April 1981 Suppl to Oh Citizens for Responsible Energy 810311 Petition to Intervene,Enumerating Contentions to Be Litigated. Contentions Concern Clam Biofouling,Steam Generator Reliability,Radiation Blocking Agent & Steam Injury ML19345G5941981-03-20020 March 1981 Response in Opposition to Oh Citizens for Responsible Energy 810306 Petition to Intervene in OL Proceeding.Petition Fails to Establish Organizational Interest Required by 10CFR2.714.Certificate of Svc Encl ML19345G5471981-03-20020 March 1981 Response in Opposition to Sunflower Alliance,Inc Et Al 810315 Petition to Intervene in OL Proceeding.Individual Petitioners Satisfy Interest Requirements But Organization Petitioners Do Not.Certificate of Svc Encl ML19343C7791981-03-16016 March 1981 Petition to Intervene in Proceeding ML19350B9871981-03-16016 March 1981 Petition to Intervene in Licensing Proceeding.W/Certificate of Svc ML20126F5351981-03-0606 March 1981 Petition for Leave to Intervene.Util May Not Be Financially Capable to Operate Plant Safely.Requests Fes & Info Re Prehearing Conference ML20126F5291981-03-0505 March 1981 Petition to Intervene in Licensing Proceeding & Request for Hearing.Proof of Svc Encl 1993-11-12
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212J1581999-09-30030 September 1999 Order Approving Transfer of License & Conforming Agreement. Orders That License Transfer Approved,Subj to Listed Conditions ML20205D4901999-02-22022 February 1999 Transcript of 990222 Informal Public Hearing on 10CFR2.206 Petition in Rockville,Md.Pp 1-105.Supporting Documentation Encl ML20198D9711998-11-0909 November 1998 Petition Per 10CFR2.206 Requesting That Facility Be Immediately Shut Down & OL Be Suspended or Modified Until Such Time That Facility Design & Licensing Bases Properly Updated to Permit Operation with Failed Fuel Assemblies ML20155F4561998-08-26026 August 1998 Demand for Info Re False Info Allegedly Provided by Wh Clark to Two NRC Licensees.Nrc Considering Whether Individual Should Be Prohibited from Working in NRC-licensed Activities for Period of 5 Yrs ML20236V5261998-07-20020 July 1998 Computer Access & Operating Agreement Between Cleveland Electric Illuminating Co & NRC PY-CEI-NRR-2284, Comment Opposing Proposed Generic Communication, Lab Testing of Nuclear-Grade Activated Charcoal1998-05-21021 May 1998 Comment Opposing Proposed Generic Communication, Lab Testing of Nuclear-Grade Activated Charcoal ML20216B5111998-04-0909 April 1998 Order Imposing Civil Monetary Penalty.Denies Request for Remission of Violation C,Ea 97-430 & Orders Licensee to Pay Civil Penalty in Amount of $50,000 within Next 30 Days PY-CEI-NRR-2269, Comment on Proposed Rule 10CFR50.NRC Should Demonstrate That Not Only Is Code Process Flawed,But That Proposed Change Justified from Cost Versus Safety Protective1998-04-0303 April 1998 Comment on Proposed Rule 10CFR50.NRC Should Demonstrate That Not Only Is Code Process Flawed,But That Proposed Change Justified from Cost Versus Safety Protective ML20216G3821998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Duquesne Light Co & Allegheny Power Systems,Inc ML20217J0661998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Dqe, Inc & Allegheny Power System,Inc ML20198P9311997-11-0707 November 1997 Comments of American Municipal Power-Ohio,Inc.NRC Should Require Allegheny Power Sys,Inc to Affirm That Capco Antitrust License Conditions Will Be Followed ML20134L3401997-01-22022 January 1997 Resolution 96-R-85, Resolution Supporting Merger of Centerior Energy Corp & Ohio Edison Under New Holding Co Called Firstenergy ML20133B6941996-12-18018 December 1996 Submits Ordinance 850-96 Re Approval of Merger of Centerior & Oh Edison Into Firstenergy ML20135F4731996-12-0606 December 1996 Memorandum & Order CLI-96-13.* Commission Reverses & Vacates ASLB LBP-95-17 Which Granted Motion for Summary Disposition Submitted by Ocre & Hiatt.W/Certificate of Svc.Served on 961206 ML20132A8461996-12-0202 December 1996 Resolution 20-1996 Supporting Merger of Ohio Edison & Centerior Corp Under New Holding Company Called Firstenergy ML20134M6191996-10-28028 October 1996 Proclamation of Support by City of Sandusky,Oh Re Merger of Ohio Edison and Centerior Energy Corp ML20112J8281996-06-18018 June 1996 Licensee Reply Brief on Review of Licensing Board Decision LBP-95-17.* W/Certificate of Svc ML20112D8721996-05-29029 May 1996 Intervenor Brief in Support of Commission Affirmation of LBP-95-17.