ML20032D861
| ML20032D861 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/06/1981 |
| From: | Ramano F AIR AND WATER POLLUTION PATROL |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8111180186 | |
| Download: ML20032D861 (4) | |
Text
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Gentlemen:
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. REQUEST FOR ADDITIO';AL TIME FOR PREPARATION OF CONTENTIONS BY THE AIR
ATER POLLUTION PARTOL AND FRANK R. ROMANO, TOGETilER A';D SEPARATELY.
Under the present schedule established by Chaiman Brenner in his remo-randum and Order of October 14, 1081 all contentions must he received in
'"ashington D.C. by Novenber 17, 1081.
In addition, the Board has requested intervenors to attempt to coordi-nate "their filings and if possible to even nake a joint statement of con-tentions".
t'hile the Board cav feel that this vill result in more organized contentions, this will not he possible under the present schedule for the folloeir.g reasons:
1)
INAVAILABILITY"*0F EROL IN PARTICULAR RECENT PAGE REVISIO"S AND SUPPLIMENTS.
Revisions nade in the EROL after docketing arrived at the Pottstown Library within the nast week, -The librarians are attempting to incorporate these chang-es, but are shorthanded and have not done so vet.
Many of these changes relate to water supply infor-mation.
In addition EROL direction towards separ-ate cover supplemental information relating to "ni-croneterological" data, first was unincorporated and second was of such poor copy and print-size that ceuld not be read by ee and others.
2)
DIFFICULTY OF COOPJ)INATING UITH OTHER PARTIES It is not possible to know exactly what contentions other parties nay uish to file and there is no au-thority to specify which party nust forego contention.
Also who uill pay for organizing coordination expen-ses: pay bills, travel expenses, lost time from work or other expenses involved in contacting other parties?
h As a volunteer citizen's organization we are hardpressed h
on tice preparing our own case naking it impossible h
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to have tine to contact the 15 or nore petitioners who are having tine problems also, i
f 8111180186 811106 PDR ADOCK 05000352 PDR G
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<? FC AIR and WATER Polution Patrol BROAD AXE, PA.
!;ovember 6, 1981 (B) 3)
10 CRF Section 2.714 (b) states that contentions are due no later than 15 days before the special prehearing conference.
The Board has presently scheduled this for Januarv 1982. This indicates it is possible to per=it more time.
Part (b) also states that additional time for filing may be granted if good cause can be shown.
In response to section (a) (1) I hereby present my argument for an extention of the November 17 deadline.
Change of specific rules to be followed, namely aspects vs no aspects; your modification requesting " group" coord-ination of contention resulting in loss of time in the failure of such effort, and the incomplete organization and coordination of revisions and suppliments at the Pottstown Library doubled my estimated time of preparation. For ex-a=ple, Philadelphia T.lectirc's letter of October 1, 1981 to Mr. Robert L.
Tedesco, Assistant Director of Licensing of the NRC, involved one contention of mine re "effect of quarry blasting on poured concrete at the Linerick reactor".
This five nonth delay in an r by the applicant adds to a pattern of keeping oponents of the reactor from timely information.
I only became aware of the delayed applicant's letter on November 2, 1981 while looking through piles of unsorted suppliments, letters, etc. sent by the NRC to the Pottstown Library.
Under 2.715 (a) all the delays discussed vill prejudice my right to an individual, fair, and reasonable tine in which to assemble necessary specific information both to protect me and my family from radiation harm as well.as'toradd information the Board can profit by. I will need at least three more weeks.
As a pollution chenist, with formal nuclear training sufficient to feel a, personal danger to me, my family and the menbers (in particular those tehose affidavits accompanied my original request for a hearing) indicate I must, rather than soncone else, represent my personal interests above.
Further, as a licensed pilot, I have experienced engine failure with the threat of fatal consequences due to carbuerator ice caused by high moisture conditions, such as the reactor will produce, together with other cloud and turbulence effects which are improperly calculated and therefore minimized in the EROL.
.y.X AIR and WATER Pollution Patrol BROAD AXE,PA.
November 6, 1981 (C)
Since the Federally operated VOR is approximactly lh miles from the reactor and is used for navicational ourposes modified weather conditions not included in Flight Service Information can result in fatal accidents both to me and passengers in other planes. Such experience vill he')
develop a sound record.
Very truly yours,
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AIRJ WATER POLLUTION PATROL G__
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Frank R. Romano, Chairman 61 Forest Ave.
Anbler, Pa. 19002 Y
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NUCLEAR REGULATORY COMIISSION
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.e BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of PHILADELPHIA ELECTRIC COMPANY Docket ';os.
50-352 50-353 (Linerick Generating Station, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that copies of Letter for Additional Time in the above-captioned proceeding have been served on the following by deposit in the United States nail, first class, this 6th day of November, 1981:
Lawrence Erenner, Esq., Chairnan- -
Walter U. Cohen, Esq.
Adninistrative Judge Consuner Advocate U. S. Nuclear Regulatory Con =iesion Office of Attorney General Washington, D.C. 20555 1425 Strawberry Square Harrisburg, Pa. 17120
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Docketing and Service Section
.__ Office of the Secretan Allen J. Nogee, U.S. Nuclear Regulatory Cornission Keystone Alliance Washington, D.C.20555 3700 Chestnut St.
Philadelphia, Pa. 19104 Troy B. Connery Jr., Esq.
Mark J. Uetterhahn, Esq.
Robert J. Sugernan Conner and Wetterhahn Del-Avare Unlinited, Inc.
1747 Pennsylvania Ave, NW Rerle, Butzel, Kass & Case Washtaton, D.C.20006 2115 Eainbridge St.
Philadelphia, Pa. 19146 Judith A. Dorsey, Esq.
Linerick Ecology Action
~ Environnental Coalition on Nuclear Power 1315 Walnut St., Suite 1632 Dr. Judith H. Johnsrud, Co-Director Philadelphia, Pa. 19107 433 orlando Ave.
State College, Pa. 19801 Respectfullv suhr t d, FranD.b./
R. Romano AIR A'!D UATER POLLUTION PATROL g
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Movenber 6, 1981