ML20092P533
| ML20092P533 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/23/1984 |
| From: | Sugarman R SUGARMAN & ASSOCIATES |
| To: | Hodgdon A NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20092P526 | List: |
| References | |
| NUDOCS 8407090062 | |
| Download: ML20092P533 (2) | |
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SUGARM AN, DENWORTH & HELLEGERS ATT O R N E YS AT L AW t
ROBERT J. $UGARM AN ISTM FLoom. CENTCn PLAZA gg,9 g g g g JOANNE R. DENWORTH lot NORTH BROAD STREET stol PCNNSYLvaNa AvCwJC. N.W.
JOHN r HELLEGERS PHILADELPHIA. PEN NSYLVANIA 19:07 e
ROalN T. LOCKE (215)751-9733
" * * " " ^ * * **E " ^C*
May 23, 1984 COuwsch j
- sio assTTED em *A i
I Ann Hodgdon, Esquire Legal Staff U.S. Nuclear Regulatory Commission i
Maryland National Bank Building
('
7735 Old Georgetown Road Bethesda, MD 20814 Re:
Application of Philadelphia Electric Company 50-352
Dear Ms. Hodgen:
On May 21, I received a copy of the Commission's release - of May 9, 1984 reflecting a briefing given to -the-Commission.on April 24, 1984, by the staff.
This briefing is_a completely inconsistent with both the facts and your letter to me dated April 25, 1984.
First, the staff briefing completely mischaracter-i cs the Point Pleasant Diversion ' situation.
It is not-being stopped by court order; on the contrary, the applicant is seeking a court order to override the decision of local
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government, on which the project is dependent, which local government has determined that. the project should not
. proceed.
The staff briefing is completely inaccurate, in also, failing to mention that the PECo fails to have li-censes ~ from the Pennsylvania PUC for the construction of
- Bradshaw Reservior and the associated conveyances of water, and cannot operate without these.
This hardly falls into j
the ' category of court u ordered work stoppage, and the net result is to drastically understate the problem of the project to the Commission.
.Second, the staff briefing completely. fails to
-disclose the fact.that the staff has failed-to consider the poten'tial delay, in order to find all possible options (as suggested at pg. 3 of the transcript would be appropriate).
~
- Third, the mere identification of the ' - Point
'l Pleasant-- Diversion "as - a major issue", in context, clearly indicates that,the staff regards it as real concern.
- This, y
8407090062 840705
~. gDRADOCK 05000352 m
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Ann Hodgdon, Esquire 2
May 23, 1984 also, is completely inconsistent with the staff's actions to refuse to re.cunsider it.
In light of this, I request that the staff revise its previous actions, and pequest the applicant to submit contingency-plans to provide water to Point Pleasant, and to schedule a meeting in which to discuss steps to be taken to expedite the licensing process, assuming another alternative rather than Point Pleasant.
I also request that the staff fully and promptly inform the Commission of the correct state of affairs.
Sincerely,
$I-Robert J.
ug rman
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