ML19321A551

Response in Support of People Against Nuclear Energy 800716 Request for Commission Decision on Psychological Distress Issue.Urges Striking Section III of Motion Re Opportunity for Reply Briefs.Certificate of Svc Encl

ML19321A551
Person / Time
Site:	Three Mile Island
Issue date:	07/21/1980
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	NRC COMMISSION (OCM)
References
ISSUANCES-SP, NUDOCS 8007230604
Download: ML19321A551 (5)

Text

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s UNITED STATES OF AMERICA

/p M'GTED j' NUCLEAR REGULATORY COMMISSION

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i In the Matter of ) ,

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5 METROPOLITAN EDISON COMPANY ) Docket No. 50-289 3 ) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

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1. . LICENSEE'S RESPONSE TO PEOPLE AGAINST NUCLEAR 5 ENERGY REQUEST FOR COMMISSION DECISION

] ON PSYCHOLOGICAL DISTRESS ISSUES l E

On July 16, 1980, counsel for People Against Nuclea 2

q Energy (PANE) filed with the Commission a request for prompt decision on the question as to whether psychological distress issues are to be considered in the TMI-l restart hearing. The PANE motion notes that the Licensing Board certified to the Commission the parties' briefs on this question almost six months ago and that there has been no sign of Commission action since that time.

Licensee heartily endorses PANE's request. The Com-mission's inaction threatens further delay in a proceeding which has already slipped far behind the schedule attached to the Commission's August 9, 1979 Order and Notice of Hearing.

PANE's motion, however, does not st'po with a request for prompt commission action.Section III of the motion is in substance a supplemental brief addressed to the merits of the

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{- question before the Commission. No such brief was contemplated 5

j in the procedures established by the Commission's August 9,

!:f 1979 Order, and no provision has been made for reply briefs by 1 i {

!= other parties. Opportunity for reply briefs would in fact de- )

g feat the main purpose sought by PANE of early Commission actiori.

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Licensee therefore requests the Commission to disregard and to I strike from the record of this proceeding Section III of PANE's V-motion. - 1 1 ,

Respectfully submitted, SHAW, PIT , POTTS & TROWBRIDGE By h // '

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Y Ge[rge F. [rowbridge[

Dated: July 21, 1980

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E h UNITED STATES OF . AMERICA // N '\

[ HUCLEAR REGULATORY COMMISS'JN M -

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,} BEFORE THE NUCLEAR REGULATORY COMMISSION r' NbW JUL 211980 > '

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1 .- e In the Matter of 1 I

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i METROPOLITAN EDISON COMPANY ) Docket No. 50-289 i 1 (Restart) i (Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response to People Against Nuclear Energy Request for Commission Deci-sion on Psychological Distress Issues," dated July 21, 1980, were served upon those persons on the attached Service List by

- 1 deposit in the United States mail, postage prepaid, this 21st day of July, 1980, and that copies of said Licensee's Response have on the same day been delivered by hand to the following:

Chairman John F. Ahearne l Commissioner Victor Gilinsky Commissioner Joseph M. Hendrie Commissioner Peter A. Bradford Samuel J. Chilk, Secretary Leonard Bickwit, General Counsel JAJ ' _ //]659 s V [eorgeF. Trowbridg[ -

Dated: July 21, 1980

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

In the Matter of )

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METROPOLITAN EDISON CCMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST  !

Ivan W. Smith, Esquire John A. Levin, Esquire  !

Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Cccc Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D.C.

20555

. Karin W. Carter, Esquire l Dr. Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 E81 West Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Ten *nessee 37830 John E. Minnich Dr. Linda W. Little Chairman, Dauphin County Board Atomic Safety and Licensing of Commissioners Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front ind Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 l James R. Tourtellotte, Esquire (4) Walter W. Cohen, Esquire Office of the Executive Legal Director Consumer Advocate U. S. Nuclear Regulatory Commission Office of Consumer Advocate Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127' Docketing and Service Section (21)

Office of the Secretary ,

U. S. Nuclear Regulatory Commission Washington, D.C. 20555 l

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i I- Jcrdan D. Cunningha:n, Escuire Karin P. Sheldon, Escuire

} Attorney for Newberry Toc.shic Attornev for People Against Nucleir Enerev i 7.M.I. Steering Committee Sheldon, ' armon' & Weiss j ' 2320 North Second Street

, 5 F.arrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506

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Washington, D.C. 20006 i Cheodore A. Adler, Esquire z'

Widoff Reager Selkowitz & Adler Robert Q. Pollard j Post Offic:e Sox 1547 609 Montpelier Street Baltimore, Ma.yland -

21218

? Harrisburg, Pennsylvania 17105 4 Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Union of Concerned Judith H. Johnsrud Scientists Environmental Coalition on Sheldon, Harmon & Weiss Nuclear Power i

1725 Iye Street, N.W., Suite 506 433 Orlando Avenue

! State College, Pennsylvania 16E

'4 . Washington, D.C. 20006 Steven C. Sholly Marvin I. Lewis 2

304 Scuth Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelshit., Pennsylvania 1914 Gail 3radford Marj or '.e. M. Aamodt R. D. 5

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Hollv 5. Ke=k Coatesville, Penn_ylvania 1932C-begislation Chairman Anti-Nuclear Group Representing York 245 West Philadelphia Street York, Pennsylvania 17404

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