ML19290E618

Motion for Unspecified Extension of Time for Discovery, Allowing Revision of State or Local Emergency Response Plan, Expected to Be Issued Following Closure of Discovery

ML19290E618
Person / Time
Site:	Three Mile Island
Issue date:	02/25/1980
From:	Bowers J ANTI-NUCLEAR GROUP REPRESENTING YORK
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19290E615	List: ML19290E613 ML19290E616 ML19290E617 ML19290E618 ML19290E623
References
NUDOCS 8003140297
Download: ML19290E618 (1)

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/ .s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 'Y BEFORE Tim ATOMIC SAFETY AND LICENSING BOARD [E- \$

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ANTI-NUCEEAR GROUP REPRESENTING YORK MOTION FOR EXTENSION OF TIME FOR DISCOVERY Intervenor Anti-Nuclear Group Representing York (ANGRY) hereby moves pursuant to 10 CFR 2.711(a) for an extension of time for the conduct of discovery in this proceeding for the reasons hereinbelow set forth. In its answers to ANGRY's interrogatories dated February 15, 1980, the Coc=onwealth of Pennsylvania indicated that the county emergency response plans included by the licensee as appendices to its emergency plan "are presently being revised." The Cottonwealth further indicated that its own emergency plan had not been reviewed for NRC concurrence pending such future revision as might be warranted in light of NUREG 0654 and of the report of the Governor's Cocmission on TMI. ANGRY believes an opportunity for discovery on such revised emergency response plans and on the bases for any NRC determination that any such plans warrant NRC concurrence therein is essential for a proper resolution of the issues before this Board in this proceeding. ANGRY therefore requests that the Board extend the time for discovery in this prodeeding in such a manner as to allcw the parties to engage in it:

A. On any revised state or local emergency response plan which may come into existence after the close of the normal discovery period in this proceeding, and B. On the bases for any determination by the NRC that any such revised emergency response plan satisfies applicable standards for NRC concurrence therein.

Respectfully submitted, Anti-Nuclear Grouf 1'ppresenting York By: T MA 9--- -

John-Bowers 245 W. Philadelphia St.

DATE: February 25, 1980 York, Pa. 17402 J 8003140 M9