ML20027E652
| ML20027E652 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/05/1982 |
| From: | Trowbridge G GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8211150575 | |
| Download: ML20027E652 (3) | |
Text
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SHAW, PITTMAN, PoTTs & TROWBRICGE A PARTNERSM6F OF PROFESSIONAL CORPORAftONS 1800 M STRE ET N. W.
WASHINGTON, D. C. 20036 12O21 822-l000 8"AMSAf D POTTS. P C.
THOM AS A. S AMTER. P C.
JOHN M. O'NEILL. JR MENNETH J MAUTMAN STEUART L. PITTMAN. P C.
J AMES M. SURGER. P C.
JAYA EPSTIEN DAv;O LAWRENCE MILLER F/f 0RGE F. TWOWSReDGE. P C.
SHELDON J. WEISES. P C.
RAr.D L. AMEN ANNE M. MRAUSMOPF TELECOPIER RTE PHEN D. POTTS. P C.
JOMN A McCULLOUOM. P C.
TIMOTMY s. McaRIDE P REDERICM L MLEsN C ELALD CHANNOFF. P C.
J. PATRICM McCMEY. P C.
12O26 S23-1099 & S23-4e99 ELISABETM M PE NDLETON GORDONR MANOFSMY PHILLJP D. 90STwtCM. P C.
GEORGE P. MICHAELY. JR. P C.
MARRYM GLASSPIEGEL MANN AM E. M LIE BERM AN PAUL A KAPLAN JEFFREY S. GIANCOLA M. TIMOTHY MANLON. P C..
J TMOM AS LENMART. P C.
GEORGE M. ROGERS. JR. P C STEVE N L. MELT 2ER. P C JEFFERY L YABLON SANDRA E. FOLSOM F; EO A. LITTLE. P C.
DEAN D. AULICM. P C.
IELEX JACM McMAY MARCtA R NIRENSTEIN 89-2693 ISMAwLAW WSHI THOM AS H. McCOMMICM JUD87M A. SANDLER JOMN ENGEL. P C'IN. P C.
JOMN S. RMINELANDER. # C.
CHARLE S 3. TE MM BUSAN M FREUND EDWARD D. YOUNG. Ist C#VCE w CMURCHILL P C.
LEILIE A. NGCMOLSON. JR, P C. STE PHE N S. MUTTLER P C.
CABL E "SM AWLAW"*
JOMN L CARR. JR ROeERT L. wtLLMORE MJ.ATIN D MRALL P C.
wtNTHROP N GROWN. P C.
PHILIP J. MARVEY ANDREW D ELLIS MCMAND J MENDALL. P C.
JAMES 5 HAMLIN. P C.
ROBERT M. GORDON WENDELIN A. WHITE JAY E. SsLSERO. P C.
RANDAL 3. MLLL P C.
sAmeARA J. MORGEN STANLEY M. BARG BALSARA M. ROSSOTTI. P C.
ROSERT E. ZAHLER BONNIE S. GOTTLif e MRaSTt L LeMeo GEORGE V. ALLEN JR. P C.
AsCHARD E. GALEN JOHN F. DEALT' HOWARD M. SM AFFERM AN LESLIE M SMITH FIED ORASNER. P C.
ROBERTS ROSSINS CouhEEL DEBORAH S. BAUSER VIRGINIA S. RUTLEDGE R. MEN (Y WEBSTER. P C.
STEVEN M LUCAS SCOTT A. ANENBERG MATHERINE P CHEEM NATMANIEL P gmEED. JR, P C.
DAVID M RUBE NSTEtN CAMPSELL MILLEFER JANICE LEMRER-STEIN MMM AUGENGLICR. P C.
LYNN WHITTLESEY WILSON SETH M. MOOGASIAN TRAvaS T. SWOWN. JR ELNEST L. BLAME. JR.. P C M ATIAS F. TRAviESO-dea 2 SMEILA McC. HARVEY GAsLE.CURREY C#JCLETON S JONES. P C.
VICTORIA J PERMINS DELISSA A. RiDGWAY RICHARD M. MRONTM AL STEPHEN 5 H EIM AN N
'NOT ADMeTTED IN D C.
WRITER'S DeRECT DIAL NUMBER 822-1026
,.. /2 November 5, 1982 Mr. Darrell G.