* Commission Should Affirm Licensing Board Decision.W/Certificate of Svc ML20108D9571996-05-0303 May 1996 CEI Response to City of Cleveland 2.206 Petition.Nrc Should Deny Petition ML20108B7571996-04-26026 April 1996 Licensee Brief on Review of Licensing Board Decision LBP-95-17.* Recommends That Commission Reverse Board Memorandum & Order Issued 951004.W/Certificate of Svc & Svc List PY-CEI-NRR-2034, Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matl1996-03-11011 March 1996 Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matl ML20101B5841996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement Or,In Alternative,For Severance of Issue & Expedited Hearing Procedures.W/Certificate of Svc ML20097B8721996-01-23023 January 1996 Petition of City of Cleveland,Oh for Expedited Issuance of Nov,Enforcement of License Conditions & Imposition of Appropriate Fines,Per 10CFR2.201,2.202,2.205 & 2.206 ML20097B8911996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement or in Alternative,For Severance of Issue & Expedited Hearing Procedures ML20096E2471996-01-0303 January 1996 Comment on PRM 50-64 Re Stockpiling Ki for Use as Thyroid Protectant in Event of Nuclear Accident.Supports Distribution of Ki to Public ML20094N1951995-11-17017 November 1995 Oh Edison Application for License Transfer in Connection W/ Sale & Related Transactions ML20094M5941995-11-15015 November 1995 Intervenors Answer to Licensees Petition for Review.* Intervenor Conclude That Commission Should Not Review Board Decision.W/Certificate of Svc ML20094J9141995-11-0707 November 1995 Petition for Review.* Submits That Commission Review of Board Decision Appropriate Under 10CFR2.786. W/Certificate of Svc & Svc List ML20093N9491995-10-23023 October 1995 Licensee Request for Extension of Time to File Petition for Review.* Requests That Commission Grant Extension Until 951107 of Deadline for Filing Petition for Review. W/Certificate of Svc ML20065L3571994-04-0505 April 1994 Intervenors Answer to NRC Staff Response to Intervenors Motion for Summary Disposition & Licensees Cross Motion for Summary Disposition.* Urges Board to Deny Licensee Cross Motion.W/Certificate of Svc ML20064N6341994-03-21021 March 1994 Affidavit of RW Schrauder in Support of Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition.W/Certificate of Svc ML20064N6081994-03-21021 March 1994 Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition.* Moves for Decision in Licensee Favor on Ocre Contention ML20064N9201994-03-21021 March 1994 Affidavit of RW Schrauder in Support of Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition. W/Svc List ML20063L4621994-02-0707 February 1994 Motion for Summary Disposition.* Intervenors Request That Board Grant Summary Disposition Favorably & Issue Declaratory Relief by Finding Challenged Portion of Amend 45 to Be in Violation of Aea.W/Certificate of Svc ML20058P4451993-12-13013 December 1993 Licensee Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Supplemental Petition for Leave to Intervene.* W/Certificate of Svc ML20059L9391993-11-12012 November 1993 Petitioners Supplemental Petition for Leave to Intervene.* Court Held That NRC May Not Eliminate Public Participation on Matl Issue in Interest of Making Process More Efficient. W/Certificate of Svc ML20059B1421993-10-19019 October 1993 Order.* Petitioners Shall File Supplemental Petition in Accordance W/Schedule in 931018 Order.W/Certificate of Svc. Served on 931020 ML20059B1761993-10-18018 October 1993 Order.* Informs That for Each Contention,Petitioners Shall Comply Fully W/Requirements of 10CFR2.714(b)(2)(i),(ii) & (III) & Their Filing Should Address Requirements Set Forth in Regulations.W/Certificate of Svc.Served on 931019 ML20059B0701993-10-12012 October 1993 Motion to Defer Consideration of Remanded Issue.* Requests That Licensing Board Defer Consideration of Remanded Issue Pending Outcome of Commission Review of 2.206 Process.W/ Certificate of Svc ML20058M8761993-09-30030 September 1993 Memorandum & Order CLI-93-21.