ML20004C839
| ML20004C839 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/27/1981 |
| From: | Knotts J KNOTTS, J.B., SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-OL, NUDOCS 8106050476 | |
| Download: ML20004C839 (4) | |
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May 27, 1981 i
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UNITED STATES'OF AMERICA NUCLEAR REGULATORY COMMISSION S-/
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In the Matter of:
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GAS COMPANY, et al.
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Docket No. 50-395-
-(Virgil C. Summer Nuclear
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Station, Unit 1)
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!g-f (j.9f. t. f APPLICANTS' RESPONSE TO INTERVENOR
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BURSEY'S REQUEST FOR EXTENSION OF TIME 93 vJN O 11961 -
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wi 1981 Applicants received Intervenor Bu'r'sey& )^
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request for an extension of time (styled as a Motion for Continuance) until June 5, 1981 for the filing of his answers to Applicants' and Staff's Motions for Summary-Disposition of certain contentions.
Applicants' Response is in the alternative.
first, we oppose the Motion on the ground that no good cause for an extension of time has been shown.
Mr. Bursey has alluded to prospective difficulties, several weeks into the response period, in securing responsive affidavits.
He has not shown that he has been diligently attempting to. secure affidavits l
during the weeks since May 8, 1981.
Moreover, he has not
~ hown any cause at all for extension of the Response itself s
as opposed to the affidavits to accompany the Response.
Once again, he apparently expects to be excused from the 3
obligations of a party.
5 O[I In the alternative, if the request is to be granted, then such relief should be afforded only upon the following conditions:
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(a)
No further extension of time for any part of the Response.to Applicants' and Staff's Motions for.
Summary. Disposition should be entertained, and a late filing should be stricken.
(b)
Mr. Bursey should be required to arrange hand delivery in Washington, D. C. on Applicant and Staff Counsel not later than 5:00 p.m. on June 5, 1981.
(c)
No further extension of time of any kind for any purpose should be accorded to Mr. Bursey absent the most extraordinary good cause, in particular, any direct testimony.or exhibits which can be presented must be filed on schedule on May 28, 1981 or such will be stricken and.such testimony or exhibits will not be permitted to be-introduced at hearing.
Respectfully submitted, m
,T,t.WN' y, hosep[hB. Knotds,Jr.
Coedsel for Applicants Date: May 27, 1981 E
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CONm UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.,,ff% s 5' In the Matter of:
SOUTH CAROLINA ELECTRIC &
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Docket No. 50-395 OL GAS COMPANY and
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SOUTH CAROLINA PUBLIC SERVICE )
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(Virgil C. Summer Nuclear _
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Station)
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i CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response To In-tervenor Bursey's Request for Extension of Time" were served upon the following persons by deposit in the United States mail, first class postage prepaid, this 27th day of May, 1981:
Herbert Grossman, Esq.
Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Board Tanel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.
C.
20555 Washington, D. C.
20555 Dr. Frank F.
Hooper George H. Fischer, Esq.
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School of Natural Resources Vice President and Group 4
University of Michigan Executive-Legal Affairs Ann Arbor, Michigan 48109 South Carolina Electric &
Gas Company Mr. Gustave A.
Linenoirger Post Office Box 764 Member, Atomic Safety and Columbia, South Carolina 29202 Licensing Board Panel U.S.
Nuclear Regulatory Steven C. Goldberg, Esq.
Commission Office of the Executive Washington, D.
C.
20555 Legal Director U.S. Nuclear Regulatory Chairman, Atomic Safety and Commission Licensing Appeal Board Panel Washington, D. C.
20555 U.S. Nuclear Regulatory Commission Mr. Brett Allen Bursey Washington, D.
C.
20555 Route 1, Box 93-C Little Mountain, S. C.
29076 r
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4 Mr. Chase R. Stephens.
John C. Ruoff Docketing and Service Section Post Office. Box 96 Office of the Secretary Jenkinsville, S. C.
29065 U.S. Nuclear hegulutory Commission Robert Guild, Esq.
Washington, D. C. 20555 314 Pall Mall Columbia, S. C.
29201 Richard P. Wilson, Esq.
Assistant Attorney General South Carolina Attorney General's' Office P.
O. Box 11549
- Columbia, S. C.
29211 j_q s
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'v %' d '*) hp Joseph B.
Knotts, Jr.
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