ML20087C444
| ML20087C444 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/10/1984 |
| From: | Doroshow J THREE MILE ISLAND ALERT |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8403130065 | |
| Download: ML20087C444 (5) | |
Text
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RELATED CCn 23PO?;DENCE O^
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION U.h5 Before the Atomic Safety and Licensing Board N0!I9
.In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 r25E C!i a, g
(SteamGeneratorRepaikT['ChfAk
)
(Three Mile Island Nuclear
)
. Station, Unit 1)
)
)
TMIA MOTION FOR EXTENSIONS OF TIME FOR FILING RESPONSE TO LICENSEE AND STAFF MOTIONS FOR
SUMMARY
DISPOSITION TMIA was served with motions for summary disposition by the Licensee and the NRC Staff on February 27, 1984.
Pursuant to the regulations, TMIA would have 20 days, or until March 19, to serve its response.
However, due to circumstances beyond our control, TMIA hereby requests an extension of time until March 30, to respond to the summary disposition motions in the above captioned case.
TMIA had not intended to request an extention so time, and regrets having to do so.
We intend to oppose these motions, but for us to present the Board with responding arguments of commensurate quality and length to the Licensee and Staff motions, we clearly must obtain the advice of an expert.
Since TMIA received these motions on February 27, we have indeed been in touch with a number of people for volutary assistance, and at least one of those individuals hac expressed skeptism regarding much of what is alleged by the Licensee and Staff.
However, this individual's employment situation prevents him from supplying an af fidavit on TMIA's behalf.
8403130065 840310 PDR ADOCK 05000299 0
PDR 3S03
e We have not, however, been in touch with Dr. George Sih, Director of the. Institute for Fracture and Solid Mechanics at Lehigh University, whom we have contacted in the past for voluntary assistance, because Dr. Sih will be' out of town until around March 19.
Some statements contained in these motions respond to, and directly contradict Dr. Sih's views.
Dr. Sih is an extremely busy person, and his volutary assistance, limited though it has been, has been invaluable to TMIA.
It is just possible that he will have the time to provide TMIA with an af fidavit refuting a number of Licensee and NRC Staff assertions regarding the lack of material facts on these contentions.
TMIA believes it would be fundamentally unfair to deny us that opportunity, since these motions, if granted, would amount to a denial of our right to participate in hearings altogether.
Any prejudice which the Licensee or the. Staff could allege may result from an 11 day extension pales by comparison to the possible consequences which TMIA
'would suffer if it'is denied the opportunity to contact Dr. Sih.
l Thus, we request until the 30th of March to serve our answers j
oppposing the Licensee and Staff motions.
We.will, however, make a
(
good faith effort to serve our response as soon after March 19 as i
possible.
i t
. we apologize for any inconvenience this may cause the Board or the parties.
Respectfully, Three Mile Island Alert, Inc.
/
By Joanne Doroshow March 10, 1984 Louise Bradford 1-f i
F
UNITED STATES OF AMERICA dUCLEAR REGULATORY COMMISSION 7,
BEFORE THE ATOMIC SAFETY AND LICENSING BOARQ"A MR 12 A10:19 In the Matter of
)
50-285$r'h)pgg SECrb$l.;
)
S METROPOLITAN EDISON COMPANY Docket No.
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the attached TMIA MOTION FOR EXTENSIONS OF TIME FOR FILING RESPONSE TO LICENSEE AND STAFF MOTIONS FOR
SUMMARY
DISPOSITIONL dated March 10, 1984, were served this 10th day of March 1984, by deposit in the U.S. Mail, first class, pestage orepaid, or, hand delivered'where possible on March 10 1984, to those on the attached service list.
yANNEoOROSeOM l
UNITED STATES OF AMERICA NUCLEAR REGULATORY CO" MISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ~~ --ET AL. )
Docket No. 50-289-OLA
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ASLBP 83-491-04-OLA (Three Mile Island Nuclear
)
(Steam Generator Repair)
Station, Unit No. 1)
)
SERVICE LIST Sheldon J. Wolfe>
1.
Administrative Judge Chairman,. Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Docketing and Service Section Washington, D.C.
20555 Offica of the Secretary U.S. Nuclear-Regulatory Commission Dr. David L. Hetrick Washington, D.C.
20555 Administrative Judge Atomic Safety and Licensing Board Professor of Nuclear Engineering George F. Trowbridge, Esq.
University of Arizona Shaw, Pittman, Potts & Trowbridge Tucson, Arizona 85271 1900 M St.,
N.W.
Washington, D.C.
20036 Dr. James C. Lamb, III Administrative Judge Jane Lee
. Atomic Safety and Licensing Board 183 Valley Road 313 Woodhaven Road Etters, Pennsylvania 17319 Chapel Hill,' North Carolina 27514 t
Norman Aamodt Richard J.
Rawson, Esq.
R. D.
5, Box 428 Mary E. Wagner,.Esq.
Coatesville, Pennsylvania 19320 Office of Executive Legal Director U.S. Nuclear Regulatory Commission l
Washington, D.C.'
20555 6
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