ML20127L849

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Motion for Continuance to File Brief.* Petitioner Requests Parties Be Allowed to Submit Brief on or Before 930215. W/Certificate of Svc
ML20127L849
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 01/19/1993
From: Kohn M
AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:
Atomic Safety and Licensing Board Panel
References
CON-#193-13554 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9301280027
Download: ML20127L849 (4)


Text

/13559' UNITED STATES OF AMERICA N[hk NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING DOARD "50 Jul 21 n2:57 Defore Adrainistrative Judgest Peter D.

Bloch, Chair Dr. James H.

carpenter Thomas D. Murphy

)

In the Matter of

)

)

Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY

)

50-425-OLA-3 at ab.,

)

)

Re: License Amendment (Vogtle Electric Generating

)

(transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2)

)

)

ASLBP No. 93-671-01-OLA-3 MOTION FOR CONTINUANCE TO FILE DRIEE On January 15, 1993 the Atomic Safety and Licensing Board issued a Memorandum and Order requesting the parties to submit briefs with the Board on or before January 29, 1993.

Petitioner, Allen L. Mosbaugh, through counsel, requests leave until February 15, 1993 to file the brief rcquested in the January 15, 1993 Order.

Petitioner's counsel socks this additional time due to a pending briefing schedule previously imposed in another matter and due to the press of other business which places an undue burden on petitioner's counsel if they are required to respond by January 29, 1993.

Petitioner's counsel has spoken with NRC Staff counsel, Charles A. Barth, who indicated that he does not oppose :such an extension providing all parties are granted until February 15, 1993 to respond to the Board's Order.

Petitioner's counsel has also spoken with counsel to the licensee, John Lamberski, who stated that his client would not consent to anything that would 9301200027 930119 PDR ADOCK 05000424 50 3 0

PDH

delay the proceedings.

WHEREFORE, Petitioner's counsel respectfully requests that the parties be allowed to submit a brief addressing the questions set out in the Board's January 15, 1993 Order on or before February 15, 1993.

Respectfully submitted,

[AL Michael D. Kohn KOHN, KOHN & COLAPINTO, P.C.

517 Florida Ave., N.W.

Washington, D.C.

20001 (202) 234-4663 Dated:

January 19, 1993 i --

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l UNITED STATES OF AMERICA U M m:C j

NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

'93 JM4 21 M2 :57 Before Administrative Judges:

i Peter B.

Bloch, Chair

'q g, 7,

Dr. James H. carpenter boun :. c,

, y; Thomas D. Murphy

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)

In the Matter of

)

)

Docket Nos. 50-424-OLA-3 1

GEORGIA POWER COMPANY

)

50-425-OLA-3 i

_qt i,

)

j-

)

Re: License Amendment (Vogtle Electric Generating

)

(transfer to Southern Nuclear) l Plant, Unit 1 and Unit 2)

)

)

ASLBP No. 9 3 -671-01-O LA-3 4

CERTIFICATE OF SERVICE l

I hereby certify that on January 19, 1993 copies of j.

Amendments to Petitioner to Intervene and Request for Hearing was l

cerved in the above-captioned proceeding, by facsimile upon the i

following:

Administrative Judge Peter B.

Bloch,' Chair Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 I

Administrative Judge i

Dr. James H.

Carpenter Atomic Safety and Licensing Board U.S.

Nuclear Regulatory Commission l

Washington, D.C.

20555 Administrative Judge Thomas D. Murphy Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 (continued on next page)

4 A

1 4

d I

Charles A.

Barth, Esq.

Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 i

1 John Lamberski, Esq.

Troutman Sanders Suite 5200 600 Peachtree Street, N.E.

Atlanta, GA 30308-2216 And, by first class mail, postage prepaid, this loth day of December, 1992, upon the persons listed on the following page:

  • Office of the Secretary

(* Original and two copies)

Attn: Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C.

20555 office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington, D.C.

20555

)

Michael D. Kohn Kohn, Kohn & Colapinto, P.C.

517 Florida Ave., N.W.

Washington, D.C.

20001 (202) 234-4663 Dated: January 19, 1993

. - -.