ML20136G419
| ML20136G419 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 03/14/1997 |
| From: | Walker N CITIZENS AGAINST NUCLEAR TRASH, SIERRA CLUB LEGAL DEFENSE FUND, INC. |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#197-18213 91-641-02-ML, 91-641-2-ML, LBP-96-25, ML, NUDOCS 9703180036 | |
| Download: ML20136G419 (6) | |
Text
-
.~ _
03/14/97 16:44 015045667242 SCLDF
@u02
, MH3 00CKETED 1
USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'97 MAR 17 A7:52 BEFORE THE COMMISSION 0FFICE OF SECRETARY i
00CKETlHG & SERVICE BRANCH
)
Docket No. 70-3070 ML In the Matter of
)
)
ASLBP No. 91-641-02-ML LOUISIANA ENERGY SERVICES, L.P.
)
)
(Special Nuclear l
(Claiborne Enrichment Center)
)
Materials License)
)
)
March 14,1997 OPPOSITION OF TNTERVENOR. CITIZENS AGAINST NUCLEAR TRASH.
TO THE MOTION BY THE NUCLEAR ENt.KGY INSurOTE FOR LEAVE TO FILE AMICUS BRIEF ON REVIEW OF LBP-96-_25 1
i Citizens Against Nuclear Trash (" CANT") opposes the motion by the Nuclear Energy Institute ("NE1") for leave to file an amicus brief in this matter. Pursuant to 10 C 4
2.715(d) it is entirely within the discretion of the Commission to deny NEl's motion, and the s
Commission should do so.
NEI states no persuasive reasons for its motion. The applicant in this matter, Ieuisiana Energy Seivices, L.P. ("LES"), is adequately represented by two large law firms with significan resources that are clearly capable of addressing the " legal errors" upon which NEI alleges that the Board's decision is based. Therefore, requiring CANT to respond to yet another entity's brief in this matter would be unduly burdensome and an unreasonable drain on CANT's extrs'mely limited resources.
Accordingly, CANT respectfully requests that the Commission deny the motion by NEI.
In the alternative, CANT requests that it be given sufficient time to respond to the NEI brief 9703180036 970314 (O
PDR ADOCK 07003070 C
03/14/97 16:44 Q1304s067242 SCLDF
@oo3 1
1 during a period of time when CANT is not responding to any pleadings filed by the parties in this matter.1 3
Respectfully submitted, l
Nathalie M. Walker SIERRA CLUB LEGAL DEFENSE FUND, INC.
400 Magazine Street, Suite 401 New Orleans, Louisiana 70130 Telephone: (504) 522-1394 Diane Curran HARMON, CURRAN, AND SPIELBERG l
2001 "S" Street N.W., Suite 430 Washington, D.C. 20009 Telephone: Q202) 328-3500 h
By:
Nathalie M. Walker Attorneys for Intervenor, Citizens Against Nuclear Trash i
4 s
.s The Licensing Board issued another partial initial decision (LBP-97-3) adverse to LES a
in this matter on March 7,1997, and CANT fully expects that LES and the NRC Staff will file petitions for review to which, of course, CANT will be required to respond.
2
03/14/97 16:44 C1904s667242 SCLDF
@oo4 DOCKETED UhTIED STATES OF AMERICA NUCLEAR REGULATORY COhBIISSION 97 tiAR 17 A7 :52 BEFORE THE COMMISSION OFFICE OF SECRETARY 00CKETl!4G & SERVICE BRANCH
)
Docket No. 70-3070-ML In the Matter of
)
)
ASLBP No. 91-641-02-ML LOUISIANA ENERGY SERVICES, L.P.
