ML19263B597
| ML19263B597 | |
| Person / Time | |
|---|---|
| Site: | 07002738 |
| Issue date: | 01/05/1979 |
| From: | Barnes J, Curtis C, Stoel T CENTER FOR LAW & SOCIAL POLICY, National Resources Defense Council |
| To: | |
| Shared Package | |
| ML19263B598 | List: |
| References | |
| NUDOCS 7901220149 | |
| Download: ML19263B597 (6) | |
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1 Before the
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cp NUCLEAR REGULATORY COMMISSIOP Washington, D.C.
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In the Matter of
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License No. XSNM-1222
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EDLCW INTERNATIONAL COMPANY
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Docket No. 70-2738
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(Agent for the Government of
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India on Application to Export
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Special Nuclear Fuel)
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PETITIONERS' MOTION FOR EXTENSION OF TIME TO SUBMIT WRITTEN COMMENTS Petitioners, Natural Rescurces Defense Council, Inc., the Sierra Club, and the Union of Concerned Scientists hereby respecr-fully move the Commission for an order c:ctending their time to submit written comments in the above-captioned proceeding from-January 11, 1979 to January 25, 1979 (14 days), as well is the time for sunmission of reply comments from January 22, 1979 to February 1, 1979.
The grounds for this motion are more fully set forth in the attached memorandum of points and authorities.
Respectfully submitted, I
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CURTIS JAMES N.
BARNES Mailing Address:
Center for Law and Social Policy 1751 N Street, N.W.
Washington, D.C.
20036 (202) 872-0670 Attorneys for the Sierra Club, Union of Concerned Scientists, and NRDC 79012201N
. THOMAS B.
STOEL, JR.
S. JACOB SCHERR Mailing Address:
Natural Resources Defense Council 917 15th Street, N.W.
Washington, D.C.
20005 (202) 737-5000 Attorneys for NRDC Dated:
January 5, 1979 Washington, D.C.
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AFFIDAVIT OF CLIFTON E. CURTIS M
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City of Washington
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CLIFTON E. CURTIS, having been sworn, states as follows:
1.
I am an attorney employed by the Center for Law and Social Policy.
2.
As one of the attorneys for the Petitioners National Resources Defensc Council, Union of Concerned Scientists, and the Sierra Club in the Commission's consideration of License Application XSNM-1222 (Docket No. 70-2738), I prepare? FOIA requests which were hand-delivered to the Commission, the Department of State, and the Depart-ment of Energy on December 19, 1978.
3.
On January 5, 1978 while reviewing FOIA documents made avail-able by the Commirsion pursuant to our December 19, 1973 request, I reproduced a copy of a January 4, 1979 letter from J. M.
Felton ad-dressed to me and James Barnes.
(That letter is attached hereto as Appendix 1).
As that letter indicates, the documents which have thus far been made available at the Commission's Public Document Room represent a " partial response" to our request.
4.
In a phone conversation today with Ms. Barbara Wagman, an emoloyee of the Commission's Division of Rules and Records, I was advised that the Commission expects to make additional documents Exhibit 3
- available pursuant to our FOIA request on January 8, 1978, but that other documents involving correspondence with the Department of State would not be available until a later time as yet undetermined.
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Subscribed and Sworn to before me this N ay of January 1979 at Washington, D.C.
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UNITED STATES
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January 4, 1979 2
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James Barnes, Esquire Center for 1.aw and Social Policy IN RESPONSE REFER 1
1751 N Street,fl.W.
TO F01A-78-346 Washington, DC 20036
Dear Messrs. Curtis and Barnes:
This is in response to your lette:. of December 19, 1978, in which you requested, pursuant to the Freedom of Information Act, access to records concerning the Terapur, India Atomic Power Station and other matters f
relating to use of nuclear energy by India.
Appendix A, enclosed, is a listing of documents which, in partial response to your request, are being placed in the NRC Public Document Room (POR),1717 H St., N.W., Washington, DC.
As Ms. Wagman of my staff has already discussed with you by telephone, additional documents will be made available as soon as staff review is completed.
Some of the records subject to your request were originated by the Departments of State and Energy.
These are being referred to those agencies for appropriate disposition and direct response to you.
Sincerely, W/
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J. M. Felton, Director Division of Rules & Records Office of Administration
Enclosure:
As stated APPENDIX 1
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Memorandum in Support of the Motion for a Further Hearing were delivermd by hand this 5th day of January, 1979, to the following:
Chase Stephens, Chief Docketing and Service Section Office of the Secretary of the Commission Nuclear Regulatory Commission Washington, D.C.
20555 Carlton R.
Stoiber, Esquire Assistant General Counsel Nuclear Regulatory Commission M
Washington, D.C.
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Irwin B.
Rothschild, III fv6
,c7 Office of the General Counsel
$l' Nuclear Regulatory Commission 2h b,b s.f.f@y Washington, D.C.
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and by mail, properly stamped and addressed, to:
Martin G.
Malsch, Esquire Office of the Executive Legal Director Nuclear Regulatory Commission Washington, D.C.
20555 Peter Tarnoff Executive Secretary Department of State Washington, D.C.
20520 Thomas S. Martin, Esquire Special Assistant to the Assistant Attorney General Department of Justice, Rocm 3143 Washington, D.C.
20530 Diane Wright Harmon Assistant to the Vice President Edlow International Company 1100 17th Street, N.W.
Washington, D.C.
20036
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e In the Matter of
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License No. XSNM-1222
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EDLCW INTERNATIONAL COMPANY
)
Docket No. 70-2738
)
(Agent for the Government of
)
India on Application to Export
)
Special Nuclear Fuel)
)
PETITIONERS' MOTION FOR EXTENSION OF TIME TO SUBMIT WRITTEN COMMENTS Petitioners, Natural Resources Defense Council, Inc., the Sierra Club, and the Union of Concerned Scientists hereby respect-fully move the Commission for an order extending their time to submit written comments in the above-captioned proceeding from-January 11, 1979 to January 25, 1979 (14 days), as well as the time for submission of reply comments from January 22, 1979 to February 1, 1979.
The arounds for this motion are more fullv set forth in the attached memorandum of points and authorities.
Respectfully submitted,
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CURTIS JAMEG N.
BARNES Mailing Address:
Center for Law and Social Policy 1751 N Street, N.W.
Washingtcn, D.C.
20036 (202) 872-0670 Attorneys for the Sierra Club, Union of Concerned Scientists, and NRDC
. THOMAS B.
STCEL, JR.
S. JACOB SCHERR Mailing Address:
Natural Resources Defense Council 917 15 th Street,
N.W.
Washington, D.C.
20003 (202) 737-5000 Attorneys for NRDC Dated:
January 5, 1979 Washington, D.C.
.