ML19296D506

Response in Opposition to Doi 800215 Motion for Extension Until 800414 to File Brief Amicus Curiae.Motion Filed at Last Day of Permitted Period.Certificate of Svc Encl

ML19296D506
Person / Time
Site:	Skagit
Issue date:	02/22/1980
From:	LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL, PUGET SOUND POWER & LIGHT CO.
To:	NRC COMMISSION (OCM)
References
NUDOCS 8003040698
Download: ML19296D506 (5)

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C- U 1 e: e sear UNITED, STATES OF AMERICA k t.3$ ' I NUCLEAR REGULATORY COMMISSION 9

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BEFORE THE COMMISSION Y In the Matter of )

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PUGET SOUND POWER & LIGHT ) DOCKET NOS.

COMPANY, et al. ) 50-522

) 50-523 (Skagit Nuclear Power Project, ) February 22, 1980 Units 1 and 2) )

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OBJECTION TO DEPARTMENT OF INTERIOR'S MOTION FOR EXTENSION OF TIME In an order dated January 16, 1980, the Commission invited the Department of Interior to express its views as an amicus curiae on an issue under review by the Commission. The Commission required that written briefs on the issue be filed no later than thirty (30) days after the date of the Order. Hence, all briefs were due by February 15, 1980.

On February 15, 19 80--the last day of the time period for briefs--the attorney for the Secretary of Interior filed a motion for an extension of time to April 14, 1980 to file a brief amicus curiae. The only reason that was offered for the extension was "more press 1.lg business." Clearly, this does not constitute good cause, which is required by 10 CFR 2.711 for an extension of a time limit. For this reason, Interior's 80**040(ca]q

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motion for an extension of time, which was filed at the last possible moment, must be denied.

DATED this 22nd day of February, 1980.

Respectfully submitted,

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Counsel for Puget Sound Power

& Light Company Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue, NW Washington, DC 20036

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UNITED STATES OF AMERICA - 990g 6pe#I '

NUCLEAR REGULATORY COMMISSION 9 "MO 9

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BEFORE THE COMMISSION b 7 In thc Matter of )

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PUGET SOUND POWER & LIGHT COMPANY, ) DOCKET NOS. 50-522 et al. ) 50-5:3

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(Skagit Nuclear Power Project, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that cocies of the following:

OBJECTION TO DEDARTMENT OF INTERIOR'S MOTION FOR EXTENSION OF TIME in the above-captioned proceeding have been served upon the following persons by personal service or deposit in the United States mail with proper postage affixed for first class mail this 22nd day of February, 1980: .

Chairman John F. Ahearne Commissioner Peter A. Bradford U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Commissioner Victor Gilinsky Commissioner Joseph M. Hendrie U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Pashington, D.C. 20555 Commissioner Richard T. Kennedy Valentine B. Deale, Chairman U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, D.C. 20555 1001 Connecticut Avenue, N.W.

Washington, D.C. 20036

Dr. Frank F. Hooper, Member Keven M. Ryan, Esq.

Chairman of Resource, Ecology, Assistant Attorney General Fisheries and Wildlife Temple of Justice University of Michigan Olympia, WA 98504 School of Natural Resources Ann Arbor, MI 48109 Robe rt C. Schofield, Director Skagit County Planning Gustave A. Linenberger, Member Department Atomic Safety and Licensing Board 218 County Administration Bldg.

U.S. Nuclear Regulatory Commission Mount Vernon, UA 98273 Washington, DC 20555 Richard M. Sandvik, Esq.

Alan S. Rosenthal, Chairman Assistant Attorney General Atomic Safety and Licensing 500 Pacific Building Appeal Board 520 S. W. Yamhill U.S. Nuclear Regulatory Commission Portland, OR 97204 Washington, DC 20555 Robert M. Leed, Esq.

Dr. John H. Buck, Member Room 610 Atomic Safety and Licensing 1411 Fourth Avenue Building Appeal Board Seattle, WA 98101 U.S. Nuclear Regulatory Commission Washington, DC 20555 CFSP and FOB Eric Stachon Michael C. Farrar, Member 2345 S. E. Yamhill Atomic Safety and Licensing Portland, OR 97214 Appeal Board U.S. Nuclear Regulatory Commission Robert Lowenstein, Esq.

Washington, DC 20555 Lowenstein, Newman, Reis,

. Axelrad & Toll Docketing and Service Section 1025 Connecticut Avenue, NW '

Of fice of the Secretary Suite 1214 U.S. Nuclear Regulatory Commission Washington, DC 20036 Wasn;_'.gton, DC 20555 (original and 20 copies) Warren Hastings, Esq.

Richard L. Black, Esq. Associate Corporate Counsel Counsel for NRC Staf f Portland General Electric U.S. Nuclear Regulatory Commission Conpany Office of the Executive Legal 121 S. W. Salmon Street Direc to r Portland, OR 97204 Washington, DC 20555 James W. Durham Nicholas D. Lewis, Chairman Portland General Electric Energy Facility Site Evaluation Company Council 121 S. W. Salmon Street 820 East Fifth Avenue Portland, OR 97204 Olympic, WA 98504

Richard D. Bach, Esq.

Stoel, Rives, Boley, Fraser and Wyse 2300 Georgia Pacific Bldg.

900 S. W. Fifth Avenue Portland, OR 97204 Canadian Consulate General Donald Martens, Consul 412 Plaza 600 6th and Stewart Street Seattle , WA 98101 Patrick R. McMullen, Esq.

Skagit County Prosecuting Attorney Courthouse Annex Mount Vernon, WA 98273 Russel W. Busch, Esq.

Evergreen Legal Services 520 Smith Tower 506 2nd Avenue Seattle, WA 98104 Charles E. O'Connell, Jr.

Of fice of the Solicitor Department of the Interior Washington, DC 00M Counsel for Puget Sound Power &

Light Company Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue, NW Washington, DC 20036