ML19327A331
| ML19327A331 | |
| Person / Time | |
|---|---|
| Site: | 07002909 |
| Issue date: | 07/30/1980 |
| From: | Mcphillips J SAFE ENERGY ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8008060019 | |
| Download: ML19327A331 (2) | |
Text
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,P NUCLEAR REGULATCRY COMMISSICN AUG 4 500 > ~
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3EFORE THE ATCMIC SAF'TY AND LICENSING BOARD f*]
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APPLICATION OF WESTINGHOUSE S
ELECTRIC CCRPCRATICN FCP A SPECIAL NUCLEAR MATERIAL S
DCCKET NC.
70-2909 LICENSE FCR THE ALA3AMA NUCLEAR FUEL FABRICATICN 5
PLANT (ANFFP) TO BE LOCATED NEAR PRATTV!LLE, ALABAMA S
I MCTICN FOR AN EXTENSION OF TIME IN WHICH TO FILE VALID CCNTENTIONS Comes now the intervenor Safe Energy Alliance of Central Alabama, Inc. (hereinaf ter "SEACA") and by and thrcugh its attorney Julian McPhillips moves the Atcmic Safety & Licensing Board for a 60 day extension of time in which to file valid contentions in connertion with SEACA's petition to intervene. As grounds there-fore, SEACA shows unto this court the following:
1.
On July 10, 1980 SEACA served Interrogatories on Westinghouse Electric Corporation (hereinafter "Westin7 house").
In a conference call of July 17, 19 80, attorney 3 art Crum acknowlefged receipt of the Interrogatories and said he would serve Answers on SEACA. As of this July 31, 1980, SEACA has yet to receive any Answers from Westinghouse. SEACA believes the Answers to said Interrogatories would furnish information that would become the basis of additional valid contentions.
2.
SEACA presently is receiving the assistance of several scientists, including Or. Edward Passerini, Dr. Louis Williams, Dr. Carl Morgan, Dr. John Hamilton, Mr. Greg Minor and others.
SEACA has yet to receive valuable information, analyses, and reports from these scientists which would be essential in framing valid contentions.
3.
SEACA has yet to receive the all-important Snvironmental Impact Statement and therefore is severely limited in critically analyzing the pr: posed Alabama Muclear Fuel Fabrication plant,
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- its only source of information as to the specificatter.s of a plant using this process is Westinghouse's own, self-serving M
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document, euphemistically called "The Environmental Report."
WHEREFORE, premises censidered, SEACA moves the Atomic Safety
& Licensing Board for a 60 day extension of time in which to file valid contentions in connection with SEACA's petition to intervene.
Respectfully submitted, SEACA Sv 0 }~
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Jglian McPhillips P.O. Box 64 i
Montgomery, Ala.
36101 CER'"IFICATE CT SERVICE I hereby certify that I have served a copy of the foregoing upon the fellowing named parties by mailing the same to them on
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this the JL day of
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19*0.
5 John F. Wolf, Esq., Chairman Donald R. Marcucci, Esq.
Atomic Safety and Licensing Board Law Dept.
3409 Shepherd Street Westinghouse Electric Corp.
Chevy Chase, MD 20015 P.O. Box 355 Pittsburgh, ?A 15230 Dr. Harry Foreman, Member Atomic Safety and Licensing Board Sherwin "*urk Box 395, Mayo Legal Staff University of Minnesota U.S. Nuclear Reg. Ocrt.
Minneapolis, MN 55455 Washington, D.C.
Dr. Martin J. Steindler, Member David L. Allred, Esq.
Atomic Safety and Licensing Board 231 Cak Forest Drive Argenne National Laboratory Montgomery, Ala.
36109 9700 South Cass Ave.
Argonne, IL 60439 Dr. Ira L. Myers, M.D.
State Health Officer Atemic Safety and Licensing Board State of Alabama Panel Dept. of Public Health U.S. Nuclear Regulatory Commission State Office Blfg.
Washington, DC 20555 Montgomery, Ala.
36104 Atomic Saf ety and Licensing Appeal Docketing and Service Section Panel Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, D.C.
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