ML20148D452
| ML20148D452 | |
| Person / Time | |
|---|---|
| Site: | 07002909 |
| Issue date: | 10/01/1980 |
| From: | Allred D AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20148D453 | List: |
| References | |
| NUDOCS 8010080280 | |
| Download: ML20148D452 (5) | |
Text
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10/1/80 o
6 gI,.4 g% cj UNITED STATES CF lE:ICA g,
g NUCLEAR REGULATC9V --'!S S ION
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.g BEFORE THE ATOMIC S AFE TY A '. C _
- C E N_S I NG 80 ARChl, In the Matter of-s APPLICATION OF WESTINGHOUSE ELECT::~.
CORPCRATION FOR A SPECIAL NUCLEAR NATERIAL LICENSE FOR THE AL A8 Air A Docket No. 70-2909 NUCLE AR FUEL FAGRICATION PLANT (A'.r s
TO BE LOCATED NEA8 PRATTVILLE, AL:5;"A MEMORANOUM IN SUPPORT Cr mE00EST TO FILE ADDITIONAL CC'TEs:TIONS Comes now David L.
Allred sn
- ecuests permission to file additional contentions and in sup:::: tnereof states as follows:
1.
I am employed as an Assista-: United States Attorney in Montgomery, Alabama, and my res:: sibilitien are primarily in the preparation and prosecutior :r criminal cases.
Since t
the.Tarch,1980, Scoping Hearing hel: 1-Orattville, Alabama, I have been engaged in the preparet':- and trial of several complex fraud cassa.
Addi tiona lly, : nave conducted four federal grand jury sassions and are:ared and argued two cases before the Court of App 9als for the ri'th Circuit.
I have oursued the instant matter strictly es a oriva te citizen and all c' y eft:::s (with the exceot::- Of anou;ering and rosaand-r in; t:
'3.C Sta ' telephone calls) 2.e :een conducted after work and an weekands.
Unlike ever; :; or carty tc theso i
or ceedings I have not been able t: s :loy a legal representa-i tive to assist me nor have I been 3:.e t0 use the normal xorL-I day to study the materials crecare- :<
2.e s t i n c h n u s e, to examina 4
the various rules, regulations, ar: :ccisione of tha NaC, or s,
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Tills DOCUMENT CONTAINS Nh8 3
P00R QUAUTY PAGES d
S91008o 2%
page Two
.to prepare petitions and moticns.-ich I have submitted.
In short, although every other carty :: these croceedings has e
participated in such proceedings :, a caid legal representative whose job is to participate, I be.e done so strictly as a concerned and interested citizen.
I simply have not had the
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time or other resources necessary :: meet the various deadlines.
2.
Although the NRC Staf f ras graciously referred to me as "an experienced attorney" (NRC 5taff's Response to Motions for an Extension of Time In Whien :: file Valid Contentions l
Filed By petitioners David L. Allre: And Safe Energy Alliance 8
of Central Alabama, Inc., da te d 3/14 /20, a t 6.),
such experience, as stated above, as been limitec :: :he crosecution of federal crimes in the Middle District of Ale:ama.
I have no experience I
whatsoever in the area of adminis;rative or civil proceedings.
1 My lack of 6xperience and unfamiliarity with the subject j
licensing procedure is absolute.
re only guidance in such
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matters which I have received ca e ' rom the.NRC Staff counsol (for which I en gratef ul) and the sexolicated language of the Code of Federal 9egulations.
l 3.
The Pra ttville Library. sre the reading room for this matter is located is open from E:::
3.m.
until 5:00 p.m.,
- Monday, Wednesday, anc Triday; 8:00 a.m.
_ til 3:00 a.m. on Tucscay and Thursday; and 10:00 a.m. u n t i '. ::CC o.m.
on Saturday; l
the llorary is closed on Sunday.
e lirrary is also a 30 minute (one way) drive from my r e s. : e.,: e in Mcotgomery.
