ML20115B989

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Motion for Leave to Reply.* Petitioners Can Be Prepared to Submit Reply by 960712.W/Certificate of Svc
ML20115B989
Person / Time
Site: Oyster Creek
Issue date: 07/02/1996
From: Decamp W, Gunter P, Katz D
AFFILIATION NOT ASSIGNED, CITIZENS AWARENESS NETWORK, NUCLEAR INFORMATION & RESOURCE SERVICE
To:
Atomic Safety and Licensing Board Panel
References
CON-#396-17738 OLA, NUDOCS 9607110124
Download: ML20115B989 (4)


Text

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UNITED STATESDECLVitRfdAE],W 00CKEilHG & i d6 NUCLEAR REGULATORY CDMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter bf

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)

General Public Utility Nuclear Corporation

) Docket 50-219 OLA

) Tech. Spec. 5.3.1.B

) Movement of Heavy Loads Over Ovster Creek Nuclear Generatina Station

)

Irradiated Fuel MOTION FOR LEAVE TO REPLY Pursuant to 10 CFR 2.730 petitioners Nuclear Information and Resource dervice, Oyster Creek Nuclear Watch, and Citizens Awareness Network respectfully make a motion for leave to reply to General Public Utility Nuclear Response (June 21,1996) and NRC Staff Response (June j

26,1996) In Opposition To Request For Hearing and Petition To Intervene of Nuclear Information and Resource Service, Oyster Creek Nuclear Watch, and Citizens Awareness 1

Network.

The petitioners argue that their petition to intervene dated June 6,1996 cannot be expected to anticipate the arguments and objections by the licensee and the staff. Therefore, the petitioners should have an opportunity to respond to all arguments calling for the dismissal of the petitioners. Houston Lighting and Power Co. (Allens Creek Nuclear Generating Station),

ALAB-565,10 NRC 521,525 (1979).

The NRC and GPUN have misinterpreted the petitioners' position as stated in the June 6, 1996 filing. Consequently, the NRC and GPUN have expressed opposition to the petitioners j

gaining standing in a matter deemed serious and worthy of a hearing.

Therefore, the petitioners respectfully request an opportunity to prepare a timely reply to the objections raised by GPUN and NRC staff. Because of the upcoming July 4th holiday, the petitioners can be prepared to submit a reply by July 12,1996.

9607110124 960702

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a Pitul Gunter'

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Nuclear Infonnation and Resource Service 142416th Street, N.W. Suite 404 Washington, DC 20036 (202)328-0002 (202)462-2183 FAX email pgunter@igc.apc.org

(/AfL dem J PG William decamp, Jr.

I Oyster Creek Nuclear Watch P.O. Box 243 l

-Island Heights, NJ 08732 i

-(908)714-0334 & (201)376-6639 email 102115.350l@compuserve.com

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[ / [df ITeborah Katz' Citizens Aw::renessNetwork P.O. Box 83 j

Shelburne Falls, MA 01370 (413)339-4374 (413)339-8768 FAX Dated July 2,- 1996 h

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DOCKETED July 2,199BSNRC

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h UNITED STATES OF AMERICA d5 NUCLEAR REGULATORY COMMISSION

% R -/ All :52 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD w. u Of SECRETARY 00CKETimi & SEgylcE In the Matter of

)

BRANCH

)

General Public Utility Nuclear Corporation

) Docket 50-219 OLA

) Tech. Spec. 5.3.1.B

) Movement ofHeavy Loads Over Oyster Creek Nuclear Generating Station

)

Irradiated Fuel CERTIFICATE OF SERVICE I hereby certify that copies of " Motion For Leave To Reply" for Nuclear Infbrmation and Resource Service, Oyster Creek Nuclear Watch and Citizens Awareness Network have been served by Facsimile Transmission and/or by U.S. Mail, first class on this date July 2,1996:

G. Paul Bollwerk, III, Chair

  • Office of the Sect:tary (3)*

d Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Attention: Docketing and Service Branch Washington, DC 20555 Dr. Peter S. Lam

  • Dr. Charles N. Kelber*

Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Adjudicatory File (2)

Ernest Blake, Jr.*

Atomic Safety and Licensing Board.

Shaw, Pittman, Potts, & Trowbridge U.S. Nuclear Regulatory Commission 2300 N. Street NW Washington, DC 20555 Washington, DC 20555 Ann P. Hodgdon, Esq.(1)*

Atomic Safety and Licensing Board Panel Office of General Counsel U.S. Nuclear Regulatory Commission l

U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Oflice of Commission Appellate Adjudication i

U.S. Nuclear Regulatory Commission Washington, DC 20555 4

Michael Laggert GPU Nuclear Corporation i Upper Pond Road Parsippany, NJ 07054 William decamp, Jr.

Oyster Creek Nuclear Watch P.O Box 243 Island Height, NJ 08732 Deborah Katz Citizens Awareness Network P.O Box 83 Shelburne Falls, MA 01370 l

Faul GuntYr Nuclear Information and Resource Service

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)

Willaim decamp, Jr.

Oyster Creek Nuclear Watch IPG Deborah Katz L)/

Citizens Awareness Network Dated July 2,1996

  • Certification of Service by Facsimile Transmission and U.S. Postal Service, First Class.

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