Eisenhut Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Eisenhut:
As reflected in the attached Motions, filed by the Licensee with the Appeal Board and the Commission, we were concerned about the effect on TMI-l of the application by the NRC staff of the recommendation by the Appeal Board in the TMI-2 proceeding concerning airplane crash computations.
Discussions with the NRC staff have indicated that this concern may reflect a misapprehen-sion with respect to how the staff intends to implement the Appeal Board's suggestion regarding Unit 1.
As a result of our discussions Licensee has agreed to a license condition for TMI-l which will require Licensee to report annually to NRC the total number of movements of aircraft larger than 200,000 pounds at the Harrisburg airport, broken down into scheduled and non-scheduled (including military) takeoffs and landings, based on a current estimate provided by the airport manager or his designee. Licensee has further agreed to a condition that in connection with the report of heavy aircraft movements at T 8211150575 821105 PDR ADOCK 05000289 i
P PDR
SHAw, PITTMAN, PoTTs & TROWBRIDGE A PARTNERSHIP OF PROFESSIONAL CORPORAftONS Mr. Darrell G.
Eisenhut November 5, 1982 Page Two the Harrisburg airport for the calendar year 1984, Licensee will update its analysis of crash probability utilizing current Harrisburg airport figures as well as updated national aerial crash density values.
This update will be based on the same methodology presented by Applicants as accepted by the Appeal Board in the TMI-2 proceeding.
The license condition will specify that following receipt of this updated analysis, the staff will discuss with Licensee and determine the need for further proba-bility analyses.
In our discussions we pointed out not only the major in-fluence which annual traffic levels at the airport have on the probability determination, but the dominant role which changes in those levels would play compared to changes in other inputs to probability analyses in redetermining probability values.
For example, new data on national aircrash statistics, when added to the 22 years of data on which probability computations were projected in the TMI-2 proceeding, would probably have at most a small effect on the probability results.
The license condition also reflects a recognition of the large margin which exists on the basis of recent Harrisburg airport traffic levels between both the Licensee's and staff's probability determinations and the staff guidelines accepted by the Board.
In our discussions with the staff we also pointed out that Licensee's annual reports to the NRC of traffic at the Harrisburg airport since 1977 show a rather steady level in the number of heavy aircraft operations.
We also adviced the staff that with respect to national aircrash statistics we had investigated for recent years the aircrash rate for non-scheduled aircraft, since it is this rate which dominated the national aerial crash density values produced in the TMI-2 proceeding.
The number of relevant crashes of non-scheduled aircraft for the years 1978-81 were as follows:
Year Number of Operations Number of Relevant Crashes 1978 193,000 0
1979 173,000 1
1980 253,000 0
1981 231,000 0
SHAw, PirrMAN, PoTTs & TROWBRIDGE A PARTNERSHIP OF PROFESSIONAL CORPORATIONS 14r. Darrell G. Eisenhut November 5, 1982 Page Three Thus the non-scheduled aircrash rate for the four years in ques-tion was significantly less than the average rate during the previous 22-year period.
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teorgd F. Trowbridge, Counsel for GPU Nuclear Corporation Enclosures i
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Octobsr 20, 1982 DESIGNA;tp ggyggg3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSS$N U M U _., _ ' - - -
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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
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METROPOLITAN EDISON COMPANY,
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et al
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Docket No. 50-320
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(Three Mile Island Nuclear
)
Station, Unit 2)
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APPLICANTS' REQUEST FOR EXTENSION OF TIME TO FILE MOTION FOR RECONSIDERATION AND MODIFICATION OF APPEAL BOARD DECISION DATED SEPTEMBER 15, 1982 (ALAB-692)
By its Decision dated September 15, 1982 (ALAB-692) the Appeal Board found, on the bases of probability analyses presented by Applicants and the Staff using air traffic and aircrash data through 1977, that the annual probability of a
-7 heavy airplane crash on TMI-2 was less than the 10 guideline set out in the Standard Review Plan.
At the same time the Board indicated a need to update the data base periodically in order to determine whether the guideline continues to be satisfied.
To this end the Board added two license conditions.
The,first of these conditions would adopt a staff recommendation to modify the present.TMI-2 Technical Specifi-cations, which already require Applicants to make an annual report.of aircraft operations at Harrisburg, to call for a D+ w
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9 breakdown of the number of heavy circraft operations into scheduled and non-scheduled operations.
