ML19289D130

Informs of Wi Public Svc Corp'S Opposition to Extension of Time Requested by co-intervenors on 790118

ML19289D130
Person / Time
Site:	Kewaunee
Issue date:	01/22/1979
From:	Baker D FOLEY & LARDNER
To:	Lazo R Atomic Safety and Licensing Board Panel
References
NUDOCS 7902230042
Download: ML19289D130 (2)

Text

g pONDENCE .

gg FOLEY a L.A R O N E R ramst wisconsim etN?tR 777 cast wiscoNsim avtNuc M ll.WAU K E E, WIS. 5 3 2 o 2 in mao. son.w scen sim i= waswe=orom. o.c.

FCLET.LA ACMER.HCLLAGAUGM 6 4ACOS$

T E L E *"C N C l** m 2 7*.2 *oo FO LEY & LAR O N CR TCLtz26 SI9 *Csf oF*ict mot e9F i?f s st == s'Lvawsa avt =w t. N. w.

wASHIN GTC N. O. C.2000 4 (FCLC* Lan3 wiL) reest wiscoms N *saza e a e t e kt a=oN C (Jo 2) 462+ s2c o *^ 'S "**5 7 '

January 22, 1978 f attawome teo s) 2s ?+ so.a s Mr. Robert M. Lazo C

• Atomic Safety and Licensing Board p , 4 U. S. Nuclear Regulatory Cocmission 84' Washington, D.C. 20555 g73 y g

$ s Re: Wisconsin Public Service Corp. - S. e=

Do cke'.: No. 50-305 h/y **L"s * #

4 -

Dear Mr. Laco:

We are in receipt of the letter dated January 18, 1979 from the representative of the co-intervenors in this .

matter which requests additional time to respond to the pending motion for su= mary disposition. Wisconsin Public Service Corporation opposes any extension of time for responding to the motion.

NRC Rules 52.749 provides a period of twenty days for parties to respond to motions for s-nry disposition.

This time limit is designed ^:o provide prompt consideration of such motions. We see no reason to alter this time limit under the circumstances of this proceeding. Intervenors and staff counsel were both informed by counsel for WPSC of its intention to file the motion well in adv1nce of the actual filing. No new or unexpected issues are presented by the motion. The issues in the motion are the merits of the contentions put forward by the Intervenors themselves.

The limited number of contentions remaining in this pro-ceeding also suggests that an enlargement of time is un -

warranted.

Finally, the schedule requested in our letters of December 28, 1978 and January 15, 1979 would be ccmpletely disrupted by the requested extension. As noted previously, time is of the essence to the requested license amendment, which has now been pending for more than a year.

790223 oo 92

~

In accordance with the foregoing, it is respectfully requested that the request for extension of time be denied, that the Board rule on the pending motion as expeditiously as possible, and that without regard to the pending motion that a hearing be scheduled within the parameters stated in our letter of January 15, 1979.

Very truly yours; FOLEY & LARDNER Sy DAVID A. BAKER David A. Baker cc: th. Glen 0. Bright Dr. Oscar H. Paris Mr. William M. Cordaro Mrs. Wend Schaefer Ms. Mary Lou Jacobi Patrick Walsh, Esq.

William J. Olmstead, Esq.

Docketing and Service Section

/