* Appeal for Hearing Re Amend to Plant OL Denied.W/Certificate of Svc.Served on 930930 ML20057C0461993-09-21021 September 1993 Supplemental Director'S Decision DD-93-15 Involving 920929 Request for Certain Actions to Be Taken Re Proposed Construction of Interim onsite,low-level Radioactive Waste Facility at Plant.Request Denied ML20056C8951993-07-19019 July 1993 Order Extending Time within Which Commission May Rule on Petitions for Review of LBP-92-32.W/Certificate of Svc. Served on 930720 ML20045B5661993-06-0707 June 1993 Comment Re Proposed Generic Communication on Mod of TS Administrative Control Requirements for Emergency & Security Plans,As Published in Fr on 930401 (58FR17293).Believes Concept of Technical Review Not Addressed by STS ML20044E2781993-05-13013 May 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re VEPCO Petition to Change Frequency of Emergency Planning Exercise from Annual to Biennial ML20127A6171993-01-0606 January 1993 Order.* Time within Which Commission May Rule on Petitions for Review of Board Order LBP-92-32,dtd 921118,extended Until 930208.W/Certificate of Svc.Served on 930106 ML20126D5171992-12-23023 December 1992 City of Brook Park Answer to Petitions for Review.* Opposes Applicants 921208 Petitions for Review Based on Fact That ASLB Decision in proceeding,LBP-92-32,adequately Addressed Issues Raised in Petitions.W/Certificate of Svc ML20126F6501992-12-23023 December 1992 Answer of City of Cleveland,Oh,Intervenor,In Opposition to Petitions for Review of 921118 Decision of Aslb.* Petitioners Petitions for Review Should Be Denied. Certificate of Svc Encl ML20126D5461992-12-23023 December 1992 Answer of Cleveland Electric Illuminating Co & Toledo Edison Co to Limited Petition for Review of City of Cleveland,Oh of 921118 Decision of Aslb.* Commission Should Deny City of Cleveland Petition.W/Certificate of Svc ML20126D5781992-12-23023 December 1992 Answer of American Municipal Power-OH,Inc in Opposition to Petitions for Review of Oh Edison Co & Cleveland Electric Illuminating Co/Toledo Edison Co.* W/Certificate of Svc ML20126D5801992-12-23023 December 1992 NRC Staff Answer in Response to Petitions for Review Filed by Oh Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & City of Cleveland.* W/Certificate of Svc 1999-09-30
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%l 9 5 THE NUCLT.AR 4.C"LATORY C0tCIS. ION UNITED STATES OF !.:: ERICA I:s THE MATTER OT: Docket Numbers 50 440
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)30-441 Cleveland :;1ectric 111uminating Co., et al Petition for Leave,to .
Perry Naclear Power Plant ) I"E'f"'"'
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@g "I l scu/
Units 1 and 2
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s Application for Facility ) '
Operating Licenses / 000 D\~
g MAR 161981 > $
cme, af t*e W C /
Deosung & semcs h 1. Now come the followings fo ksach h Sunf1 ver Alliance, Inc. Jenny Steindam Northshore Alert Harold steindas Evelyn Stebbins Les Gerlosky Richard Laring Margaret Cerlosky p David Nash William Brotzman Gail Caduff Nash Grand River L:inery Linda Qualls Cumings homsted Park Corp.
David Qualls Toledo Coalition for safe Energy ,
Citizens for aafe Energy
- and petition the Commission to grant them leave to intervene in the captioned matter pursuant to 10 CFR 2.714 and to set this matter down for public hearing.
In support of their petition, the above petitioners make the following representations as to themselves; their righta to be made parties in this procuecing; tne u.ture of their property, financial and other interests in this proceeding and the effects that any order issued in thth proceeding will have on your petitioners 8 interest.
1 IDENTITY OF PETITIONERS
- 2. The Sunflover Alliance Inc. is a non-profit Ohio Corporation made up of and controlled by residents of Ohio who live and work and own property in Lake and Aahtabula Counties, Ohio. These areas are within a 1 to 50 mile radius of cne rerry piant. as residents or tnw geogsaphical area immediately surrounding the Perry plant, their economic, social, ,
political and psychological interests are impacted and effected by the potential operation of the Perry plant. Further, the members of the
.,unflouer Alliance are directly affected by the safe operation of the
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,. s u nrum w. Petr ..nt. 1.ccr mem5cr c f tS unflo er A!!!cnce, In:. is dire:ti, concerne' :n' nr.s an inten st .? a ac t i vi t v
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which effects the econor.ic vitality of tais area or .tich in any way lessens the value of their property. !)e eperation of t e Perry plant, if permitted, vill directly anc insediately ispect on Lake and r.sntabula Countica and the ability of these areaa to co=pete effectively witn otter areas of the nation f or economic development. If the oeeratioe of en.
