ML20101A994

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Request for Extension of Time to 850114 to Answer TMI Alert, Inc 841210 Motion to Reopen Record.Extension Date Coincides W/Due Date for Responsive Appellate Brief.Certificate of Svc Encl
ML20101A994
Person / Time
Site: Crane Constellation icon.png
Issue date: 12/17/1984
From: Churchill B
GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#484-701 83-491-04-OLA, 83-491-4-OLA, OLA, NUDOCS 8412200010
Download: ML20101A994 (5)


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e December [s 6uty84 7,_J U'MC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'84 Efj 19 All :13 Before the Atomic Safety and Licensing AppeaS5Ebaid C[f MANCF In the Matter of

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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)

)

REQUEST FOR EXTENSION OF TIME On December 10, 1984 Intervenor Three Mile Island Alert, Inc.

("TMIA") filed a brief on appeal from the Initial Decision in this proceeding and a motion to reopen the record.

Applicant's re-sponsive brief to TMIA's appeal is due on January 14, 1985, and the Staff's is due January 24.

10 C.F.R. S 2.762 (c).

Applicant's answer to'the motion to reopen, however, is due on December 25, and the Staff's answer is due on January 31.

10 C.F.R. S 2.730 (c).

TMIA has filed a single brief for both the appeal and the motion to reopen.

The issues for the two filings are discussed together_in the brief, with no effort to segregate them.

While Applicant plans to respond to each in separate filings, for pur-poses of' avoiding confusion in the record, the two responses should be prepared and filed together because of their interre-lationship.

In addition, it would be very difficult for Applicant to respond to the motion to reopen by December 25 because of the unavailability of two of the attorneys who worked on the hearing, pg488% aush Q

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the complications of the holiday season, and the need to review and assess the information contained in TMIA's supporting exhibits.

Accordingly, Applicant requests that the time for answering the motion to reopen be extended to January 14, 1985 to coincide with the due date for the responsive appellate brief.

Counsel for the Staff has advised Applicant that the Staff supports this motion and will be filing a. motion of its own to commensurately extend the Staff's date for answering the motion to reopen.

Counsel for TMIA has informed Applicant that TMIA does not oppose this motion.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE I

By:

/

George'F. Trowbridge, P.C.

Bruce W.

Churchill, P.C.

Counsel for Licensee 1800 M Street, N.W.

Washington, D.C.

20036 (202) 822-1000 Dated:

December 17, 1984 n

g-r :tr-UNITED STATES OF AMERICA 7:G C" '

NUCLEAR REGULATORY COMMISSION

'84 EC 19 A11:13 Before the Atomic Safety and Appeal Board CFF.h 3 %CRbira 00CXElaG A SEsVmi In the Matter of

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METROPOLITAN EDISON COMPANY, ET AL.)

Docket No. 50-289-OLA

)

ASLBP 83-491-04-OLA (Three Mile Island Nuclear

)

(Steam Generator Repair)

Station, Unit No. 1)

)

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Request For Extension of Time" were served, by deposit in the U.S. Mail, first class, postage prepaid, to all those on the attached Service List, except that ti.ose marked with an asterisk were served by hand delivery or by deposit with Federal Express, this 17th day of December, 1984.

Bruce W.

Churchill, P.C.

i Dated:

December 17, 1984 l

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- 5 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board In the Matter of

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. METROPOLITAN EDISON COMPANY, ET AL.

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Docket No. 50-289 OLA

)

4 (Three Mile Island Nuclear Station,

)

Unit No. 1)

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SERVICE LIST

  • Gary J. Edles Dr. James C. Lamb, III Administrative Judge Administrative Judge Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Appeal Board Board U.S. Nuclear Regulatory 313 Woodhaven Road Commission Chapel Hill, N.C.

27514 Washington, D.C.

20555

  • Mary E. Wagner, Esq.
  • Dr. W. Reed Johnson Office of Executive Legal Directo Administrative Judge U.S. Nuclatar Regulatory Atomic Safety and Licensing Commission Appeal Board Washington, D.C.

20555 i

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.

20555 Appeal Board Panel i

  • Dr. Reginald L. Gotchy U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C.

20555 Atomic Safety and Licensing l

Appeal Board Atomic Safety and Licensing l

U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555 Administrative Judge Docketing and Service Section (3)

Chairman, Atomic Safety and Office of the Secretary Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555 Dr. David L. Hetrick

  • Joanne Doroshow, Esq.

Louise Bradford Administrative Judge

-Atomic Safety and Licensing Board Three Mile Island Alert, Inc.

315 Peffer Street College of Engineering Harrisburg, PA 17102 Dept. of Nuclear and Energy Engr.

The University of Arizona Tucson, Arizona 85721 1

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ASLAB Servica Lict

'l Paga Two TMI-l Thomas Y. Au Assistant Counsel Commonwealth of Pennsylvania Department of Environmental Resources Bureau of Regulatory Counsel Room 505 Executive House P. O. Box 2357 Harrisburg, PA 17120 4

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