Specifically, the Staff recommendation adopted by the Board would modify the TMI-2 Technical Specifications to require Applicants to re-port annually "the total number of movements of aircraft larger than 200,000 pounds (broken down into scheduled and non-scheduled operations), based on a current percentage estimate provided by the airport manager."
Applicants have no objection to this modification.
The second requirement imposed by the Board would require Applicants to update their analysis of crash proba-bility utilizing current Harrisburg Airport traffic figures
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as well as updated national aerial crash density values.
The update would be required prior to any return of TMI-2 to operation and every three years thereafter.
While the Board requirement applies only to TMI-2, the Board suggests in footnote 61 of the Decision chat the Staff may wish to impose a similar requirement in conntetion with a resumption of oper-ation of TMI-1.
Applicants believe that the Board's objectives can be achieved short of a mandatory full-scale reanalysis of aircrash probability requiring collection and analysis of M
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detailed information on national'aircrashes and their spatial distribution.
In Applicants' view such a full-scale reanalysis should be triggered only in the event of a significant change in the key data which dominate the probability determination.
Applicants have' requested their consultants to identify such key data and to propose ari intermediate cal'culation which would be used to determine whether a full-scale analysis is necessary.
To allow time for'.the development of this proposal Applicants request an extens' ion o'f time to November 15, 1982, in which to file a motion for reconsideration of the Board's decision.
Respectfully submitted, SHAW, P T
POTTS & TROWBRIDGE hd d'
n eF.Tfosbridge[P.C.
Geo Dated: October 20, 1982 O
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M Cert 3f,,, Py UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of~
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METROPOLITAN EDISON COMPANY,
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et al
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Docket No. 50-320
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(Three Mile Island Nuclear
)
l Station, Unit 2)
)
f CERTIFICATE OF SERVICE l
I hereby certify that copies of " Applicants' Request for Extension of Time to File Motion for Reconsideration and Modification of Appeal Board Decision Dat,ed September 15, 1982 (ALAB-692)," were served upon those persons on the attached i
Service List by deposit in the United States mail, postage pre-l l
1 paid, or as indicated by asterisk by personal service, this 20th day of October, 1982.
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Trowbridge Dated: October 20, 1982 O
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F UNITED STATES.OF AMERICA E3
, NUCLEAR REGULATORY COMMISg.g b g
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BEFORE THE ATOMIC ~SA5ETY AND LICENSING APPEAL BOARD
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In the Matter of ^
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, 1 METROPOLITAN EDISON COMPANY,
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et al
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Docket No. 50-320 *
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(Three Mile Island Nuclear
)
Station, Unit 2)
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l SERVICE LIST
- Alan S. Rosenthal, Esq.
Karin W. Carter, Esquire Chairman, Atomic Safety and Assistant Attorney General Licensing Appeal Board Commonwealth of Pennsylvania U.S. Nuclear Regulatory Commission 505 Executive House Wash'ington, D.C.
20555 P. O. Box 2357 Harrisburg, PA.
17120
- Dr. W. Reed Johnson Atomic Safety and Licensing Dr. Chauncey R. Kepford
, Appeal Board 433 Orlando Avenue U.S. Nuclear Regulatory Commission State College, PA 16801
)
Washington, D.C.
20555 Atomic Safety and Licensing
- Dr. John H. Buck Appeal Board Panel l
Atomic Safety and Licensing U.S. Nuclear Regulatory Commission l
Appeal Boa'rd Washington, D.C.
20555 i
U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 Atomic Safety and Licensing Board Panal Ldwrence J. Chandler, Esq.
U.S. Nuclear Regulatory Commission Office of the Executive Legal Washington, D.C.
20555 Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section (3)
Office of the Secretary U.S. Nuclear. Regulatory Commission, Washington, D.C.
20555 i
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October 20, 1982 1
UNITED STATES OF AMERICA DESIGNATED ORIGIHAIl.,,
3 NUCLEAR B5GULATORY COMMISSION
's new+trina By BEFORE THE COMMISSION ls In'the Matter of
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1 METROPOLITAN EDISON COMPANY,
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et al
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Docket No. 50-320
)
(Three Mile Island Nuclear
)
Station, Unit 2)
)
1 APPLICANTS' MOTION TO EXTEND PERIOD OF TIME FOR COMMISSION REVIEW OF ALAB-692
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l On September 15, 1982, the Atomic Safety and Licensing
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Appeal Board issued a decision in this proceeding (ALAB-692) which concluded, on the bases of probability analyses presented s
I by Applicants and the Staff using air tr'affic and aircrash data through 1977, that the annual probability of a heavy airplane
-7 crash on TMI-2 was less than the 10 guideline set out in the
$tandard Review Plan.
