ML19343A327
| ML19343A327 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/11/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8009170219 | |
| Download: ML19343A327 (5) | |
Text
LIC 9/11/80
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION p'I SEP ! 5193} > ;
Cifice C1the Secrey BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Dodetint & Smice
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Bran:n N
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S REQUEST FOR RELIEF FROM BOARD MEMORANDUM AND ORDER DATED SEPTEMBER 8, 1980 The Board's Memorandum and Order dated September 8, 1980, set forth in attachments the contentions and Board questions to be addressed in the first hearing segment ccm-mencing on October 15, 198.0.
The September 8 Memorandum and Order reiterated pre-vious Board instructions that written direct testimony and proposed exhibits with respect to the identified contentions be served by September 15, 1980.
Licensee expects to ccmply with these instructions.
For the first time, however, the Memorandum and Order also requires answers to Board questions to be served by September 15.
This Licensee is unable to do.
At the prehearing conference on August 12-13, 1980, Dr. Jordan read into the record a series of Board questions which, with some refinements, have been restated in an O
e 96 8009170
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attachment to the September 8 Memorandum and Order.
He also presented several Board questions with respect to UCS Conten-tion Nos.
6, 8 and 12, which contentions had been withdrawn by UCS but adopted by the Board.
These latter Board questions, with significant additions, have also been restated in attach-ments to the September 8 Memorandum and Order.
Following Dr. Jordan's presentation at the August 12-13 prehearing conference, Licensee's counsel advised the Board that it was questionable whether consistent with prepar-ing all of Licensee's other testimony, Licensee could meet the filing date for other testimony on all of Dr. Jordan's ques-tions.
Licensee's counsel did, however, indicate that Licensee would try to provide prior to the first hearing session answers to those Board questions pertinent to that session. (Tr. 2400)
After having had an opportunity to review in detail the Board questions pertinent to the first session, Licensee has advised its counsel that Licensee is indeed unable to supply answers to all of the Board's questions by September is.
Answers to some of the Board's questions will, of course, be contained in Licensee's testimony on contentions.
Substantial further time and effort will be required, however, to respond adequately to other Board questions.
Licensee even has some concern that full answers to certain Board questions, especially the new questions on UCS Contention Nos. 8 and 12, may not be possible by October-15. _
Accordingly,-Licensee requests the Board to extend-(
until October 15, 1980, the time for answers to Board ques-tions included in the attachments to its September 8.v.emoran-dum and Order.
Should Licensee conclude as to any of the Board's questions that a further extensicn of time is required, 4
Licensee will promptly so advise the Board.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By M./
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Y George F. Trowbridg[
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Dated:
September 11, 1980 7
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matte; of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Request "or Relief from Board Memorandum and Order Dated September 8, 1980," dated September 11, 1980, were servcd upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this lith day of September, 1980.
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G[orgeF Trowbridg[
Dated: September 11, 1980
.s SERVICE LIST Ivan W. Smith, Fsquire Walter W. Cchen, EA~uim Chaiman Consumer Adm cate Atmic Safety and Iicensing Board Office of Const=er Advocate U.S. Nuclear Regulatory Cern-'ission 1425 Strawberry Square Washington, D.C.20555 Harrisburg, Ferrsylvania 171,27 Dr. Walter H. Jcrdan.
Jordan D. Cunningham,-Esquire Atcmic Safety art. Ilcersing Scard Fox, Farr & Cunningham 881 West Cuter Drive 2320 North'Second Street
- Oak Ridge, Tennessee.37830 Harrisburg, Perrsylvania 17110 Dr. Linda W. little
'Iheodore A. Adler, Esquire Atomic Safety and Licensing Scard Wideff Paager SelkcWit: & Adler 5000 Hermitage Drive P. O. So:: 1547 Raleich, North Carclina 27612.
Harrisburg, Per sylvania 17105 James R. Tourtellette, Esquire (4)
Ellyn R. Weiss, Esquire
- Office of Execucive Iagal Director Harmon & Weiss U.S. Nuclear Regulatory Cum.issicn 1725 Eye Street, N.W., Suite 506 Washingten, D.C.
20555 Washingten, D.C.
20006 Decketing and Service Secticn (3)
Steven C. Sholly Office of the Secretary 304 South Parket Street i
U.S. Nuclear Regulatcry Ccmissicn Mechanicsburg, Pennsylvaria 17055' Washington, D.C.
20555 Daniel M. Pell, Esquire John A. Levin, Escuire ANGE Assistant Counsel 32 South Beaver Street Pennsylvaria Pttlic "tility Ccmission York, Pennsylvarla 17401 P. 0. Box 3265 Harisburg, Penrsylvania 17120 William S. Jcrdan, III, Esquire Harmon & Weiss Karin W. Carter, Esquire.
1725 Eye Street,.N.W., Suite 506 Assistant Attorney General Washington, D.C.
20006 505' Executive House P. O. Scx 2357 Pcoert Q. Pollard Harisburg, Pennsylvania 17120 609 Mcntpelier Street Baltimore, Maryland 21218 Jchn E. Minnich Chai =an, Dauphin County 3 card of Clauncey Kepferd Cc eissioners.
Judith H. Jcbesrui Dauphin County Ccurthouse Environmental Coalitica en Nuclear Pcwer Frcnt and Parket-Streets.
433 Orlando Avenue Harisburg, Pennsylvaria 17101 State College, Pe= sylvarla 16501 Marjorie M. Aamodt Parvin I. Isais R.D. 5 6504 Bradford Ten ace
' Coatesville, Pe:usylvaria 19?20 Philadelphia, Penrsylvaria 19149 w
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