ML20069C181
| ML20069C181 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/14/1983 |
| From: | Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8303170447 | |
| Download: ML20069C181 (3) | |
Text
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ele I'3 bl4-83 UC UNITED STATES OF AMERICA
_g NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD in the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
)
Station, Unit No.1)
)
UCS's OPPOSITION TO LICENSEE'S MOTION FOR LEAVE TO SUPPLEMENT TESTIMONY UCS strongly opposes the Licensee's request to " supplement" its testimony, dated March 11, 1983 As to the correction of errors, factual errors in the record should be corrected in writing.
/ The shortness of the time certainly does not preclude this; Licensee had the time to file this motion in writing, which is presumably more lengthy than its corrections.
The second part of the request, to put a new witness on the stand (without prefiled testimony) at this late date is totally without justification. GPU must live, like all the parties, with its own tactical choice regarding the witnesses it chooses to offer. The questions posed by the Board were clear.
GPU has had at least three bites at this apple; it now apparently regrets its choice of witnesses.
GPU has made no showing at all that it meets the standards for a late-filed submission or for re-opening the record.
Its request must be denied.
In addition, UCS has had just a few days to prepare for the hearing h
8303170447 830314 PDR ADOCK 05000289 0
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The tightness of this schedule was exacerbated by the fact that the Staff's filing on BM-83-21, due in hand by close of business on Friday, March 11, was not received until 10 a.m. on Monday, March 14.
We do not have the time to prepare to cross-examine a new witness (especially since it is not known what his testimony will be) and to prepare for the testimony already scheduled.
The Licensee's Motion for Leave to Supplement Testimony, March 11, 1983, should be denied.
Respectfully submitted,
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Ellyn'R. Weisi~~
General Counsel Union of Concerned Scientists Harmon & Weiss 1725 I Street, NW Suite 506 Washington, D.C.
20006
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We were willing to agree only to a brief oral correction by Mr. Lanese p.
of two allegedly factual errors contained in his testimony, if the Board I
wishes to accept this.
L
ag Ih? 16 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION P3:34
'M '
In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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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 hereby certify that copies of " UNION OF CONCERNED SCIENTISTS' OPPOSITION TO LICENSEE'S MOTION FOR LEAVE TO SUPPLEMENT TESTIMONY" have been served on the following persons by deposit in the United States mail, first class postage or as indicated by asterisk, this 14th day of March, 1983.
Nunzio Palladino, Chairman Dr. Linda W. Little U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel 5000 Hermitage Drive John Ahearne, Commissioner Raleigh, North Carolina 27612 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Professor Gary L. Hilhollin 4412 Greenwich Parkway James Asselstine, Commissioner Washington, D.C. 20007 U.S. Nuclear Regulatory Commission
- Washington, D.C. 20555
- Judge Gary J. Edles, Chairman Atomic Safety and Licensing Victor Gilinsky, Commissioner Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Thomas Roberts, Commissioner
- Judge John H. Buck U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel y
i U.S. Nuclear Regulatory Commission Ivan W. Smith, Chairman Washington D.C. 20555 Atomic Safety and Licensing Board Panel
- Judge Reginald L. Gotchy U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555-Appeal Board Panel U.S. Nuclear Regulatory Commission Dr. Walter H. Jordan Washington D.C. 20555 Atomic Safety and Licensing Board Panel
Judge Christine N. Kohl 881 West Outer Drive Atomic Safety and Licensing l
Oak Ridge, Tennessee 37830 Appeal Board Panel U.-S. Nuclear Regulatory Commission l
Washington, D.C. 20555
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Mrs. Marjorie Aamodt Ms. Gail B. Phelp
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R.D. #5 245 West Philadelph.
Coatsville, Pennsylvania 19320 York, Pennsylvania 17-
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Robert Adler, Esq.
- Steven C. Sholly g
Assistant Attorney General Union of Concerned Scientist, g
505 Exi,cutive House 1346 Connecticut Ave., N.W.
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P.O. sax 2357 Suite 1101
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Harrisburg, Pennsylvania 17120 Washington, D.C. 20036 Louise Bradford
- Joseph R. Gray Three Mile Island Alert Office of Executive Legal Director 325 Perfer Street U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17102 Washington, D.C. 20555
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- Thomas Baxter Es Jordan D. Cunningham, Esq.
Pittman, Polts S. Trowbridge Fox, Farr & Cunningham
- Shaw, 2320 North Second Street 1800 M Street, N.W.
Harrisburg, Pennsylvania 17110 Washington, D.C. 20036 Docketing and '5ervice Section Dr. Judith H. Johnsrud Dr. Chauncey Kepford Office of the Secretary Environmental Coalition on U.S. Nuclear Regulatory Commission Nuclear Power Washington, D.C. 20555 433 Orlando Avenue State College, PA 16801 68' William S. Jordan, III p/$y b
' At' Harmon & Weiss a
1725 I Street, N.Y.
Suite 506 Washington, D.C. 20006 John A. Levin, Esq.
l Assistant Counsel Pennsylvania Public Utility
- Hand delivered to 4350 East-West Hwy.,
Commission P.O. Box 3265 Bethesda, Maryland.
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Harrisburg, Pennsylvania 17120
Hand delivered to indicated address.
y Hand delivered to 7735 Old sees Georgetown Road, Bethesda, Maryland.
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