ML20148B427
| ML20148B427 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 12/12/1979 |
| From: | Leithauser J AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20148B410 | List: |
| References | |
| NUDOCS 8001220225 | |
| Download: ML20148B427 (2) | |
Text
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L 3EIATED MCTICN FOR UAVE TC FIU FCADING CUT CF TI:'E John A. leithauser, speaking on my own behalf, as well as that of the Northwest Coalition, hereby petitions the Board to grant this motion to file pleadings cut of time for the following reasons:
A. I had been unable to meet the schedule for the pre-hearing conference due to an excessively heavy personal schedule.
In September of 1979, I moved both both my heme an'. offices.
Not only did this entail the usual disruptien of normal events, but, due to a strict budget, it was necessary for me to perform numerous mechanical tasks including:
- 1) "take-down" of a mobile hcme (i.e. disconnect the various utilities, removal of jacks,-etc.);
- 2) set-up of said mobile home
- 3) moving a ten by six by eight foot entry shed;
- 4) hand-digging a sixty by three by one foct trench;
- 5) installing appropriate underground water line
- 6) installing a water pump;
- 7) determining static water level by inspectien
- 8) =ajor plumbing repairs:
- 9) major remodeling (wall tear-down):
10)_ installation of a chimney
- 11) installatien of a wood stove;
- 12) majcr insulating:
- 13) cut and collect fireweed:
- 14) numerous miscellaneous tasks.
It was additionally ne cessary for me to work in the employ of others for two-hundred and eighty hours during the peried of September ist through December 3rd.
- 3. Motions filed out of time are not prohibited by N.R.C.
regulations (reference Title 10, Chapter 1 C.F.R.
Energy Fart 2: 2-707; 2-7tha; 2-751a; and 2.756).
C. I had been completely unacquainted with N.R.C. rules, regulations and practices.
D. As the 5.E.R. and E.I.A. are estimated to be completed by mid-February 1980, filings of December 15th, 1979 should not interfere with the progress of these precedings.
E. I would have no difficulty in meeting the schedule approved by the Scard on December 5th, 1979 i
F. I have raised issues as yet unspoken to.
1 J
I G. Grant of this motien will not prejudice any party to the J
proceding.
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?cr goed cause shown the metien should be panted.
Respege-' ly su bmitted,
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- T John A. 7 'thauser for myself and for the Northwest Cealition 90030091
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