ML20049A836

Motion to Schedule Concluding Session of Hearing for Wk of 811019,in Order to Avoid Further Delay.Const Nearly Complete & Every Wk Is Crucial.Certificate of Svc Encl.Related Correspondence

ML20049A836
Person / Time
Site:	Summer
Issue date:	09/30/1981
From:	Knotts J SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8110020317
Download: ML20049A836 (4)

Text

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a I' # IiELATED CORDESPONDENCF

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, {. p e Date: September 30, 1981

. OCT I 1981 .

d. gl UNITED STATES OF AMERICA Orcr#Mg7 CxA NUCLEAR REGULATORY COMMISSION k '& d BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

' South Carolina Electric & )

Gas Company, et al. )

(Virgil C. Summer Nuclear cket No. 50-39 g ,ye,f,4 .

Station, Unit 1) ) g 9- O '\

APPLICAUTS' MOTION TO ~

N I.l ESTABLISH SCHEDULE .- OOIA _7 C)  % g & %r

%4e ,

As discussed during last week's hearings (Tr. 8 o J' 3890 and Tr. 4672 to 4679) Applicants are nost anxir,us to move forward to conclude the outstanding matters in this proceeding which now consist of the Board'c @mstions regarding seismology matters. The NRC Staff has reported that they would probably

! be unable to secure the attendance, during the week of

. October 12, 1981, of one or both of the key additional witnesses whom they would expect to call to sponsor Staff's. supplemental testimony and to respond to Board questions. That being the case, and since Applicants' key witnesses are unavailable for the weeks of October 26th and November 2nd, we believe it is nso3 imperative to schedule further proceedings for the week of llI October 19, 1981.

We recognize that the week of October 19th is not the most convenient one for the Board's witnesses (assuming that they appear and testify) and perhaps others as well. Nonetheless, we request that you ascertain whether it is at all possible for

'8110020317 810930 PDR ADOCK 05000395 (O PDR L _ _ -

them to rearranje their schedules or to give priority to this matter ove.r other activities, since hearings the week of October 19th would avoid delaying the' commencement of further proceedings to the week of November 9, 1981. Should the matter pending before the Appeal Board be unresolved prior to that week or should the resolution somehow affect the schedule, we could of course take up the question of rescheduling in a conference call.

With construction of the Virgil C. Summer facility nearly complete, every week is important, indeed crucial. The costs associated with delays in operation have been previously pointed out in our April 6, 1981 response to Fairfield United Action's Petition to Intervene at Appendix C-2 which was updated in the affidavit of Mr. Thomas C. Nichols, Jr. offered (but not I received) at Tr. 2891.

l For the foregoing reasons, Applicants urge the Board l

' to schedule the concluding session.of the hearing in this matter for the week of October 19, 1981.

Respectfully submitted,

%L '

Joseph Knotts, Jr.

Att'orn/B.

ey for Applicants' l

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

SOUTH CAROLINA ELECTRIC & ) Docket No. 50-395 OL GAS COMPANY and )

)

SOUTH CAROLINA PUBLIC SERVICE .)

AUTHORITY )

)

(Virgil C. Summer Nuclear )

Station) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion to Establish Schedule" in the above captioned matters, were served upon the following persons by deposit in the United States mail, first class postage prepaid this 30th day of September, 1981.

Herbert Grossman, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Board Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 ,

George Fischer, Esq.

l Dr. Frank F. Hooper Vice President and Group l School of Natural Resourced Executiva- Legal Affairs University of Michigan South Carolina Electric &

Ann Arbor, Michigan 48109 Gas Company Post Office Box 764 Mr. Gustave A. Linenberger Columbia, South Carolina Member, Atomic Safety and 29202 Licensing Board Panel U.S. Nuclear Regulatory Steven C. Goldberg,.Esq.

Commission Office of the Executive Washington, D.C. 20555 Legal Director U.S. Nucleur Regulatory Chairman, Atomic Safety and Commission Licensing Appeal Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Mr. Brett Allan Bursey Washington, D.C. 20555 Route 1, Box 93-C Littic Mountain, S.C. 20076

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Mr. Chase R. Stephens ,

John C. Ruoff Docketing and Service Section Post Office Box 96 Office of the Secretary Jenkinsville, S.C. 29065 U.S. Nuclear Regulatory Commission Robert Guild, Esq.

Washington, D.C. 20555 314 Pall Mall Columbia, South Carolina 29201 Richard P. Wilson, Esq.

Assistant Att'orney General South Carolina Attorney General's Office P.O. Box 11549 Columbia, South Carolina 29211 Y

(os,4ph B. Knbtts, Jr.

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