At the same time the Board indicated a need to update the data base periodically in order to determine whether the guideline continues to be sat,isfied.
To this end v
the Board added a condition requiring Applicants to update their analysis of. crash probability util"izing current Harrisburg Air-N port' traffic figures as well as updated national aerial crash density values.
The update would be required prior to any re-turn of TMI-2 to operation and every three years thereafter.
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While the Board requirement applies only to TMI-2, the Board suggests in footnote 61 of its Decision that the Staff.may wish to impose a similar requir' ment in connection with a re-e sumption of operation of TMI-1.
Applicants have today. filed with the Appeal Board a motion indicating Applicants' intent to seek a modification of the Appeal Board's decision and requestin'g an extension of time until November 15, 1982, within which to file a motion for reconsideration and modification of.that decisio'.
A copy n
of Applicants' motion is attached.
Under Section 2.786 the Commission has 40 days, i.e.
unt'il October 25, 1982, to review the Appeal Board's September 15 decision on its own motion.
In light of Applicants' motion to the Appeal Board for extension of tims hnd proposed motion for reconsideration and modification of that decision, and in order to avoid any question of the Appeal Board's jurisdiction to entertain such motions, Applicants request that the Commis-sion extend the period for its sua sconte review of the Appeal Board's decision until 40 days after final disposition by the Appeal Board of Applicants' motions.
Respectfull'y submitted,
- SHAli, ITTMAN, POTTS TROWBRIDGE E92/
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Geo/rge F. Trowbridge,/P.D.
Dated: October 20, 1982
DESIGNATED ORIGINAL Certified By UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE' COMMISSION In the Matter of
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METROPOLITAN EDISON COMPANY,
)
et al
)
Docket No. 50-320.
)
(Three Mile Island Nuclear
)
Station, Unit 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion to Extend Period of Time for Commission Review of ALAB-692,"
were served upon those persons on the attached Service List by I
deposit in the United States mail, postage prepaid, or as indi-cated by asterisk'by personal service, this 20th day of Octo-ber, 1982.
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J George F. Trowbridge[
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Dated: 00tober 20, 1982
DESIGMign OEM M
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UNITED STATES OF AMERICA 19 NUCLEAR REGULATORY COMMISSION 2
egifted M BEFORE THE COMMISSION In the Matter of
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METROPOLITAN EDISON COMPANY,
)
et al
)
Docket.No. 50-320
)
(Three Mile Island Nuclear
)
Station, Unit 2)
)
SERVICE LIST
- Nunzio J. Palladino, Chairman
- Dr. John H. Buck U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Appeal Board U.S. Nuclear Regulatory Commission
- Victor Gilinsky, Commissioner Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Lawrenc'e
- J. Charidler, Esquire Office of the Executive Legal
- John F. Ahearne, Commissioner Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555' Washington, D.C.
20555
- Thomas M. Roberts, Commissioner Docketing and Service Section (3)
U.S. Nuclear Regulatory Commis'sion Office of the Secretary Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- James K. Asselstine, Commis'sioner U.S. Nuclear Regulatory Commission Karin W. Carter, Esquire Washington, D.C.
20555 Assistant Attorney General Commonwealth of Pennsylvania
- Alan S. Rosenthal, Esquire 505 Exe,cutive House Chairman, Atomic Safety and P. O. Box 2357 Licensing Appeal Board Harrisburg, PA 17120 U.S. Nuclear Regulatory Commission Washington, D'.C." 20555
$Dr. Chauncey'R.~ Kepford
'43.3 Orlando. Avenue
- Dr. W. Reed Johnson
. State College., PA 16801 Atomic Safety and Licensing Appeal Board Atomic Safety and Licensing Appeal U.S. Nuclear Regulatory Commission Board Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Commission i
Washington, D.C.
20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Octob::r 20, 1982 ic1EG 5, UNITED STATES OF AMERICAn,-tW P
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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
')
)
METROPOLITAN EDISON COMPANY,
)
et al
)
Docket No. 50-320
)
(Three Mile Island Nuclear
)
Station, Unit 2)
)
APPLICANTS' REQUEST FOR EXTENSION OF TIME TO FILE MOTION FOR RECONSIDERATION AND MODIFICATION OF APPEAL BOARD DECISION DATED SEPTEMBER 15, 1982 (ALAB-692)
By its Decision dated September 15, 1982 (ALAB-692) the Appeal Board found, on the bases of probability analyses presented by Applicants and the Staff using air traffic and aircrash data through 1977, that the annual probability of a
~7 heavy airplane c2. ash on TMI-2 was less than the 10 guideline set out in the Standard Review Plan.
