ML20079J346

Motion for Enlargement of Time Until 830131 to File Exceptions to ASLB 821214 Partial Initial Decision.Delay Needed Since Decision Is Extensive & Counsel Is Involved W/ Litigation in Federal Courts.Certificate of Svc Encl

ML20079J346
Person / Time
Site:	Callaway
Issue date:	12/23/1982
From:	Chackes K CHACKES & HOARE, JOINT INTERVENORS - CALLAWAY
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
ISSUANCES-OL, NUDOCS 8212280179
Download: ML20079J346 (3)

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI6NgEP BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD R DEC 27 P4:07 In the Matter of ) . ,

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UNION ELECTRIC COMPANY ) Docket No.j5T{lpoe483-OL

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(Callaway Plant, Unit 1) )

MOTION FOR ENLARGEMENT OF TIME TO FILE EXCEPTIONS TO PARTIAL INITIAL DECISION Come now Joint Intervenors Coalition for the Environment, St. Louis Region; Missourians for Safe Energy; and Crawdad Alliance, by their undersigned counsel, and respectfully request an enlargement of time to file their exceptions to the Partial Initial Decision served December 14, 1982. Joint Intervenors seek until January 31, 1933 to file their exceptions. The grounds for this motion are set out below:

1. The Partial Initial Decision of the Atomic Safety and Licensing Board was served by mail December 14, 1982, making exceptions due by December 29, 1982.

2. The subject decision concludes, in essence, that' the requested operating ,

license may be issued notwithstanding Joint Intervenors' contentions regarding the failure of the Applicant's quality assurance program and serious safety-related construction <

deficiencies. The decision is 111 pages long and arises out of hearings which generated a transcript of over 2,000 pages (excluding prefiled testimony). Extensive review and l

analysis is required to properly frame ecxeptions.

3. The undersigned counsel has been and is involved in major litigation in the federal courts, including a metropolitan school desegregation case (Liddell v. Board of l

l Education of the City of St. Louis, No. 72-100C(4) (E.D.Mo.)), and another matter set for trial January 10,1982 (Clay v. Sauer, No.81-77C(5) (E.D.Mo.)). Those cases, and a vacation scheduled for January 15-24, 1982, have prevented and will prevent the undersigned from preparing the subject exceptions before the end of January 1983.

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4. The undersigned has been authorized to represent herein that Applicant is not opposed to this Motion. Counsel for the NRC Staff has not yet expressed their position.

WlIEREFORE, Joint Intervenors respectfully request an enlargement of time until January 31, 1983 in which to file their exceptions to the Partial Initial Decision served December 14, 1982.

F.espectfully submitted, CHACKES, HOARE & SEDEY h

Kenneth M. Chackes Attorneys for Joint Intervenors 314 North Broadway St. Louis, Missouri 63102 314/241-7961 i

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )

)

UNION ELECTRIC COMPANY ) Docket No. STN 50-483-OL

)

(Callaway Plant, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of Joint Intervenors' Motion for Enlargement of Time have been served on the folloiwng by deposit in the United States mail this 23rd day of December,1982.

Chairman

- Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James P. Gleason, Esq., Chairman Atomic Safety and Licensing Board 513 Gilmoure Drive Silver Spring, MD 20901 Mr. Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.

Washington, D.C. 20036 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

Roy P. Lesey, Jr., Esq.

Office of the Executive Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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11 Kenneth M. Chnckes

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