Since the library is the only source :' :s license coplica tion and i
s.
c i.
page"Three related. materials, I have had a vary li.ited occortunity to examins such materials.
Indeed, gi.s-the freauent necessity
.of working on weekends at my job, I eve not hao real access to the-materials.
4 The ma terials provided by 'te stinghouse in response to.:he NRC Staf f meeting were. unava.'.3:le to me until August 25, 1960.
(SEE Letter to John Wolf, Eso.,et al. from Barton Cowan datec August 25, 1980).
Those materials are almost as voluminous as the original E nvironmental Report
. filed by Westinghouse and contain c:nsiderable additiona}
inf ormatior concerning the environmental imoact of the proposed facility.
Of course, the previous uravailability crevented the making of any contentions with respect thereto.
5.
Granting my request to file additional contentions will not significantly delay the lice 9 sing orecedura.
The parties, with the Scard's tentative a:crcval as set forth in the Scard's Order of Septec5er 11. 1920, have already l
established a schedule for conferrin; :n additional contentions.
The 2:ard is also orecaring for anct er cre-hearing conf erence to be held after the i nformal ecnfers :e between the carties.
J t
That cre-hearing conference will n:t :e relaved by the granting of this request.
5.
I fully expect my contenti: :- to identify issues of concern to the residents of Centre'. A13 cama as well as the J
NRC and Westinghouse.
Xy contenti s a ll be soecific and my participation in future proceedings. 11 assic; the NRC in i
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Page four l
reaching sound dec.sions.
I subti. that my interests in being-a_ participant in tns-licensing pr::ccure are these.of'a private citizen who will live, with his 'e
.ly, in the vicinity of the proposed facility.
7.-
TheEcontentions which I s.rmit will not he presented by. any other party to these procee:ings and to the extent such cententions may be raised by other-carties I will withdraw Same.
8.
For-the-foregoing reasons I renpectfully ask that my request for an extension of time ts granted.
Resce::'ully submitted this the 1st ca/ of October, 1980.
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Devic.. Allred 231 Cnx f orest Drive Mont;: ery, Alabama 35109 l
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CERTIFICATE OF SE:. ICE I_hereby certify that I have ssrved a copy of the foregoing upon the following named parties by alling the same to them on this the
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day of d[A/W4 198 d.
John F. Wolf, E sq., Chairman Dr.vartin J. Steindler, Member Atomic'Sefety & Licensing Bd.-
At:mic Safety & Licensing Sd.
3409 Shepherd Stree t Ar;cnne -National Laboratory Chevy Chase, MD 2C015 97;3 South Cass Avenue Ar;cnne, IL 60439 Dr. Hcrry Foreman, irember Atcmic Safety and Licensing Bd.
E ar ten Z. Cowan, E sq.
Box 395, Mayo Ec<ert, Seamans, Cherin & Mellot Univ. of Minnesota 42nc Flocr Minneapolis, MN 55455 6C; Crant Street
- i
- *.sburgh, PA 15219 Donald R. Marcucci, E sq.
Law Dept.
Oc:'<eting & Service Section Westinghouse Electric Corp.
Of# ice of the Sectecary P. O. Box 3S5 U.
- 5. Nuclear Regulatory Comm.
Pittsburgh, PA 15230 1ashington, DC 20555 Julian L. McPhillios, Jr., Esq.
Sherwin Turk, Esq.
P. O. Box 64 Le;a! Staf f 516 South cerry 5treet-L.
- 5. Nuclear Regulatory Comm.
Montgomeru AL 351C1
'ia sning ton, D.C.
20555 Dr. Ira Jyers, M.D.
At:mic Safety & Licensing 5d. Panel State Ht
- h Cfficer L. 5. Nuclear Regul' tory Comm.
a State of ilebara Aa smington, DC 20555 Dept. Of Publi: Health State Office 5;ilding A :-i; Safety & Licensing Appeal Panel Montg:mery, AL 26104 L. 5. Nuclear Regulatory Corr.i.
..a
-ington, DC 20555 n> /
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