ML20148P673
| ML20148P673 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 06/05/1997 |
| From: | Curran D, Walker N HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., SIERRA CLUB LEGAL DEFENSE FUND, INC. |
| To: | Diaz N, Dicus G, Shirley Ann Jackson, Mcgaffigan E, Rogers K, The Chairman NRC COMMISSION (OCM) |
| References | |
| CON-#397-18361 08-814, 8-814, LBP-97-08, LBP-97-8, ML, NUDOCS 9707030010 | |
| Download: ML20148P673 (4) | |
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BRANCH June 5, 1997 4
Ref: 08-814 Shirley Ann Jackson, Chairman Kenneth C. Rogers, Commissioner Greta J.
Dicus, Commissioner l
Nils J.
Diaz, Commissioner Edward McGaffigan, Jr., Commissioner U.S. Nuclear Regulatory Commission Washington, D.C.
20555 RE:
In the Matter of Louisiana Enerav Services, Docket No. 70-3070-ML
Dear Chairman and Commissioners:
Enclosed is the Answer of Citizens Against Nuclear Trash
(" CANT") to the petitions for Commission review of LBP-97-8 filed by Louisiana Energy Services ("LES") and the NRC Staff.
This Answer is within the a*lowable combined total of 20 pages for responding to both petitions.
(Also enclosed is the " Opposition of Citizens Against Nuclear Trash To The Motion By The Nuclear Energy Institute For Leave To File Amicus Answer To Petition By Applicant Louisiana Energy Services For Review Of LBP-97-8".)
At this time, five separate petitions for review in this proceeding are pending before the commissien.
If any of the petitions are granted and briefing schedules are set, we ask the Commission to take into account certain factors.
First, both undersigned counsel for CANT have previously scheduled family obligations out of town during the entire month of 4
August.
Second, it is imperative that the subject of each petition be briefed separately.
Each contested decision is quite lengthy, covering numerous legal and factual issues; thus, appellate briefs are likely to be lengthy.
The most recent briefing of an appeal in this matter (LBP-96-25, pertaining to financial qualifications and NEPA issues), demonstrates the need to consider issues separately.
In that instance, CANT was required to respond to briefs totalling r.early 120 pages filed by LES and the Nuclear Energy Institute and their considerable bevy of lawyers, as well as the NRC Staff.
This same scenario is likely to occur with respect to each and every issue which is the subject of review, and it is simply not possible 9707030010 970605 PDR ADOCK 07003070 s
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6 NRC Commissioners June 5, 1997 Page 2 for undersigned counsel, who have very limited resources, to engage in simultaneous lengthy briefing of different issues.
Accordingly, should any of the five petitions for review be
. granted, we ask that these factors be taken into account by
.prov d ng for br ef ng in seriatum, and'with adequate preparation i
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i time that also permits undersigned counsel to honor their prior obligations.
We appreciate your consideration of'this matter.
Very truly yours, EM N
Ndit alle M. Walker l
SIERRA CLUB LEGAL DEFENSE FUND cNmv Diane Curran HARMON CURRAN & SPIELBERG cc:
Eugene Holler Michael McGarry f
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
In the Matter of LOUISIANA ENERGY SERVICES, L.P.
Docket No.(s) 70-3070-ML (Claiborne Enrichment Center l
SNM License) l CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing LTR CANT TO COMM RE LBP-97-8 have been served upon the following persons by U.S. mail, first class, except as otherwise noted and in accordance with the requirements of 10 CFR Sec. 2.712.
Administrative Judge Office of Commission Appellate Thomas S. Moore, Chairman Adjudication Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop - T-3 F23 Washington, DC 20555 U.S. Nuclear Regulatory Commission i
Washington, DC.20555 Administrative Judge Administrative Judge Richard F. Cole Frederick J. Shon
. Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop - T-3 F23 Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 Eugene Holler, Esq.
-Janice E. Moore, Esq.
Diane Curran, Esq.
Office of the General Counsel Harmon, Curran &'Spielberg Mail Stop 15 B18 2001 S Street, N.W., Suite 430 U.S. Nuclear Regulatory Commission Washington, DC 20009 Washington, DC 20555 Jay E. Silberg, Esq.
Roland J. Jensen Counsel for NEI President Shaw, Pittman, Potts & Trowbridge Lousiana Energy Services, L.P.
2300 N Street, N.W.
2600 Virginia Avenue, N.W., Suite 608 i
Washington, DC 20037 Washington, DC 20037 l
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Docket No.(s)70-3070-ML LTR CANT TO COMM RE LBP-97-8 Robert G. Morgan Licensing Manager J. Michael McGarry, III, Esq.
LES - c/o Duke Engineering and Counsel for LES Services, Inc.
Winston & Strawn PO Box 1004 1400 L Street, N.W.
Charlotte, NC 28201 Washington, DC 20005 l
I Ronald Wascom Nathalie M. Walker, Esq.
Deputy Assistant Secretary l
Robert B. Wiygul, Esq.
Office of Air Quality & Rad. Protection Sierra Club Legal Defense Fund, Inc.
Dept. of Environmental Quality 400 Magazine Street, Suite 401 P.O. Box 82135 New Orleans, LA 70130 Baton Rouge, LA 70884 Dated at Rockville, Md. this 12 day of June 1997 Office of the Secretary of the Coninission i
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