ML20040D769
| ML20040D769 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/27/1982 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20040D770 | List: |
| References | |
| NUDOCS 8202020236 | |
| Download: ML20040D769 (5) | |
Text
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Licin=3 1/27/82
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00(KETE tSNRr UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'82 JM 28 P2:03 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
'N MCT CF D. -'jj J' 00 1 In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-aa
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(Restar g
(Three Mile Island Nuclear
)
g Station, Unit No. 1)
)
T4 RECEtVED y E:
FEB1 1982> %,
LICENSEE'S REPLY TO UCS MOTION AND SUPPLEMENTAL Ti(NS$
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[<p FOR RECONSIDERATION OF MOTION FOR EXTENSION O T
E EC TO FILE EXCEPTIONS r __
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In response to a motion filed by UCS on December 18, 1981, the Appeal Board extended the time for filing exceptions to the Licensing Board's December 14, 1981, partial initial de-cision until February 1, 1982.
On January 21, 1982, UCS filed a motion for further extension of the deadline for filing excep-tions until February 16, 1982 (or until March 1, 1982, in the event the Commission granted UCS' motion to extend the time for filing comments on immediate effectiveness of the Licensing Board's decision until February 15, 1982).1/
This motion was denied by the Appeal Board in an order dated January 22, 1982.
On January 26, 1982, UCS filed with the Appeal Board a supplement to and request for reconsideration of its January 21 motion for extension of time to file exceptions.
Licensee opposes this request.
%Q3 1/ Licensee's counsel has been informed by telephone by the 5
Office of the Secretary of the Commission that the Commis-sion is today issuing an order denying UCS' motion for
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further extension of the comment period.
8202020236 820127 PDR ADOCK 05000289 C
UCS asserts in its supplemental filing that its motions to the Commission and the Appeal Board for extensions of time were " compelled by the unusual number of pleadings re-quired at this stage of the proceeding, and the resulting prejudice of UCS' ability to participate in a meaningful way'.'.2/
i' UCS does not identify in its motion for reconsideration the
(
" unusual number of pleadings" to which it refers.
Licensee assumes, however, that UCS has reference to the same documents l
and workload urged by UCS upon the Commission as the basis for the extension of the deadline for filing comments on immediate i
effectiveness.
Licensee has addressed each of these bases in I
response to UCS' filings with the Commission, none of which in Licensee's view justify an extension of the six-week period already allowed by the Appeal Board for the filing of exceptions.
Copies of Licensee's responses to UCS' filings with the Commis- ~
sion dated January 5 and January 25, 1982, are' enclosed with this reply.
Respectfully submitted, SHAW, PI TMAN, POTTS & TROWBRIDGE By b)
/ZW d
n Ge[rge F. Trowbridge[
Dated: January 27, 1982 2/ As pointed out by the Appeal Board in its January 22 decision, UCS did not in its January 21 motion allege that it would be unable to comply with the schedule established by the Appeal Board for exceptions or that its ability to litigate its posi-tion effectively would be in any way compromised.
UCS' allega--
tion is made for the first time to the Appeal Board in its motion for reconsideration. _ _ _ _ __________ ______
i UNITED STATES OF AMERICA NUCLEAR REGULATORY-COMMISSION c
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In.the Matter 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 Reply to UCS Motion and Supplemental Motion for Reconsideration of Motion for Extension of Time to File Exceptions," dated January 27, 1982, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, or as noted by asterisk (*) by hand delivery, this 27th day of January, 1982.
Aff/2 Y
/J M
[eorge F. Trowbridge [
Dated: January 27, 1982
l UNITED STATES OF AMERICA UCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinc Appeal Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
( estart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST Administrative Judge Administrative Judge Gary J. Edles, Chairman Ivan W.
Smith, Chairman' Atomic Safety & Licensing A'tomic Safety & Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 j
Administrative Judge Administrative Judge Walter H.. Jordan John H. Buck Atomic Safety & Licensing Board-Atomic Safety & Licensing 881 West Outer Drive Appeal Board Oak Ridge, Tennessee 37830 U.S. Nuclear Regulatory Commission
~ Administrative Judge Washington, D.C.
20555 Linda W.
Little Atomic Safety & Licensing Board Administrative Judge 5000 Hermitage Drive Christine N. Kohl Raleigh, North Carolina 27612 Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatcry Washington, D.C.
20555 Commission Washington, D.C.
20555 James R. Tourtellotte, Esq. (4) l Office of the Executive Atomic Safety & Licensing Appeal Legal Director Board Panel L
U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission-Commission Washington, D.C.
20555 Washington, D.C.
20555
~
Docketing'& Service Section (3)
Robert Q. Pollard Office of the Secretary 609 Montpelier Street U.S. Nuclear Regulatory Baltimore, MD 21218 Commission Washington, D.C.
20555
2-Robert Adler, Esquire Ms. Louise Bradford Karin W.
Carter, Esquire TMI ALERT Assistant Attorney General 1011 Green Street 505 Executive House Harrisburg, PA 17102 Post Office Box 2357 Harrisburg, PA 17120 Mr. Norman Aamodt R.
D.
5 Attorney General of New Jersey Coatesville, PA 19,}20 Attn: Thomas J. Germine, Esq.
Deputy Attorney General Division of Law - Room 316 1100 Raymond Boulevard Newark, New Jersey 07102 John A. Levin, Esquire Ms. Gail Phelps Assistant Counsel ANGRY Pennsylvania Public Utility 245 West Philadelphia Street Commission York, PA 17404 Post Office Box 3265 Harrisburg, PA 17120 Jordan D..Cunningham, Esquire Fox, Farr & Cunningham John E. Minnich, Chairman 2320 North Second Street Dauphin County Board of Harrisburg, PA 17110 Commissioners Ellyn R. Weiss, Esquire Dauphin County Courthouse Front and Market Streets William S. Jordan, III, Esquire Harrisburg, PA 17101 Harmon.& Weiss 1725 Eye Street, N.W.,
Suite 506 Walter W.
Cohen, Esquire Washington, D.C.
20006 Consumer Advocate
~' ~ ~ ~ ~ Office of Consumer Advocate Mr. Steven C. Sholly 1425 Strawberry Square Union of Concerned Scientists Harrisburg, PA 17127 1346. Connecticut Avenue,.NW'#1101 Washington, D.C.
20036 Chauncey Kepford Judith H.
Johnsrud Marvin I. Lewis Environmental Coalition on 6504 Bradford Terrace Nuclear Power Philadelphia, PA 19149 433 Orlando Avenue 3
State College, PA 16801 e
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