ML20040H597

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Objects to ASLB Granting Applicant Extension of Time Re ASLB 820129 Memorandum & Order,Due to Util Refusal to Confer on Contentions.Util Should Provide Written Guarantee That No Surveillance on Public Would Be Conducted
ML20040H597
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 02/10/1982
From: Romano F
AIR AND WATER POLLUTION PATROL
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8202180425
Download: ML20040H597 (2)


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Washington, D.C. 20555 BRA!4CH In the Matter of Docket Nos. 50 50-353 PHILADELPHIA ELECTRIC CO'-IPANY (Limerick Generating Station, Units 1 & 2)

During the Jan. 6-7-8/82 prehearing conference Judge Lawrence Brenner, for the sake of assuring co-operation in serving the public interest, ahked if the Applicant's counsel would consider getting together with the co-ordinated intervenors/and/or intervenors' counsel, to iron out points regard-ing certain aspects of contentions including the PRA.

The Applicant's Counsel refused on the basis that Philadlephia Electric might be caused to reveal a fact or information which the intervenors might then use against P.E.

Judge Brenner was correct in generally stating the basis for tha hearings is to secure the safety of the'public. The Applicant, therefore, should not fear that discussion with intervenors might smoke out information detrimental to the Applicant.

Such information belongs to the public...and inparticular, the Licensing Board, in order to insure the completion of the record as it affects public nafety.

Because P.E. refused to co-operate (with apparent selfish intent). I object to the Licensing Board extending P.E.'s request re the Jan. 29/82 NRC Memorandum and Order re " Applicant's request for Extension of Time".

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I object on the basis that I did not receive the above subject matter notice until Fec. 6/82 a day after the extension date.

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Further, as it relates to Applicant's letter of 2/3/82 to Mr. A. Schwen-l cer (!mC) re Plant Security Personnel Training and Qualification Plan, the Applicant requests that the " enclosed response be witheld from public disclo-sure because of safeguards information, and information relating to details of the security plans of a licensed facility."

As an intervenor, I ask the NRC to require of the Applicant a written guarrantee the Applicant will conduct no surveillance that directly or in-directly infringes on the civil rights, privacy, and freedom of movement of the public outside the property limits of the Applicant's proposed Facility.

1ced the attached list.

j I certify I have, by first class mail, this day h

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TU@R. Rcmano Fran 61 Forest Ave.

FRR/jch Ambler, Pa. 19002 06 I

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8202180425 020210 PDR ADOCK 05000352 G

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cc:

Administrative Judge Lawrence Brenner

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Administrative Judge Richard F. Cole Administrative Judge Peter A. Morris Stephen H. Lewis, Esq.

Mr. Charles B. Taylor

!!r. Robert: L. Anthony Mr. Marvin I. Lewis Samuel and Clarissa B. Cooper Judith A. Dorsey, Esq.

Charles W. Elliott, Esq Mr. William Lochstet Mr. Alan J. Nogee Mr. Steven Levin Edward G. Bauer, Jr., Esq.

Robert W. Adler, Esq.

Mr. Thomas Gerusky Director, Pennsylvania Emergency Management Agency John Shniper, Esq.

Steven P. Hershey James M. Neill, Esq.

Donald S. Bronstein, Esq.

Mr. Joseph H. White, III Dr. Judith H. Johnsrud Walter W. Cohen, Esq.

Robert J. Sugarman, Esq.

Mr. W. Wilson Goode Atomic Safety and Licensing Appeal Panel Atomic Safety and Licensing Board Panel Docket and Service Section Troy B. Conner, Jr., Esq.