ML20049H887
| ML20049H887 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/22/1982 |
| From: | Chackes K CHACKES & HOARE, JOINT INTERVENORS - CALLAWAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8203040415 | |
| Download: ML20049H887 (3) | |
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UNITED STATES OF AMERICA NJCLEAR REGULATORY COMMISSION m? pq-2 M $9 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD y
In the Matter of
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Docket No. STN 5 -483-OLi x',
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JOINT INTERVENORS' MOTION FOR EXTENSION OF' TIME Joint Intervenors - Coalition for the Environment, St. Louis Region; Missourians for Safe Energy; and Crawdad Alliance - by their counsel, move the Board for an Order extending the time for the filing and service of their Proposed Findings of Fact and Conclusions of Law for one week, until March 1,1982.
This motion is not due to a lack of dulgence on the part of Joint intervenors or their counsel and is not made for purposes of delay. Joint intervenors recognize the advantage, to themselves as well as the Board, of submitting the issues for the decision to the Board as soon as possible after the hearing so the testimony remains fresh in the minds of the Board.
This additional time is necessitated by the following circumstances. Due to an extremely heavy snowstorm over the weekend of January 30-31, 1982 followed by several lesser snowstorms during the next week, the entire week of February 1 - 7 was disrupted, substantially delaying counsel's work on this and other pressing matters, in addition, counsel's receipt of Applicant's Proposed Findings of Fact, etc., which had been expected on February 2, was delayed until February 4.1 Finally, the drafting of Joint Intervenors' proposed findings and conclusions was delayed by the fact that during a portion of the r
l IThe Express Mail receipt for said document indicates it was mailed in a timely' manner on February 1, but not delivered to counsel's office until February 3.
Due to another snowstorm on February 3 counsel was unable to reach his office and did not obtain the. document until the following day.
82030A0415 820222 PDR ADOCK 05000483 O
,s time available for the completion of that task, Kay Drey, one of the representatives of Joint Intervenors and the person who was primarily responsible for the issues involving embeds and honeycombing, was hospitalized.
Counsel regrets the filing of this request at the last moment, but has made every effort during the preceding weeks to complete the proposed findings and conclusions on time. For example, counsel's time records for February 14 - 21 reflect a total of j
over 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> on this matter alone, out of a total of nearly 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> for the period.
WHEREFORE, counsel for Joint Intervenors respectfully requests an extension of time, for one week, until March 1,1982, in which to file and serve Joint Intervenors' Proposed Findings of Fact and Conclusions of Law.
Respectfully submitted, I
l CHACKES AND HOARE M
W Kenneth M. Chackes Attorneys for Joint Intesenors 314 North Broadway, Suite 1010 St. Louis, MO 63102 314/241-7961
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD in the Matter of
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UNION ELECTRIC COMPANY
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Docket No. STN 50-483-OL
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(Callaway Plant, Unit 1)
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CERTIFICATE OF SERVICE 1 hereby certify that copies of Joint Intervenors' Motion for Extension of Time have been served on the following by deposit in the United States mail this 22th day of February,1982.
James P. Gleason, Esq., Chairman Atomic Safety and Licensing Board 513 Gilmoure Drive Silver Spring, MD 20901 Mr. Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Thomas A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Roy P. Lessy, Jr., Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 de Kenneth M. Chackes CHACKES AND HOARE
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