ML19206A167

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Licensees Reply to Intervenors Request for Extension of Time to File Response to ALAB-480.Certificate of Svc Encl
ML19206A167
Person / Time
Site: Crane 
Issue date: 06/19/1978
From: Trowbridge G
SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
References
NUDOCS 7904180351
Download: ML19206A167 (4)


Text

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O June 19, 197 3 UNITED STA"ES OF AMERICA NUCLEAR REGULATORY COMMISSION 3efore the Atanic Safety and Licensing Appeal Scard In the Matter of

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ME"'ROPOLITAN EDISON COMPArt,

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Occket No. 50-320 et al.

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.i (Three Mile Island Nuclear

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Station, Unit 2)

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LICENSEES' REPLY TO INTERVINORS' REQUEST FOR EX"'ENSION OF TDIE TO FILE RESPONSE TO ALAB-480 On June 11, 1978, Intervencrs filed a request for exten-sian of time to file a response to ALA3-480.

As Licensees under-stand Intervencrs' motion, Intervencrs request two extensions of time.

F ir s t, Intervencrs request that in the event the Perkins evidentiary record is received by Intervencrs before July 11, 1973, Intervencrs be granted at least 14 days from July 11, 1978, in which to request that additional written evidence be received, to request that a further hearing be held and/cr to object to any aspect of the Perkins raden proceeding, as permitted by paragraph numbered 3 at page 13 of ALA3-480 (slip Opinion).

Second, Intervencrs request that in the event the Licensing Scard's decision in the Perkins proceeding is served on Intervencrs prior to July 11, 1978, Intervencrs be granted at least 14 days from July 11, 1973, to file a memorandum en the two que'stions specified in paragraph nu=bered 4 at page 19 cf ALAS-480.50-025 7904180 3 57/

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Licensces have no objection to Intervenors' request for extension of time provided that szmilar extensions are also granted to Licensees.

Licensees urge a prcmpt decision by nhe Appeal Board on the matter of extensions of time in order that the parti es may schedule their -wcrk.

Intervenors base cheir request for extension of time solely on prior personal ecmmitments of their authcrized representative, Dr. Chatacey Kepford.

Licensees observe, however, that the exten-siens of

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if grated, may allcw time for thi Cc= mission to dispose of Intervenors' =ction dated June 12, 1973, to review and reverse ALA3-480 before the parties are requirec to take steps to implement ALA3-480.

Respectfully submitted, SHAW, PITTMAN, POTTS & T'.',CWBRIDGE M

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By A/

'G)torgW ?.

Trowcr dge

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Counsel for Licensees Dated:

June 19, 1978 50~02G

e June 19, 1973 UNITED STA"'ES CF AMERICA NUCI. EAR REGI.'.I.ATORY CCMMISSICN 3efc.te the Atomic Safety and Licensinc Appeal Board In the Matter of

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METRCPOLITAN EDISCN CCMPANY,

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Cocket No. 50-3IO en al.

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(Three Mile Island Nuclear

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Station, Unit 2)

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CERTIFICA*E OF SERVICE I hereby certify that a true and ccrrect copy of the foregoing " Licensees' Reply to Intervencrs' Request For Extension Of Tine To File Response to ALAB-480" dated June 19, 1973, has been served upon each of *he persens listed en the attached ser-vice list by nail, postage prepaid, this 19th day of June, 1973.

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GE f. TRCW3 ell M, ESQUZRE Dated:

June 19, 1978 50;0Z7

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O UNITED STATES CT AMERICA sJu.C. e h Ra.,- - m.nRv.

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u Before the Atomic Safety and Licensine Acceal Scard In the Matter of

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METRCPOLITAN EDISON CCMP ANY,

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Docket No. 50-320 et al.

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(Three Mile Island Nuclear

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Generating Stacion, Unit 2)

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SERVICE LIST Alan S.

Rosenthal, Esq., Chair an Henry J.

McGurren, Esq.

Atcmic Safety and Licensing Appeal Office of the Executive Lecal 3 card Director U.S. Nuclear Regulatory Cc= mission U.S.

Nuclear Regulatory Ccamission Washing cn, D.C.

20555 Washington, D.C.

20555 Dr.

W.

Reed Johnson, Member Karin W.

Carter, Esq., Assistant Atomic Safety and Licensing Appeal Atter..ey General 3 card Office of Enforcement U.S. Nuclear Regula: cry Cc= mission Department of Environmental Washington, D.C.

20555 Resources 709 Health and Welfare Building Jerome E.

Sharfman, Esq., Member Harrisburg, PA 17120 Atomic Safety and Licensing Appeal Scard Dr. Chauncey R.

Kepford C.S. Nuclear Regulatory Cc= mission 433 orlande Avenue Washington, D.C.

20555 State College, PA 16501 Edward Lucca, Esq.

Atomic Safety and Licensing Appeal Atomic Safety and Licensing Scard Scard Panel U.S. Nuclear Regulatory Cc= mission U.S. Nuclear Regulatory Cc=missicn Washing cn, D.C.

20555 Washington, D.C.

20555 Mr. Gustave A.

Linenberger Atomic Safety and Licensing 3 card Atcmic Safety and Licensing 3 card Panel U.S.

Nuclear Regula: cry Cc= mission U.S.

Nuclear Regulatory Commission Washington, D.C.

20555 Washing ca, D.C.

20555 Dr. Ernest O.

Salc Decketing and Service Section Professor, Eisheries Research Office of the Secretary Institute, WH-10 U.S. Nuclear Regula: cry Ccamission University of Washing On Washington, D.C.

20555 Seattle, WA 98195 t-00 LhzS