Perry plant lessens the coececitive acility of Late anc ashtacula '
Coonties for economic development, tnis will redace the value cf treir property and reduce their aoility to locate jobs and support treir ,
families and therselves.
- 3. Thus, the inpact of any order promulgatec in this croceeding will affect the memoership of tne Sunflower Alliance in torna of their economic, social, psfchological and political interests.
l
- 4. The borthonore Alert is an unincorporated association of 1 8 i individuals residing in Cuyahoga, Lake, Aantabula, Portage and Samnit j Counties Ohio unich are within a radius of 1 to 50 niles of the Perry {
plant. Members of the Northshore Alert osn real property in the affected area; are employed in the af fected area and are raising their f aa 11es within the affected area. Parts of this five suunty ar.., also suown as toe mestern asserve, have a rich and unique historical heritage going back to the northwest territory. This co::sination of unique historical heritage; strong natural resource base; economic diversity; political stability sake tnw *estern Reserve the strong backbone of t e l
' united States. Members of the Northshore Alert, tho live and wert and I
own property in tais area, have an !=portant interest in the economic and safe operation of the Perry plant. If th6 operation of the Perry plant lessens the competitive aoility of the L estern Reserve f or i
economic development, this v111 recuce the value et toets property and reduce their ability to locate jobs and support their families and
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I themselves. It is also a well known fact that this area of the state of i
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Ohio pays into the federal treasury note ttan it receives back th tre form of federal prograss. Thus, any adverse economic impact on this area caused by the inef ficient or unsafe operation of the Perry plant w!!!
hlb 5 FAN.HE%NFH l = s asntnerw. al.co adversiv 1 sact the nat!cr. as a . cole.
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- 5. The Toledo Coalition for aafe Energy is an unincorporated association of individuals living in northwest Ohio. Their intervention vould permit individuals residing in the northern third of the state of Ohio to have their vital interests protected. horthwest Ohio, too, is part of the midwest industrial belt of this Country. The Toledo Edison Co, one of the applicants, is based in this area. Obviously Toledo Edison believes that it will somehoe benefit with this partnership rich the Cleveland Electric Illuminating Co. in a plant not in its geographical terri tory. Jince Toledo Edison is investing capital into the Perry plant, it is obviously affecting its service area and the area in which Toledo Coalition for Safe Energy is based. The adverse impact to Toledo Coalition for safe Energy is the f act that the capital invested by the Toledo l Edison Co sill not be available for useful purposes in the service area of the Toledo Ldison Co. This will adversely affect the members of the ,
Toledo Coalition for Safe Energy because the drain of capital from the area will lessen the ability of northsest Ohio to attract economic development. Thus, members of the Toledo Coalition for aafe Energy are vitally interested in the safe and economic operation of the Perry plant and have an interest to protect by intervention.
- 6. Evelyn Stebbins and Richard ering are individuals and residents of Cuyahoga County, Ohio. David Nash, Cail Caduf f Nash, Linda Qualls, David Qualls, Jenny Steindam, Harold Steindam, .es Gerlosky, Margaret Cerlosky and .1111am Brottman are all individual.s who reside either in Madison, Ohio or in Geneva. Ohio all within a ten mile radius of the plant. Grand River t inery and Cumings homsted Park Corp. are businesses located within a ten mile radius of the plant. Citizens for aafe Energy is a membership based orgaatzation with members living, working and owning property in Cuyahoga and E~ke Counties, Ohio all vithin the af fected area. These individuals and businesses who own property and operate businesses within the affected area are vitally interested in the safe, economic and professional operation of the Perry plant and their lives and property sill be affected by any order entered in this proceedings.
stow n utma n 11 Fi?.ST GROUND of !?.i!WENTION
~,27.7,f7."*; 7. Petitioners restate all enat is alleged in paragraphs 1
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- 8. Petitioners allege that the emergency and evacuation plans for the subject facilities are fatally defective in numerous respects including but not limited to inadequacy of notification plans;-
deficiencies in radiation exposure measurement techniques, insufficient practical workability; no agreement with local response organizations as to cost and implimentation of plans and inadequate notification of and information to media and residents within the ten (10) and fif ty (50) mile radil.
