ML20024E286

Request for Extension Until 830909 to Allow Response to Joint Intervenor 830722 Motion to Reopen Record on Basis of Moisture Found on Foundation Mat Floor.Engineering Rept Due 830901.Certificate of Svc Encl

ML20024E286
Person / Time
Site:	Waterford
Issue date:	08/04/1983
From:	Churchill B LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 8308100194
Download: ML20024E286 (6)

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81983 > i' UNITED STATES OF AMERICA 3 NUCLEAR REGULATORY COMMISSION CJ SrN[$yfM bLcy.,

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Before the Atomic Safety and Licensing Appeal Board / '

In the Matter of )

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LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

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(Waterford Steam Electric )

Station, Unit 3) )

REQUEST FOR EXTENSION OF TIME Joint Intervenors' motion dated July 22, 1983, filed July 25, 1983, seeks to reopen the record in this proceeding on the basis of moisture discovered on the foundation mat floor of the auxiliary building. Applicant's answer is due August 9, 1983, and the Staff's answer is due August 15.

Applicant has contracted with an independent engineer-ing firm to conduct an analysis of the water seepage, and the engineering report is expected by September 1, 1983. See letter dated July 29, 1983 to NRC's Offi;e of Inspection and Enforcement, Region IV, attached. In the interests of pre-senting as complete a record as possible, Applicant is there-fore requesting an extension of time to' allow response to the motion after the engineering report has become available to the parties and the Appeal Board, and to enable Applicant to take the engineering analysis into account in its response.

In addition, Staff counsel advised Applicant's counsel today that he intended to seek an extension of time, which would B308100194 830804 PDR ADOCK 05000382 G PDR Q

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also enable the Staff to review Applicant's engineering report before filing a response to Joint Intervenors' motion.

Accordingly, Applicant requests that the time for its response to Joint Intervenors' motion be extended from August 9 to September 9, 1983, and that the time for the Staff's response be extended frgm August 15 to September 15, 1983. No prejudice accrues to any party as a result of the extension (with the possible exception of increased risk to Applicant's project schedule), and the extension will provide a more complete record for the Appeal Board in its deliberations on the motion. Staff counsel has stated that he supports this request, and Joint Intervenors have indicated that they do not oppose the request.

Respectfully submitted, i

! SHAW, PITTMAN, POTTS & TROWBRIDGE J

Brbte W7 Churchill,

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P.C.

Counsel for Applicant 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: August 4, 1983

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Urruils sTsiEM July 29, 1983 I. W3P83-2581 3-A1.01.04 3-A14.09 Mr. John T. Collins U. S. Nuclear Regulatory Co==ission Region IV Office of Inspection and Enforce =ent 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76012

SUBJECT:

Waterford SES Unit 3 Water Seepage in Concrete Base =at

Dear Mr. Collins:

s . This is to confir= discussions with you and =e=bers of your staf f in which we infor=ed you that Harstead Engineering Associates, Inc. is conducting an analysis of the water seepage which has been identified in thetWaterford 3 SES base =at. A report of this analysis vill be issued on or before Septe ber 1, 1983. Yours verv ruly, M*" ' i F. J. Dru==ond Manager Engineering & Technical Services FJD/TFG/sm l cc: ,E.c4;r Blake, W. M. Stevenson, G. L. Constable l l l 1 l l I 1

1 D UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board In the Matter of )

                                        )

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-328 , ) (Waterford Steam Electric ) Station, Unit 3) ) CERTIFICATE OF SERVICE This is to certify that copies of the foregoing

     " Request for Extension of Time" were served this 4th day of August, 1983, by hand delivery on'those persons on the attached Service List indicated by an asterisk (*) preceding their 4

, c names; by deposit in Federal Express to Gary Groesch and i Carole H. Burstein; and by deposit in the United States mail, postage prepaid, addressed to all other persons on the attached j Service List, this 4th day of August, 1983. L , J BriNM!!i W. Thurchill, 'P.C . Dated: August 4, 1983 1

P UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board In the Matter of )

                                                         )

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

                                                         )

(Waterford Steam Electric ) Station, Unit 3) ) SERVICE LIST

• Administrative Judge Administrative Judge Christine N. Kohl, Chairman Sheldon J. Wolfe, Chairman Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory -

Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• Administrative Judge Administrative Judge W. Reed Johnson Harry Foreman Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board Board U.S. Nuclear Regulatory Director, Center for Population Commission Studies Washington, D.C. 20555 Box 395, Mayo University of Minnesota
• Administrative Judge Minneapolis, MN 55455 Howard A. Wilber Atomic Safety & Licensing Administrative Judge Appeal Board Walter H. Jordan U.S. Nuclear Regulatory Atomic Safety & Licensing Commission Board Washington, D.C. 20555 881 West Outer Drive Oak Ridge, TN 37830
• Sherwin E. Turk, Esquire Office of the Executive Dock'eting & Service Section (3)

Legal Director Office of the Secretary U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 t

1 Mr. Gary Groesch Luke B. Fontana, Esquire 2257 Bayou Road 824 Esplanade Avenue New Orleans, LA 70119 New Orleans, LA 70116 Brian Cassidy, Esquire Spence W. Perry, Esquire Federal Emergency Management Federal Emergency Management Agency Agency Region I Office of the General Counsel 422 J. W. McCormack 500 C Street, S.W., Room 840 Boston, MA 03109 Washington, D.C. 20472 Carole H. Burstein, Esquire 445 Walnut Street New Orleans, LA 70118 i s

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