ML20052F514

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Motion for Leave to Suppl Reply to NRC Motion for Extension of Time,By Adding Dj Vandewalle Affidavit.Reply Was Expeditiously Submitted W/O Time to Include Affidavit
ML20052F514
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 05/05/1982
From: Gallo J
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20052F515 List:
References
ISSUANCES-OLA, NUDOCS 8205130133
Download: ML20052F514 (2)


Text

_.

5/5/82 o

A E%gg UNITED STATES OF AMERICA e

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-9 NUCLEAR REGULATORY COMMISSION

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1 EFORE THE ATOMIC SAFETY AND LICENSING BOARD s

FG In the Matter of

)

) Docket No. 50-155-OLA CONSUMERS POWER COMPANY

) (Spent Fuel Pool

)

Modification)

(Big Rock Point Nuclear Power Plant)

)

MOTION TO SUPPLEMENT REPLY TO MOTION FOR TIME EXTENSION Consumers Power Company (" Licensee") moves this Atomic Safety and Licensing Board to enter an Order permitting Licensee to supplement its reply to the NRC Staff's motion for a time extension by adding the affidavit of David J. Vande-Walle.

In support of the motion, Licensee states:

1.

Mr. VandeWalle's affidavit is an essential part of Licensee's reply to the Staff's motion for a time extension because it demonstrates that postponement of the hearings be-yond June 16 would be prejudicial to the interests of Licensee.

2.

The NRC Staff's motion for a time extension was received at 6:30 p.m. Monday, May 3.

Since time was of the essence, Licensee prepared and submitted its reply to the I

Licensing Board and the parties on an expedited basis.

Li-censee's reply was served in the early morning hours of May 5 hhSY 9205130133 820505 f/ /

PDR ADOCK 05000155 0

PDR

. Because of these time constraints, Licensee was not able to include the Vandewalle affidavit in its reply.

3.

No prejudice should accrue to any party by the grant of this motion.

To expedite matters, this pleading is being served by messenger with respect to the Licensing Board, Counsel for the NRC Staff, and Counsel for Intervenors' Christa-

-Maria, et al.

For good cause shown, Licensee's motion should be granted.

Respectfully submitted, G m--

1 J

epK Gallo e of the Attorneys for Consumers Power Company ISHAM, LINCOLN & BEALE Suite 840 1120 Connecticut Avenue, N.W.

Washington, D. C.

20036 (202) 833-9730 DATED:

May 5, 1982

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