ML20084P796

Response to NRC 840515 Motion for Further Extension of Time Until 840615 to Respond to Joint Intervenors Amended & Supplemental Motion to Reopen Contention 22.Motion Should Be Granted.Certificate of Svc Encl

ML20084P796
Person / Time
Site:	Waterford
Issue date:	05/17/1984
From:	Blake E LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
OL, NUDOCS 8405180431
Download: ML20084P796 (4)

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May 17, 1984 UNITED STATES OF AMERICA Of, gg NUCLEAR REGULATORY COMMISSION '

Before the Atomic Safety and Licensing Ahe@!ySQ,ard

'" E10:41 OFr n-In the Matter of ) Sn ,;,

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' 2;1h SGik LOUISIANA POWER & LIGHT COMPANY ) Docket No. 5'00 382 0L

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(Waterford Steam Electric Station, )

Unit 3) )

APPLICANT'S RESPONSE TO NRC STAFF'S MOTION FOR FURTHER EXTENSION OF TIME On May 15, 1984, the Staff requested a further extension of time, until June 15, 1984, to respond to Joint Intervenors'

" Amended and Supplemental Motion To Reopen Contention 22."

Applicant continues to believe that Waterford 3 will be physically ready for fuel loading by the end of May. We under-stand, however, that the Staff intends to complete its ongoing review with respect to the basemat before the Director of Nuclear Reactor Regulation would authorize fuel loading. We also understand that the Staff's response to Joint Intervenors' motion is awaiting completion of the Staff review, although we believe that the motion should be denied for the reasons set out in our filing of January 13, 1984.

Applicant does not oppose the Staff's request for extension, and we would hope that the Staff will not need or use the entire additional month it has requested.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By

• Nh, 8405180431 840517 Ernest L. Blake, Jr., P.C.

PDR G ADOCK 05000382 Counsel for Applicant PDR 1800 M Street, N. W.

Washington, D.C. 20036 Dated: May 17, 1984 (202) 822-1000 /7 02

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l' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board i

i In the Matter of )

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LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-362 i

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(Waterford Steam Electric Station, )

Unit 3) )

CERTIFICATE OF SERVICE 1

This is to certify that copies of the foregoing " Applicant's Response to NRC Staff's Motion for Further Extension of Time" were served, by deposit in the United States mail, first class, postage prepaid, to all those on the attached Service List, except those marked with an asterisk were served by hand delivery I this 17th day of May, 1984.

f d 't . 4 4 4 ) , ,

Ernest L. Blake, Jr., P.C.

Dated: May 17, 1984

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

)

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

)

(Waterford Steam Electric )  :

Station, Unit 3) )

SERVICE LIST Christine N. Kohl Sheldon J. Wolfe -

Administrative Judge Administrative Judge Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Board Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 '

W. Reed Johnson Harry Foreman Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission Director, Center for Population >

Washington, D.C. 20555 Studies Box 395, Mayo '

Howard A. Wilber University of Minnesota Administrative Judge Minneapolis, MN 55455 Atomic Safety and Licensing Appeal Board Walter H. Jordan U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C. 20555 Atomic Safety and Licensing Board Sherwin E. Turk, Esquire 881 West Outer Drive Office of the Executive Oak Ridge, TN 37830 Legal Director U.S. Nuclear Regulatory Commission Docketing & Service Section (3)

Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

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LP&L Service List-ASLAB Page Two Mr. Gary Groesch, Luke B. Fontana, Esquire 2257 Bayou Road 824 Esplanade Avenue New Orleans, LA 70119 New Orleans, LA 70116 Brian Cassidy, Esquire Spence W. Perry, Esquire Federal Emcrgency Management Federal Emergency Managernent Agency Agency Region I Office of the General Counsel 422 J. W. McCormack 500 C Street, S.W., Room 840 Boston, MA 03109 Washington, D.C. 20472 Carole H. Burstein, Esquire 445 Walnut Street New Orleans, LA 70118

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