U III SECX)MD GROUND OF INTERVENTION c i i
- 9. Petitioners restate all that is alleged in paragraphs one through eight herein. I
{J t 6 10. Petitioners allege that the Applicants have not demonstrated I l
" i that they have the financial capability of completing Units 1 and 2; ;
P that they lack the financial capability of operating Units 1 and 2; !
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f that they lack the financial capability of decommisionning the facilities F
i and protecting the facilities after decommisatonning.
I IV THIRD CMOUND OF INTERVENTION
- 11. Petitioners restate all that is alleged in paragraphs one through ten herein.
1 i
- 12. Petitioners allege that the licensure of Perry Units land p 2 to operate will cause them and their members, as the case may be,.
! irreparable harm on the ground that the forecasted net energy demand of Cleveland Electric Illuminating Co and the other applicants (herein.
P af ter referred to as " Applicants") for the coming two to eight* years does not justify licensure at this time.
- 13. There is considerable dispute on the issue of net energy h demand forecasts by Ohio utility companies . including Applicants, as t
,e demonstrated by the fact that Applicants have revised their ten year j i
electricity demand forecasta downtard by approximately 25* between their i L l 1978 and 1979 projections. This of course occurred after Applicants i
[ i were granted a construction license. A 1980 study by the United states General Accounting Qffice found that the national grouth rate in w row Av. n Es%Lr u electrict1
- demand may range as lov as 2.$7. per year through 1998.
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1 A 1980 analysis commissioned by the Ohio Office of Consumers' Counsel concludes that Ohio utilities, including Applicants, have greatly and historically overprojected estimates for net energy demand.
For Applicants, the Consumers' Counsel study reveals that the 1978
'986 gros th rates forecast may actually be overestimated Wrom 23; to more tr.an 100%. .
V FOURTH CROUND OT INTERVENTION
- 14. Petitioners restate all that is alleged in paragraphs 1 through 13 herein.
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- 15. Petitioners allege that there is insufficient consideration i
I in the draft environmental statement for the subject facilities of '
I alternative energy possibilities including but not limited to industrial cogeneration and conservation in all sectors of electrical usage. I Petitioners further allege that adequate consideration of said altern- l i
atives could formulate the basis for a long range plan which, if implemented, vould completely obviate the need for operating licensure '
i of the Perry units at this time.
V1 FIFTH CROUND OF INTERVENTION
- 16. Petitioners r& state all that is alleged in paragraohs 1 through 15 herein.
- 17. Petitioners allege that the draft environmental statement i
for the subject facilities fails to adequately set forth and consider energy management options available to the co-owners of said facilities.
These inadequately considered possibilities include the implementation of load management plans; the use of innovative rate structures which encourage conservation and or equalization of usage by time of day and improved power exchange capabilities with utilities in otuus region. of tne state or unto and other counties which periodically have excess ;
productive capacity.
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i VII sir!H CROUND OF INTERVENTION
- 18. Petitioners restate all that is alleged in paragraphs 1 through 17 herein.
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consto. 61on, eitner in cne environmental impact statement documents -
or tne application for license or in the Final safety Analysis Report, of the health, safety and environmental effects of a possible major radiation release accident in the spent fuel storage pond contemplated I for usage at the facilities. Petitioners allege that this inadequate consideration impacts on the of f site emergency plans'and preparations, endangers the health and safety.of residents for a very large radius
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.rouno 6ue plant, and is fatally defective to any serious consideration -
of licensure at this time.
VIII SLT!NTF CROUND OF INTERVENTION *
" 20. Petitioners rescate all that is alleged in paragraphs 1 ,
through 19 herein. ->
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- 21. Petitioners allege that there is insufficient documentation l of the ability of the containment structures of said f acilities to safely inhibit a hydrogen explosion of the magnituee'and type which i occurred at the Three Mile Island Unit 2 near Harrisburg,' Pennsylvania ,
and of which the Commission is aware. Petitioners further allege that Licensing of the subject f acilities to emic certain minimal amounts of i radiation is inadequate to ensure the health and safety of persona, I animals and vegetation near the plant, including your petitioners herein.
