ML20148P688
| ML20148P688 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 06/18/1997 |
| From: | Mcgarry J LOUISIANA ENERGY SERVICES, WINSTON & STRAWN |
| To: | Diaz N, Dicus G, Shirley Ann Jackson, Mcgaffigan E, Rogers K, The Chairman NRC COMMISSION (OCM) |
| References | |
| CON-#397-18369 LBP-97-03, LBP-97-08, LBP-97-3, LBP-97-8, ML, NUDOCS 9707030021 | |
| Download: ML20148P688 (4) | |
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WINSTON & STRA(YIONTED USNRC 35 WEST WACKER QRIVE 1400 L STREET. N.W.
- a. RUE 00 CIRQUE CHICAGO. ILLINotS 60601-97M WASHINGTON,0.c. 20005-3502 7soos paris. FRANCE 200 PARK AVENUE (202) 371 5700 43, RUE OU RHONE NEW YORK. NY 10166-4193 1204 OENEVA, SWITZERLAND rAesuts ao23 an s9s 0FFICE OF SECRE TARY J. MICHAEL McGARRY, ll1 00CXETING & SERVICE (202)an 5na BRAHCH June 18,1997 Shirley Ann Jackson, Chairman Kenneth C. Rogers, Commissioner Greta J. Dieus, Commissioner Nils J. Diaz, Commissioner Edward McGaffigan, Jr., Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re:
In the Matter of I nuisinnn Energy Services Docket No. 70-3070-ML
Dear Chairman and Commissioners:
LES responds to the request by Intervenor CANT for delay in the anticipated brief' g m
schedule assuming the Commission agrees to review either or both decisions of the Licensing Board in LBP-97-3 and LBP-97-8, or CANT's separate petition to review denial of its waiver petition.
The unfortunate practice of CANT's counsel in seeking (and often obtaining) delay to meet personal and other obligations has already seriously prejudiced LES in this proceeding. For example, the proceeding was delayed several months from November 1994 to March 1995, in the transition from hearings on environmental issues to hearings on safety issues, because the Licensing Board postponed hearings at the request of CANT's counsel. Similar requests and delays have occurred sporadically throughout the proceeding.
These requests have, in the aggregate, contributed to a proceeding now seven years in length, with several important issues now just reaching the Commission. Accordiagly, LES vigorously opposes any further adjustment of schedule other than necessary to meet emergencies.
Typically, licensing boards and this Commission have insisted that all parties and their counsel meet professional obligations as necessary to cooperate in a fair and expeditious completion of the
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proceeding.
97t#703OO21 970618 PDR ADOCK 07003070 C
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June 18,1997 Page Two With respect to Intervenor's suggestion that "each petition b'e briefed separately," it is Applicant's position that a single brief and briefing schedule be established by the Commission, for those matters on which the Commission grants review, the length of the brief and the timing ofits submission to be determined by the Commission in consideration of the complexity of the issues.
Very truly yours, cc: Service List J. Michael McGarry, III Counsel for Applicant Louisiana Energy Services l
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W UNITED STATES OF AMERICA 00CKETED NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE COMMISSION 97 JtN 19 P1 :59
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0FFICE OF SECRETARY In the Matter of
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00CKETING & SERVICE
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BRANCH LOUISIANA ENERGY SERVICES, L.P.
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Docket No. 70-3070
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(Claiborne Enrichment Center)
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CERTIFICATE OF SERVICE I hereby certify that copies of the attached letter were served upon the following by deposit in the United States mail, first class, this 18th day of June,1997:
Administrative Judge Administrative Judge Thomas S. Moore, Chairman
- Richard F. Cole
- Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 (2 copies)
Administrative Judge Secretary of the Commission
- Frederick J. Shon*
U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Attention: Chief, Docketing and Commission Service Section Washington, D.C. 20555 (Original plus 2 copies)
OEce of Commission Appellate Eugene Holler, Esq.*
Adjudication
- OEce of the General Counsel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555
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l Ronald Wascom, Deputy Assistant Joseph DiStefano, Esq.
Secretary '
Quinn, Racusin & Gazzola Office of Air Quality &
1401 H Street, N.W.
Radiation Protection Suite 510 P.O. Box 82135 Washington, D.C. 20005 Baton Rouge, LA 70884-2135 i
Robert G. Morgan - WC26B Marcus A. Rowden Licensing Manager Fried, Frank, Harris, Shriver &
Duke Engineering & Services, Jacobsen Inc.
I101 Pennsylvania Avenue, N.W.
400 South Tryon Street Suite 900 South Charlotte, NC 28201-1004 Washington, D.C. 20004 Diane Curran
- Nathalie Walker Harmon, Curran, Gallagher &
Sierra Club Legal Defense Fund 4
Spielberg 400 Magazine St.
2001 S Street, N.W.
Suite 401 Suite 430 New Orleans, LA 70130 Washington,D.C. 20009.-l125 Adjudicatory File
- Roland J. Jensen l
Atomic Safety and Licensing Louisiana Energy Services, L.P.
i Board Panel 2600 Virginia Avenue, N.W.
U.S. Nuclear Regulatory Commission Suite 608 Washington, D.C. 20555 Washington D.C. 20037 Thomas J. Henderson, Esq.
David S, Bailey, Esq.
Lawyers' Commmittee for Civil Rights Under Law 1450 G Street, N.W.
Suite 400 Washington, D.C. 20555 LOUISIANA ENERGY SERVICES, L.P.
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J.4dichael McGarry, III
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WINSTON & STRAWN, COUNSEL FOR LOUISIANA ENERGY SERVICES, L.P.
Via Messenger 4%