ML19340D088
| ML19340D088 | |
| Person / Time | |
|---|---|
| Site: | 07002909 |
| Issue date: | 12/05/1980 |
| From: | Mcphillips J SAFE ENERGY ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8012290041 | |
| Download: ML19340D088 (2) | |
Text
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UNITED STATES OF AMERICA N,.
NUCLEAR REGULATORY COMMISSION 0
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4 1n BEFORE THE ATOMIC SAFETY AND LICENSING BOARDC der /4 a
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8 In the Matter of c,
APPLICATION OF WESTINGHOUSE ELECTRIC
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CORPORATION FOR A SPECIAL NUCLEAR
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MATERIAL LICENSE FOR THE ALABAMA
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DOCKET NO. 70-2909 NUCLEAR FUEL FABRICATION PLANT (ANFFP)
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TO BE LOCATED NEAR PRATTVILLE, ALABAMA
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RESPONSE OF SEACA TO JOIN" MOTION FOR SUBSTITUTION OF CATHALYNN DONELSON FOR DAVID ALLRED OF NAMED INTERVENOR Comes now the intervenor Safe Energy Alliance of Central Alabama (SEACA) and hereby represents that it supports fully the Petition for Leave to Intervene dated November 10, 1980 filed by Cathalynn Donelson and the simultaneous Joint Motion for Sub-stitution of Named Intervenor filed by Ms. Donelson and petitioner David Allred.
As grounds therefore, SEACA shows unto this Honorable Commission the following:
1.
SEACA hereby adopts the reasons stated by petitioners Donelson and Allred, the same as if more fully stated herein.
l 2.
SEACA also hereby adopts the reasons in support of said 1
substitution stated in NRC Staff's Response to Joint Motion for l
Substitution of Named Intervenor dated December 1, 1980, the same as if more fully stated herein.
l WHEREFORE, premises considered, SEACA hereby prays that this Honorable Commission will grant the Petition for Leave to Inter-vene filed by Cathalynn Donelson and the Joint Motion for substitu-tion of Named Intervenor filed by Ms. Donelson and petitioner m,
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Respectfully submitted,; g g
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E SAFE ENERGY ALLIANCE OF 'W JJ -
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CENTRAL ALABAMA, INC.
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W.ian L.
McPhillips', Jr.
P.O. Box 64 Montgomery, Alabama 36101 CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the foregoing j
upon the following named parties by mailing the same to them on this the M day of N c d.>->
1980.
Donald R.
Marcucci, Esq.
John F. Wolf, Esq., Chairman Atomic Safety and Licensing Board Law Dept.
Westinghouse Electric Corp.
3409 Shepherd Street Chevy Chase, MD 20015 P.O. Box 355 Pittsburgh, PA 15230 Dr. Harry Foreman, Member Atomic Safety and Licensing Board Sherwin Turk Legal Staff Box 395, Mayo U.S.
Nuclear Reg. Comm.
University of Minnesota Minneapolis, MN 55455 Washington, D.C.
Dr. Martin J.
Steindler, Member David L. Allred, Esq.
Atomic Safety and Licensing Board 231 Oak Forest Drive Argonne National Laboratory Montgomery, Alabama 36109 9700 South Cass Ave.
Argonne, IL 60439 Dr. Ira L. Myers, M.D.
State Health Officer Atomic Safety and Licensing Board State of Alabama Panel (2)
Dept. of Public Health State Office Bldg.
0 U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Montgomery, Alabama 36104 1
Atomic Safety and Licensing Docketing and Service Section Office of the Secretary Appeal Panel U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Washington, D.C.
20555 Bart Cowan Eckert, Seamans Cherin & Mellott
, d = WMw //r h Forty-Second Floor Juli'an McPhillips 600 Grant Street Pittsburgh, PA 15219 i
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