ML19220A304

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Motion for Extension of Time Until 781117 for Filing Testimony.Certificate of Svc Encl
ML19220A304
Person / Time
Site: Crane 
Issue date: 11/15/1978
From: Chandler L
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
References
NUDOCS 7904170388
Download: ML19220A304 (4)


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11/10/73

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NUCLEAR REGULATCRY CO'd.'JISSION

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BE THE ATCMIC S AFETY AND L* CENSING APPEAL ECARD

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METROPOLITAN EDISON CC.'.iPANY,

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Docket No.

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) For the Appea! Board (Three Mile Island Nuclear Station,

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By Order dated Cctcber 10,1C73, the Atomic Safetf and Licensing Appeal Beard extended the date for fiting testimonf in the captiened proceeding to November 17, 1978.

Although the NRC Staff has been diligent in

.s efferts to meet that deadline, we now find that unanticipated events =ake : possible to enlf :ile partial testi-many. First, more time than expected was necessary to manually search cid accident data which is net available frem ccmputer scurces. Second

. alter-able prier Sta.fi ec=mitments have severely limited availability of a number cf key individuals, particuarly these involved in preparin-the statistical analyses.

5 Third, it was discovered last week that some ecmputer tapes frem the National Archives which cent...

sigrificant infermation en operations at Harrisburg Internaticnal Airport were unusable; efforts are still underway to extract as much information as possihlc frem *hese tapes. Fourth, testimenv frcm non-NRC witnessec 'ccated out-of-town was received late en November 9,1973 and 7 ; - o.y0 L.

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O-s is not considered to be adequate in its present form. Further communication and transmittal of documents between the Staff and these individuals is neces-sary before the testimony can be finali:ed and this cannot be completed by November 17. Accordingly, while much data has been gathered and is avail-able*, it has not been possible to complete preparation of testimony as originally anticipated.

Consequently, the NRC Staff respectfully moves for an extension of time, until November 30, 1973, in which to complete the filing i..f its testimony. We have contacted counsel for the Applicant and Dr. Kepford and are authorized to represent that they have no objection to the extension recuested.

Respe'ctfully submitted,

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Hjl8W Lawrence J. Chandler Counsel for NRC Staff Dated at Bethesda, Maryland this 15th day of November,1978 The Staff will file on November 17, 1978 testimony addressing Questions 1, 2 and 5 contained in ALA3-486. As testimony addressing the other matters raised by the Appeal Board and Commission is finalized between Novem-ber 17 and 30, it will immediately be filed.

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UNITED STATES OF ALIERILA NUCLEAR REGULATORY COhih1ISSION BEFORE T'-!E ATOh1IC SAFETY AND LICENSING APPEAL BOARD In the hiatter of

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Docket No. 50-320

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D CERTIFICATE OF SERVICE

/igti I hereby certify that copies of 9.fCTION FOR EXTENSION CF TILE FOR FILING TESTIh10NT' in the above-captioned proceeding have been served en the follcwing by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regualtory Commission's inter-nal mail system, this 15th day of November,197E:

Alan S. Rosenthal, Esq., Chairman" hir Gustave A. Linenberger" Atomic Safety and Licensing Appeal Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C.

20555 George F. Trowbridge, Esq.

Dr. W. Reed Jonnson, hiember" Shaw, Pittman, Potts L Trowbridge Atomic Safety and Licensing Appeal 1800 hi Street, N. W.

Panel Washington, D. C. 20036 U.S. Nuclear Regulatory Commission Washington, D. C.

20555 Dr. Ernest O. Salo Professor, Fisheries Research Jerome E. Sharfman, Esq., hiember" Institute, WH-10 Atomic Safety and Licensing Appeal College of Fisheries Panel University of Washington U.S. Nuclear Regulatory Commission Seattle, Was%gton 98195 Washington, D. C. 20555 Dr. Chauncey R. Kepford Edward Luton, Esq., Chairman

  • Citi:: ens for a Safe Environment Atomic Safety and Licensing Board 433 Orlando Avenue U.S. Nuclear Regulatory Commission State College, Pennsylvania le301 Washington, D. C. 20555 6 4 ' '* "Y. v) m..

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i Karin W. Carter, Assistant Attorney Atomic Safetf and Licensing General Appeal Panel" Office of Enforcement U.S. Nuclear Regulatory Commissica -

Department of Environmental Washington, D. C. 20555 Resources 709 Health and Welfare Building Docketing and Service Section Harrisburg, Pennsylvania 17120 Office of the Secretary U.S. Nuclear Regulatory Commission Ms. Judith H. Johnsrud Washington, D. C. 20555 433 Orlando Avenue State College, Pennsylvania 16301 Atomic Safety and Licensing Board Panel" U.S. Nuclear Regulatory Commission Washington, D. C.

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