ML19317H443
| ML19317H443 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Hope Creek, Sterling, Crane  |
| Issue date: | 05/20/1980 |
| From: | Kepford C CITIZENS FOR SAFE ENVIRONMENT |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8006060245 | |
| Download: ML19317H443 (4) | |
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UNITED STATES'0F AMERICA g.
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NUCLEAR REGULATORY COMMISSION MAY 2 31980 > Z
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Before the Atomic Safety and Licensing Appeal Board (
Office of the Secretary i
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Dc:keting & Service i
Branch In the Matter of y
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METROPOLITAN:EDIS0N COMPANY, et al.
Docket Number 50-320 -
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(Three Mile ' Island Nuclear StatioE,
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Unit 2) j et al?
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PHILADELPHIA ELECTRIC COMPANY, TonZ W
'j ' ' 50-278 (Peach Bottom Atomic Power Stat l
Units 2and!3)_ _.%. ~. n, ~ 1
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PUBLIC SERVICE ELECTRIC AND GAS. COMPANY 4,g 50i354 (Hope Cmek Generating StatiosiUnits.1 & 2) i 50-355 E
ROCHESTER GAS AND ELECTRIC bRPORATI'0 ket 'al.!, -
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REQUEST'0F INTERVEN0RS YORK COMMITTEE FOR A SAFE ENVIRONMENT i
AND CITIZENS FOR A SAFE ENVIRONMENT FOR EXTENSION OF TIME
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p Followihg the February,L1'980. Evidentiary Hearings on the iadon issue, the Appeal Board set a date of May 28, 1980, for the submission of post-
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hearing memoranda, with subsequent response from the NRC Staff. For the
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masons stated herein, these Intervenorsyre, quest an extension of time of 21 days for all parties to filj membrands;on the radon issde, including a comparable extension of time for the Staff's reply memorandum.
The mcord on the radon issue ihlengthy, including the 1.
transcripts from the TMI-2 Operating License, Perkins transcripts.
earlier Appeal Board Hearing, and filings from the Sterling and Tyrone Intervenors, as well as the BreVt Generic Environnental Impact Statement on Uranium Milling, and the transcript of the February,1980, Hearings before this Appeal Board.
2.
These Intervenors have,been required to prepare.for and participate in additional Prehearing. Conferences before Atomic Safety and Licensing Boards in the TMI:1 Restart and Susquehanna 1 and 2 Operating License, proceedings since the time of this Appeal Board Hearing on radon.
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These Intervenors l[ ave' prepare' band submitted their post-3.
hearing memorandum on the aircraft crash probability issues in the interim as well, having agreed to the 'NRC Staff's request for an extension of time for that filing, which has reduced further the available time for preparation of the radon memorandum.
4.
The press of other comitments made long prior to the February,1980 Hearings has substantially reduced the ability of these Intervenors to complete the radon memorandum before May 28.
5.
Personal family obligations that could not have been antici-pated in February have further reduced the time available to these
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representatives to devote to pmparation of the radon memorandum.
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~6 s Because of the major importance of this unresolved issue.
the Intervenors wish to present as full and careful a post'-hearing..
memorandum as is possible.
. 7.
No substantial operational delays or adverse economic impacts for the affected Applicants and Licensees would result from the grant-ing of this added time; to the contrary, the record on radon would be enhanced.
8.
Distance and financial constraints require these Intervenors and Ms. Reinert representing the Sterling and Tyrone Intervenors to com-municate primarily via the less than rapid U.S. Mails. Since these.
parties expect to be submitting either a joint memorandum on radon or concurring or complementary memoranda, these communications are vital to the presentation of our posicions.
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Prior to submission of this request for additional time of 21 days to file post-hearing memoranda, these Intervenors have spoken with Ms. Reinert of Ecology Action of Oswego who also represents the Tyrone Intervenors. She Shares our reasons and our desire for this extension of time. The NRC Staff has also been consulted and the Staff has no objection to the extension ~ of l
time requested, provided that the Staff is granted a comparable extension of time to file its reply memorandum.
If the Appeal Board grants the mquested extension, the filing date for the parties other than the NRC Staff would be June 18, 1980, rather than May 28.
Respectfully submitted, 1
") y' Chauncey Kepford Repmsentative of the Intervenors Dated this M day
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of May, 1980 1
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J CERTIFICATE OF SERVICE
'I certify that copies of REQUEST OF IllTERVENORS YORK C041ITTEE FOR A SAFE ENVIRONMENT AND CITIZENS FOR A SAFE ENVIRONMENT FOR EXTENSION OF TIME have been filed on the parties in this proceeding by deposit in the U.S. Mails, i
first class...postag'e paid, this M day of May,1980.
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Ace Cha;uncey Kepford
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Edward Luton, Eso., Chairman George F.(Trowbridge',.Esq.-
Atomic Safety and licensing Board Shaw, Pittman, Potts.b U.S. Nuclear Regulatory Commission Trowbridge 4
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1800 M Street, N.W.
Washington, D.C. 20535 Washingtok, D.C. 20036 Mr. Gustave A. Linenberger i
Atomic Safety and Licensing Board Atomic Safety & Licensing U.1'. Nuclear Regulatory Commission Board Panel t
Washington, D.C; 20555 i; '
U.S. Nuclear Regulhtory k
Commission I
Dr. Ernest O. Salo Washingtoit, D.C. 20555 i
Professor. Fisheries Research Institute, Wil-10 j
Atomic Safety and Licensing i
College of Fisheries r
Appeal Board y
University of Washington U.S. Nucigar Regulatory fl Seattle, Washington 98195 Commission Washington, D.C. 20555 Karin W. Carter, Asst. Attorney' General Office of Enforcement Docketing land Service D'epartment of Environmental Resources Section' 709 Health and Welfare Building' Office of.the Secretary Harrisburg, Pennsylvania 17120
~0.S. Nuclear Re-ulatory 1
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Comminaion as ingt n. D.C.
20 W Alan S. Rosenthal, Esq., Chairmafi,Ianel
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Atomic Safety and Licensing Appe I Henry J.
cGurrem U.S. Nuclear Regulatory Commission
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Counsel for NRC Staff t
Washington, D.C. 20555 Nuclear Regulatory Commission
{, f" Washingto(, D.C.
20555 Dr. W. Reed Johnson. Member,
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Atomic Safety and Licensing Appeal Panel i
U.S. Nuclear Regulatory Commission
Washington,D.C.30555 I
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Myron Bloom, Esq.
'Nichael C. Farrar. Esq., Chairman U.S. Environmental Protection n.
Atomic Safety and Licensing
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P nn ania 19106_
l Wa ng Troy 8. Conner, Jr., Esq.
Dr. John H. Buck Conner, Pbore and Corber Atomic Safety and Licensing 1747 Pennsylvania Avenue, N.W.
Appeal Board Washington, D.C.
20006 U.S. Nuclear Regulatory Comission-Washington, D.C.
20555 Raymond L. Hovis, Esq.
Stack and Leader Jahn B. Griffith Esq.
35 South Duke Street
, Special Assistant Attorney General York, Pennsylvania 17401 i.Ttwes State Office Sufiding (C-4)
I Annapolis' Maryland 21401 i
W. W. Anderson, Esq.
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.l Deputy Attorney General Department of Justice Capitol Annex
- Richard S. Salzman, Esq.
Atomic Safety and Linensing James M. Cutchin, IV, Esq.
Counsel for the NRC Staff U
c ar Regulatory Comission W$shington,D.C.20555 U.S. Nuclear Regulktory Commission-Washington, D.C. 20555 I
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