ML19260E074
| ML19260E074 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/01/1980 |
| From: | Jordan W BIER, MILLS, CHRISTA-MARIA, ET AL, SHELDON, HARMON & WEISS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8002130286 | |
| Download: ML19260E074 (4) | |
Text
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- (exs UNITED STATES OF AMERICA
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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CONSUMERS POWER COMPANY
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Docket No. 50-155
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(Big Rock Point Nuclear
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Power Station)
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MOTION FOR RELIEF FROM THE 20 COPY REQUIREMENT OF 10 CFR 2.708(d)
Christa-Maria, James Mills, and JoAnn Blers move that they be relieved of the burden of supplying twenty copies of all filings to the Commission as required by 10 CFR 2.708(d).
They request that they be permitted instead to serve single copies on all of the parties, including the NRC staff, the members of the Licensing Board, and the Secretary of the Commission.
Relief from the twenty copy requirement is essential to allow these Intervenors to devote all of their resources to substantive participation in this proceeding.
Any unnecessary drain on their resources will severely limit their ability to participate effectively and to assist the Licensing Board in reaching its decision.
A clear example of the undue and unnecessary burden posed by the twenty copy requirement is the set of interrogatories that these Intervenors recently served on the Licensee.
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~ Despite the fact that the Commission is not required to respond, the Intervenors are required to spend approximately S70.00 for copies to be distributed within the Commission.
Since these copics are for the Commission's use, surely the Commission can bear the expense.
The relief that Christa-Maria, et al, are requesting is specifically authorized by 10 CPR 2.708(d), which requires that twenty copies be filed with the Secretary "[e]xcept as otherwise provided by this Part or by order."
The Board, therefore, has the authority to order that only a single copy need be filed with the Secretary.
Th.is request also is not without favorable precedent.
Although there has been no written order to this effect, the Licensing Board in Metropolitan Edison Co. (Three Mile Island Unit No. 1), Docket No. 50-289 (Restart) has permitted all Intervenors to serve single copies on the NRC Staff, the Licensee, the members of the Board, and the Secretary of the Commission.
The Secretary is then responsible for making copies for internal NRC use and for all other Intervenors and for serving all other Intervenors.
Christa-Maria, et al, request essentially the same procedure here, except that they would continue to serve John O'Neill, the other Intervenor.
Respectfully submitted,
' c / % :* l~ s ;n William S., Jordan, III
_3 SIIELDON, IIARMON & WEISS 1725 "I"
- Street, N.W.
Suite 506 Washington, D.C.
20006 (202) 833-9070 Counsel for Christa-Maria, et al.
Dated:
February 1, 1980 e
UNITED STATES OF M1 ERICA NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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CONSUMERS POWER COMPANY
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Docket No. 50-155
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(Big Rock Point Nuclear
)
Power Station)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Motion for Relief From the 20 Copy Requirement of 10 CFR 2.708(d)," were mailed postage pre-paid this 1st day of February, 1980, to the following:
Herbert Grossman, Esq.
Janice E. Moore, Esquire Atomic Safety and Licensing Counsel for NRC Staff Board Panel U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Oscar H.
Paris Joseph Gallo, Esquire Atomic Safety and Licensing Isham, Lincoln & Beale Board Panel 1050 17th Street, N.W.
U.S.
Nuclear Regulatory Commission Suite 701 Washington, D.C.
20555 Washington, D.C.
20036 Mr. Frederic J.
Shon John O'Neill, II Atomic Safety and Licensing Route 2, Box 44 Board Panel Maple r#'~
Michigan 49664 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
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US EhdeE William S.
Jordan, III
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