ML19274F284
| ML19274F284 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/01/1979 |
| From: | Larry Jones GILLESPIE & JONES |
| To: | |
| References | |
| NUDOCS 7907130114 | |
| Download: ML19274F284 (5) | |
Text
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g,y 3 UNITED STATES OF AMERICA 7
II NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY & LICENSING BO ARD
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In the Matter of LOUISIANA POWER & LIGHT COMPANY Docket No. 50-382 (Waterford Steam Electric Station Operating License Unit 3)
Application MOTION BY INTERVENORS TO DISPENSE WITH PART 2.708(D)
FILING REQUIREMENTS Now before the Atomic Safety and Licensing Board in the above captioned and numbered matter come Oystershell Alliance, Inc. (Oystershell) and Save Our Wetlands, Inc. (SOWL) and respectfully mov3 this Honorable Board for an order relieving them from the provisions of Section 2.708(D) which require the filing of the original and twenty (20) copies with the Nuclear Regulatory Commission as to each " pleading or other document other than correspondence", for the following reasons:
1.
The joint petitleners are citizens groups with extremely limited funds and resources; and it is an undue burden on the joint petitioners both in terms of reproduction costs and Dostage costs to require that the joint petitioners be required to provide the Nuclear Regulatory Commission, as an agency of the United States Government, with as many as twenty (20) copies of joint petitioners pleading # and related documents.
2.
The granting of this order would in no way relieve joint petitioners of their obligation to provide individual copies of pleadings and other documents filed in connection with these proceedings to all members of the Safety and Licensing Board, all counsel of record, and any other specific individuals whom the Board may direct joint petitioners to serve with copies 7 9071 ft N\\i
of pleadings and other documents.
3.
The role of intervenors can be served better by Oystershell and SOWL if they are not faced with the burden of providing such large numbers of copies.
Respec+ ully Su t
d, BY j
Y. AN L. /0
, JR.
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Security mestea Idg.
4 00 Veteran Mem.B1d.
Metairie, Louisiana 7 02 (504) 885-5672 Counsel for Joint Petitioners e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of LOUISIANA POWER AND LIGliT COMPANY DOCKET NO. 50-382 (Waterford Steam Electric Station Unit 3)
CERTIFICATE OF SERVICE f
,1979, I mailed copies of Save I hereby certify that on e
Our Wetlands, Inc. anu Oystershell Alliance, Inc.'s Motion by Intervenors to Dispense With Part 2.708(D) Filing Requirements to all individuals or entities a
in th appearing on the attached Service List, postage paid, firs United States Mail.
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Sheldon J. Wolfe, Esquire U.S. Nuclear Regulatory, Commission Atomic Safety and Licensing Board Panel Washington, D. C.
20555 Dr. IIarry Foreman Box 395, Mayo University of Minnesota 55455 Dr. Walter II. Jordan 881 West Outer Drive Oak Ridge, Tennessee 37830 Chairman, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Chairman, Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D. C.
20555 IIenry J. McGurren, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D. C.
20555 George F. Trowbridge, Esquire
& Alan Yuspeh, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N. W.
' Washington, D. C.
20036 W. Malcolm Stevenson, Esquire Monroe & Lemann Whitney Building 625 Gravier Street New Orleans, Louisiana 70112 Stephen Irving, Esquire One American Place, Suite 1601 Baton Rouge, Louisiana 70825
.