ML20063J425
| ML20063J425 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/01/1982 |
| From: | Bradford L THREE MILE ISLAND ALERT |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8209020395 | |
| Download: ML20063J425 (2) | |
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s UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC.
BEFORE Tif E ATOMIC S AFETY AND LICENSING APPEAL BOARE E "l. Pl2 56 FFICE OF SECRtilAf f In the Matter of
)
OCKETING & SERvlCE
)
BRANCH METROPOLITAN EDISION COMPANY
)
Docket No. 50-289
)
(Three Mile Island Nuclear
)
t Station, Unit 1)
)
TMIA MOTION FOR EXTENSION OF TIME l
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ON FILING BRIEF ON EXCEPTIONS i
AND FOR WAIVER OF PAGE LIMITATION TMIA requests an extension of time until October 15, 1982, for filing its brief in support of exceptions, and a j
waiver of the 70-page limit on such brief with a request that the page limit be extended to 140 pages.
TMIA makes I
this request in light of the truly exceptional circumst'ances!
of this case.
The Appeal Board has ordered that briefs in support of I
i exceptions on management issues presented in the first-i partial initial decision of August 27, 1981, and the third-1 partial initial decision of July 27, 1982, be consolidated l
into one document.
TMIA submitted 83 exceptions 10 pages long, and 159 exceptions, 20 pages long, on the first and third PID's respctively.
While TMIA is making every attempt to. consolidate these exceptions into major topic' areas, the i
l task of properly developing all the complex issues consi-1 dered by both decision into one 70 page document, within a 8209020395 820901 PDR ADOCK 05000289
/X G
i
i-
'D 30 day time limit, is proving to be overwhelmingly diffi-cult.
The record in this case is massive.
The two PID's together total over 500 pages.
In addition, this case also
'l involves consideration of a Special Master's Report, dated April 28, 1982.
These decisions'all require in-depth explan-ation and analysis.
Further, no party will be harmed by the granting of these extensions.
The Commissioners, not the Appeal Board, are making the decision on immediate effectiveness of the l
Licensing Board's decision, and in any event, by Licensee's own estimates, TMI-l will not even be ready to operate until 1983, pending resolution of the psychological stress decision.
Thus THIA requests that the parties be granted until Octobe r 15, 1982 to complete briefing exceptions on the first and third PID's, including the table of contents and table of cases required by the rules, that the 70 page limit be waived, and that TMI A be permitted a 140 page limit.
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Respectfully submitted,
[
LW.i Ac Dated: Septembe r 1, 1982 Louise Bradford l
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