ML20082D603
| ML20082D603 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/14/1983 |
| From: | Dorsey J DORSEY, J.A., LIMERICK ECOLOGY ACTION, INC. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20082D571 | List: |
| References | |
| NUDOCS 8311220482 | |
| Download: ML20082D603 (6) | |
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DOCHETED USHRC UNITED STATES OF AMERICA 13 8 18 40:33 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING,,ROARD 50'CII$TNG & fp'y1,jl' BRANCH In the Matter of
. Docket Nos. 50-352 PHILADELPHIA ELECTRIC COMPANY
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50-353 1-(Limerick Generating Station, Units 1.and 2)
MOTION FOR RELIEF FROM MAY 16, 1903 MEMORANDUM AND ORDER REQUIRING COORDINATION OF OFF-SITE EMERGENCY PLANNING CONTENTIONS In its May 16, 1983 Memorandum and Order, the Board required that filings of emergency planning contentions be coordinated among intervenors.
Limerick Ecology Action had previously agreed to be lead intervenor on any such contentions, and thus the task of coordinating emergency ' planning contention filings was to fall upon LEA.
It has been throughout this proceeding the desire of the Board that it not receive filings from intervenors that result in the need.to consider multiple contentions that are similar in content, and thus the coordination l
requirement.
l Judith Dorsey, one of LEA's counsel in this proceeding, is unable to continue representing LEA.
Until another attorney is found to replace Ms. Dorsey, Phyllis Zitzer intends to represent the organization, since Mr. Charles Elliott, also counsel for LEA is unable to take over all of Ms. Dorsey's responsibilities, f
due to other commitments.
8311220482 831114 PDR ADOCK 05000352 O
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f Given LEA's present circumstances, it moves this Board to I
i relieve LEA of the responsibility to coordinate the filing of off-site emergency planning contentions, which if the present schedule' remains, will be due by the end of December.
- LEA,
-through Ms. Zitzer, has no objection to the Applicant's continuing to use LEA as the repository of on-going emergency planning documents; LEA will continue to make those available to any f
I other intervenors who wish to use them, from its Pottstown office, l
so that the Applicant will not have to individually supply all parties with these documents.
While LEA is aware of and sympathizes with the Board's desire to avoid duplication in these contentions, LEA points out that such duplication is unlikely to occur except in a few instances, as evidenced by the original emergency planning filing in 1981.
i In a'ny case, LEA has been cooperative in the past regarding the Board's desire for coordination, and now requests relief from what has become, unfortunately, a large burden.
LEA respectfully moves the Board to direct.the parties to file their off-site emergency planning contentions separately.
Respectfully submitted,
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J ith-A. Dorsey
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i 00CMETED USNRC h hg b32 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIbb M up.
fNfyc In the Matter of Docket Nos. 50-352 PHILADELPHIA ELECTRIC COMPANY 50-353 (Limerick Generating Station, Units 1.and 2)
WITHDRAWAL OF APPEARANCE Notice is hereby given that the undersigned attorney withdraws her appearance in the above-captioned matter.
Respectfully submitted, J
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Ju th A.
Dorsey November 14, 1983 g D3
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UNITED STATES OF AMERICA NUC' LEAR REGULATORY COMMISSION 13 E 18 #0:33 4
BEFORE THE ATOMIC SAFETY AND LICENSING B(:4%RD OF SEr.,i<t ir,i.
00CKEifNG & SEPv'r:'
BRANCH In-the Matter of Docket Nos. 50-352
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PHILADELPHIA ELECTRIC COMPANY 50-353 (Limerick Generating Station, Units 1.and 2)
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NOTICE OF APPEARANCE 3
' Notice is hereby given that the undersigned enters an appearance in the above-cuptioned matter, on behalf of
' LLimerick Ecology Action.
In accordance with 10 CFR S2. 713 (a),
-the following information is provided:
e t
t Name:
Phyllis Zitzer Address:
Limerick Ecology Action P.O.
Box 761 Pottstown, PA 19464 Telephone:
(215) 326-9122 Basis of authority to act:
See affidavit of Phyllis Zitzer,
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attached N 1stition to Intervene and RemAiit 'or Hearing (9/18/81)
Name of Party:
Limers._4 i.3gy Action P.O.
Box 761 Pottstown, PA 19464 Resp ptfully submitted, I gg PhyllisdZitzer v
President, Limerick Ecology Action November 14, 1983
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e Td5p CERTIFICATE OF SERVICE 5 18 go;33 I hereby certify that the foregoing Motion Fgyg{ Relief ~ i. -
00CK T From May 16, 1983 Memorandum and Order Requiring Coor,,,p; W:/
of Off-site Emergency Planning Conte'tions; Admitted On-site Emergency Planning Contentions; Notice of Appearance; and Withdrawal of Appearance, have been served upon the following:
' Lawrence Brenner, Chairman (2)
Ann P.
Hodgdon, Esq.
Administrative Judge Office of the Executive Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Benjamin Vogler, Esq.
Dr. Richard F. Cole Office of the Executive Legal Director 1
Administrative Judge U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission 1 Washington, DC 20555 Troy H.
Conner, Jr., Esq.
Conner and Wetterhahn Dr. Peter A. Morris 1747 Pennsylvania Ave., NW Administrative Judge Washington, DC 20006 U.S. Nuclear Regulatory
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Commission Philadelphia Electric Company Washington, DC 20555 Attn:
Edward G.
Bauer, Jr.
VP and General Counsel Docketing and Service Section 2301 Market St.
Office of the Secretary Phila., PA 19101 U.S. Nuclear Regulatory Commission Thomas Gerusky, Director Washington, DC 20555 Bureau of Radiation Protection, DER 5th fl, Fulton Bank Bldg.
Atomic Safety and Third and Locust Sts.
' Licensing Board Panel Harrisburg, PA 17120 U.S. Nuclear Regulatory Commission Spence W.
Perry, Esq.
Washington, IX: 20555 Associate General Counsel FEMA Atomic Safety and Room 840 Licensing Appeal Panel 500 C St.,
SW D.S. Nuclear Regulatory Washington, DC 20472 Commission Washington, DC 20555 Zori Ferkin, Esq.
Governor's Energy Council P.O.
Box 8010 1625 Front St.
Harrisburg, PA 17105
Jay M. Gutierrez, Esq.
Robert Sugarman, Esq.
U.S. Nuclear. Regulatory Commission Sugarman and Denworth Region 1 Suite 510 631 Park Ave.-
North American Building King of Prussia, PA 19406 121 S.
Broad St.
Phila., PA 19107 Director, PEMA Basement, Transportation David Wersan, Esq.
and Safety Building Assistant Consumer Advocate Harrisburg, PA 17120 Office of the Consumer Advocate 1425 Strawberry Square Angus Love, Esq.
Harrisburg, PA 17120 101 East Main St.
Norristown,.PA 19401 Robert Anthony 103 Vernon Lane Moylan, PA 19065 Martha W. Bush, Esq.
Kathryn S.
Lewis, Esq.
Solicitor's Office City of Philadelphia s
Municipal Services Building Phila., PA 19107 Steven Hershey, Esq.
community Legal Services 5219 Chestnut St.
Phila., PA 19139 Marvin I. Lewis 6504 Bradford Terrace Phila., PA 19149 Frank Romano 61 Forest Ave.
Ambler, PA 19002 Joseph H. White,III 15 Ardmore Ave.
Ardmore, PA 19003 ftb A)
W JyDITH A.
DORSEY
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Novedber 14, 1983
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