ML19341A411

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Reply Supporting NRDC 810113 Motion for Extension Until 810209 to File Brief Opposing Exceptions.Issues Are Detailed & All Counsel Are New to Case.Certificate of Svc Encl
ML19341A411
Person / Time
Site: 07002623
Issue date: 01/19/1981
From: Bishop L, Weiss E
HARMON & WEISS, National Resources Defense Council
To:
NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 8101230462
Download: ML19341A411 (4)


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VNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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

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DUKE POW 2R COMPANY

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Docket No. 70-2623 (Amendment to Materials

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License SNM-1773 for Oconee

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Nuclear Station Spent Fuel

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3-E N [.J.

Transporation and Storage

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JAN 211981 =- 3)

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NATURAL RESOURCES DEFENSE COUNCIL' ELD ya^lg "'

1 TO DUKE'S RESPONSE TO g

MOTION FOR EXTENSION OF TIME s

N In its January 16 response to NRDC's Motion for Extension of Time, Duke acknowledges that it has no objection to NRDC's request to file its brief opposing exceptions on February 9, 0-but for counsel's scheduled participation in other hearings on that date.

Nevertheless, it is essential that NRDC be allowed to file its brief on February 9.

As set out in our January 13 motion, all NRDC counsel hre new to the case, and lead counsel has been continuously occupied in hearings in Harrisburg from before Thanksgiving until January 9.

NRDC must respond to two briefs over the page limitation -- Duke's brief alone being 134 pages -- as well as the brief of a new intervenor.

Given these facts, and the nature of the detailed issues raised (which compel a thorough analysis of the record),

it is critical that NRDC be permitted to file on February 9.

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Such a time period would amount to four weeks for NRDC's lead i

i counsel to become familiar with the entire case and file a brief, an extremely compressed time schedule in itself.

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i Wherefore, for all the above-mentioned reasons, N2DC res-pectfully requests that its motion for extension of time to file brief opposing exceptions until February 9, 1981, be granted.

Respectfull'y submitted, 9 ")f Ellyn R.

Weiss s

Lee L. Bishop

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Harmon & Weiss 1725 I Street, N.W.

Suite 506 Washington, D.C.

20006 (202) 833-9070 Attorneys for NRDC, Inc.

January 19, 1981 i

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o UNITED STATES OF AMERICI NUCLEAR REGULATORY CO.vJ1ISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 1

In the Matter of

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N l-DUKE POWER COMPANY

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Docket No. 70-2623 s-

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(Amendment to Materials

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Nuclear' Station Spent Fuel.

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Transportation and Storage

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At McGuire Nuclear Station)

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CERTIFICATE OF SERVICE n.,

I hereby cettify that copies of the " Natural Resou'rces-E Defense Council's Reply to Duke's Response to Motion for'

, ' ~f Extension of Time," have been hand-delivered and mailed post-age' pre-paid.this.19th day of January, 1981, to.the following l

parties:

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  • Alan S.

Rosenthal, Esq.

Dr. Emmeth A. Luebke.

l Chairman Administrative Judge Atomic Safety & Licensing Atomic Safety & Licensing Board i

Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.

20555 j ~

Washington, D.C.

20555 a

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  • Dr. John H. Buck, Dr. Cadet H.

Hand, Jr.

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Atomic ' Safety & Licensing Administrative Judge Appeal Board Bodega Marine Laboratory U.S. Nuclear Regulatory of California

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Commission Post Office Box 247 Washington, D.C.

20555 Bodega Bay, California 94923

  • Richard S. Salzmar., Esq.

Jesse L.

Riley Atomic Safety & Licensing President Appeal Board Carolina Environmental U.S. Nuclear Regulatory Study Group Commission 854 Henley Place Washington, D.C.

20555 Charlotte, NC 23207

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Marshali E. Miller Edward G. Ketchen, Esq.

Chairman Counsel for NRC Regulatory Atomic Safety & Licensing Staff Board Office of the Executive EU.S. Nuclear Regulatory Legal Director Commission U.S. Muclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555 Richard P. Wilson, Esq.

Chairman Assistant Attorney General Atomic Safety & Licensing State of South Carolina Appeal Board

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2600 Bull Street U.S. Nuclear Regulatory Columbia, South Carolina 29201 Commission Washington, D.C.-

20555

.1 Chairman William L. Porter, Esq.'

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Atomic Safety & Licensing Associate General Counsel Board Panel Duke Power Company e

U..S. Nuclear Regulatory Post Office Box 33189 Commission Charlotte, NC _28242 Washington, D.C.

20555 Chase R. Stephens J. Michael McGarry, III, Esq.

Docketing & Servico Sectio.

Debevoise & Lieberman U.S. NL.; lear Regulatory 1200 17th Street, N.H.-

Commission Washington, D.C.

20006 Washington, D.C.

20555 3

Leonard Trosten, Esquire J.

1333 New Hampshire Ave., N.W.

Washington, D.C.

20036

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Lee L.

Bishop

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  • hand-delivered.

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