ML20049K008
| ML20049K008 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/24/1982 |
| From: | Weiss E UNION OF CONCERNED SCIENTISTS |
| To: | Buck J, Eddles G, Gotchy R NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8203290315 | |
| Download: ML20049K008 (2) | |
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UNION OF 1346 connecticut Avenue, N.W.
Dupont Circle Building. Suite 1101 CONCERNED washington, o.c. 2003e SCIENTISTS (202) 296-5600
'82 MM 26 P1 :57 24 Ma ch 19821 Gary J.
Eddles, Esq.
Chairman Atomic Safety and Licensing Appeal Board U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 e[
Dr. John H.
Buck
,b Dr. Reginald L.
Gotchy xC/
Atomic Safety and Licensing Appeal Board j[/,
C U.S.
Nuclear Regulatory Commission c
-6 kl Washington, D.C.
20555
[
s J.
l- ;
Dear Mr. Eddles:
' ///
y On March 16, 1982, the Union of Concerned Scientists filed a Motion for Extension of Time for Filing Brief..onfExceptions and for Waiver of Page Limitation, seeking an extension until April 5 to complete briefing its exceptions on the Partial Initial Decision of December 14, 1981, in the TMI-l restart case.
The Licensee has objected to the April 5 extension.
We have not received a response from the NRC Staff.
On March 18, UCS was the primary participant in an evidentiary preliminary hearing called by the TMI-1 Licensing Board to consider UCS's motion to reopen the record based on new information.
After the hearing, the Licensing Board set a deadline of one week -- until March 26 -- for filing of 20-page pleadings based on the transcript of that preliminary hearing.
I While I asked the Licensing Board to put off that deadline in view of our hope that the Appeal Board would grant our motion and the result that we would then have to be working on the Appeal Board brief, the Licensee objected because the Appeal Board had not yet granted UCS an extension and asked the Licensing Board to set its schedule independently.
As a result, we have been required to meet an unanticipated deadline of March 26 for the Licensing Board and have therefore been unable to work on the Appeal brief.
Therefore, I would like to amend our March 16 motion so that, if granted, UCS would have a period of three weeks from the time it is granted, which would correspond to the period of time p rcviously requested.
Since the Licensee's objection is to any extension per se, this would not affect its arguments.
3 82032903{0 I
PDR ADOC ppg G
(617) 547 5552 Cambridge. MA 02238 Massachusetts O// ice:
1384 Massachusetts Avenue
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, I have not responded to the Licensee's_ extraordinary efforts'to portray UCS_as dilatory.
They are unfair and the impression they seek.to. convey is a grossly. distorted one.
The fact is that UCS is the reason why there is_a record on safety matters in this proceeding and its-participation throughout was professional, as I am sure the' Licensing Board would: attest.
UCS has not even delayed the operation of TMI-l'for one day.
Under these-circumstances, we believe than an extension is appropriate.
y truly yours, B
Ellyn R. Weiss Counsel for UCS cc:
TMI-l Service List By Hand to Appeal Board, James M._Cutchin,;IV, and Thomas A.
Baxter t
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