ML19296A162

Consents to Offshore Power Systems Motion That Direct Briefs Be Filed by 790105 & Reply Briefs by 790115.W/781222 Request for Extension of Time for Filing

ML19296A162
Person / Time
Site:	Atlantic Nuclear Power Plant
Issue date:	01/02/1979
From:	Conner T CONNER, MOORE & CORBER
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 7902080322
Download: ML19296A162 (1)

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Mr. Samuel J. Chilk

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In the Matter of Offshore Power Systems (Floating Nuclear Power Plants)

STN 50-437

Dear Mr. Chilk:

Today we received the telegraphic motion of Offshore Power Systems objecting to our letter request dated December 22, 1978, for an additional two weeks in which to file an amicus curiae brief pursuant to the Commission's Order dated December 8, 1978.

We note that OPS wi/Jhes the matter to be resolved as quickly as possible and moves that all direct briefs be filed not later than January 5, 1979, and all reply briefs by January 15, 1979. The intervencr, Natural Resources Defense Council, Inc., joins in the motion, and the Staff advises that it can meet the January 5 date for direct briefs.

Although we have not as yet received word ficm several clients who may wish to file, we consent to the revised schedule suggested by OPS in order to expedite the prompt resolution of this matter by the Commission. Accordingly, any direct brief that we may file will be submitted not later than January 5, and any reply brief by January 15, 1979.

Sincerely, 3

M. .

Troy 3. onner, Jr. O TBC/mwm cc: Service List 79020863 9

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=*"'2=3-=^^=3*- December 22, 1978 303327 M.EADRE (202) 833-3500 REITE at. ELL 2B h amastma sJ u CABLE ADDEES&* ATOMLAW Samuel J. ChiLk Secretary E U.S. Nuclear Regulatory p 4 Commission Washington, D. C. 20535 y f,o

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STN 50-437 E g P

Dear Mr. Chilk:

Pursuant to your authority under 10 C.F.R. 52. 772 (b) , we request an extension of time within which to file a brief as amicus curiae in the captioned matter. As you know, the Commission, by order date<1 December 8, 1978, accepted review of the question certified to it in ALAB-500 and encouraged amicus participation on the pending question of whether " Class 9 accidents are a proper subject for consideration in the staff's environmental statomant on the floating nuclear power plant application."

The record in this case is, of course, extremely voluminous.

The briefs of the parties and the decisions cf the boards below ccmprise several hundred pages. We have re"tewed die record to determine whether the material already on file adequately states the position our clients may wish to take in order to avoid the filing of redundant arguments as to the impact of extending the review of hypothetical Class 9 accidents to existing and planned land based facilities. This examination and analysis of the record has itself consumed' considerable time. We are now in the process of cb"4 M ng our clients' views to determine whether an amicus brief should be submitted.

The Commission's Order allowed only 21 days for submission of briefs without regard to mailing tize. In view of the ccmplicated nature of the issue presented and the additional time necessary to analyze our pcsition in light of the arguments already on record, the 21 day period provided is simply inadeqate.

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Samuel J. Chilk December 2.'., 1978 Page Two Accordingly, we request an extension of two weeks within which to file an amicus brief.

Thank you for your attention to this request.

Sincerely, N1. . , -

Troy B. Conner, Jr. C' TBC:dr cc: Service I tat

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