ML20067A106

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Requests Consideration of West Valley Agricultural Protection Council,Inc Supplemental Memorandum Supporting Council Petition to Intervene.Brief Includes Useful Analysis
ML20067A106
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 11/29/1982
From: Berlin K
AFFILIATION NOT ASSIGNED
To: Callihan D, Cole R, Lazo R
Atomic Safety and Licensing Board Panel
References
NUDOCS 8212010202
Download: ML20067A106 (1)


Text

DOCKETED

. USNRC

'82 NOV 30 A10:24 Attorney at Law 2550 M Street, N.W.

u:fla J Sitat m r Washington, D.C. 20037 00CXEimG A SERVICE BRANCH November 29, 1982 Robert M. Lazo, Esq., Chairman Dr. Richard F. Cole Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Dr. Dixon Callihan Washington, D.C. 20555 Administrative Judge Union Carbide Corporation P. O. Box Y Oak Ridge, Tennessee 37830

~

In the Matter of ARIZONA PUBLIC SERVICE COMPANY, ET AL.

(Palo Verde Nuclear Generating Station, Units 1, 2 and 3)

Docket Nos. STN 50-528, STN 50-529 and STN 50-530 _

Dear Administrative Judges:

On November 24, 1982 counsel for NRC staff, Lee Scott Dewey, sent you a letter suggesting that you not consider West Valley Agricultural Protection Council, Inc.'s (West Valley)

"Supplemente.1 Memorandum" in support of its petition to intervene.

While West Valley recognizes that under NRC regulations it has no right to file a reply brief, we believe the brief includes analysis which you will find useful in considering West Valley's petition to intervene. Since the document will be useful to you and since it does not contain any new information improperly submitted for the first time in reply papers, we request that you consider the Supplemental Memorandum.

. Sincerely, ,

[M W

~

~ c212'010202 821129 gDR ADOCK 05000gD Kenneth Berlin -

Counsel for West Valley Agricultural KB:gik Protection Council, Inc.

cc: Arthur C. Gehr, Esq.

Rand L. Greenfield Atomic Safety and Licensing Board Panel Docketing and Service Section "'

Charles Bischoff, Esq.

Ms. Lee Hourihan Atomic Safety and Licensing Appeal Board {)_])

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