ML20076H655

Joint Motion of Util & City of Philadelphia for Addl Time to Submit Contentions Re Util Severe Accident Risk Assessment. Time Requested for Util & City to Attempt to Resolve or Narrow Contentions.Certificate of Svc Encl

ML20076H655
Person / Time
Site:	Limerick
Issue date:	09/01/1983
From:	Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC, PHILADELPHIA, PA
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8309060109
Download: ML20076H655 (4)

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'83 SEP -2 T40 :55 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIORrlCE OF SECRETAN <

00CKETING A SERvir.i' BRANCH Before the Atomic Safety and Licensing Board l

4 In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353

(Limerick Generating Station, )

Units 1 and 2) )

4 JOINT MOTION OF APPLICANT AND CITY OF PHILADELPHIA FOR ADDITIONAL TIME TO SUBMIT CONTENTIONS RELATING TO THE APPLICANT'S SEVERE ACCIDENT RISK ASSESSMENT

The Atomic Safety and Licensing Board's Second Prehearing Conference Order, LBP-83-39 (July 26, 1983) at n.*, p. 9, set a revised schedule and procedure for t 2 submission of contentions relati%g to Applicant's Severe Accident Risk Assessment (" SARA") which is referenced in its l Environmental Report - Operating License Stage, Chapter 7.

l Subsequent to the issuance of that order, the City of Philadelphia (" City"), a participant in the proceeding pursuant to 10 C.F.R. 52.715(c), indicated its intent to propose contentions relating to the SARA.

Preliminary discussions between counsel for Applicant and City concerning these matters have taken place.

Additional discussions between the Applicant and the City are planned to attempt to resolve, if possible, the City's contentions and to refine and better focus any that remain.

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The involved parties believe that such discussions may be fruitful in achieving these objectives. A 30 day. period to complete these steps appears to be reasonable. The Applicant and City therefore jointly move that the City be granted until September 30, 1983 in which to file any contentions related to SARA.

Counsel for the Staff has been contacted and has indicated that it would not object To additional time being granted in order to refine or eliminate the City's contentions which were discussed by, counsel for the parties on August 30 and 31, 1983. Counsel for Limerick Ecology Action has been informed that this request is being made.

Respectfully submitted, CONNER & WETTERHAHN, P.C.

V Mark J. Wetterhahn Counsel for the Applicant September 1, 1983 O

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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 " Joint Motion of Applicant and City of Philadelphia for Additional Time to Submit Contentions Relating to the Applicant's Severe Accident Risk Assessment" dated September 1, 1983, in the  ;

captioned matter have been served upon the following by (

deposit in the United States mail this 1st day of September, 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 i

Washington, D.C. 20555

• Judge Peter A. Morris Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel i 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.

l U.S. Nuclear Regulatory Vice President &

Commission General Counsel Washington, D.C. 20555 2301 Market Street Philadelphia, PA 19101

• Hand Delivered I

{

o o Mr. Frank R. Romano David Wersan, Esq. Consumer 61 Forest Avenue Assistant Advocate Ambler, Pennsylvania 19002 Office of Consumer Advocate 1425 Strawberry Square Mr. Robert L. Anthony Harrisburg, PA 17120 Friends of the Earth of the Delaware Valley Steven P. Hershey, Esq.

P. O. Box 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 Angus Love, Esq.

Judith A. Dorsey, Esq. 101 East Main Street 1315 Walnut Street Norristown, PA 19401 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 Commonwealth of Pennsylvania i DER *

• Martha W. Bush, Esq.

505 Executive House P.O. Box Kathryn S. Lewis, Esq.

l 2357 Harrisburg, PA 17120 City of Philadelphia Municipal Services Bldg.

Thomas Gerusky, Director 15th and JFK Blvd.

Bureau of Radiation Philadelphia, PA 19107 Protection Department of Environmental Spence W. Perry, Esq.

Resources Associate General Counsel 5th Floor, Fulton Bank Bldg. Federal Emergency Third and Locust Streets Management Agency Harrisburg, PA 17120 500 C Street, S.W., Rm. 840 Washington, DC 20472 h )

Mark y;/ Wetterhahn

• • Federal Express