ML20049J437
| ML20049J437 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/12/1982 |
| From: | Weiss E UNION OF CONCERNED SCIENTISTS |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20049J434 | List: |
| References | |
| NUDOCS 8203180200 | |
| Download: ML20049J437 (4) | |
Text
N UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of METROPOLITAN EDISON COMPANY, et al.,
Docket No. 50-289
}
(Restart)
(Three Mile Island Nuclear Station, Unit No. 1)
MOTION FOR EXTENSION OF TIME TO COMPLETE BRIEFING EXCEPTIONS UCS has had hand-delivered today its brief on exceptions 1-45 and 110-120 to the TMI-l Partial Initial Decision (Plant Design and Procedures Unit Separation, and Emergency Planning Issues).
We have not been able to brief the remainder in the time allowed us.
UCS has only one attorney, the undersigned, who returned to wo.rk from maternity leave on March 3.
In addition to this brief, I have been required to engage in the past several weeks in confer-ences and preparation for.a preliminary hearing before the TMI-1 Licensing Board scheduled for March 18 on the question of whether this proceeding should be reopened and to prepare a brief for the U.
S.
Court of Appeals for another NRC case concerning the Erwin facility.
It has simply not been possible to do all of the above.
The Appeal Board has the obligation to review this entire record.
It is a record of unprecedented complexity and technical dispute, accompanied by extraordinarily detailed proposed findings of fact.
We believe that UCS can assist materially in the Board's consid-8203100200 820312 PDR ADOCK 05000289 C
/
. eration of these issucc if permitted to complete our briefing.
UCS has spent years litigating these issues and at this point wishes only to preserve the record for the Appeal Board's consideration.
An extension will harm no other party.
Even if TMI-l were ready to operate (which it manifestly is not, due to recently discovered steam generator problems), the Appeal Board is likely to be fully occupied in considering the issues raised in exceptions 1-45 and 110-120 during the time covered by the requested extension.
Therefore, UCS hereby requests an extension until April 5,
- 1982, to complete its brief on exceptions to the Partial Initial Decision (Plant Design and Procedures, Unit Separation, and Emergency Planning Issues).
B f
b_
u Ellyn R. Weiss March 12, 1982
e.
0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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 " UNION OF CONCERNED SCIENTISTS' BRIEF ON EXCEPTIONNS TO THE PARTIAL INITIAL DECISION OF DECEMBER 14, 1981" and
" MOTION FOR EXTENSION OF TIME TO COMPLETE BRIEFING EXCEPTIONS" have been served on the following persons by deposit in the United States mail, first class postage prepaid, this 12th day of March 1982.
- Nunzio Palladino, Chairman Dr. Walter H.
Jordan U.
S.
Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C.
20555 881 West Outer Drive Oak Ridge, Tennessee 37830
- Victor Gilinsky, Commissioner U.
S.
Nuclear Regulatory Dr. Linda W.
Little Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel 5000 Hermitage Drive
- Peter Brad ford, Commissioner Raleigh, North Carolina 27612 U.
S.
Nuclear Regulatory Commission Professur Gary L.
Milhollin Washington D.C.
20555 1815 Jefferson Street Madison, Wisconsin 53711
- John Ahearne, Commissioner U.
S.
Nuclear Regulatory
- Judge _ Gary J.
Edles, Chairman Commission Atomic Safety and Licensing Washington, D.C.
20555 Appeal. Board U.
S.
Nuclear Regulatory
' TP s Roberts, Commissioner Commission U.
S, delear Regulatory Washington, D.C.
20555 Commission Washington, L.C.
20555
- Judge John H.
Buck Atomic Safety and Licensing
- Ivan W.
Smith, Chairman Appeal Board Panel Atomic Safety and Licensing U.
S.
Nuclear Regulatory Board Panel Commission U.
S.
Nuclear Regulatory Washington D.C.
20555 Commission i
Washington, D.C.
20555
- Judge Christine N.
Kohl l
Atomic Safety and Licensing f
Appeal Board Fanel U.
S.
Nuclear Regulatory Commission Washington, D.C.
20555
~
- Judge Reginald L.
Gotchy Mr. Marvin I.
Lewis Atomic Safety and Licensing 6504 Bradford Terrace Appeal Board Panel Philadelphia, PA 19149 U.
S.
Nuclear Regulatory Commission Ms. Gail B.
Phelps Washington D.C.
20555 245 West Philadelphia Street York, Pennsylvania 17404 Mrs. Marjorie Aamodt R.D.
- 5 Mr. Robert Q.
Pollard Coatsville, Pennsylvania 19320 609 Montpelier Streat Baltimore, Maryland 21218 Robert Adler, Esq.
- Mr. Steven C.
Sholly Assistant Attorney General 505 Executive House Union of Concerned Scientists P.O.
Box 2357 1346 Connecticut Ave., NW Harrisburg, Pennsylvania 17120 Washington, DC 20036 Louise Bradford
- Counsel for NRC Staff Three Mile Island Alert Office of Executive Legal 325 Perfer Street Di' rector Harrisburg, Pennsylvania 17102 U.
S., Nuclear Regulatory Commission Walter W.
Cohen, Esq.
Washington, D.C.
20555 Office of Consumer Advocate
- George F.
Trowbridge, Esq.
1425 Strawberry Square Harrisburg, Pennsylvania 17127 Shaw, Pittman, Potts &
Trowbridge Jordan D.
Cunningham, Esq.
1800 M Street, N.W.
Fox, Farr & Cunningham Washington, D.C.
20036 2320 North Second Street Harrisburg, Pennsylvania 17110
- Docke. ting and Service Section
~
Office of the Secretary Thomas J.
Germaine, Esq.
U.
S.
Nuclear Regulatory Deputy Attorney General Commission Division of Law - Room 316 Washington, D.C.
20555 1100 Raymond Boulevard Newark, New Jersey 07102 Dr. Judith H.
Johnsrud v
Dr. Chauncey Kepford Environmental Coalition on Nuclear Power 433 orlando Avenue
- Will be hand delivered to the State College, PA 16801 Appeal Board Members on Saturday, March 13, 1982, and
- William Jordan, III to the other ind.icated Harmon & Weiss individuals on Monday, March 172S Ey'e St.,
N.W.,
Suite 506 15, 1982.
Washington, D.C.
20006 Joan A.
Levin, Esq.
Assistant Counsel Pennsylvania Public Utility Commission P.O.
Box 3265 Harrisburg, Pennsylvania 17120 r
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