ML20030B886

Requests to Be Excused from Participation in Oral Argument Scheduled for 810901.Issues Have Been Joined & Briefed & Oral Argument Is Not Essential.Request Partially Due to Budgetary Restraints

ML20030B886
Person / Time
Site:	05000471
Issue date:	08/18/1981
From:	Hermann H HERRMANN, H., MASSACHUSETTS WILDLIFE FEDERATION
To:	Buck J, Kohl C, Moore T NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 8108250102
Download: ML20030B886 (2)

Text

HENRY HERRMANN ATTORNEY AT LAW 50 CONGRESS STREET (1045)

BOSTON. MASSACHUEETTS C2109 (6178 423 6096

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<s Moore, Chairman 6'

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Dr. John II.

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Christine N. Kohl, Equire Atomic Safety and Licensing 8, E8 Naame }

Appeal Board

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U.S. Nuclear Regulatory CommissfQQ'f-

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Re:

Boston Edison Company et al.

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(Pilgrim Nuclear Generating

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Station, Unit 2)

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Docket No. 50-471 f

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L' Order dated August 10, 1981 To the Chairman and Members of the Atomic Safety and Licensing Appeal Board:

The Massachusetts Wildlife Federation ("MWF"), an Intervenor in the above-captioned proceeding, respectfully requests to be excused from participation in oral argument on appeal currently scheduled by the Board for September 1, 1981 (irrespective of any adjournments granted pursuant to Applicant's motion).

The'MWF has already extensively briefed the basis for its exceptions filed with this Board.

Neither the Applicant nor the Regulatory Staff have responded to the substantive arguments of the MWF's brief but have restricted themselves to merely alleging, in cursory fashion, that the MWF's exceptions constitute.an attack on a Commission' Regulation The MWF had already which is procedurally impermissible.

anticipated that position in its brief and had argued that

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it is unsound.

Accordingly, unless the Board, in its dis'cretion, re-

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the MWF respectfully quires oral argument on this issue, submits that the issues have been joined and briefed and oral argument is not essential.

We further make this request

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I 8109250102 810G10 PDR ADOCK 05000471

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August 18, 1981 because of the budgetary restraints on the MWF and the j

fact that travel to Washington would pose a burden to MWF's counsel because of the effects of a back injury.

I Respectfully, LL numl HH/lpn Henry Her'mann

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Attorney for the Massachusetts Wildlife Federation cc:

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