ML19338D672

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Request for 45-day Extension to File Direct Testimony on Contention V(D) Re Emergency Filtration of Containment,Due to Change of Counsel & Involvement in Answering Interrogatories
ML19338D672
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 09/15/1980
From: Pell D
ANTI-NUCLEAR GROUP REPRESENTING YORK
To:
References
ISSUANCES-SP, NUDOCS 8009230639
Download: ML19338D672 (2)


Text

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ANGRY 9/15/ " m G 4

  1. D cecggSO 9I gp 19 N " 52 g SM UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION ,

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f BE? ORE THE ATOMIC SAFETY AND LICENSING BOARD 4 f p IN THE MATTER OF  :

METROPOLITAN-EDISON COMPANY,  : Docket No. 50-289 et al.,  :

(Three-Mile Island Nuclear  :

Station, Unit No. 1)  :

ANGRY REQUEST FOR EXTENSION OF TIME TO FILE DIRECT TESTIMONY ON ITS CONTENTION V(D)

ANGRY, because of change of personnel in counsel from John Bowers, Esquire to Daniel M. Pell, Esquire and also because of the requirements of answering licensee's interrogatories on Revision 2 of its EP, and further because of its efforts to subpoena Randy Curry to give his deposition concerning emergency contentions of ANGRY, has been unable to timely prepare its testimony on Emergency Filtration of Containment; namely, Contention V(D). ANGRY is prepared to tender the testimony of Dr. Jan Beyes within 45 days of the date hereof. This testimony, ANGRY believes, is crucial to its case and to this Board's obligation not to allow restart of Unit 1 unless the public health, welfare and safety is adequately protected. Dr. Beyea is a consultant to Princeton University and is Senior Energy Scientist with the National Audubon Society, New York, New York, f)SB5 S o/

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Consequently, this Board is requested to grant ANGRY an additional 45 days to submit this written testimony.

Respectfully submitted, by: ,

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Daniel M. Pell Attorney for ANGRY 32 South Beaver Street York, PA 17401 (717) 845-6291 1

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