ML19210B463

Applicant'S Answer to AEC Motion for Postponement of Public Hearings.Agrees to Postponement But Requests Commencement of Hearings No Later than 680412

ML19210B463
Person / Time
Site:	Three Mile Island
Issue date:	03/13/1968
From:	Charnoff G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 7911080686
Download: ML19210B463 (2)

Text

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\' UNITED STATES OF AMERICA ,

ATOMIC ENERGY COMMISSION j_ /S 6 Y In the Matter of METROPOLITAN EDISON COMPANY Docket No. 50-289 Three Mile Island Nuclear Station .

Unit No. 1 - -

ANSWER OF THE APPLICANT, .

TO THE AEC'S REGULATORY STAFF'S MOTION FOR POSTPONEMENT OF PUBLIC HEARING

1. On March 12, 1968, the AEC Regulatory Staff filed with the Atomic Safety and Licensing Board a motion for the post-ponement of the public hearing in this matter which had been scheduled ror April 10, 1968, pursuant to the Order of the Board, issued February 13, 1968.

2. The Regulatory Staff has requested that the public hearing be postponed to April 25, 1968.

3 The Applicant proposes to file its prepared testi-mony in this proceeding on March 19, 1968. That testimony will deal with all matters relevant to the issues set forth in the Notice of Hearing issued on January 24, 1968, and published in the Federal Register on January 27, 1968 (33 F.R. 1082), except with respect to the possibility of an airplane hitting the Three Mile Island Station while arriving at, or departing from, Olmsted State Airport and the capability of the station to safely withstand such an unlikely event. The latter m&cterr are described in Appli-cant's Amendments'8 and 9 which were filed on February 26 and March 6, 1968, and will be discussed in supplemental prepared testimony which 1584 101 ,791 1 0 8 0 6 K G/

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-g-will be filed with the Board on approximately April 15, 1968.

4. The Applicant filed its application on May 3, 1967, for a construction permit and operating license relating to its proposed Three Mile Island Nuclear Station Unit 1. The Three Milo Island $tation is scheduled for commercial operation on May 1, 1971.

The availability of the station on May 1, 1971., is required to assure that Applicant will have sufficient plant capacity to meet its requ.iremen.ts and those of the General Public Utilities system and those of the Pennsylvania-New Jersey-Maryland.(PJM) pool with which the Applicant is 'issociated. To meet such schedule, the Applicant must commence construction of the station, pursuant to an AEC construction permit, as close to May 1, 1968, as is reasonably possible. -

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5 While the Applicant consents to the granting of the AEC's Regulatory Staff's Motion for Postponement, Applicant urges that the public hearing commence no later than April 25, 1968, to permit reasonable adherence to the construction schedule.

Respectfully submitted, SHAW, PITTMAN, POTTS TROWBRIDGE & MADDEN By Gerald Charnoff ,

Counsel for Metropolftan Edison Company Dated: March 13, 1968 102 1584