ML20069E968

Request for Enlargement of 70-page Limit on Brief Opposing Joint Intervenors exceptions.Sixty-one Exceptions Cannot Be Addressed in 70 Pages.Certificate of Svc Encl

ML20069E968
Person / Time
Site:	Waterford
Issue date:	03/18/1983
From:	Churchill B LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 8303220238
Download: ML20069E968 (5)

Text

4 March 18, 1983 kF'

'83 Hm 21 p79:9 UNITED STATES OF AMERICA NUCLEAR REGULATION COMMISSION EU I 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) )

APPLICANT'S REQUEST FOR ENLARGEMENT OF PAGE LIMITATION Pursuant to section 2.762 (e) of the Commission's Rules of Practice, 10 C.F.R. S 2.762 (e) , Applicant requests, for good cause shown, enlargement of the seventy-page limitation on its brief to be filed in opposition to the exceptions of Joint Intervenors now before the Appeal Board in this pro-ceeding. Applicant's brief is due March 25, 1983.

On December 27, 1982, Joint Intervenors filed 86 exceptions to the Licensing Board's November 3, 1982 Partial Initial Decision. Joint Intervenors subsequently filed a brief in support of 61 of the exceptions. Applicant is unable to adequately address this large number of briefed exceptions within the seventy-page limitation set out in section 2.762(e).

The hearing record in this proceeding is long, with testimony by 23 witnesses, and most of Joint Intervenors' exceptions are of the type which require extensive reference to and discussion of numerous portions of the record evidence. After allowing 8303220238 830318 O

PDR ADOCK 05000382 PDR Q)

.c pages for introductory and background information, a seventy-page limitation for responding to 61 exceptions allows little more than one page per exception, which is inadequate to sufficiently inform the Appeal Board of the record evidence relating to the exceptions and to present argument on that evidence.

Applicant presently estimates that it will require an additional twenty pages to adequately respond to Joint Intervenors' exceptions, although we will attempt to minimize that figure to the extent feasible. Accordingly, for the foregoing reasons, Applicant requests that it be granted a waiver of the page limitatio6s to allow its filing of a ninety-page brief in opposition to Joint Intervenors December 27, 1982 exceptions to the Partial Initial Decision.

Respectfully submitted, SHAW, PITTMAN., POTTS & TROWBRIDGE

/

By .. ..

Bruce W. Churchill Counsel for Applicant 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: March 18, 1983

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) )

CERTIFICATE OF SERVICE, This is to certify that copies of the foregoing

" Applicant's Request for Enlargement of Page Limitation" were served by deposit in the U.S. Mail, first class, postage prepaid, to all those on the-attached Service List, except that those marked with an asterisk were served by hand de-livery this 18th day of March, 1983.

/

s Bruce W. Churchill Dated: March 18, 1983 l

k.

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

• Stephen F. Eilperin, Esquire Atomic Safety and Licensing Administrative Judge Appeal Board Panel Chairman, Atomic Safety and U.S. Nuclear Regulatory Licensing Appeal Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Sheldon J. Wolfe, Esquire Administrative Judge

• Christine N. Kohl Chairman, Atomic Safety and Administrative Judge Licensing Board Atomic Safety and Licensing i U.S. Nuclear Regulatory Appeal Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr. Harry Foreman Administrative Judge

• Dr. W. Reed Johnson Director, Center for Population Administrative Judge Studies Atomic Safety and Licensing Box 395, Mayo Appeal Board University of Minnesota l U.S. Nuclear Regulatory Minneapolis, MN~ 55455 Commission Washington, D.C. 20555 Dr. Walter H. Jordan Administrative Judge

• Sherwin E. Turk, Esquire 881 West Outer Drive l Office of the Executive Oak Ridge, TN 37830 i Legal Director l U.S. Nuclear Regulatory Docketing and Service Section (3) l Commission Office of the Secretary l Washington, D.C. 20555 U.S. Nuclear Regulatory

! Commission Atomic Safety and Licensing Washington, D.C. 20555 l Board Panel j U.S. Nuclear Regulatory Mr. Gary Groesch Commission 2257 Bayou Road

, Washington, D.C. 20555 New Orleans, LA 70119 l

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4 Docket No. 50-382 Service List-ASLAB Page Two Luke B. Fontana, Esquire ,

824 Esplanade Avenue New Orleans, LA .70116 Brian Cassidy, Esquire Federal Emergency Management Agency Region I 422 J. W. McCormack Boston, MA 03109 Spence W. Perry, Esquire Federal Emergency Management Agency Office of General Counsel 500 C Street, S.W., Room 840 Washington, D.C. 20472

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