ML19340D155

Answer in Opposition to Dl Allred 801110 Motion for Substitution of Named Intervenor Unless Viewed as Request for Withdrawal.Certificate of Svc Encl

ML19340D155
Person / Time
Site:	07002909
Issue date:	11/24/1980
From:	Cowan B, Kenrick J, Marcucci D ECKERT, SEAMANS, CHERIN & MELLOTT, WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:
References
NUDOCS 8012290206
Download: ML19340D155 (4)

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UNITED STATES OF AMERICA

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of WESTINGHOUSE ELECTRIC CORPORATION Docke t No. 70-2909 (Alabama Nuclear Fuel Fabrication Plant Special Nuclear Material License)

ANSWER OF WESTINGHOUSE ELECTRIC CORPORATION TO JOINT MOTION FOR SUBSTITUTION OF NAMED INTERVENOR Wesuinghouse Electric Corporation (" Westinghouse")

files this Answer in response to a Joint Motion for Substi-tution of Named Intervenor (th.e " Substitution Motion")

dated November 10, 1980, filed by David L. Allred ("Allred")

and Cathalynn Donelson ("Donelson").

Westinghouse believes that with respect to Donelson the Substitution Motion raises the same issues as the untimely Petition for Leave to Inter-vene (the " Intervention Petition") filed by Donelson on November 10, 1980.

Accordingly, with respect to Donelson I

ygb3 the response of Westinghouse to the Substitution Motion is 3

included in the Answer of Westinghouse Electric Corporation 1[I l

to Petition for Leave to Intervene of Cathalynn Donelson l

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(the " Westinghouse Answer") filed simultaneously herewith.

l Tr*"* (7) l g6 8012290 166 L

As noted in that Westinghouse Answer, Westinghouse opposes the Donelson Intervention Petition and the attempt to sub-stitute Donelson for Allred as a participant in this pro-ceeding.

With respect to Allred, Westinghouse interprets the Substitution Motion as a motion by Allred to withdraw from all participation in the instant proceeding.

Westing-house does not object to such withdrawal.

Respectfully submitted,

/s/ Barton Z. Cowan

/s/ John R. Kenrick/BZC Eckert, Seamans, Cherin & Mellott

/s/ Donald R. Marcucci/BZC Law Department Westinghouse Electric Corporation Counsel for Westinghouse Electric Corporation Dated:

November 24, 1980..

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of WESTINGHOUSE ELECTRIC CORPORATION Docket No. 70-2909 (Alabama Nuclear Fuel Fabrication Plant Special Nuclear Materia' License)

CERTIFICATE OF SERVICE I hereby certify that copies of the " Answer of Westinghouse Electric Corporation to Joint Motion for Substitution of Named Intervenor" were served upon the persons listed on Attachment 1 to this Certificate of Service by deposit in the United States Mail (First Class), postage prepaid, this 24 th day of November, 1980.

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/s/ Barton Z. Cowan Barton Z. Cowan Counsel for Westinghouse Electric Corporation i

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e ATTACHMENT 1 John F. Wolf, Esquire, Chairman Ms. Cathalynn Donelson Atomic Safety and Licensing Board 855 Park Avenue U.S. Nuclear Regulatory Commission Montgomery, Alabama 36106 3409 Shepherd Street Chevy Chase, Maryland 20015 Dr. Ira L. Myers State Health Officer Dr. Harry Foreman, Member State of Alabama Atomic Safety and Licensing Board Department of Public Health Box 395, Mayo State Office Building University of Minnesota Montgomery, Alabama 36104 Minneapolis, Minnesota 55455 Atomic Safety and Licensing Board Panel Dr. Martin J. Steindler, Member U.

S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, D.

C.

20555 Argonne National Laboratory 9700 South Cass Avenue Atomic Safety and Licensing Appeal Panel Argonne, Illinois 60439 U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Barton Z. Cowan, Esquire Eckert, Seamans, Cherin & Mellott Docketing & Service Section 42nd Floor, 600 Grant Street Office of the Secretary Pittsburgh, Pennsylvania 15219 U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Donald R. Marcucci, Esquire Law Department Westinghouse Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230 Julian L. McPhillips, Jr., Esquire i

P.O. Box 64 516 South Perry Street Montgomery Alabama 36101

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Sherwin E. Turk, Esquire i

Office of the Executive Legal l

Director U. S.

Nuclear Regulatory Commission.

Washington, D. C.

20555 David L. Allred, Esquire 231 Oak Forest Drive Montgomery, Alabama 36109 l

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