ML20065D738

Opposition to State of La 820721 Request for 20-day Extension of Time to Respond to ASLB 820831 Order.Request Excessive & Would Delay Operation.Certificate of Svc Encl

ML20065D738
Person / Time
Site:	Grand Gulf
Issue date:	09/27/1982
From:	Wetterhahn M CONNER & WETTERHAHN, MISSISSIPPI POWER & LIGHT CO.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8209300215
Download: ML20065D738 (3)

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4 000METEn USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION >82 SEP 29 A10:46 Before the Atomic Safety and Lic;ensing BoardlCE OF SECREW uuKETING & SEpygu' In the Matter of ) eRANCH

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MISSISSIPPI POWER & LIGHT ) Docket Nos. 50-416 COMPANY, et al. ) 50-417

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(Grand Gulf Nuclear Station, )

Units 1 and 2) )

APPLICANT'S OPPOSITION TO REQUEST FOR EXTENSION OF TIME BY STATE OF LOUISIANA On July 21, 1982, State of Louisiana, petitioner in the captioned proceeding, moved for a 20-day extension of time to respond to the Atomic Safety and Licensing Board's

(" Licensing Board" or " Board") " Order to Petitioner to Respond to Arguments of Staff and Applicant," dated August 31, 1982. The request for an extension had been anticipated in the undersigned counsel's letter to the Board dated September 20, 1982, which is incorporated herein as answer by the Mississippi Power & Light Company, et al.

(" Applicant") to petitioner's motion.

One point should be emphasized. The Applicant's

" conditional agreement" to which petitioner refers, while unexplained in the motion, constituted Applicant's qualified l

assent to additional time only if the extension would not i affect the operation of Grand Gulf Unit 1.

When it was determined that the requested extension could have the effect of delaying the unit's operation, 1

l 8209300215 820927

, PDR ADOCK 05000416 l

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counsel for the State of Louisiana was notified that Applicant could not stipulate to the requested extension, as explained in our letter of September 20, 1982.

Applicant submits that the requested extension of time has not been justified, is excessive in any event, and should be denied.

Respectfully submitted, CONNER & WETTERHAHN, P.C.

f hA4L Troy B. Conner, Jr.

Mark J. Wetterhahn Robert M. Rader Counsel for Applicant September 27, 1982 l

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f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

MISSISSIPPI POWER & LIGHT ) Docket Nos. 50-416 COMPANY, et al. ) 50-417

)

(Grand Gulf Nuclear Station, )

Units 1 and 2) )

o CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Opposition to Request for Extension of Time by the State of Louisiana,"

dated September 27, 1982 in the captioned proceeding have been served upon the following by der sit in the United States mail this 27th day of September, 1982:

James A. Laurenson, Chairman William J. Guste, Jr., Esq.

Atomic Safety and Licensing Ian Lindsey, Esq.

Board Peter M. Arnow, Esq.

U.S. Nuclear Regulatory Office of Attorney General Commission Department of Justice Washington, D.C. 20555 7434 Parkins Road, Suite C Baton Rouge, LA 70808 Glenn O. Bright Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry Harbour Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission -

Washington, D.C. 20555 Washington, D.C. 20555 Richard J. Rawson, Esq.

Robert B. McGehee, Esq. Counsel for NRC Staff Wise, Carter, Child Office of the Executive

& Caraway Legal Director P. O. Box 651 U.S. Nuclear Regulatory Jackson, Mississippi 39205 Commission Washington, D.C. 20555 Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 A 841

' Robert M. Rader I

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