ML20133F815

Motion for 2-day Extension to File Responsive Brief Re Pending Appeals from ASLB Third Partial Initial Decision Concerning Offsite Emergency Planning.Certificate of Svc Encl

ML20133F815
Person / Time
Site:	Limerick
Issue date:	07/31/1985
From:	Ferkin Z PENNSYLVANIA, COMMONWEALTH OF
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#385-134 OL, NUDOCS 8508080449
Download: ML20133F815 (4)

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v UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD DOCKETED U5tlRC In the matter of )

PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 AUS -5 A11 :35

) 50-353 (Limerick Generating Station, ) CFru t 0; :.[ ;q rg Units 1 and 2) ) DCCtElpu & SEevira

rtAtiCH COMMONWEALTH'S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE ITS RESPONSIVE BRIEF This Board's Order of June 27, 1985 set August 6, 1985 as the deadline for all parties other then the NRC staff to file briefs in response to the pending appeals from the Licensing

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Board's third partial initial decision. The Commo_nwealth of

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Pennsylvania is an interested governmental participant in this proceeding pursuant to 10 C.F.R. 2.715(c). In accordance with its role in offsite emergency planning for nuclear facilities in the state, the Commonwealth intends to file a brief pursuant to 10 C.F.R. 2.762(c) in response to certain issues raised by the pending appeals. For the reasons stated below, the Commonwealth requests a two-day extension until August 8, 1985 in which to file its responsive brief.

The Commonwealth is an integral actor in offsite emergency planning for the Limerick facility under federal and state law.

The Commonwealth accordingly participated actively in hearings before the Licensing Board on these contentions. Emergency planning issues by their very nature involve matters of state policy. Consequently the Commonwealth's brief must undergo 8508080449 850 i DR ADOCK 050 2 g

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several levels of government review before it can be submitted on behalf of the state. Significant time is therefore required to coordinate and obtain approval of the Commonwealth's brief through the proper government channels. The additional time requested is necessary to obtain the requisite review and approval of the Commonwealth's brief.

The NRC Staff has authorized the Commonwealth to represent that the staff has no objection to the request on the condition that the staff receive an equivalent extension.

For the foregoing reasons, the Commonwealth requests this board to extend until August 8, 1985 the time in which to file its responsive brief on the p_ending appeals from the Lice _nsing ,

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Board's -third partial initial decision. _

Respectfully submitted,

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ori G. Ferkin Counsel for the Commonwealth Dated: July 31, 1985

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d eggoAUGI ~196 l UNITED STATES OF AMERICA $ ogg'C4 s E

NUCLEAR REGULATORY COMMISSION 7 #

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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL B0 /l iu In the Matter of )

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PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

I hereby certify that I have 31st day of July 1985 served a copy of Commonwealth Motion for Extension of Time upon the following by first class mail, postage paid:

Helen.F. Hoyt Benjamin H. Vogler, Esq. -

Administrative Judge Counsel for NRC Staff

- Atomic Safety and Licensing Z Office of the Executive Board _

Legal Director U.S. Nuclear Regulatory Commission -

U.S. Nuclear Regulatory Commis:

Washington, D.C. 20555 Washington, D.C. 20555 Dr. Richard F. Cole Robert L. Anthony Administrative Judge Friends of the Earth of the Atomic Safety and Licensing Delaware Valley Board P.O. Box 186 U.S. Nuclear Regulatory Commission 103 Vernon Lane Washington, D.C. 20555 Moylan, Pennsylvania 19065 Dr. Jerry Harbour Joseph H. White, III Administrative Judge 15 Ardmore Avenue Atomic Safety and Licensing Ardmore, Pennsylvania 19003 Board U.S. Nuclear Regulatory Commission Charles W. Elliott, Esq.

Washington, D.C. 20555 Brose and Postwistilo 325 N. 10th Street Atomic Safety and Licensing Easton, Pennsylvania 18042 Appeal Panel U.S. Nuclear Regulatory Commission Thomas Gerusky, Director Washington, D.C. 20555 Bureau of Radiation Protection Department of Environmental Troy B. Conner, Esq. Resources Conner and Wetterhahn, P.C. 5th Floor, Fulton Bank Buildin 1747 Pennsylvania Avenue, N.W. Third and Locust Streets Washington, D.C. 20006 Harrisburg, Pennsylvania 1712

• U.S. Express Mail

.o Page two Docketing and Service Section Phyllis Zitzer Office of the Secretary Limerick Ecology Action U.S. Nuclear Regulatory Commission P.O. Box 761 Washington, D.C. 20555 Pottstown, Pennsylvania 194:

Atomic Safety and Licensing Steven P. Hershey, Esq.

Board Panel Community Legal Services, In:

U.S. Nuclear Regulatory Commission Law Center West Washington, D.C. 20555 5219 Chestnut Street '

Philadelphia, Pennsylvania .

Timothy R.S. Campbell Director Kathryn S. Lewis, Esq.

Department of Emergency Services City of Philadelphia

14. East Biddle Street Municipal Services Building West Chester, Pennsylvania 19380 15th and JFK Boulevard Philadelphia, Pennsylvania .

Philadelphia Electric Company ATTN: Edward G. Bauer, Jr. Director, Pennsylvania Emerge Vice President & General Counsel Management Agency 2301 Market Street B-151 Transportation and Saft Philadelphia, Pennsylvania 19101 Building Harrisburg, PennsyTvania 17%

r Angus Love, Esq. -

101 East Main Street Spence W. Perry, Esq.

Norristown, Pennsylvania 19404 .

Associate General Counsel -

Federal Emergency Management David Wersan, Esq. 500 C. Street, S.W. , Room 84' Assistant Consumer Advocate Washington, D.C. 20472 Office of Consumer Advocate 1425 Strawberry Square Jay Gutierrez, Esq.

Harrisburg, Pennsylvania 17120 U.S. Nuclear Regulatory Comm Region I Christine N. Kohl 631 P ark Avenue Atomic Safety and Licensing King of Prussia, Pennsylvani Appeal Board U.S. NRC Reginald L. Gotchy Washington, D.C. 20555 Atomic Safety and Licensing Appeal. Board Gary J. Edles U.S. NRC Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U.S. NRC Washington, D.C. 20555 d'(

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Zori G. Ferkin Acting Chief Counsel Governor's Energy Council Dated: July 31, 1985

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