ML20073D699

Request for Extension Until 830427 to File Opposition to Wisconsin Environ Decade Brief on Exceptions.Counsel Has Numerous Obligations Before ASLB & Aslab.Certificate of Svc Encl

ML20073D699
Person / Time
Site:	Point Beach
Issue date:	04/11/1983
From:	Churchill B SHAW, PITTMAN, POTTS & TROWBRIDGE, WISCONSIN ELECTRIC POWER CO.
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
ISSUANCES-OLA1, NUDOCS 8304140124
Download: ML20073D699 (4)

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April 11, 1983 Jcq l q

UNITED STATES OF AMERICA 'g3 NUCLEAR REGULATORY COMMISSION Ab? 13

] AIO:01 Before the Atomic Safety and Licensing Appeal Board- m i 'n

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=]I$l,};l' In the Matter of )

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} WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266 (OLA1) 1 ) 50-301 (OLA1) 2 (Point Beach Nuclear Plant, )

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' Units 1 and 2) )

LICENSEE'S REQUEST FOR AN EXTENSION OF 1 TIME TO FILE BRIEF IN OPPOSITION TO INTERVENOR'S EXCEPTIONS f

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$ On March 16, " Decade's Brief In Support of Its Exceptions j

To Board's Initial Decision" was filed in the above-captioned 1

(" sleeving") proceeding. Licensee's brief in opposition to

! Decade's exceptions is presently due April 20, 1983, with the NRC Staff's brief due May 2, 1983.

I j Counsel for Licensee have numerous other obligations before

.g the Appeal Board and Licensing Boards, necessitating additional J

! time to respond to intervenor's brief. Specifically, counsel

$ for Licensee are concurrently preparing for an April 19 oral argument before the Appeal Board on numerous exceptions by inter-1 i

venors to the Waterford 3 Licensing Board's partial initial de-4 l cision on emergency planning, and must attend the Appeal Board's l April 18 tour of the Waterford 3 site. In addition, counsel for l Licensee are preparing proposed findings of fact and conclusions i

! of law on the reopened evidentiary hearings in the Waterford 3 1

i proceeding, which are due to the Licensing Board there on April 22, 1983. .

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i C304140124 830411

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PDR ADOCK 05000266 PDR O  ;

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Counsel for Licensee are also presently assisting in the preparation of responses to the detailed technical questions posed by this Appeal Board in the related Wisconsin Electric steam generator replacement proceeding; those responses are due April 29, 1983. In addition, the defaulting petitioner in that proceeding (the intervenor in the above-captioned proceeding) has just filed with the Commission itself a petition for the review of the Appeal Board's March 22, 1983 decision in that case, to which counsel for Licensee must respond. See " Petition For Review of Appeal Board's Decision" (April 7, 1983).

Accordingly, pursuant to 10 C.F.R. S 2.711, Licensee respectfully requests that the Appeal Board extend the time for filing of Licensee's opposition to Decade's brief on its excep-tions by one week, to April 27, 1983. Counsel for Licensee has contacted counsel for the NRC Staff, who does not oppose Licensee's request, and seeks a corresponding one week extension of time for the filing of the Staff's brief (to May 9, 1983). Counsel for Licensee has also contacted Decade's representative, Mr. Anderson, who opposes the requested extension of time due to the imminence of sleeving operations at Point Beach. However, Decade did not request a stay pursuant to 10 C.F.R. S 2.788. Therefore, no party would be prejudiced by the requested extension.

Respectfully submitted, SHAW, PITTMAN, PC{TS & ROWBRIDGE By . VE J V Bruce W. Churchill Delissa A. Ridgway Counsel for Licensee Dated: April 11, 1983 202/822-1000

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board In the Matter of )

i WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266 (OLA1) l

) 50-301 (OLA1) '

(Point Beach Nuclear Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE  !

r I hereby certify that copies of " Licensee's Request For i An Extension of Time to File Brief In Opposition To Intervenor's Exceptions" were served upon those persons on the attached Service List by deposit in the United States mail, postage pre-paid, this lith day of April, 1983, except that Decade has been served by deposit with Federal Express, this lith day of April, 1983.

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' 'Qelissa AS RlBgfjy q Dated: April 11, 1983 .

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION j Before the Atomic Safety and Licensine Apoeal Board j In the Matter of )

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WISCONSIN ELECTRIC POWER COMPANY ) Docket No. 50-266-(oLA1)

) 50-301 (OLA1)

(Point Beach Nuclear Plant, )

-Units 1 and 2)

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SERVICE LIST i

• Thomas S. Moore, Chairman Atomic Safety and Licensing Board Atomic Safety and Licensing Panel Appeal Board U. S. Nuclear Regulatory Commiscion U. S. Nuclear Regulatory Washington, D. C. 20555 Commission

Washington, D. C. 20555 Atomic Safety and Licensing Appeal Board Panel

• Dr. W. Reed Johnson U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D. C. 20555 Appeal Board 4 U. S. Nuclear Regulatory Docketing and Service Section j Commission . Office of the Secretary Washington D. C. 20555 U. S. Nuclear Regulatory Commission Washington, D. C. 20555

*Dr. Reginald L. Gotchy Atomic Safety and Licensing Stuart A. Treby, Esquire Appeal Board Office of the Executive Legal Directo&

U. S. Nuclear Regulatory U. S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 i

Richard G. Bachmann, Esquire Peter B. Bloch, Chairman Office of the Executive Legal Directo(

. Atomic Safety and Licensing U. S. Nuclear Regulatory Commission 1 Board Washington, D. C. 20555

) U. S. Nuclear Regulatory l Commission Myron Karman, Esquire i Washington, D. C. 20555 Office of the Executive Legal Directo$

U. S. Nuclear Regulatory Commission Dr. Hugh C. Paxton Washington, D. C. 20555 1229 - 41st Street Los Alamos, New Mexico 87544 Peter Anderson Wisconsin's Environmental Decade

, Dr. Jerry R. Kline 114 North Carroll Street Atomic Safety and Licensing Suite 208 i

Board Madison, Wisconsin 53703 >

U. S. Nuclear Regulatory j

Commission -

Washington, D. C. 20555 .

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• Hand Deliver ,

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