ML19206A334
| ML19206A334 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/27/1977 |
| From: | Kepford C CITIZENS FOR SAFE ENVIRONMENT |
| To: | |
| Shared Package | |
| ML19206A336 | List: |
| References | |
| NUDOCS 7904190328 | |
| Download: ML19206A334 (3) | |
Text
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NUCLZA2 RT.JTL1 C2! CC10C33:CN 4
Befers the Atc:::ic Safety a=d Licamd g Sca:i g
b the.".atter of
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"etropolitan F41sen Cc=pa=7, et al.
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Generati=g Statics, Unit 2)
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ENEN RS' RF.FLT *O APPLICATI'S HC* C?! FCR E!CION CF ~~1C Cn August 25,1.977, the Eterveners received the Applicant's =otion recuesting the 3 card to grant a two day extensica of
'4 e to file a rescense to the hterveners' f*-A*
gs of fact and conclusions of lav.
For resscus set forth belev, the Interveners oppose this notion.
Se Applicant !.nt ntas that the Intervencrs filed a false Certificate d
of Service, dated Acqust 15,1,.'7, and, is reality, =ciled their f*-d*
?s en August 16, 1977. Se Applicant's suggestien is false. Intervencrs' f*-"* cs of fact and cenc1:siens of lav vere nailed shortly before 7:CC F.E en Yenday, August 15, 1977, at the State Conege, Penns7 7a=ia, U.S. rest 1
Cffice. ?ney were placed in the special bc= cffering a State College post-nark precisely so that 'he tine and place of -d c veuld appear en Se envelep.
"'his was icne after having received assurances f cza the Post Cffice in State College dat nail deposited by 7:C0 F.E veuld be post n-ked prior to =idnight of the ss=e day. Se attached Certificate of Se:-rice with de Stervencrs' f"dag ecrrectly states the date of the filing en Angest 15, 1977, is accordance vi d 10 CFR Part 2.712 (d) and (e).
- he Applicant had previces27 reccested to send a nessenger to State Conege to pick up a ecpy cf the Etervencrs' fi-d'-~s.
21s request was ul'c.ately denied bf the Interveners fcr two basic reascns:
(1) dne to the Ete.-vancrs ' perpetual shcr: age of f*-ences and
_a=pcver, eere was o var of :cevi=g deferena=d enac :7 ten
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s}'La _ngi 1 ir 7804190 3)22 G
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7 the Wteered y, hg veuld be c4vted, when the reproduction of the reqcired ::=cer of ecpies vecid be ~
done, s.=d when the f*-d*
- s veuld act
- :,"y be read ; and 7
(2) the request of the lipplicant to obtain a ecpy of the fd-d*
Is en An; st 15, 1977, was Tieved b7 the Eterveners as an
=derhanded atte=pt to get an extra fm days to rescend to the Interveners' f*'*.g, an advantage not scught by er available to the other parties.
he Applicant be=es:s the fact that the htervmors ' f4'
- g was post-
=ad ed Ang:st lo, 1977, and was act delivered un'd_1 ing.st 20 1977.
~:he 3
inteneners can cake no respcasibility for the idicuperecies cf the U. S. 'nd ' 5 Etervencrs =cte that, according to the schedule ag eed upcn by the parties en July 5, 1977, the findings of fact cf the Staff were to have been filed en Aug.st 19, 1977. As of the delivery of - to the htervencrs' antherized representative en August 27:. 1977, this filing had not been received. htervencrs therefore cenclude ene er =cre of the folleving evento occur ed:
(a) the Staff =ade no such timely fd'*
c; (b) the f*'i g of the Staff was =ade late:, andvill go : detected since 2.0 f"d gs ars =ade withent pc:st= arks >-
(c) the U.S. ::. ail takes =cre than eight i 73 to travel f::'en ined -y~n, D.C., to State College, ?1., as ec= pared with the ac"al f =r day delivery ti=e abc'it which the Applicant has ccmplained.
%a h*erveners therefore opcose the A Olicant's =ction en the ; en=da that it lacks justification.
Respectf=117 cab =itted,
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17 Chaence7 3. Iepford Representative of the Etervencre
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August 27, 1977
[l 27 f?
$ 5 G ' 8 2 j :. f $ ( c( $ 6 !
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