ML19343D348
| ML19343D348 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 04/16/1981 |
| From: | Cady G, Halterman H FRIENDS OF THE EARTH, HALTERMAN, H.L. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8105040328 | |
| Download: ML19343D348 (3) | |
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4/16/1981
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g NUCLEAR REGULATORY COMMISSION 19 8 / h BEFORE THE ATOMIC SAFETY AND LICENSING BOARD A
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GENERAL ELECTRIC COMPANY
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MOTION TO CONSOLIDATE THE INTERVENTIONS OF FRIENDS OF THE EARTH AND REP. RONALD V. DELLUMS 1.
Under the provisions of 10 C.F.R. g2.730, Intervenor Ronald V. Dellums, on his own behalf and on behalf of Congressmen John L. Burton and Philip Burton, moves the Board to consolidate their intervention with that of the Friends of the Earth.
Friends of the Earth joins in this motion.
2.
While Intervenors have previously filed many documents jointly, they have always maintained their separate identities.
This was to protect each of the Intervenors against the possibility that ther'! might arise some disagreement regarding strategy, tactics or basic facts underlying the case.
Now that discovery is completed and testimony is being prepared, it is apparent that Intervenors will rely upon the same witnesses, agree to the same factual bases and have no dispute regarding strategy or tactics during the remaining procedures of this case.
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Therefore, the reason for the Intervenors' earlier and continuing decision no longer remains.
3.
In the interest of minimizing costs and maximizing the efficient exchange l
l of information leading up to the hearing and facilitating the smooth operation of the evfdentiary hearing, it ts the posttion of Intervenors that this proposed consolidation is in the best interests of all parties and the PaoaFd, 95A
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It would allow for the submission of one set of testimony from Intervenors and would. provide that at the hearing Intervenors would not be duplicating cross-examination or otherwise adding to the burden of the Board and the Parties.
4.
Intervenor Dellums therefore moves, in conjunction with Intervenor Friends of the Earth, that the Board consolidate their Intervention for the remainder of this Show Cause proceeding and that the Board recognize that the consolidated Intervention would be under the direction of Glenn W. Cady, Esq., as lead counsel for all Intervenors who are parties to this proceding.
Intervenors further request that unless there is objection to this motion within five (5) days of its receipt that the Board issue an order, through the Chairman, telephonically to be followed up by written memorialization.
Respectfully submitted, Executed at:
Q Oakland, California H. Lee Halterman, Attorney for April 16, 1981 Intervenors Reps. Dellums, Burton and Burton
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Lafayette, California Glenn W. Cady, Attorney for April 17, 1981 Intervenors Friends of the Earth and l
Ms. Barbara Shockley i
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V UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION e
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g
In the Matter of
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DOCKET No. 50-70
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(Show Cause)
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CERTIFICATE OF SERVICE I hereby certify that copies of MOTION TO CONSOLIDATE THE INTLRW.NTIONS OF FRIEND 9 OF THE EARTH AND REPRESENTATIVE RONALD V. DELLUMS in the'above captioned proceeding have been served on the following by deposit in the United States mail, first class postage prepaid, or by personal service, this 29enty second day of April, 1981.
Herbert Grossman, Esq., Chair George Edgar, Esq.
Atomic Safety and Licensing Board MORGAN, LEWIS & BOCKIUS U.S. Nuclear Regulatory Comission 18G0 M Stteet, NW Washington, D.C.
20555 Washington, D.C.
20036 Mr. Gustave A; Linenberger, Judge Jed Somit, Esq.
Atomic Safety and Licensing Board 100 Bush Street, Suite 304 U.S. Nuclear Regulatory Cormiission San Francisco, CA 94104 Washington, D.C. 20555 Mr. Ken Wede,
Dr. George A. Ferguson 1735 New York' Avenue, NW, Room 503 School of Engineering Howard University Washington, D.C.
20006 2300 - 6th Street, NW Washington, DC 20059 Edward A. Firestone, Esq.
General Electric Company Richard G. Bachman, Esq.
Nuclear Energy Group U.S. Nuclear Regulatory Comission 175 Curtner Avenue Washington, D.C.
20555 San Jose, CA 95125 l
(Mail Code 822)
Ms. Barbara Shockley l
1890 Bockman Road The Honorable John L. Burton San Lorenzo, CA 94580 1714 Longworth House Office Building Washington, D.C.
20515' The Honorable Phillip Burton 2454 Rayburn House Office Building Atomic Safety and Licensing Board Panel Washington, D.C.
20515 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
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Glenn W. Cady, Esq.
l CARNIATO & D0DGE Atomic Safety and Licensing Appeal Panel 3708 *1t, Diablo Elyd.
U.S. Nuclear Regulate,ry Commission Lafayette; CA 94549 Washington, D.C.
2N55 Docketing and Service Section l
l Office of the Secretary Respectfully submitted, U.S. Nuclear Regulatory Commission Washington, D.C.
20555 jg H. Lee Halteman d
ar0akland, Calif Counsel for Intervenors DelltrLs, Burton
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and Burton