ML20084P803

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Resubmittal of Financial Qualification Contention in Light of Recent DC Court of Appeals Order
ML20084P803
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 05/14/1984
From: Lewis M
CITIZEN ACTION IN THE NORTHEAST
To:
Shared Package
ML20084P806 List:
References
OL, NUDOCS 8405180434
Download: ML20084P803 (1)


Text

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UNITED STATES O' AMIRICA NUCEAR RK,UIATORY COYJiISSION BEFORE THE AIESTs SAFETY AND LICENSING gD In the matter of

)

MC Philadelphia Electric Company Dockets Nos 50-352 and 353.0l-(Limerick Generating Stations

'84 MAY 18 A10:46 thits 1 and 2)

Resubmittal of C.A.N.E. Financial Qaalification Contenhhjjgpgofirecent D.C. Court of Appeals Order.

BRANCH 1

On 5-5-Si+, Marvin Iewis, legal. representative for C.A.E.E., received by Express l

Mail from the NRC, a letter from Nathene A. Wright.

Enclosed in the lette*

which was sent in response to an or' der by the present ASLB, was a copy of the Court of Appeals Order on wis:h I base my and C.A.N.E.'s right to resubmit this Contention. Also I respectfully request t!e Board's forbearance. Some delay was l

necessitated in that the C.A.N.E. legal representative is not a lawyer and required I

extra research time to fathom that resubmitini of the Contention is appropriate at i

this time.

{

i This contention is both timely and appropriate at this time.

l 1.

This contention is submitted within 10 days of the first knowledge of the DC Court of Appeals Order.This 10 days seems to be the genaral rule throuhhout the 10CFR Part 2. I am considering the NRC April 14 letter as a Bagfr to &

l Board Order. Therefore in Part 2 Clapter 2.706, this Contention is a reply to an answer and timely filed up to May 15 which is 10 days after receipt.

2.

This contention is most appropriate. The PECo financial condition has deteriorated further. Also PECo now has Salen in its rate base but may not be allowed to collect for Salen outages. This'having and not hav&ng' shows how problemmatical the financial condition of PECo or any regulated utility can be.

Also the Order of the DC Court of Appeals directly requires the NRC to allow a similar contention to be considered in another OL Hearing. [he parallel and similarities are exact. There is no reason not to accept this i.3ntention l

and a DC Court Order requiring acceptance in a precedent making hearing.

I respectfully apologize to the Board since this submittal is not couched in proper legal format.

I hope that this wil'1 not affect 'the Board's decision adversely.

Respectfully submitted, 4Wmf

.A2hte.

I LeJ W f& nd 8405180434 840514 gg '##u PDR ADOCK 05000352 nA G

PDR The above letter was placed in first cliss asil on 14 MLy 1984 The distribution list was the ?one included in the NRC letter of Jtsy'4,%, above.

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