ML20032D862
| ML20032D862 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/09/1981 |
| From: | Johnsrud J Environmental Coalition on Nuclear Power |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8111180187 | |
| Download: ML20032D862 (2) | |
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o ENVIRONMENTAL COALITION ON NUCLEAR POWER LOL4E TEt Ca osrector
(*%g r Dr. Jud.th Johnsrud-433 Orlando Aver.ve, State College, Pa. 16801 814-237 3900 U':ITED STATES OF ll*:RIC/.
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'!UCLEff T.EGULATCP.Y C0 r!ISSIO.*!
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PHIL/CELPHIt. ELECTI.IC CD:*T !Y.
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(Li7erich Carerating' Station,
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?.':?UEST' 0F : TIT 10"ET E'!'.'ITT!"E"Ill C0f LITIO1 0" 1'.'CLETR PT!EP FT Uai n, " TP T?LI C/*;T TO "MVI FSt.E /ar. 5e f.*!3 T0 m//lT TO ALL PETITIO';ERS A.:/C "!.;LE EXTE"5I31 0F TI"E TO FILE C01TE*lTIO3S On October 14, 1931, the Ceard in this proceeding ordered the Applicant to prcvide promptly copies of t!.e FSAR and EE., up to date, to certain Petitioners and at certain locations for the convenience of other Petitioners.
On ':oveder 2,.10:1, EC'!? received notification froa counsel for the Applicant that copies t.ould Le nade available to EC:!P.
This day, !!ovember 7, 1El, I have received a copy of Volanes 1 and 2 of the Prcbabilistic Risk As s es sn.cnt.
EC*P has had no fure.cr notification concerning the FSAn and ER.-
The Coard's schedule in the October 14th Order directs Petitioners to coorJinate cnd consolidate to the greatest degr2e possible their contentions and to file tr cse contentions. ith the Ceard by ::ovember 17, 1901.
EC'!P's legal represcntative trill be out of to.en on business until the evening of
- ova:c.ber 12th, se that, even should the docu. tents arrive at the earliest pcssible mail delivery, the afterr. con of :;ovealer 9, there will remain only one week in which to read, digest, and ponder the contents of these nuaerous volu..es and to dra't, scordinate and consolidate, type, and copy contentions.
Claarly, the A?plicant's bilure to comply pror:ptly -- indeed, at all --
.uith tha Coard's directiv2 to provide the FS/J. and EP. to these Petitioners sericusly prejudices EC::P's, and other Petiticners', ri0 ts in this pro-h ceeding.
The Pcttstcun Public Decunents Roo, is about 175 r.iles distant froa EC'P's representative; good faith efforts have, however, been made to visit that library and to begin C task cf studyin ; the docunents, at
.artahtta, perscnal expenditure.
It i'
- that the Applicant's fail be a
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by tai: ".c;rJ..ith an c: rc.riate reri.ad cnd,..e would suriest, renalty sinilt.r tc t5c restrictiu.: u:.cn partici; aticn in cross-examinaticn that hav2 been..2ted cut tc In ervenors ir., inter alic, Tnrec !!ile Island, Unit 1, Tastart and Suse,uehanna 3:erating License proceedings.
EC'P so noves.
EC:P furtner requests respectfully that this 30ard demonstrate fair practice by granting to tne Petitioners who have been handicapped by the Ipplicant's f ailure to conoly with a Goard order a nininua extension of time of twenty days from the date of arrival of the FST.P. and ER.
Even that time. period will be grossly inadequate for the coordination and consolidation of contenticos by all Petitioners.
EC::P will, however, attempt to do so within such an extended period of time.
The Applicant, being responsible for the delay, cannot claim that its interests are prajudiced by the granting of this recuest.
- or will the NRC Staff be prejudiced, in view of its presently distant projected dates for the provision of documents.
P.espectfully subnitted, s-j o. /M'rnJ ir. Judith H. Johnsrud g
Representative and Co-Director,
..m.
Dated this 7-day Environmental Coalition on uclear her of : ovember,1931 CEI.TIFICATE OF SERVICE I hereby ce rti f y that copies of the above naned P.EAUEST have been served on the pariies to thipeproceeding by deposit in the US : tail, first class, posta:e paid, this 7 day of ::ovember,1901.
/nd // /) /P$rfuxS
[adith H. Johnsrud
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