ML19339C038
| ML19339C038 | |
| Person / Time | |
|---|---|
| Site: | 07002909 |
| Issue date: | 11/09/1980 |
| From: | Allred D, Donelson C AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8011170210 | |
| Download: ML19339C038 (5) | |
Text
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UNITED STATES OF AMERICA I?07.,,,
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NUCLE AR REGULATORY COMNISSION BEFORE THE ATOMIC S AFETY AND LICENSING BCDDorg,,
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In the Matter of M
APPLICATION OF WESTINGHOUSE S 6 N* \\
ELECTRIC CORPORATION FOR A SPECIAL NUCLEAR MATERIAL DOCKET NO. 70-2909 LICENSE FOR THE ALABAMA NUCLEAR FUEL F ASRICATION PLANT ( ANFFP) TO BE LOCATED NEAR PRATTVILLE, ALABAMA JOINT MOTION FOR SUBSTITUJION OF NAMED INTERVENOR Come now Movants David L. Allred and Cathalynn Donelson and request the Atomic Safety and Licensing Board to permit the substitution of Cathalynn Donelson as the named inter-venor for David L. Allred with respect to all pleadings and matters heretofore filed and addressed by David L. Allred and as grounds therefor state as follows:
1.
David L. Allred and Cathalynn Donelson have jointly worked on all matters heretofore filed in this matter by David L. Allred.
2.
Cathalynn Donelse, has done much of the work with respect to research into and analysis of the application and environmental report which forms the basis for the croposed contentions heretofore filed by David L. Allred.
3.
The interests and concerns of Cathalynn Donelson have been incorporated into the proposed contentions of David L. N$j[j Allred at her sugaestion and with the aoproval of Donelson and Allred.
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4 The concerns and issues considered and set forth in the pleadings heretofore filed by David L. Allred are the result of joint research, analysis and discussion between Allred and Donelson.
5.
Cathalynn Donelson has not filed a petition for intervention heretofore in reliance on the petition and intervention of David L. Allred which adequately set forth her interests and conc 9tns.
In the absence of Allred's continued intervention and participation Donelson's interests and concerns will not be protected.
5.
David L. A llred must withdraw from participation in the instant proceedings for the fellowing reasons:
A.
Petitioner Allred is an Assistant United States Attorney whose case load has increased to the point that he can no longer devote sufficient time to the licensing precedure.
8.
Petitioner Allred, as a private individual, does not have sufficient monetary resources to continue his participation in the licensing procedure.
7.
David L. Allred and Cathalynn Qanelsen celieve that the intervention heretofore conducted under the name of David.
L. Allred can be successfully continued to the benefit of all parties and the public interest by Cathalynn Donelsen.
8.
If this motion is granted, Cathalynn Donelsen will voluntarily and knowingly assume the ocsitien of David L. Allred and step into his shoes with rescect to this matter.
Any disabilities, waivers or other steps taken by David L. Allred will be assumed by Cathalynn Donelson.
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9.
No prejudice to any party will result from the granting of this motion.
The best interests of all parties and the public will be advanced by'the granting of this motion.
WHEREFORE David L. Allred and Cathalynn Ocnelson respect-fully request that Cathalynn Donelson be permitted to under-taks the intervention heretofore conducted in the name of David L. Allred and that her name be substituted for his in this matter.
Respectfully submitted this the b
ay of November, d
1980 Asasb]A Of&e exu. A a~
MOVANTS,
VERIFICATION We, David L. Allred. and Cathalynn Donelson, believe the foregoing statements to be true and correct in every particular.
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STATE OF ALABAMA COUNTY OF MONTCOMERY Before me, the undersigned Notary Public, appeared Cathalynn Donelson and David L. Allred, known to me, who did sign the above Motion and Verification as testament that their statements in the foregoing are true and correct in every particular, on this the day of November, 1980.
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Wendy H. #11 red,'No tary 'Public State at Large Commission Expiration: 1984
E CERTIFICATE OF SERVICE l
I hereby certify that I have served a copy of the foregoing g
upon the fcilowing named parties by mailing the same to them on
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- OyeM /76r 198 O.
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, John T. Wolf, E sq., Chairman Dr. Martin J. Steindler, Member p-F
' Atomic Safety & Licensing Od.
Atomic Safety & Licensing Bd.
3409 Shepherd Stree t Argonne National Laboratory Chevy Cb _ se, MD 20015 9700 South Cass Avenua-Argonne, IL 60439 Dr. Harry Foreman, Zember Atomic Safety and Licensing Bd.
Barton Z. Cowan, Esq.
Box 395, Jayo Eckert, Seamans, Cherin & Mellot Univ. of Minnesota 42nd Floor Minneapolis, MN 55455 600 Grant Streat Pittsburgh, PA 15219 Donald R. Xarcucci, Esq.
- Law Dept.
Docketing & Service Section
- Westinghouse Electric Corp.
Office of the Secretary I P. O..: o x 355 U. S. Nuclear Regulatory Comm.
lPittsburgh,PA 15230 Washington, DC 20555 i: Julian L. 7:cPhi_ lips, Jr., Esq.
Sherwin Turk, Esq.
iP. O. Box 54 Legal Staff
- 516 South perry S tree t U. S. Nuclear Regulatory Comm.
Montgomery, AL 35101 Washington, D.C. 20555 Dr. Ira L. Myers, M.D.
Atomic Saf ety & Licansing Sd. Panel S tats ' Health Of ficer U. S. Nuclear Regulatory Comm.
State of Alabama Washington, DC 20555 Dept. of Puolic Health S tata Of fice Euilding Atomic Saf ety 1 Licensing Appeal Panel Montg:mery, AL 35104 U. S. Nuclear Regulatory Comm.
F Washington, DC 20555 f
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