ML20071Q743

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Motion for Extension Until 830610 to Respond to NRC Use of Facility Pra.Filing Allowed Per ASLB 830516 Order Confirming Schedules.Certificate of Svc Encl
ML20071Q743
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 06/06/1983
From: Wetterhahn M
CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8306090240
Download: ML20071Q743 (4)


Text

P

'.?;UED

'd3 t 7' -7 00 :14 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of

)

)

Philadelphia Electric Company

)

Docket Nos. 50-352

)

50-353 (Limerick Generating Station,

)

Units 1 and 2)

)

APPLICANT'S MOTION FOR AN EXTENSION OF TIME The Atomic Safety and Licensing Board's " Memorandum and Order Confirming Schedules Established During Prehearing Conference" (May 16, 1983)

(" Order Confirming Schedules")

permits Applicant, Philadelphia Electric Company, to file a response to the NRC Staff's Use of Limerick PRA which is appended to the NRC Staff Response to Licensing Board's Order of May 16, 1983 and Limerick Ecology Action Response to Licensing Board's Order of May 16, 1983 (May 31, 1983).l_/

Applicant's response is due for filing on Wednesday, June 8,

1983.

A meeting has been scheduled between Appli-cant and the NRC Staff for June 8,

1982 to brief the Staff and to discuss the Severe Accident Risk Assessment

(" SARA")

which is supportive of Section 7.1 of the Environmental 1/

OrderCcnfirmingSchedulesak6 F306090240 830606 PDR ADOCK 05000352 O

PDR So3

x i

p Operating License Stage.

This meeting, which is Report expected to extend over the entire day, is to be attended by counsel for the NRC' Staff, Applicant, and LEA.

Counsel will also be meeting separately to discuss the PPA-related contentions, including possibl'e elimination or modification of particular contentions.

Applicant therefore requests that it be permitted until Friday, June 10, 1983 to deliver its response in hand to the Licensing Board. 2.,/

This will give it the opportunity to report to the Board regarding any agreements reached among

,the parties and to focus its presentation on the remaining issues.

Counsel for the Staff and LEA have consented to this extension.

Respectfully submitted, CONNER & WETTERHAHN, P.C.

Mark J. Wetterhahn Counsel for the Applicant June 6, 1983 i

l 2/

Every effort will be made to file this pleading on June 9,

1982.

Counsel for L7:A has consented to delivery by l

Federal Express on the neyt business day following Applicant's filing with the Board.

,)

E Nf, QEI' 33 UN -7 A10:14 UNITED STATES OF AMERICA NUCL' EAR REGULATORY COMMISSION i

In the Matter of

)

)

Philadelphia Electric Company

)

Docket Nos. 50-352

)

50-353 (Limerick Generating Station,

)

Units 1 and 2)

)

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Motion for an Extension of Time" dated June 6, 1983, in the captioned matter have been served upon the following by deposit in the United States mail this 6th day of June, 1983:

  • Judge Lawrence Brenner (2)

Docketing and Service Section Atomic Safety and Licensing Office of the Secretary Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555 Ann P.

Hodgdon, Esq.

Judge Richard F. Cole Elaine I. Chan, Esq.

Atomic Safety and Licensing Counsel for NRC Staff Board Office of the Executive U.S. Nuclear Regulatory Legal Director Commission U.S. Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555 Judge Peter A. Morris Atomic Safety and Licensing Atomic Safety and Licensing Board Board Phnel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555 Atomic Safety and Licensing Philadelphia Electric Company Appeal Panel ATTN:

Edward G. Bauer, Jr.

U.S. Nuclear Regulatory Vice President &

Commission General Counsel Washington, D.C.

20555 2301 Market Street Philadelphia, PA 19101

  • Hand Delivered

.J.

Mr. Frank R.

Romano David Wersan, Esq. Consumer 61 Forest Avenue Assistant Advocate Ambler, Pennsylvania 19002 Office of Consumer Advccate 1425 Strawberry Square Mr. Robert L. Anthon'y Harrisburg, PA 17120 Friends of the Earth of the Delaware Valley Steven P.

Hershey, Esq.

P. O. Fox 186 Community Legal 103 Vernon Lane Services, Inc.

Moylan, Pennsylvania 19065 Law Center North Central Beury Bldg.

Mr. Marvin I.

Lewis 3701 North Broad Street 6504 Bradford Terrace Philadelphia, PA 19140 Philadelphia, PA 19149 Donald S.

Bronstein, Esq.

Judith A.

Dorsey, Esq.

1425 Walnut Street 1315 Walnut Street Philadelphia, PA 19102 Suite 1632 Philadelphia, PA 19107 Mr. Joseph H. White, III 8 North Warner Avenue Charles W.

Elliott, Esq.

Bryn Mawr, PA 19010 Brose and Postwistilo 1101 Building Robert J.

Sugarman, Esq.

lith & Northampton Streets Sugarman & Denworth Suite Easton, PA 18042 510 North American Building-121 South Broad Street Jacqueline I.

Ruttenberg Philadelphia, PA 19107 Keysteon Alliance 3700 Chestnut Street Director, Pennsylvania Philadelphia, PA 19104 Emergency Management Agency Basement, Transportation Thomas Y. Au, Esq.

and Safety Building Assistant Counsel Harrisburg, PA 17120 l

Commonwealth of Pennsylvania l

DER Martha W.

Bush, Esq.

l 505 Executive House P.O.

Box Kathryn S.

Lewis, Esq.

l 2357 Harrisburg, PA 17120 City of Philadelphia l

Municipal Services Bldg.

Thomas Gerusky, Director 15th and JFK Blvd.

Bureau of Radiation Philadelphia, PA 19107 Protection Department of Environmental Resources 5th Floor, Fult6n Bank Bldg.

l Third and Locust Streets Harrisburg, PA 17120

/

Mhtk J. Wetterhahn l

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