ML19331D939

Response to ASLB 800820 Order Re Ucs Motions for Summary Disposition.Suggests 800910 for Response to Motion on Contention 5 & 801001 for Responses to Motion on Contention 13.Certificate of Svc Encl

ML19331D939
Person / Time
Site:	Three Mile Island
Issue date:	08/29/1980
From:	Weiss E SHELDON, HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8009040358
Download: ML19331D939 (3)

Text

.

O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ~_

I s. d - f, In the Matter of ) ,_ ~~

)

METROPOLITAN EDISON ) Docket No. 50-289 COMPANY, et al., ) (Restart)

)

(Three Mile Island )

Nuclear Station, Unit )

No. 1) )

)

UNION OF CONCERNED SCIENTISTS' RESPONSE TO BOARD ORDER OF AUGUST 20, 1980 By Order dated August 20, 1980, the Board addressed the issues raised at the Prehearing Conference of August 12 and 13.

The Board noted that it tentatively agreed with UCG's position that we are entitled to responses to our summary judgment motions, but did not establish a date for such responses. Because the ,

hearing date is fast approaching, UCS hereby requests the Board to set a deadline of September 10 for responses to the motion on Contention No. 5. Since the Staff and licensee have had the motion since approximately August,5, that deadline is not unduly burdensome. If responses are delayed much beyond that date, their usefulness to UCS in preparing its case is greatly diminished.

Because submittal of testimony on UCS Contention No. 13 has been delayed, a later deadline for responses to that motion is appropriate; we would suggest October 1. It should be noted that even if the staff does not yet have a position on the ultimate merits of the UCS Contention, it is in a position to say whether 1)S d IS # /

60 09040 3EF

~

s and why it disputes any of UCS's assertions of material fact and should be directed to do so.

Respectfully submitted, Ellyn R. Weiss Harmon & Weiss 1725 I Street, N.W.

Suite 506 Washington, D.C. 20006 (202) 833-9070 Counsel for Union of Concerned Scientists Dated: August 29, 1980 1

1 4

, . o -

- s UNITED STATES OF N{ ERICA ' '

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

' ) .. C)'

In the Matter of )

)

METROPOLITAN EDISON ) Docket No. 50-289 COMPANY, et al., ) (Restart)

)

(Three Mile Island )

Nuclear Station, Unit )

' No. 1) ) '

)

CERTIFICAT'! OF SERVICE I hereby certify that copies of the " Union of Concerned Scie'ntists' Response to Board Order of August 20, 1980," have been hand-delivered and mailed postage pre-paid this 29th day of August, 1980, to the following parties:

I

!, Secretary of the Commission Dr. Linda W. Little 5000 Hermitage Drive I ATTN: Chief, Docketing & Service Raleigh, North Carolina 27 f -

f Section U.S. Nuclear Regulatory Commission l

20555

• George F. Trowbridge, Esq.

Washington, D.C.

l Shaw, Pittman, Potts &

Trowbridge I

• Ivan W. Smith, Esquire 1800 "M" Street, N.W.

' Atomic Safety & Licensing Board 20006 Washington, D.C.

! Panel i U.S. Nuclear Regulatory Comission

• James Tourtellotte, Esq.

Washington, D.C. 20555

Office of the Executive Legal Director

' Dr. Walter H. Jordan U.S. Nuclear Regulatory 881 W. Outer Drive Commission Oak Ridge, Tennessee 37830 r-Washington, D.C. 20555

~

,y' .. .

., . I ~ , -

4 Ellyn R. Weiss

• hand-delivered

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