ML19029A760
| ML19029A760 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/10/1979 |
| From: | Rader R Conner, Moore & Corber, Public Service Electric & Gas Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML19029A760 (5) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of PUBLIC SERVICE ELECTRIC AND GAS COMPANY, et al.
(Salem Nuclear Generating Station, Unit 1)
Docket No. 50-272 (Proposed Issuance of Amendment to Facility Operating License No. DPR-70)
APPLICANT'S REQUEST FOR AN EXTENSION OF TIME TO RESPOND TO INTERVENORS ' "MOTION TO REOPEN COLEMAN'S CONTENTIONS TWO.AJ.'1D SIX FOR RECEIPT OF NEWLY DISCOVERED EVIDENCE" AND "MOTION FOR RECONSIDERATION OF DISMISSAL OF COLEM.:z\\N'S CONTENTION NUMBER THIRTEEN" Intervenors Alfred C. Coleman, Jr. and Eleanor G. Coleman
("Interveno_rs") have moved the Atomic Safety and Licensing Board ("Board") herein to reopen consideration of Contentions two and six, and to reconsider the Board's earlier dismissal of Contention thirteen.
Public Service Electric and Gas Company
("Applicant") requests an extension of time until August 31, 1979, within which to respond to Intervenors' motion.
The additional time is required because Mr. Wetterhahn, counsel for the Applicant, is presently in Cincinnati engaged in licensing proceedings before a different Atomic Safety and Licensing Board and will also be out of town next week.
Mr. Wetterhahn is the only attorney in his law firm who has responsibility for the representation of the Applicant in the instant proceed-ing.
Upon his return, it will be necessary for Mr. Wetterhahn to review Intervenors' motion, do legal research and possibly obtain an affidavit in opposition to the motion.
Further, Mr. Fryling, house counsel for the Applicant, has been ill for some time and has not yet returned to work.
His assistance will also be required.
The brief extension
- /
requested will not unduly delay this proceeding.-
Mr. Smith of the NRC Staff and Mr. Onsdorff, representing the Coleman Intervenors, do not object to this request for an extension.
Respectfully submitted, CONNER, MOORE & CORBER Robert M. Rader Counsel for the Applicant
~/
It is noted that this Board, by Order dated August 2, 1979, recently granted a similar extension of time to the NRC Staff to respond to Board Question No. 4.
UNITED STATES OF A.i.'1ERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE ELECTRIC AND GAS C0~1PANY, et al.
Docket No. 50-272 (Proposed Issuance of Amendment to Facility Operating License (Salem Nuclear Generating Station, Unit 1)
No. DPR-70)
NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance on behalf of the Applicant in the captioned matter.
In accordance with §2.713, 10 C.F.R. Part 2, the following information is provided:
Name Address Telephone Number Admission Name of Party Robert M.. Rader Conner, Moore & Corber 1747 Pennsylvania Avenue, N.W.
Suite 1050 Washington, D. C.
20006 Area Code 202/833-3500 United States Court of Appeals District of Columbia Circuit Public Service Electric and Gas Company Robert M. Rader Dated at Washington, District of Columbia, this day of August, 1979.
UNITED STATES OF AflERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of PUBLIC SERVICE ELECTRIC AND GAS COMPANY, et al.
(Salem Nuclear Generating Station, Unit 1)
)
)
) Docket No. 50-272
)
(Proposed Issuance of
) Amendment to Facility
) Operating License
) No. DPR-70)
CERTIFICATE OF SERVICE I hereby certify that copies of "Applicant's Request for an Extension of Time to Respond to Intervenors' 'Motion to Reopen Coleman's Contentions Two and Six for Receipt of Newly Discovered Evidence' and 'Motion for Reconsideration of Dismissal of Coleman's Contention Number Thirteen' 11 and "Notice of Appearance,"
both dated August 10, 1979, in the captioned matter, have been served upon the following by deposit in the United States mail, this 10th day of August, 1979:
Gary L. Milhollin, Esq.
Chairman, Atomic Safety and Licensing Board 1815 Jefferson Street Madison, Wisconsin 53711 Mr. Frederick J. Shon Member, Atomic Safety and Licensing Board Panel U. S-.* Nuclear Regulatory Commission Washington, D.C.
20555 Dr. James C. Lamb, III Member, Atomic Safety and Licensing Board Panel 313 Woodhaven Road Chapel Hill, N.C.
27514 Chairman, Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Chairman, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Barry Smith, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Richard Hluchan, Esq.
Deputy Attorney General Department of Law and Public Safety Environmental Protection Section 36 West State Street Trenton, N.J.
08625
2 -
Richard Fryling, Jr., Esq.
Assistant General Solicitor Public Service Electric
& Gas Company 80 Park Place Newark, N. J.
07101 Keith Onsdorff, Esq.
Assistant Deputy Public Advocate Department of the Public Advocate Division of Public Interest Advocacy Post Off ice Box 141 Trenton, N. J.
08601 Sandra T. Ayres, Esq.
Department of the Public Advocate 520 East State Street Trenton, N. J.
08625 Mr. Alfred C. Coleman, Jr.
Mrs. Eleanor G. Coleman 35 "K" Drive Pennsville, New Jersey 08070 Carl Valore, Jr., Esq.
Valore, McAllister, Aron
& Westmoreland Mainland Professional Plaza P. 0. Box 175 Northfield, N. J.
08225 Office of the Secretary Docketing and Service Section U.S. Nuclear Regulatory Conunission Washington, D. C.
20555 June D. MacArtor, Esq.
Deputy Attorney General Tatnall Building, P. O. Box 1401 Dover, Delaware 19901 Robert M. Rader