ML20058J361

Motion for Extension of Time Until 820820 & 0920 to File Exceptions & Supporting Brief in Response to ASLB 820727 Decision Re Restart.Delay Due to Conflicting Commitments

ML20058J361
Person / Time
Site:	Three Mile Island
Issue date:	08/03/1982
From:	Aamodt M AAMODTS
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20058J355	List: ML20058J351 ML20058J361
References
NUDOCS 8208090240
Download: ML20058J361 (2)

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9 UNITED STA TES OF AMERICA DogEiE0 g i NUCLEAR REGULA TORY COMMISSION l

. i BEFORE THE A TOMIC SAFETY AND LICENSING APPEA L BOARD u N .f $ k In the Matter of )

METROPOLITAN EDISON COMPANY

) Docket 50 - 2EhJhC -

OF SECRgig%

ggjeg (Nuclear Genera ting Station )

Unit 1)

AAMODT MOTION FOR AN EXTENSION OF TIME TO FILE EXCEPTIONS (AND SUFFORTING ARGUMENTS) TO THE BOARD'S DECISION OF JULY 27 The Board states in their decision of July 27 at

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paragraph #2425 that any party may take an appeal of their decision to the Appeal Board by filing exception to all or portions of their decision within ten days and a supporting brief within thirty days. The . Board suggests that any party desirous of making an appeal but unable to do so within these t.ime limits should request the Appeal Board for an additional time.

The Aamodts rece.ived the Board's decision on July 28 by Express Mail Delivery. The first opportunity they had-i to - study the decision was July 30. By August 1 they were fully aware of the extent of their disagreement and the inadequacy of, the standing time limits for appeal. An oral l ~

1 motion was made to the Secretary of the Appeal Board on August 1.

This motion was requested to be 'in writing and- is stated herewith:

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The Aamodts request an additional two weeks or until August 20 to serve exceptions and thirty days, thereaf ter, or until Septemb'cr 20, to serve a supporting brief.

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l 8208090240 820803 PDR ADOCK 05000289 C PDR

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• The reasons for the need for additional time are as follows:

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(1) The Board 's decision arrived at an importune time. We  !

. l had made other plans which. involve nbmerous' people and are l difficult, if not impossible, to change. If we had had a. notice 6f ' the '.date +of ' issuance .of the Bosrd 's decision in advance, we would have had the opportunity to plan appropriately.

(2) We are already occupied with.ahother matter concerning the same docket. The Appeal Board considering Emergency Planning for the TMI area has requested the parties to file comments by August 6. Relevant information was just received -- 500 pages (approximately) as recently as July 28.

All available time until August 6 must be devoted to~ this matter.

(3) The Board 's decision is lengthy, 184 pages in length. It addresses many issues and sub-issues.. The Board delib2 rated for The at least three months since our last round of filings.

Board's findings and conclusions come as a surprise. We do-not agree with a number of these findings and conclusions. The matter of taking exception must be given our carefu1~ consideration.

The other parties to the proceeding whom we were able to contact (Licensee, ' Staff and the Commonwealth of Pennsylvania)'

do not oppose our motion. (We were unable to contact the legal ~

representative of Three Mile Island Alert, Ms. Bradford.} } The Licensee differs, however, in the computation of the n' umber of days of extension requested. Licensee computes the ' deadline for service of exceptions to be August 12, thus considering our request to be an eight day extension.

. A Respectful 1y ubmitt ,

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bli:mYk blj{1ti --

Marjo/le M. Aamod t August jg 1982 - Served this day by deposit in U. S. Mail, first class, to the A ppeal Board, the Board and parties.