ML20065A578

Response Supporting TMI Alert 820901 Motions to Extend Time Until 820930 to File Briefs & Take Position on Motion for Waiver of Page Limit.Extension Should Be Granted for All Parties If Page Limitation Waived

ML20065A578
Person / Time
Site:	Three Mile Island
Issue date:	09/06/1982
From:	Aamodt M AAMODTS
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20065A582	List: ML20065A578 ML20065A587 ML20065A589
References
ISSUANCES-SP, NUDOCS 8209130265
Download: ML20065A578 (2)

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, UNIED STATES OF AMERICA 00CNETED NUCLEAR REGULA TORY COIO:ISSION USNRC EEFORE EE A20MIC SAFETY AND LICENSING APPEAL B66Rg'9 kh.'55 In the Fetter of )

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(5hree Mile Island Nuclear Generating Station, Unit 1 )

AAMODT RESPONSE 20 TMIA MOTIONS (9/1/82)

, (20 EXTEND TIME AND PAGE IIKITS OF BRIEF) .

We stated to TMIA's. representative, Iouise hadford, in response to her telephone call last week, that we have no objection to an extension of the time to file briefs until September 30, 1982. Ms. 3radford plans to initiate a conference call among the parties on Tuesday afternoon.

She stated that the only subject of this call would be the EII motion to extend. the time to file briefs until September 3 .

.We could see no reason to be included in this conference call..

We take no position on TMIA 's request for a waiver' of the page limit. We make no such request for ourselves.

We received a call from the Appeal Board concerning a division of effort among the intervenors in order to retain the page limit and avoid repetitious arguments. We have studied TEIA Proposed Findings of Fact and. Conclusions of Iew on Issues Raised in Reopened TMI-1 Restart Proceeding, filed January 15, 1982.

We note that TEIA took e different position than we did on the -

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conduct of the proceeding, the extent of chesting, the conduct of the NRC investigation and Licensee's investigation, the involvement of management in cheating, and proposed no findings on the Ross issues the 92 training program, the NRC examination, or the attitudes of the operators. Although TKIA 's later position, following Judge Milho111n's report, is closer to ours (Aamodt Findings,

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January 18, 20 and Farch 4,1982), we have no assurance that D1IA's representative would represent our interests. We would, prefer, therefore, to accomodate the Appeal Board by briefing all our exceptions within the ps ge limitation. If, however,the Appeal Board waivers he page limitat' ion for TKIA, we believe the opportunity for an extension should be granted to all parties.

Respectfully submitted,

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/ c September 6,1982 Iarjorie E. Aamodt l

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