ML19263B331

Motion by Intervenor Skagitonians Concerned About Nuclear Plants,For Extension of Time Until 790130 to File Its Reply to Applicant'S Appeal of ASLB 781124 Order.Certificate of Svc Encl

ML19263B331
Person / Time
Site:	Skagit
Issue date:	12/22/1978
From:	Leed R SKAGITONIANS CONCERNED ABOUT NUCLEAR POWER (SCANP)
To:
References
NUDOCS 7901180045
Download: ML19263B331 (4)

Text

.

gc ,s O

, NRC p -"n- ., ,, ,_ ., m.w n m' . . cP

,ywo \

• . gSNEC * ,

g .

(M OEC2?**Nh#b 1 9 a UNITED STATES OF AMERICA \ 'cL$r. *# zQ NUCLEAR REGULATORY C0!O!ISSION q/ g (p]

4 i./

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of: )

)

PUGET SOUND POUER AND LIGHT ) Docket Nos. STS 50-522 COMPANY, et al., ) 50-523

)

(Skagit Nuclear Fower Project )

Units 1 and 2) )

)

MOTION FOR EXTENSION OF TIME BY INTERVENORS SCANP, ET AL.

Intervenor SCAMP hereby requests an extension of the time for filing its reply to the applicant's appeal of the ASLB order herein dated November 24, 1978, to January 30, 1973.

The basis for this motion is that the time for response falls during the Christmas holidays, and intervenors' counsel are heavily occupied with other matters, and require the addition-al time requested to adequately prepare a responding brief.

In addition, an adequate reply to the applicant's appeal and brief requires a lengthy reexamination of the voluminous record, which will be very time consuming. Many of the appli-cant's characterications of matters occurring in these proceed-ings are inaccurate or misleading. The suggestion that the ASL3 or intervenors have unnecessarily delayed the proceedings is entirely untrue. As intervencrs ill de=cnstrate in their reply, the principal reason for the delays in this proceeding 70011800'{S _ _

q

has been the failure of the applicant to present an adequate factual case, forcing staff and the ASLB to continually call for further documentation of safety hacards, alternatives and need for power. The ASLB would have been justified in dismis-sing the application, on numerous occasions, but instead exten-ded to applicant the grace to cure its deficient record.

Next to Diablo Canyon, this docket may present the mos:

clearcut example of patently inadequate geologic investigation of a highly dangerous site. This site is the only one ever proposed for a Uild and Scenic River. The independent inves-tigation of siting alternatives by staff, as far as the record shows, is nil. Finally, there is serious question as to the need for power, due to the unique abundance of hydro resources in this region. Any cne of these circumstances could account for major delays in the siting crocess. Taken together, they suggest why this site will probably not be licensed, and indeed cannot be unless the Secretary of Agriculture issues a waiver under 57(a) of the Wild and Scenic Rivers Act.

DATdD this - '

day of December, 1978.

/

. . , /

ROGER M. LEED Counsel for Intervenors

. 2_

' C 0 E E2 '# ,

(s 9 . . .n2

' 'LiwG Q d-  :-

i D E g g,7- \$I3 -i 7 UNITED STATES OF AMERICA C) c*$.#

e NUCLEAR REGULATORY COMMISSION p BEFORE THE ATOMIC SAFETY LICENSING AND APPEAL BO0)4 Q@

In the Matter of )

)

PUGET SOUND POWER & LIGHT ) DOCKET NOS. STN 50-322 CO MP ANY , et al., ) 50-523

)

)

(Skagit Nuclear Power Project, )

Units 1 and 2) )

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of:

MOTION FOR EXTENSION OF TIME BY INTERVENORS SCANP , ET AL have been served on the following by depositing the same in the United States mail, postage prepaid, on this 22 day of December, 1978.

Valentine B. Deale, Esq., Chairman Alan S. Rosenthal, Chairman Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Appeal Board Commission U.S. Nuclear Regulatory Commissior 1001 Connecticut A venue N.W. Washington, D.C. 20055 Washington, D.C. 20036 Dr. John H. Buck, Member Dr. Frank F. Hooper, Membe r Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board School of. Natural Resources U.S. Nuclear Regulatory Commissicr University of Michigan Washington, D.C. 20555 Ann Arbor, MI. 48104 Michael C. Farrar, Member Gustave A. Linenberger, Member Atomic Safetv and Licensing

~

Atomic Safety and Licensing Board Apm al Board U.S. Nuclear Regulatory U.S.' Nuclear Reculatorv Commissior.

Commission Washington, D.C. 2055'5 Washington, D.C. 20555 Certificate - 1

~

Docketing and Service Section Canadian Consulate General Office of the Secretary Peter A. van Brakel U.S. Nuclear Regulatory Vice-Consul Commission 412 Plaza 600 Washington, D.C. 20555 6th and Stewart Street Seattle, Washington 98101 Richard L. Black, Esq.

Counsel for NRC Staff F. Theodore Thomsen U.S. Nuclear Regulatory Perkins, Cole, Stone, Olsen Commission & Williams Office of the Executive Legal 1900 Washington Building Director Seattle, Washington 98101 Washington, D, C. 20d55 A an P. O' Kelly Nicholas D. Lewis, Chairman ,

Paine Lowe, Coffin, Herman Energy Facility Site Evaluation 1400 Washington Trust Financial 820 E s Fifth Avenue Olympia, Washington 98504 Spoka e Washington 99204 Robert C . Schofield, Director Russel W. Busch Skagit County Planning Depart- Evergreen Legal Services ment . . 520 Smith Tower 120 West Kincaid Street Seattle, Washington 98104 Mt.Vernon, Washington 98273 Richard M. Sandvik, Esq.,

Assistant Attorney General Department of Justice 500 Pacific Building 520 S. W. Y amhill Portland, Oregon 97204 Robert Lowenstein, Esq.

Lowenstein, Newman, Reis &

Axelrad 1025 Ccnnecticut Avenue, N.W.

Washignton, D.C. 20036 H. H. Phillips, Esq.

vice President and Corporate Counsel Portland General Electric Company DATED-

• 121 S.W. Salmon Street ,

Portland, Oregon 97204 CFSP and FCB _ ,

E. S tachon & L. Marbet RCGER M. LEED 19142 S. Bakers Ferry Road Counsel for Intervenors Boring, Oregon 97009 Certificate - 2