Re: ISP CISF: BEYOND NUCLEAR’S REPLY TO OPPOSITIONS TO HEARING REQUEST AND PETITION TO INTERVENE

On November 5, Diane Curran of Washington, D.C., and Mindy Goldstein of Atlanta, GA -- Beyond Nuclear's legal counsel -- filed a REPLY TO OPPOSITIONS TO HEARING REQUEST AND PETITION TO INTERVENE, addressing various U.S. Nuclear Regulatory Commission (NRC) staff, and Interim Storage Partners (ISP), challenges (or, in NRC's case, lack thereof -- see immediately below) to Beyond Nuclear's request for a hearing, and petition for leave to intervene, in thge ISP irradiated nuclear fuel centralized interim storage facility (CISF) NRC license application proceeding.

(It is worth noting that NRC staff, in its filing, acknowledged Beyond Nuclear's legal standing claims, as well as the worthiness of its contention for admission to hearing. The NRC filing concluded:

"...the NRC Staff agrees that Beyond Nuclear has demonstrated standing and an admissible contention, and so the Petition should be granted.")

ISP is a consortium comprised of Orana (formerly Areva, formerly Cogema) of France, and Waste Control Specialists, LLC (WCS) of Andrews County, Texas. The WCS site in West Texas is targeted for the 40,000 metric ton commercial irradiated nuclear fuel CISF.

The NRC and ISP challenges had been filed on Oct. 29th. Beyond Nuclear filed its request for hearing and petition for leave to intervene on Oct. 4th.

Beyond Nuclear also filed a motion for the ISP CISF licensing proceeding to be dismissed, as it lacks legal authority to proceed. However, the NRC rejected that motion to dismiss.