ML20012E144
| ML20012E144 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 03/26/1990 |
| From: | Rutherford P ROCKWELL INTERNATIONAL CORP. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#190-10145 89-594-01-ML, 89-594-1-ML, ML, NUDOCS 9003300125 | |
| Download: ML20012E144 (5) | |
Text
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NliI CDCYEiED March 299101990
% NAR 27 P3 :22 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIONM 0: HCaf TAFv vubKihNG /, 'j!imCJ' ATOMIC SAFETY AND LICENSING BOARDBRANpi Before Administrative Judge:
Peter B. Bloch In the Matter of Docket 70 (h L.
Request to ROCKWELL INTERNATIONAL Renew till CORPORATION October 30, 1990 Rockwell Division ASLBP No.
(Special Material License 89-594-01-ML Number SNM-21)
MOTION FOR RECONSIDERATION (SCHEDULE)
Rockwell International Corporation (the Applicant), files this motion for reconsideration of the Applicant's April 5,
1990 deadline ' for it's response to the intervenors' direct cases for the reasons set forth herein.
1 In the teleconference of March 15, 1990, the Applicant's original 60 day schedule for response was reduced by two weeks.
At that time, the Applicant objected by citing the three months which the intervenors had to file their individual concerns, the l
added burden on the Applicant to respond to six separate direct p
1 9003300125 900326 PDR ADOCK 07000025 C
) 5 03
L.
q' cases and our lack of knowledge of what would and would not be i
struck.
i Since the teleconference, the Applicant has received Judge Bloch's Memorandum and Order, dated March 21, 1990, responding to our motion to strike, just 15 days before the new deadline.
The striking of various intervenors' concerns has not substantially helped the Applicant in meeting the new schedule, as.' might be thought.
Prior to March 21, 1990 the Applicant could not wait for a decision on its motion to strike, but rather had to initiate preparation of responses to every original concern (including those struck).
This has therefore detracted from the time we could have spent on the unstruck concerns.
Moreover this order included new interpretations resulting in imposition of add!onal requirements (pages 4-6) over and above those of the is 4.*
g intervenors' concerns.
1 Judge Bloch indicated that the Applicant has had ample time i
i since October to prepare responses (Trans. 337-19).
The Applicant
-submits, however, that this is incorrect for two reasons.
- First, concerns at the earlier pleading stage were not specific, appeared 1
to be unsubstantiated allegations, and therefore were not susceptible for the most part to formulation of specific responses.
Second, Rockwell personnel involved in this hearing have had a full l
workload throughout the time in question on matters unrelated to this hearing and complete responses could be better developed upon 1
2
p 3
-receipt of the more specified concerns on February 20,-1990.
The~
Applicant reluctantly files this motion for reconsideration of schedule but does so in order to be in a
+
position to fully respond to the concerns of intervenors.
Given the status of response preparation and the estimated time for completion, including a complete executive management review and Corporate approval, the Applicant has determined that a complete and thorough response will require an additional two weeks beyond April 5, 1990, per the original schedule.
Since the apparent reason for the accelerated schedule is the Judge's concern that TRUMP-S testing would be started before a hearing decision is reached, the Applicant hereby commits to notify the Judge two weeks prior to commencement of any such testing, should this motion be granted.
Such notification would not be submitted until after completion of our responses.
Respectfully submitted, d
R.
Philip D. Rutherford, Manager Nuclear Safety and Reliability Engineering Rocketdyne Division Rockwell International dated at Chatsworth, California this M day of AM
, 1990 3
I i
n's -
la nEiEC' U%c UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judge: h[0CkbMNSIMliY Peter B. Bloch BRANCH In the Matter of Docket No. 70-25-ML Request to renew till ROCKWELL INTERNATIONAL CORPORATION October 30, 1990 Rocketdyne Division, ASLBP NO. 89-594-01-ML (Special Materials License l
Number SNM-21)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Motion For Reconsideration (Schedule) have been served upon the following persons by Federal Express, unless otherwise noted, and in accordance with the requirements of 10 CFR Sec. 2.712.
Administrative Judge-Administrative Judge Christine N. Kohl, Chairman G. Paul Bollwerk, III Atomic Safety and Licensing Appeal Atomic Safety and Licensing l
Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory L
Washington, DC 20555 Commission l
Washington DC 20555 Administrative Judge Howard A. Wilber-Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555
, Administrative Judge Peter B. Bloch Presiding Officer Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comm.
Washington, DC 20555
. Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn:
Docketing and Servicing Branch
(.
,)..
m'L Administrative Judge Gustave A. Linenberger, Jr.
Special Assistant.
Office of the General Counsel
. Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U;S. Nuclear Regulatory Ccmmission Washington, DC 20555 Washington, DC 20555 Estelle Lit Jon Scott I'
.18233 Bermuda Street 6 Roundup Road Northridge, CA 91326 Bell Canyon, CA 91307
'Jerome E. Raskins, et al Cecelia Riddle c/o 18350 Los Alimos Senior Librarian Northridge, CA 91326 Chatsworth Branch Library 21052 Devonshire St Chatsworth, CA 91311 Daniel Hirsch Committee to Bridge the Gap 1637 Butler Ave.
Suite 203, Los Angeles, CA 90025 Sheldon'C. Plotkin Phd, PE Richard Saxon,. President Executive Board Representative Los Angeles Physicians So. California Federation of for Social Responsibility Scientists 1431 Ocean Ave. Suite B 3318 Colbert Ave.
Santa Monica CA 90401 Los Angeles, CA 90066
- Faxed and federal express Dated at Los Angeles, CA, this eb day of M 4,
, 1990 d cwn M% Mu Office Q f Nuclear Safety and Reliability ROCKWELL INTERNATIONAL CORPORATION Rocketdyne Division
.