ML20055B931
| ML20055B931 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/20/1982 |
| From: | Gallo J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20055B932 | List: |
| References | |
| ISSUANCES-OLA, NUDOCS 8207230594 | |
| Download: ML20055B931 (2) | |
Text
"
7/20/82 00CKETED UNITED STATES OF AMERICA US:if C NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAkD'.
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In the Matter of
)
) Docket No. 50-155-OLA CONSUMERS POWER COMPANY
) (Spent Fuel Pool
)
Modification)
(Big Rock Point Nuclear Power Plant)
)
MOTION FOR LEAVE TO FILE RESPONSE OUT OF TIME Consumers Power Company (" Licensee") moves this Atomic Safety and Licensing Board to enter an order permitting Licensee to file out of time its response to Intervenors Christa-Maria, et al motion to call rebuttal witnesses on O'Neill Contention II.E.3.
In support of the motion, Licensee states:
1.
The Licensing Board granted Intervenors until June 28, 1982 to file its motion.
Replies were due by July 12, (Tr. 2618-20).
Intervenors filed their motion on July 1, 1982 -- three days late.
This unexplained delay necessarily delayed Licensee's response.
2.
Counsel for Licensee have been heavily committed to other litigation since July 1, making it impossible to file its response in a timely manner.
Specifically, Mr. Thornton has been primarily occupied in preparation for a rate case that is currently in trial.
Mr. Steptoe is committed to a pending NRC proceeding involving Licensee's Midland plant.
The undersigned has likewise been immersed in another NRC B207230594 e20720 PDR ADOCK 05000155 C
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proceeding involving a pending operating license application for the Byron Station.
3.
The motion, if granted, would permit Intervenors to call rebuttal witnesses at resumed hearings to be convened towards the end of this year.
Thus, a nine-day delay in responding to Intervenors' motion will not prejudice any party.
For good cause shown, Licensee's motion should be granted.
Respectfully submitted,
% > A, s/" J/seph' Gallo One of the Attorneys for CONSUMERS POWER COMPANY ISHAM, LINCOLN & BEALE 1120 Connecticut Avenue, N.W.
Suite 840 Washington, D.C.
20036 Dated:
July 20, 1982
..