ML20147E814

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Forwards American Municipal Power-Ohio,Inc Request for 30 Day Extension for Filing Comments
ML20147E814
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 02/29/1988
From: Straus D
SPIEGEL & MCDIARMID
To: Murley T
Office of Nuclear Reactor Regulation
Shared Package
ML20147E818 List:
References
NUDOCS 8803070164
Download: ML20147E814 (5)


Text

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M ARC R PCARIER RCHARO A B' TOWN JOSEPH VAN EATON CF CLUeSEL u ^"~c 5**"sca February 29, 1988 RENA STEWZOR Dr. Thomas E. Murley Director Office of Nuclear Reactor Regulation Nuclear Regulatory Commission 1717 H Street, N.W.

Washington, D.C. 20555 Re: Intervantion and Extension of Time, Docket No. 50-440-A

Dear Dr. Murley:

Enclosed please find a request by American Municipal Power-Ohio, Inc. ("AMP-Ohio") for an additional 30-day extension of the deadline for filing comments in this docket. The reasons underlying the request are fully explained therein.

With this letter, the undersigned counsel for AMP-Ohio would also like to clarify a statement made in AMP-Ohio's January 29, 1988 Motion for Leave to Intervene. Because that intervention was out-of-time, it was necessary for AMP-Ohio to comply with 10 CPR S2.714, which requires parties seeking late intervention to confirm the extent to which the movant's interests will be represented by existing parties. The City of Cleveland, which operates a public power system and is a member of AMP-Ohio, is and has been from the start an active party to this proceeding. In AMP-Ohio's motion, therefore, it was stated that:

While the City of Cleveland, as we understand it, intends to participate on an active basis in this docket, and although AMP-Ohio intends to coordinate its participation with that of llt feCh i

i i

Dr* Thonca E. Murlcy Fcbrucry 29, 1988

, Page 2 Cleveland (one of its members) in order to avoid duplication, AMP-Ohio's interests are broader than those of Cleveland and may not be adequately represented by Cleveland.

j In order to assure that such statement is not misinterpreted, it should be understood simply as a statement that, in certain i respects, AMP-Ohio (which has 75 members throughout Ohio) has l concerns that may be somewhat broader (but certainly not in l l conflict with) those of the City of Cleveland. The City of I Cleveland does not purport to represent AMP-Ohio's interests. j

Yours truly, f

W avid R. Straus W

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j cc: All Parties As Shown on Service List Attached To Enclosed Motion DRS:bf

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