ML20093D027
| ML20093D027 | |
| 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 | |
| ML20093D022 | List: |
| References | |
| NUDOCS 8407160084 | |
| Download: ML20093D027 (2) | |
Text
e 1
.e p.
,e -
SUGARM AN, DENWORTH & HELLEGERS AT TO R N E Y S AT L AW ROBERT J. SUGARMAN seTH FLOOR. CENTER PL AZ A g,q g 3, s2OI PENNSYLVANIA AVENUE. N.W.
JOANNE R. DENWORTH 101 NORTH DROAO STREET WASHINGTON. D. C. 20004 JOHN F. HELLEGERS PHILADELPHIA. PENNSYLVANIA 19107 (ao 372744eo ROBIN T. LOCKE (215)751 9733
" * * " ' " ^ ' " "
C'"
'7"C*
Mg U, 1984 counsel
- es o one TT a c ose pA.
Ann Hodgdon, Esquire Legal Staff U.S.
Nuclear Regulatory Commission 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-izes 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 cecision of local 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 alco, 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 the category of court 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 potential 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 Pleasant Diversion "as a major issue", in context, clearly indicates that the staff regards'it as real concern.
- This, 8407160084 840629 PDR ADOCK 05000352 o
Ann flodgdon, Esquire 2
May 23, 1984 also, is completely inconsistent with the staff's actions to refuse to reconsider it.
In light of this, I request that the staff revise its previous actions, and request 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, Robert J.
u rman
/vc Enclosure 1
4 s
1
~
_