)
)
(Special Nuclear (Claiborne Enrichment Center)
)
Materials License)
)
J
)
March 14,1997 CERTIFICATE OF SERVICE i
i l
I hereby certify that copies of the " Opposition of Intervenor, Citizens Against Nuclear 4
Trash, To The Motion By The Nuclear Energy Institute For Leave To File Andcus Brief On Review of LBP-96 25" have been served on this 14th day of March,1997, as follows:
Shirley Ann Jackson, Chairman By first class mail U.S. Nuclear Regulatory Commission and facsimile Washington, D.C. 20555 1 copy Kenneth C. Rogers, Commissioner By first class mail U.S. Nuclear Regulatory Commission and facsimile Washington, D.C. 20555 1 copy Greta J. Dicus, Commissioner By first class mail U.S. Nuclear Regulatory Commission and facsimile Washington, D.C. 20555 1 copy Nils J. Diaz, Commissioner By first class mail U.S. Nuclear Regulatory Commission and facsimile Washington, D.C. 20555 1 copy Edward McGaffigan, Jr., Commissioner By first class mail U.S. Nuclear Regulatory Commission and facsimile Washington, D.C. 20555 1 copy I
03/14/97 16:45 015045667242 SCLLF
@oos Administrative Judge By first class mail Thomas S. Moore, Chairman and facsimile Atomic Safety and Licensing Board 1 copy U.S. Nuclur Regulatory Commission Washington, D.C. 20555 Administrative Judge By first class mail Richard F. Cole and facsimile Atomic Safety and Licensing Board 1 copy U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Administrative Judge By first class mail Frederick J. Shon and facsimile Atomic Safety and Licensing Board Icopy U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Secretary of the Commission By first class mail U.S. Nuclear Regulatory Commission and facsimile Washington, D.C. 20555 original plus 2 copies Attention: Chief, Docketing and Service Section Office of Commission Appellate By first class mail and facsimile Adjudication U.S. Nuclear Regulatory Commission 1 copy Washington, D.C. 20555 Eugene Holler, Esq.
By first class mail Office of the General Counsel and facsimile U.S. Nuclear Regulatory Commission 1 copy Washington, D.C. 20555 Joseph DiStefano By first class mail Quinn, Racusin & Gauola 1 copy 1401 H Street, N.W.
Suite 510 Washington, D.C. 20005 l
2
03/14/97 16:45 015045667242 SCLDF
@ 006 Robert G. Morgan - WC26B By first class mall Licensing Manager 1 copy l
Duke Engineering & Services, Inc.
400 South Tryon Street
)
Charlotte, NC 28201-1004 Marcus A. Rowden By first class mail Fried, Frank, Harris, Shriver and facsimile
& Jacobsen Icopy 1101 Pennsylvania Avenue, N.W.
Suite 900 South Washington, D.C. 20004 Diane Curran By first class mail Harmon Curran & Spielberg and facsimile 2001 S St NW Suite 430 1 copy Washington, DC 20009 Ronald Wascom, Deputy Asst. Sec.
By first class mail Louisiana Dept. of Enytl. Quality 1 copy Office of Air Quality & Radiation Protection P.O. Box 82135 Baton Rouge, LA 70884-2135 J. Michael McGarry, III By first class mail Winston & Strawn and facsimile 1400 L Street, N.W.
1 copy Washington, D.C. 20005 Adjudicatory File By first class mail Atomic Safety & Licensing Bd. Panel and facsimile U.S. Nuclear Regulatory Commission 1 copy Washington, D.C. 20555 Robert W. Bishop By first class mail and facsimile Nuclear Energy Institute 17761 I Street, N.W.
Icopy Washington, D.C. 20006 3
03,'14/97 16:46 CISO45667242 SCLDF id ou7
)
Jay E. Silbcrg By first class mail Shaw, Pittman, Potts & Trowbridge and facsimlie 2300 N Street, N.W.
Icopy Washington, D.C. 20037 Nahalie M. Walker SIERRA CLUB LEGAL DEFENSE FUND, INC.
Attorneys for Intervenor, Citizens Against Nuclear Trash l
l
/
bomer\\ amicus.1 4
.