14 EICHTH CaDUND OF INTERVENTION ~i
- 22. Petitioners restate all that is alleged in paragraphs 1 [
through 21 herein.
- 23. Petitioners allege that the tandem licensing of Units 1 and ,
2 is improper and contrary to the safvty considerations set forth in !
I the nuclear energy policy established by Congress. Unic 2 is not ,
anticipated to be completed until May 1, 1987, if ever. This is more j than six years from now. To permit Unit 2 to be licensed for facility
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operation at this time sill run afoul of safety considerations and economic policy considerations of both the Atomic Energy Act and the National Environmental Polciy Act. It is entirely conceivable that events during the ensuing six years will coviate the need for Unit 2.
i mTADI A N H E5%1 F H LaCh Unit must be licensed on its een unique set of facts. '
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e i NTNTH CHOUND OF INTERVENTION q-24 Petitioners restate all that is alleged in paragraphs 1 through 23 herein.
- 23. Petitioners allege that Applicants have demonstrated 5 throughout the construction process their inability to comply with the Quality Assurance Program established by both the Co=P.ission and ;be
- Applicants. Applicants construction practices, as demonstrated in the Commission's own inspection reports, are totally inexcusable. ,
Petitioners allege that Applicants have not constructed Perry in
- accordance with applicable standards and that there are the following but by no means the only deficiencies i f A) that the General Electric reactors, being used at Perry, !
have developed cracking at the primary coolant nozzles. !
Thus, the safety of these reactors are currently under-going investigation. . ,
i B) that Perry is built on a geological fault and that the I i plant has not been built to earthquake standards. i C) that this plant uses baf fles in the cooling tosere made of asbestos; that during operation of the reactor the i asbestos will flake causing asbestos to leak into the I air or otherwise interfere with the safe operation of j the plant. ,
D) that Perry is being built in an area with a high water table; that as a consequence of this the concrete being
- poured into the ground is porous which will require- ,
that water be pumped from the concrece; that the contain- +
ment floor is being built on this type of concrete construction; that this technique is not a proven construction technique.
I Petitioners further allege that Applicants have wholly failed to operate f i
Davis-Bessie in a professional, economic and efficient manner as demonstrated by the Commissions own reporta. Pet'itioners allege that t
there is no reason to believe that Applicant's will operate Perry in the public interest either.
A1 TEhTH CROUND OF ffCERV!h710N t
- 26. Petitioners restate all that is alleged in paragraphs 1 i r through 25. !
- 27. Petitioners allege that the application of Applicant i
f ails to adequately address the decommissioning process; has f ailed to satisfactorily to set forth what vill happen to Perry plant once [
- cGMAN HthMth its useful life has expired; has f ailed to estabit sh satisf actority a13NDERht48
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financial protection to protect the public during the decorsissioning j ,
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' HTedLFORI, Petitioners respectfully request that this honorable ,
s Cor.nission grant them the following relief forthwiths A) that Petitioners be granted leave to intervene on all , ;
i the grcunds as stated herein;
- 3) that this matter be set for such pre. adjudicatory and j.
b adjudicatory proceedings as the Comunission shall see fit all with l 5 leave of Petitioners to participate as full parties herein; C) that a hearing be granted to Petitioners with full participation! ;
by the Petitioners prior to the licensure of Perry Units 1 and 2; D) that by way of adjudicatory relief, after a full hearing, ,
that this Coenission deny operating licensure of Perry Units 1 and 2.
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paniel D. 111. Esq. ,
Attorney for Petitioners
, 7301 Chippewa M. ,
Brecksv111e, Chio 44141 !
! (216) 526 2330 l
Terry Lodge,Jvsq.' ;
Attorney forJetittsvers :
915 f.pitzer Bldg. !
Toledo, Ohio 43604 (419) 25 % 5058 I,
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e 4 I Proof of service The undersigned attorney for Petitioners does hereby certify ttat on the O$ day of rarch, 1981 he sent a true copy of the Petition for Leave to intervene, by regular U.S. Mail, postage prepaid, to tru f ollowing s Lxecutive Legal Director United atates Nuclear kegulatory Commission Lashington, D.C. 20555 i
Cerald Charnof f, Esq.
a b aw, Pittman, Potts and Trewbridge ,
1800 M Ltreet K'd basnington, D.C. 20036 l
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ante! D. 11t , E sq . j
/ Attorney for Petitioners 7301 Chippewa Rd.
Brecksv111e, Ohio 44141 (216) 526-2330 l
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