ML20071H091
| ML20071H091 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 05/23/1983 |
| From: | Edgar G, Luck W ENERGY, DEPT. OF, PROJECT MANAGEMENT CORP. |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| 75-291-12, NUDOCS 8305240503 | |
| Download: ML20071H091 (6) | |
Text
5/23JS3,
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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4Qp h
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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL OARD In the Matter of
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UNITED STATES DEPARTMENT OF ENERGY
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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION
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ASLBP Docket
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No. 75-291-12 TENNESSEE VALLEY AUTHORITY
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(Clinch River Breeder Reactor Plant)
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APPLICANTS' MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO INTERVENORS' BRIEF IN SUPPORT OF EXCEPTIONS The Department of Energy and Project Management Corporation, for themselves and on behalf of the Tennessee Valley Authority (the Applicants),hereby file this Motion for Extension of Time to file Response to Intervenors' Brief in Support of Exceptions.
In support of this Motion, Applicants state the following:
l 1.
Intervenors' Brief in Support of Exceptions was served by mail on May 18, 1983 and received by Applicants on May 20, 1983.
This brief addresses eighty-nine (69) exceptions, and involves matters of considerable complexity and importance to the Clinch River Breeder Reactor Plant (CRBRP) Project.
2.
Counsel for PMC has served as lead licensing counsel for the Project since 1973, and his extensive participation in l
preparation of Applicants' brief is considered essential to
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development of an adequate response.
A recent death in his family has and will require a substantial and unanticipated commitment of his time to estate administration matters through July of this year.
3.
During the period through July of this year, Applicants will be required to devote substantial efforts to a pending case in the United States District Court for the District of Columbia (NRDC v. Brewer, Civil No. 82-2706), and to preparation for commencement and completion of the CRBRP Construction Permit hearings.
(Pursuant to the Licensing Board's Order of March 29, 1983, hearings will commence on July 18, 1983.)
4.
The matters discussed above have resulted in a severe compression of. the efforts of Applicants' counsel, and an extension of time is necessary for Applicants to develop an adequate response.
5.
On April 4, 1983, the Appeal Board granted Intervenors' Motion for a thirty (30) day extension of time in which to file their brief.
Applicants raised no objection to Intervenors' Motion at that time.
6.
The undersigned believe that an extension of thirty days until July 22, 1983 will be sufficient to enable preparation of an adequate response.
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Applicants have contacted counsel for the NRC Staff and were advised that the NRC Staff has no objection to this Motion.
Applicants also contacted counsel for Intervenors and were advised that Intervenors have no objection to this Motion.
Accordingly, Applicants respectfully request a thirty-day (30-day) extension of time until July 22, 1983, in which to file a response to Intervenors' brief.
Respectfully submitted, f,2 GeorgeC27. Edgar f/'
j Attorney for Project Management Corporation tJ ks William D. Luck Attorney for United States Department of Energy DATED:
May 23, 1983
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
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In the Matter of
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UNITED STATES DEPARTMENT OF ENERGY
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PROJECT MANAGEMENT CORPORATION
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Docket No. 50-537
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TENNESSEE VALLEY AUTHORITY
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(Clinch River Breeder Reactor Plant)
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CERTIFICATE OF SERVICE Service has been effected on this date by personal delivery or first-class mail to the following:
Gary J. Edles Chairman Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission East-West Towers l
4350 East-West Highway l
Bethesda, Maryland 20014 (by hand)
Dr. W. Reed Johnson Atomic Safety & Licensing Appeal Board l
U. S. Nuclear Regulatory Commission East-West Towers 4350 East-West Highway Bethesda, Maryland 20014 (by hand)
Howard A. Wilber Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission East-West Towers 4350 East-West Highway Bethesda, Maryland 20014 (by hand)
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- Marshall E. Miller, Esquire Chairman Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 (2 copies)
Dr. Cadet H. Hand, Jr.
Director Bodega Marine Laboratory U iversity of California n
P. O. Box 247 Bodega Bay, California 94923
- Mr. Gustave A. Linenberger Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Stuart Treby, Esquire Sherwin E. Turk, Esquire Elaine I. Chan, Esquire Geary S. Mizuno, Esquire Office of Executive Legal Director U. S. Nuclear Regulatory Commission Maryland National Bank Building 7735 Old Georgatown Road Bethesda, Maryland 20014 (2 copies by hand)
- Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C.
20555
- Docketing & Service Section Office of the Secretary l
U. S. Nuclear Regulatory Commission Washington, D. C.
20555 (original, 3 copies, and return copy)
William M. Leech, Jr., Attorney General William B. Hubbard, Chief Deputy Attorney General Michael D. Pearigen, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 l
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1 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire W. Walter LaRoche, Esquire James F. Burger, Esquire Edward J. Vigluicci, Esquire Office of the General Counsel Tennessee Valley Authority 400 West Summit Hill Drive Knoxville, Tennessee 37902 (2 copies)
Dr. Thomas Cochran Barbara A. Finamore, Esquire Natural Resources Defense Council 1725 Eye Street, N. W.,
Suite 600 Washington, D. C.
20006 (2 copies by hand)
Ellyn R. Weiss, Esquire Harmon & Weiss 1725 Eye Street, N. W.,
Suite 506 Washington, D. C.
20006 Lawson McGhee Public Library 500 West Church Street Knoxville, Tennessee 37902 William E. Lantrip, Esquire Attorney for the City of Oak Ridge Municipal Building Post Office Box 1 Oak Ridge, Tennessee 37830 Leon Silverstrom, Esquire William D. Luck, Esquire i
U. S. Department of Energy 1000 Independence Avenue, S. W.
Room 6B-256--Forrestal Building Washington, D. C.
20.585 (4 copies by hand)
Eldon V. C. Greenberg, Esquire Galloway & Greenberg l
1725 Eye Street, N.W.,
Suite 601 Washington. D. C.
20006 l
Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, Tennessee 37219 M
CEorg g. Edgar, Ariorney for DATED:
Proj ect Management Corporation
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Denotes hand delivery to 1717 "H" Street, N.W., Washington, D.C.
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