At the same time the Board indicated a need to update the data base periodically in order to determine whether the guideline continues to be satisfied.
To this end the Board added two license conditions.
The_first of these conditions would adopt a staff recommendation to modify the present.TMI-2 Technical Specifi-cations, which already require Applicants to make an annual report of aircraft operations at Harrisburg, to call for a a
~
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breakdown of the number of heavy aircraft operations into scheduled and non-scheduled operations.
Specifically, the Staff recommendation adopted by the Board would modify the TMI-2 Technical Specifications to require Applicants to re-port annually "the total number of movements of aircraft larger than 200,000 pounds (broken down into scheduled and non-scheduled operations), based on a current percentage estimate provided by the airport manager."
Applicants have no objection to this modification.
The segund requirement imposed by the Board would require Applicants to update their analysis of crash proba-bility utilizing current Harrisburg Airport traffic figures as well as updated national aerial crash density values.
The update would be required prior to any return of TMI-2 to operation and every three years thereafter.
While the Board requirement applies only to TMI-2, the Board suggests in footnote 61 of the Decision that the Staff may wish to impose a similar requirement in connection with a resumption of oper-ation of TMI-1.
Applicants believe that the Board's objectives can be achieved short of a mandatory full-scale reanalysis of aircrash probability requiring collection and analysis of detailedinfo$mationonnational'arcrashesandtheirspatial distribution.
In Applicants' view such a full-scale reanalysis should be triggered only in the event of a significant change in the key data which dominate the probability determination.
Applicants-have~ requested their consultants to identify such key data and to propose an intermediate cal'culation which would be used to determine whether a full-scale analysis is necessary.
To allow time for'.the development of this proposal Applicants
~
request an extension o'f time to November 15, 1982, in which to i
file a motion for reconsideration of the Board's decision.
Respectfully submitted, SHAW, P T
POTTS & TROWBRIDGE
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eF.Tfowbridge[P.C.
Geo Dated: October 20, 1982 O g e
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DESIGNATED ORIGIHAL..
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSzON g 37 g
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of~~
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)
METROPOLITAN EDISON COMPANY,
)
et al
)
Docket No. 50-320
)
(Three Mile Island Nuclear
)
Station, Unit 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Request for Extension of Time to File Motion for Reconsideration and Modification of Appeal Board Decision Dat,ed September 15, 1982 (ALAB-692)," were served upon those persons on the attached Service List by deposit in the United States mail, postage pre-paid, or as indicated by asterisk by personal service, this 20th day of October, 1982.
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~W eorh F.
Trowbridge Dated: October 20, 1982 4
UNITED STATES.0F AMERICA
, NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SA5ETY AND LICENSING APPEAL BOARD In the Matter of.~
)
)
METROPOLITAN EDISON COMPANY,
)
et al
.)
Docket No. 50-320
)
(Three Mile Island Nuclear
)
Station, Unit 2)
)
SERVICE LIST
- Alan S.
Rosenthal, Esq.
Karin W. Carter, Esquire Chairman, Atomic Safety and Assistant Attorney General Licensing Appeal Board Commonwealth of Pennsylvania U.S. Nuclear Regulatory Commission 505 Executive House Washington, D.C.
20555 P.
O. Box 2357 Harrisburg, PA.
17120
- Dr. W. Reed Johnson Atomic Safety and Licensing Dr. Chauncey R.
Kepford
. Appeal Board 433 Orlando Avenue U.S. Nuclear Regulatory Commission State College, PA 16801 Washington, D.C.
20555 Atomic Safety and Licensing
- Dr. John H. Buck Appeal Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Boa'rd Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel Ldwrence J. Chandler, Esq.
U.S. Nuclear Regulatory Commis= inn Office of the Executive Legal Washington, D.C.
20555 Director U.S. Nuclear Regulatory Commission
-j Washington, D.C.
20555 i
Docketing and Service Section (3)
Office of the Secretary U.S. Nuclear. Regulatory Commission-:
Washington, D.C.
20555 s
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