ML20070D324

Ga Power Companys Motion for Extension of Time.* Requests That Board Grant One Week Extension to Util.W/Certificate of Svc & Svc List

ML20070D324
Person / Time
Site:	Vogtle
Issue date:	06/29/1994
From:	Blake E SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
CON-#394-15298 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9407080017
Download: ML20070D324 (4)

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DOCKETED June 29, {ljyjRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '94 JUN 30 P4 :15 Before the Atomic Safety and Licensing Board 0FFICE OF SECRETARY t i

DOCKETING & SERVICE BRANCH

)

In the Matter of ) Docket Nos. 50-424-OLA-3

) 50-425-OLA GEORGIA POWER COMPANY, )

et al. ) Re: License Amendment

) (Transfer to Southern (Vogtle Electric Generating ) Nuclear)

Plant, Units 1 and 2) )

) ASLBP No. 93-671-01-OLA-3 GEORGIA POWER COMPANY'S MOTION FOR EXTENSION OF TIME Georgia Power Company (GPC) hereby requests a short extension to respond to Intervenor's Request for Admissions to Georgia Power Company. Under the agreement reached at the May 26,1994 prehearing conference, GPC's response is due on June 30.

GPC requests that this date be extended by one week, until July 7.

This extension has proven necessary because of the enormity of Intervenor's request for admissions, which involves reviewing and addressing approximately 650 paragraphs from the 01 report. Our review has involved having each employee to whom a statement is attributed verify the accuracy of the statement, and in many instances this verification required listening to Mr. Mosbaugh's tapes to attempt to confirm NRC transcripts. This has been logistically difficult and very time-consuming. Review by counsel representing a number of individuals has also been necessary. Becuase of the size of this undertaking, and despite the devotion of considerable resources, we will be unable to complete the admis-sions by June 30.

I have spoken with the other parties in the hope of obtaining their consent to this motion, but have not been successful. While counsel for the NRC Staff consents to this l

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motion, counsel for Intervenor has indicated that he will agree only if he is granted an addi-tionii six days of discovery in August, plus a seventh day to depose Mr. Meier on illegal license trartsfer issues. Since the short delay in our admissions will not prevent Intervenor's depositions from proceeding, and in no way justifies reopening discovery on illegal license transfer issues, Intervenor's conditions do not appear reasonable.

Accordingly, Georgia Power Company requests that the Board grant the one week extension requested. Georgia Power Company will continue to work as rapidly as possible to complete the admissions, and will file its response before July 7 if it is able.

Respectf ully submitted, r

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Ernest L. Blake, Jr.

David R. Lewis SHAW PITTMAN POTTS & TROWBRIDGE 2300 N Street, N.W.

Washington, D.C. 20037 (202) 663 8000 John Lamberski TROUTMAN SANDERS 600 Peachtree Street, NE i l

Suite 5200 A tlanta, G A 30308-2216 l (404) 885 3360 Counsel for Georgia Power Company Dated: June 29,1994  ;

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00CKETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board '94 JJN 30 P 4 35 0FFICF OF SM #N

) 00CKETlHG & SERNlC' Docket Nos. 50-424-OLA-33g AHCh In the Matter of )

) 50-425-OLA-3 GEORGIA POWER COMPANY, )

et al. ) Re: License Amendment

) (Transfer to Southern (Vogtle Electric Generating ) Nuclear)

Plant, Units 1 and 2) )

) ASLBP No. 93-671-01-OLA-3 CERTIFIC ATE OF SERVICE I hereby certify that copies of " Georgia Power Company's Motion for Extension of Time," dated June 29, 1994, were served by deposit in the U.S. Mall, first class, postage prepaid, and where indicated by an astersik by f acsimile, upon the persons listed on the attached service list, this 29th day of June,1994.

A <

David Lewis Dated: June 29,1994 i

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UNITED STATES OF AMERICA INUCLEAR REGULATORY COMMISSION Before the Atomic Safety and_ Lice _nsing Board

)

In the Matter of ) Docket Nos. 50-424-OL A-3

) 50-425-OLA-3 GEORGIA POWER COMPANY, )

et al. ) Re: License Amendment

) (Transfer to Southern (Vogtle Electric Generating ) Nuclear)

Plant, Units 1 and 2) )

) ASLBP No. 93-671-01-O L A-3 SERVICE LIS_T

• Administrative Judge Offlee of the Secretary Peter B. Bloch, Chairman U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission ATTN: Docketing and Services Branch Washington, D.C. 20555

• Mitzi A. Young, Esq.

Administrative Judge

• Charles Barth, Esq.

James H. Carpenter Office of General Counsel Atomic Safety & Licensing Board One White Flint North 933 Green Point Drive Stop 15B18 Oyster Point U.S. Nuclear Regulatory Commission Sunset Beach, N.C. 28468 Washington, D.C. 20555

• Administrative Judge Director, Thomas D. Murphy Environmental Protection Division Atomic Safety & Licensing Board Department of Natural Resources U.S. Nuclear Regulatory Commission 205 Butler Street, S.E.

Washington, D.C. 20555 Suite 1252 Atlanta, Georgia 30334

• Michael D. Kohn, Esq.

Kohn, Kohn & Colapinto, P.C. Office of Commission Appellate 517 Florida Avenue, N.W. Adjudication Washington, D.C. 20001 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Stewart D. Ebneter Regional Administrator Adjudicatory File USNRC, Region II Atomic Safety and Licensing Board 101 Marietta Street, NW U.S. Nuclear Regulatory Commission Suite 2900 Washington, D.C. 20555 Atlanta, Georgia 30303 M:/0329/073DRL.94 ,

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