ML20052F414
| ML20052F414 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/07/1982 |
| From: | Baxter T METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8205120437 | |
| Download: ML20052F414 (6) | |
Text
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LIC 5/7/82 y
UNITED STATES OF AMERICA gr c 7:
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEd32 BUERB) NO Si 7
In.the Matter of
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G METROPOLITAN EDISON' COMPANY
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Docket No.
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(Resta t (Three Mile Island Nuclear
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4f Station, Unit No. 1)
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- dhg, LICENSEE'S MOTION FOR g
ENLARGEMENT OF PAGE LIMITATION
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9 Pursuant to the Appeal Board's Order of March 2
- 1982, Licensee's single, consolidated responsive brief to the exceptions in this proceeding of the Union of Concerned Scientists, the Commonwealth of Pennsylvania, and the Aamodts on plant design and emergency planning issues, is due no later than May 10, 1982.
The responsive brief is to be no longer than 140 pages, exclusive of pages containing the Table of Contents and Authorities and any addenda limited to statutes, rules or reguIations.
Licensee hereby moves that the page limitation for its responsive brief be extended by 25 pages, to a total of 165 pages.
Licensee is responding here to appellants' briefs which total in excess of 150 pages in length.
While Licensee has made a concerted effort to be concise in its arguments, the evidentiary record involved with these appeals is massive, and we feel that a complete discussion of the record will be greatly beneficial to the Appeal Board's difficult task of reviewing the Licensing Board's decision.
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8205120437 820507 PDR ADOCK 05000289 G
i In.the case of the UCS brief in particular, Licensee did not anticipate the extent to which the appellant would rely upon proposed findings of fact filed with the Licensing Board (instead of citations to the evidentiary record) and the absence of an organizational format (i.e., with a state-ment of the case, questions presented, and argument) which would enable the appellee to respond efficiently to the matters raised upon appeal.
Consequently, it has required a greater ef fort on our part,- and a longer reply brief, -in order to present the Appeal Board with a well reasoned and comprehensive reply to the UCS exceptions.
While 10 C.F.R.
S 2.762(e) provides that a request for enlargement of the page limitation,shall be made by motion submitted at least seven days before the date upon which the brief is due for filing, Licensee was unable to anticipate earlier.that an enlargement would be required.
Because of the diversity of issues which must be addressed in this consolidated responsive brief, several attorneys and various elements of our client's organization have been involved in contributing to the preparation of Licensee's reply.
It was only upon consolidating those contributions today that the need for an enlargement became apparent.
Licensee can foresee, however, no prejudice to other parties either from i
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. the lateness of this motion or the relief requested.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Thomas A.
- Baxter, P.C.
Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1090 O
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD i
In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289 4
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(Restart)
(Three Mile-Island Nuclear
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Station, Unit.No. 1)
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CERTIFICATE OF SERVICE i
I hereby certify that copies of " Licensee's Motion - for Enlargement of Page Limitation" were served this 7th day of May, 1982, by hand delivery upon the parties. identified by an asterisk and by deposit in the U.S.
mail, first class, postage prepaid, to the other parties on the attached Se~rvice List.
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i Thomas A.
- Baxter, P.C.
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______...,__,_____-_._..._.-.,.___,.._.-_____,__..m
9 UNITED STATES OF AMERICA NUCLEAR P2GULATORY COMMISSION 3EFOP2 THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
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SERVICE LIST
- Gary J. Edles, Esquire James M. Cutchin, IV, Esquire Chairran Office of the Executive Iegal Director Atcmic Safety and Licensing Appeal U.S. Nuclear Regulatory Ccmrission Board Washington, D.C.
20555 U.S. Nuclear Regulatory CJ:trission Washington, D.C.
20555 Docketing and Service Sectica Office of the Secretary
- Dr. John H. Bt.ck U.S. Nuclear Regulatory Ccmnission
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Atcmic Safety and Licensing Appeal Washington, D.C.
20555
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Board Panel U.S. Nuclear Pegulatory Ccmrission John A. Levin, Esquire Washington, D.C.
20555 Assistant Counsel Pennsylvania Public Utility Ccmnission
- Dr. Feginald L. Gotchy P.O. Box 3265 Atcmic Safety and Licer. sing Apoeal Harrisburg, Pennsylvania 17120 Board Panel U.S. N'.iclear Regulatory Co:rnission Ibbert Adler, Esquire Washington, D.C.
20555 Assistant Attorney General 505 Executive House Ivan W. Smith, Esquire P.O. Box 2357 Ch.* i nian Harrisburg, Pennsylvania 17120 Atcmic Safety and Licensing Board U.S. Nuclear Regulatory Cc:: mission John E. Minnich Washington, D.C.
20555 Chair: nan, Dauphin County Board of Cu.uissioners Dr. Walter H. Jordan Dauphin County Courthouse Ateric Safety and Licensing Ecard Front and Market Streets Panel Harrisb=g, Perr.sylvania 17101 E31 West Cuter Drive Cak Fidge, Te.nessee 37830 Walter W. Cohen, Esquire Office cf Constraer Advocate Dr. Linda W. Little 1.;25 Straderry S=are Atcric Safety and Licensing Scard Harrisburg, Pennsylvania 17127 2,-e 5000 Heritage Drive Jordan D. Cecr.inghrn, Esqcire Faleigh, N:r-5 Carolina 27612 2220 Nenh Second Stree:
Farisb=g, Fe c.sy2 cania 17110 1
a F.s. Icuise Bradford Josech R. Grav, Escuire L'I ALERT
' Office of the B:ecutive Legal Director 101.1 Green Street U.S. Nuclear Regulatory Cv....issicn Harrisburg, Pennsylvania 17102 Washington, D.C.
20555 Ellyn R. Weiss, Escuire Ea_w n & Weiss 1725 Dfe Street, N.W., Suite 506 Washington, D.C.
20006 Steven C. Sholly Unicn of Concerned Scientists 1346 Connecticut Avenue, N.W., Suite 1101 Washingten, D.C.
20036 Gail B. Phelps ANGRY 245 West Philadelphia Street York, Pennsylvania 17404 William S. Jordan, III, D; quire Harren & Weiss
-1725 Dfe. Street, N.W., Suite 506 Washington, D.C.
20006 Pcbert Q. Pollard 609 bbntpelier Street Baltinore, Maryland 21218 Chauncey Kepford Judith H. Johnsrud Environ: ental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Parvin I. Leais j
6504 Bradford Terrace l
Philadelthia, Pennsylvania 19149 i
i Fhrjorie M. Aarodt R. D. 5 Ccatesville, ' Pennsylvania 19320 s
Th=as J. G3:-ine, Esquire
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Daputy Attorney Cceral Division cf Iaw - Prem 316 1100 P2yrend Eculevard Sc ark, Nea Jersey 07102 l
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