ML19291B526

Applicant'S Motion for Extension of Time Until 721002 to Reply to Addendum to Petition for Intervention.Certificate of Svc Encl

ML19291B526
Person / Time
Site:	Three Mile Island
Issue date:	09/26/1972
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 7911080556
Download: ML19291B526 (3)

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UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION BEFORE THE COMMISSION In the Matter of )

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METROPOLITAN EDISON COMPANY, ET AL ) Docket No. 50-289

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(Three Mile Island Nuclear Station )

Unit 1) )

APPLICANT'S MOTION FUR EXTENSION OF TIME TO REPLY TO ADDENDUM TO PETITION FOR INTERVENTION

1. On September 6, 1972, Citizens for a Safe Envi-ronment and the Environmental Coalition for Nuclear Power filed an Addendum to their petition to intervene in this proceeding dated August 7, 1972. Contrary to the requirements of the Commission's Rules of Practice, 10 CFR 2.701(b), the Addendum was not served on Applicants or Applicants' counsel, notwithstanding the fact that Applicants in their reply to the initial petition noted the failure of Petitioners to comply with this requirement with respect to the initial Petition and specifically requested Petitioners in the future to comply with this requirement. Applicants and their counsel were unaware of the filing of the Addendum until Monday, September 25, 1972, at which time Applicants' counsel received in the mail a copy of the AEC Staff reply to the Addendum and also received a telephone call from AEC Staff counsel inquiring as to the status of Applicants' reply.

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o Accordingly, Applicants request an extension of time to reply to the Addendum until Monday, October 2, 1972, which date is five days (excluding Saturday and Sunday) from the date of Applicants' first notice of the filing of the Addendum.

2. By copy of this motion, Applicants again request that copies of all filings by Petitioners in this proceeding be served on Applicants and their counsel. Such copies should be addressed to:

Mr. John G. Miller Vice President Metropolitan Edison Company P. O. Box 542 Reading, Pennsylvania 19603 George F. Trowbridge, Esq.

Shaw, Pittman, Potts & Trowbridge 910 17th Street, N.W.

Washington, D.C. 20006 Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By 5) *

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g ~G%rge F. Trowbridge /

COUNSEL FOR APPLICANTS Dated: September 26, 1972 1583 149

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UNITED STATES OF AMERICA .

ATOMIC ENERGY COMMISSION m

In the Matter of )

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METROPOLITAN EDISON COMPANY, ET AL ) Docket No. 50-289

)

(Three Mile Island Nuclear Station )

Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of Applicant's Motion for Extension of Time to Reply to Addendum to Petition for Interventicn, dated September 26, 1972, have been served upon the following by deposit in the United States mail, postage prepaid, this 26th day of Sep-tamber, 1972.

Mr. Frank W. Karas (21) Joseph Gallo, Esq. (6)

Chief, Public Proceedings Staff Howard M. Wilchins, Esq.

Office of the Secretary Office of General Counsel U. S. Atomic Energy Commission U. S. Atomic Energy Commission Washington, D_C. 20545 Washington, D.C. 20545 Miss Mary V. Southard, Chairman (1) Herbert C. Goldstein (1)

Citizens for a Safe Environment Attorney-at-Law P. O. Box 405 133 State Street Harrisburg, Pa. 17108 Harrisburg, Pa. 17101 Douglas Baker (1) Lawrence Sager, Esq. (1)

Environmental Coalition on 45.High Street Nuclear Power Pottstown, Pa.

1919 Sandy Hill Road Norristown, Pa. 19401 Mr. Frank R. Clokey (1) 3pecial Assistant Attorney General Room 219 Towne House Apartments Harrisburg, Pa. 17105 N -f Gefrge'F.

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Trowbridge '

Dated: September 26, 1972 1583 150