ML19256E603
| ML19256E603 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/12/1979 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| NUDOCS 7911080129 | |
| Download: ML19256E603 (4) | |
Text
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October 12, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
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)
METROPOLITAN EDISON COMPANY, et al. )
Docket No. 50-320
)
(Three Mile Island Nuclear Station, )
Unit No. 2)
)
LICENSEES' RESPONSE TO APPEAL BOARD MEMORANDUM DATED SEPTEMBER 10, 1979 By Memorandum dated September 10, 1979, the Appeal Board invited all parties to submit'a memorandwm on or before October 12, 1979, addressing the question of rescheduling the resumption of the evidentiary hearing on the aircraft crash probability issue.
Licensees favor scheduling of a hearing session to complete the evidentiary hearing on this issuc in the near future, allowing sufficient time for the NRC Staff to arrange for scheduling of pilot testimony.
The basi
,r Licensees' position is as follows:
1.
While resumption of operation of TMI-2 may be some time off, Licensees expect following the completion of recovery operations to seek authority to resume operation of TMI-2.
The issue presently before the Appeal Board, i.e.
the point at which an increase in large aircraft traffic at i295 118 7911080 G
Harrisburg International Airport would require reconsideration of the need for additional protection against the possibility of a crash by a large a_ccraft into TMI-2, remains a matter of importance to Licensees and the Nuclear Regulatory Commission.
2.
The preparation and taking of complicated evidence on the aircraft crash probability issue has largely been com-pleted.
Technical witnesses for the Licensees and the NRC Staff are still familiar with that evidence and are still available to assist in the conclusion of the hearing and to provide tech-nical input into the preparation of proposed findings.
Counsel for Licensees and the NRC Staff are still the same individuals and hopefully still retain their grasp of the evidence.
This situation with respect to the familiarity and availability of witnesses and counsel is likely to deteriorate if the hearing is postponed for a protracted period of time.
3.
The Appeal Board has elected to preside, itself, over the hearings partly in recognition of the generic aspects of the issues and the precedential importance of its decision to other licensing proceedings.
The completion of hearings and rendering of a decision by the Appeal Board will provide important regulatory guidance.
Respectfully submitted, SHAW, PI TMAN, POTTS & TROWBRIDGE By
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V 'Ge6rgd F.M rowbridp Dated: October 12, 1979 1295 119 October 32, gy UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
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METROPOLITAN EDISON COMPANY, et al. )
Docket No. 50-320
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(Thre.e Mile Island Nuclear Station, )
Unit No. 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Licensees' Response to Appeal Board Memorandum Dated September 10, 1979," dated October 12, 1979, were served upon those persons on the attached Service List by deposit in the United States mail, postage pre-paid, this 12th day of October, 1979.
240ff./
M J
' s/ Geprgd F. Trowbridgb Dated: October 12, 1979 1??5
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I UNITED STATES OF AMERICA NUCLEAR RIGULATORY CCMMISSION 3efore the Atemic Safety and Licensinc Appeal 3 card 4
s In tte Matter of
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1 METROPOLITAN EDISON CCMPANY, et al
)
Dccket No. 50-320
)
(Three Mile Island Nuclear Station,
)
Unit 2)
)
SERVICE LIST Alan S.
Rosenthal, Esq., Chairman Lawrence J.. Chandler, Esq.
Atemic Safety and Licensing Appeal Office of the Executive Legal Direct Scard U.S.
Nuclear Regulatcry Cccmission U.S. Nuclear Regulatory Cccmission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Chauncey R.
Kepford Dr.
W.
Reed Johnson, Member 433 Orlando Avenue Atomic Safety and Licensing Appeal State College, Pennsylvania 16301 Scard U.S. Nuclear Regulatory Cc= mission Karin W.
Carter, Esq., Assistant Washington, D.C.
20555 Attorney General Office of Enforcement Jercme E.
Sharfman, Esq., Member Depa.tment of Environmental Rescurce Atemic Safety and Licensing Appeal 709 Eealth and Welfare Building Harrisburg, Pennsylvania 17120 3 card U.S.
Nuclear Regulatory Cccmission Washington, D.C.
20555 Atemic Safety and Licensing Appeal Scard Panel Edward Luton, Esq., Chairman U.S.
Nuclear Reculatcrv Cc= mission Atcmic Safety.and Licensing Board Washington, D.C.
20555 U.S.
Nuclear Regulatory Cc= mission Washington, D.C.
20555 Atemic Safety and Licensing 5 card Panel Mr. Gustave A.
Linenberger U.S.
Nuclear Regulatory Commission Atomic Safety and Licensing Scard Washington, D.C.
20555 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section Office of the Secretary Dr.. Ernest O.
Salo U.S. Nuclear Regulatory Cc=missicn Professor, Fisheries Research Washington, D.C.
20555 Institute, NH-10 University of Washington Seattle, Washington 98195 1295 121-e O