ML19347C594

Request for Extension Until 810126 to Respond or Object to NRC Second Interrogatories.Certificate of Svc Encl

ML19347C594
Person / Time
Site:	Zimmer
Issue date:	12/24/1980
From:	Conner T, Wetterhahn M CINCINNATI GAS & ELECTRIC CO., CONNER, MOORE & CORBER
To:	NRC COMMISSION (OCM)
References
NUDOCS 8012310291
Download: ML19347C594 (4)

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UNITED STATES OF AMERICA -

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In the Matter of .s -

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The Cincinnati Gas & Electric )

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Company, et al. ) Docket No. 50-358

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(Wm. H. ::i==er Nuclear Pcwer )

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APPLICANTS' MOTION FOR ADDITICNAL TIME TO RESPOND OR OBJECT TO "NRC STAF? SECOND INTERRCGATORIES TO APPLICA'iTS" Despite the fact that the Certificate of Service recites that the "'IRC Staff Cecond Interrega: cries to Applicants" was served by deposit in the United States mail en December 9, 1980, this dccument was not received by Applicants' counsel until December 23, 1980.

As the 3 card knows, it is the nor=al practice for the tech-nical staff of the Office of Nuclear Reactor Regulation to obt;ain additional informatien which it censiders necessary to ccmplete its review by meeting with the applicant or by si= ply asking the applicant to provide it as an amendment to the application or other-wise. No explanation has been provided by the Office of the Executive Legal Director for the departure frem the standard pro-cedure in this instance. The legalistic approach to obtaining the information necessitates additional time and effort to provide the information in the form requested, particularly when the inter-rogatories were received at the height of the holiday season when

=any individuals are unavailable.

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Considering the failure of prompt service-1/ and the nature of the incerrogatories, the Applicants move for an extension of time to January 26, 1981, to file their response or objections.

Respectfully submitted, CONNER & MOORE

. 'M Trol . Conner, Jr.

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i Mark J. Wetterhahn Counsel for the Applicants 1/ This appears to be due to the fact that service by mail by the Staff no longer is made by direct deposit in the United States mail but involves a cumbersome procedure in the NRC mail recm prior to actual mailing.

UNITED F7ATES OF AMERICA NUCLD.R RECU'.ATORY CCIOCSSION In the F.atter of )

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The Cincinnati Gas & Electric ) Docket No. 50-358 Ccmpany, et al. )

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(William H. Zimmer Nuclear Pcwer )

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._ CERTIFICATE CF SERVIC L . - - -

I hereby certify that copies of " Applicants ' Motion for Additional Time to Respond or Object to 'NRC Staff Second Interrogatories to Applicants'" dated December 24, 1980, in the captioned matter, were served upon the following by deposit in the United States mail this 24th day of December, 1930:

~~Esries C Secdhcifer, Esq. Michael C. Farrar, Esq.

Chairman, Atemic Safety Atomic Safety and Licensing and Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Frank F. Hooper, Member Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Appeal Board Panel Scard U.S. Nuclear Regulatory School of Natural Resources Commission University of Michigan Washington, D.C. 20555 Ann Arbor, Michigan 48109 Chairman, Atomic Safety and

, Mr. Glenn O. 3,right, Member Licensing Scard Panel -

Atomic Safety and Licensing U.S. Nuclear Regulatory 3 card Commission l U.S. Nuclear Regulatory Washington, D.C. 20555 Commission .

Washington, D.C. 20555 Charles A. Barth, Esq.

! Counsel for the NRC Staff l Richard S. Salzman, Esq. Office of the Executive Legal l

Chairman, Atomic Safety and Director Licensing Appeal Laard U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission '

Commission Washington, D.C. 20555 Washington, D.C. 20555 William J. Moran, Esq.

Dr. Lawrence R. Quarles General Counsel Atomic Safety and Licensing Cincinnati Gas & Electric Appeal Board -

Ccmpany U.S. Nuclear Regulatory Post Office Box 960 Commission Cincinnati, Ohio 45201 t Washington, D.C. 20555

Mr. Chase R. Stephens James H. Feldman, Jr., Esq.

Docketing and Service Branch 216 East Ninth Street Office of the Secretary Cincinnati, Ohio 45202 U.S. Nuclear Regulatory Ceramission Washington, D.C. 20555 John D. Woliver, Esq.

Clermont County Community William Peter Heile, Esq. Council Assistant City Solicitor Box 181 City of Cincinnati Batavia, Ohio 45103 Box 214 Cincinnati, Ohio 45202 David K. Martin, Esq.

Assistant Attorney General Mrs. Mary Reder Acting Director Box 270 Division of Environ = ental Law Route 2 Office of Attorney General California, Kentucky 41007 209 St. Clair Street Frankfort, Kentucky 40601 Andrew 3. Dennison, Esq.

Attorney at Law Robert A. Jones 200 Main Stree Prosecuting Attorney of Batavia, Ohio 45103 Clermont County, Ohio 154 Main Street Batavia, Ohio 45103

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.An Mark (f. Wetterhahn t

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