ML20071M560
| ML20071M560 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/21/1982 |
| From: | Lindsey I LOUISIANA, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8209270171 | |
| Download: ML20071M560 (6) | |
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$lflhp UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ETI$
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BR RWCF BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF MISSISSIPPI POWER & LIGHT COM-PANY DOCKET NOS.
50-416 MIDDLE SOUTH ENERGY, INC.
50-417 j
AND SOUTH MISSISSIPPI ELECTRIC POWER ASSN.
(Grand Gulf Nuclear Station, Units 1 and 2)
-MOTION FOR EXTENSION OF TIME l
On July 21, 1982 petitioner, State of Louisiana, (hereinafter " Louisiana") filed a " Petition to Participate i
as an Interested State...," by Assistant Attorney General Linda i
B. Watkins.
The NRC Staff and the Applicant having filed an-I I
swers and arguments to Louisiana's petition, Louisiana was ordered on August 31, 1982 to respond to their arguments that the petition be dismissed or denied by September 21, 1982.
Mrs. Watkins is no longer employed within the Louis-iana Department of Justice, her work load in the above incap-tioned matter having been assumed by the undersigned mover.
8209270171 820921 l
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Because of undersigned's unfamiliarity with the matter at hand, and realizing the importance of Louisiana's partici-pation in the instant proceeding, I quickly realized that I needed additional time within which to prepare Louisiana's response in order to do justice to the NRC, the Applicant i
and the State of Louisiana.
Consequently, on or about September 13, I attempted to contact Judge Laurenson to explain the situation to him.
Although I did not speak with him personally, Judge Laurenson's secretary explained to me the procedure to use in either the event that my request was agreeabic with both the NRC Staff and the Applicant or opposed by the NRC Staff and the appli-cant.
I immediately contacted the NRC Staff, specifically
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Mary Wagner, and the applicant, specifically Mark Wetterhahn and explained the situtation to them.
Ms. Wagner stated that she would take my request under advisement and get back in touch with me.
Mr. Wetterhahn, after discussing the matter 1
with his client, gave me his conditional agreement to honor l
Louisiana's request for additional time in which to_ respond.
Meanwhile, continuing to proceed with the investi-l gation and research necessary to respond as ordered, it was
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not until September 16, 1982 that I was even able to locate Louisiana's original petition in this matter.
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On Friday, September 17, 1982 Ms. Wagner informed me that the position of the NRC Staff was to oppose any re-quest for an extension of time by Louisiana.
Minutes later, Mr. Wetterhahn informed me that he was withdrawing his con-ditional approval and likewise would oppose any request for an extension of time.
Mover respectfully suggests that because of his unfamiliarity with practice before the NRC and specifically with the issues involved in the instant matter, that additional time is required in order for Louisiana to prepare an intelli-gible and acceptable response to the answers of the NRC Staff and the Applicant.
Accordingly, mover hereby requests that it be granted an additional twenty (20) days to respond to the arguments of NRC Staff and Applicant that the petition of Louisiana be dis-missed or denied.
Respectfully submitted, WILLIAM J. GUSTE, JR.
ATTO EY GENERAL J
FIAN dDUG INDQE1' Assistant ttorney Genera Louisiana Department of Justice 7434 Perkins Road, Suite C j
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Baton Rouge, Louisiana 70808 (504) 766-8610 l
AFFIDAVIT "I hereby certify that the foregoing motion was prepared by me and that the statements contained therein are true and correct."
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WAN DOUCLASg4INDSEtf
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Assistant Attorney GeneraY
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY MIDDLE SOUTH ENERGY, INC.
DOCKET NOS. 50-416 AND 50-417 SOUTH MISSISSIPPI ELECTRIC POWER ASSN.
(Grand Gulf Nuclear Station, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that a copy of " Motion for Extension of Time", dated September 21, 1982 in the above-captioned pro-ceedings, has been served on the following by deposit in the United States Mail, first class, this 21 day of September, 1982.
James A.
Laurenson, Chairman Mark J. Wetterhahn Atomic Safety and Licensing CONNER AND WETTERHAHN, P.C.
Board 1747 Pennsylvania Avenue, N.W.
U.S. Nuclear Regulatory Com-Washington, D.C.
20006 mission Washington, D.C.
20555 Glenn O.
Bright Mary E. Wagner Atomic Safety and Licensing U.S.
Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Office of the Executive Legal Commission Division Washington, D.C.
20555 Washington, D.C.
20555 Dr. Jerry Harbour Richard J.
Rawson Atomic Safety and Licensing U.S.
Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Office of the Executive Legal Commission Division Washington, D.C.
20555 Washington, D.C.
20555
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Connission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Secretary to the Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 ATTENTION: Docketing and Service Section
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