ML20040D777
| ML20040D777 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/25/1982 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20040D770 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8202020242 | |
| Download: ML20040D777 (6) | |
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LIC 1/25/82
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C?yfl:7 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 02 J4!/ 28 P2:03 CFnc
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00CM e f,0 Before the Commission In the Matter of
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Docket No. 50-289 SP METROPOLITAN EDISON COMPANY
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(Restart)
(Three Mile Island Nuclear
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Station, Unit No. 1)
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LICENSEE'S REPLY TO UCS MOTION FOR RECONSIDERATION On January 21, 1982, UCS filed a Motion for reconsideration of the Commission's Order of January 11, 1982, extending until January 28, 1982, the time for comments on immediate effectiveness of the Licensing Board's partial initial decision of December.14, 1981.
The UCS motion for. reconsideration, which was filed only one week before the due date for comments,-repeats UCS's earlier request that the comment period be extended to February 15, 1982.
Contrary to.the UCS certificate of service which accompanied its motion for reconsideration, the motion was not hand-delivered to T
Licensee's counsel but was placed in the ordinary U.S. mail on January 21.
UCS's original request for extension was based on UCS's other involvements during the comment pericd in the TMI-1 proceeding.
These involvements have already been considered by the Commission in. rescheduling comments from January 13 to January 28, 1982.
The m
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only new involvement asserted by UCS is the Commission's invitation to parties on January 15, 1982, to comment on certain additional i
materials presented by the Staff and ACRS to the Commission at a January 8, 1982, briefing session on water level instrumentation.
In its earlier request, UCS a'lso argued as a basis for exten-
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sion of the comment period an earlier opportunity afforded by the Commission to comment on another set of papers provided to the Commission by the Staff on the water level instrumentation issue.
At that time Licensee pointed out that UCS had abandoned its con-tention on this issue before the Licensing Board, did not parti-cipate in any of the testimony or argument on the issue before the Licensing Board, and filed no proposed findings on the is' sue.
In
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these circumstances, any decision by UCS to reenter the fray could not justify extension of the comment period on immediate effective-ness.
i Further, considering the comments filed by UCS in response-to the Commission's earlier invitation, the Commission should view with skepticism both the contribution which UCS is likely to make in a second round of comments on the water level issue and the time involved in making such comments.
UCS's earlier comments, consist-ing of little more than a page, were buried in its filing with the Commission, dated January 13, 1982, entitled "UCS Comments on Staff Briefing of Commission and Renewal of Motion for Affidavits Con-cerning Ex Parte Contacts."
Like the rest of the document, UCS's comments attacked the propriety of Commission meetings with'the
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' s Staff and contained no technical information or analysis.
Respectfully submittled, SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 202/822-1000 M
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By:
M/
' y iceorge r.'Trowbrig e Counsel for Licensee 4
e e
C t
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LIC.1/25/82
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission In the Matter of
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Docket No. 50-289 SP METROPOLITAN EDISON COMPANY
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(Restart)
(Three Mile Isidnd Nuclear
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Station, Unit No. 1)
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CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing-
" Licensee's Reply to UCS Motion for Reconsideration" was served by hand delivery on those persons on the attached Service List with l
an asterisk (*) appearing before their names, and by deposit in
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l the United States mail, postage prepaid, addressed to all'other persons on the attached Service List, this 25th day of January, 1982.
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Gegrge F. Trowbridge/
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LIC 1/25/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission In the Matter of
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Docket No. 50-289 SP METROPOLITAN EDISON COMPANY
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(Restart)
(Th'ree. Mile Island Nuclear
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Station, Unit No. 1)
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SERVICE LIST Chairman Nunzio Palladino Administrative Judge U.S. Nuclear Regulatory Ivan W. Smith (2)
Commission Chairman, Atomic Safety &
Washington, D.C.
20555 Licensing Board' U.S. Nuclear Regulatory Commissioner Victor Gilinsky Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Administrative Judge Walter H. Jordan Commissioner Thomas Roberts Atomic Safety & Licensing Board U.S. Nuclear Regulatory 881 West Outer Drive Commission Oak Ridge, Tennessee 37830 Washington, D.C.
20555 Administrative Judge Commissioner John Ahearne Linda W. Little U.S. Nuclear Regulatory Atomic Safety & Licensing Board Commission 5000 Hermitage Drive Washington, D.C.
20555 Raleigh, North Carolina 27612 Commissioner Peter Bradford Docketing & Service Section (3)
U.S. Nuclear Regulatory Office of the Secretary Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 James R.
Tourtel20tte, Esq. (4)
Robert Adler, Esquire Office of Executive Legal Karin W.
Carter, Esquire Director Assistant Attorneys General U.S. Nuclear Regulatory 505 Executive House Commission Post Office Sox 2357 Washington, D.C.
20555 Harr:sburg, PA 17120
=,..
. Chairman, Atomic Safety &
Jordan D. Cunningham, Esquire 4
Licensing Board Panel-Fox, Farr & Cunningham U.S.. Nuclear Regulatory 2320 North Second Street Commission Harrisburg, PA 17110 1
Washington, D.C.
20555 Ms. Louise Bradford i
Chairman,' Atomic Safety & Licensing TMI ALERT l
Appeal Board Panel 1011 Green Street U.S. Nuclear Regulatory Harrisburg, PA 17102 Commission Ellyn R. Weiss, Esquire Washington, D.C.
20555 Harmon & Weiss Attorney General of New Jersey, 1725 I Street, N.W.,
Suite 506 Attn: Thomas J.
Germine, Esquire Washington, D.C.
20006 Deputy Attorney General Division of Law - Room 316 Ms. Gall Phelps 1100 Raymond Boulevard ANGRY Newark, New Jersey 07102 245 W. Philadelphia Street York, PA 17404 John A.
Levin, Esquire Assistant Counsel Mr. Steven C.
Sholly Pennsylvania Public Utility Union.of Concerned Scientists Commission 1346 Connecticut Avenue, N.W.
Fast Office Box 3265 Dupont Circle Bldg., Suite 1101 Harrisburg, PA 17120 Washington, D.C.
20036 John E..Minnich, Chairman William S.
Jordan, III, Esquire Dauphin County Board of Harmon & Weiss Commissioners 1725 I Street, N.Ws, Suite 506 Dauphin County Courthouse Washington, D.C.
20006 Front and Market Streets Harrisburg, PA 17101 Chauncey Kepford Judith H. Johnsrud Walter W.
Cohen, Esquire Environmental Coalition on Consumer Advocate Nuclear Power Office of Consumer Advocate 433 orlando Avenue 1425 Strawberry Square State College, PA 16801 Harrisburg, PA 17127 Marvin I. Lewis Robert Q. Pollard 6504 Bradford Terrace 609 Montpelier Street Philadelphia, PA 19149 Baltimore, MD 21218 Mr. Norman Aamodt R.
D.
5 Coatesville, PA 19320 i
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