ML20054E151

Motion for Extension of Time for Filing Addl Contentions Since Portions of PSAR & Amend 5 to Application for Site Certificate/Environ Rept Received on 820416,4 Days Before Contentions Due

ML20054E151
Person / Time
Site:	Skagit
Issue date:	04/20/1982
From:	Bell N NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML17276B809	List: ML17276B807 ML20054E151
References
NUDOCS 8204260190
Download: ML20054E151 (4)

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UNITED STATES OF A.vERICi NUCLEAR REGULATORY COMMISSION BEFORE THF ATOMIC SAFETV AND LTCENSING E0ARD . ., -

In the Matter of ) eff -

PUCET SOUNO POWFR & LICHT CO.

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) eket Nos. STN-50-522  !

_e _t . al. ) STN-50-52.1

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(Skaeit/Hanford Nuclear Trojects, )

Units 1 and 2) )

VOTION FOR EXTENSTON OF TTME Tursuant to 10 CFR 2.711(a) the Coalition for Safe Po-wer requests an extension of time for the filine of addi-tional contentions in the above-captioned proceeding. The Coalition asserts that good cause exists and even the more stringent recuirements of 10 CFR 2 714(a)(1) are met. Thus this motion sboatd receive a fnvorable ruline.

Good Cause The Coalition, by letter dated December 2, 1981 (.At-tachment 1) eeque.-ted a copy of the Skacit Preliminary Safety Analysis Report (PSAR) from the NRC Staff. NRC Staff at-torney Richard Black informed Nina Bell of the Coalition on January S, 1952 in a telephone conversation that the proper course to follow in this matter was to make the re-quest of Puget Fower, the' Applicant.

Amendment 23 to the PSAR was received by the Coalition on January 10, 1982. Also received on that day was the i

i Amendment 4 to the $kacit/Hanford Application for Site Cer-tification/ Environmental Report (ASC/ER) as amended. Upon review of the received PSAR we noticed that sections that were not amended were not included. So, on February 19, 19S2, Ms. Bell contacted Pucet Power by telephone re r;aest t

820426019d '

1982, Ms. Bell contacted Fucet Power by telephone requestinc a complete copy of the PSAR. Tucet Power responded on Fe-bruary 24, 1982 that they would not supply the requested ma-terial. ,

On March 6, 1982 the Coalition filed an amended petition to intervene in response to the Commission's notice. The Atomic Safety and I.icensine Board issued an Order on April 2, 1982, which was served on parties April 5, 1932 and re ceived by the Coalition on April S, 1982, crantine the Coalition's petition for leave to intervene and orderinc a pre-hearine conference approximately 12 days before con-tentions were due.

Following the Board's Order of April 2, 1982 Applicant's attorne) sent a letter dated April 13, 1982 confirmine mat-ters covered in a telephone call with Ps. Bell on April 8, 1982. In its letter, Applicant agreed to supply the remain-der of the PSAR. Applicant also informed the Coalition that it was filine an Amendment 5 to the ASC/ER. This material arrived at the Coalition office on April 16, 1992, (Attach-

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ment 2) four days before contentions were due.

r-iven this late arrival date it was impossible to re-view these documents and formulate any meaningful conten-tions.

To date the only documents filed by the NRC Staff is a iafety Evaluation Report Supplement 2 which addresses only issues related to NUREr 0719, Rev. 1. The Coalition has reviewed this document and filed contentions based en that review. Ilo we ve r , the Coalition cannot he espected to filed

file contentions on NRC documents when these documents have yet to be produced.

The Availability of Other Means Whereby the Petitioner's interest h'ill be Protected .

Clearly there is not other means availabic to petitioner outside this hearings process.

The Extent to Which Petitioner's Participation May Rea-sonably be Expected to Assist in Developine a Sound Record Petitioner has already tiled a number of contentions which raise substantive issues. l'e t i t i o ne r , in the past, has participated in previous hearings on this application ,

and other matters before tne NMC. retitioner was in part responsible for a combined hearine on the need for power issue in tne early Skacit and rebble Sprines proceedines.

.etitioner was responsible for the settine of a li-cense conditico in the Trojan Control Bulloing case, Doc-ket 50-344. reti tioner also presented numerous wi tnesses in the Trojan Spent Fuel Pool proceedines in the same doc-ket.

The Fxtent to Which the Petitioner's Interest Wi l l be Re-Eresented by Fxistine Parties To date there are no other existing parties other than the Appiicant and tne NKC Staft. Llearly neither or tnese parties can represent retitioner's interest.

3he Fxtent to Which the l'e t i t i oner 's Participation Wi i t ti ru a d e n tne issues or 9elAy the Proceedines Since retitioner is already a party to these proceedines this test does not apply. Fven so, i f the aforementioned

docuecabs hed been made abailable the issues would exist anyway. Fu rthermo re Petitioners have already raised a number of issues and the possibility exists that no new issues will arise.

Conclusion Gi ven the above facts and the showine that the require-ments of 10 CFR 2.711(a) and 2 714(a)(1) have been met, Petitioner Coalition for Safe Power prays that the Board in the above-captioned proceedine erant this motion f c .-

an extension of time.

Respectfully submitted, Dated this day, the 20th of April, 1982 Aw a NL f of T U3

.ina Bell, Staff Coalition for Safe Power I

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