ML20196B452

Motion for Third Extension of Time in Which to File Contentions.* Granting of Addl Extension of Time of 60 Days Until 880824 for Filing of Contentions in Matter Requested. W/Certificate of Svc

ML20196B452
Person / Time
Site:	Peach Bottom
Issue date:	06/17/1988
From:	Spiegelman R PENNSYLVANIA, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
References
CON-#288-6582 88-569-06-OLA, 88-569-6-OLA, OLA, NUDOCS 8806300275
Download: ML20196B452 (4)

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35F L COLKEiED UNITED STATES OF AMERICA usNrC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD E M In the Matter of )

) OUtCE ggcK[im Ua .5*-'g/ ' th Philadelphia Electric Company ) Docket Nos. 50-27YEOLA (Peach Bottom Atomic' Power ) 50-278-OLA Station, Units 2 and 3) ) ASLBP No. 88-569-06-OLA MOTION FOR A THIRD EXTENSION OF TIME IN WHICH TO FILE CONTENTIONS NOW COMES the Commonwealth of Pennsylvania and requests an extension of time in which to file its contentions in this licensing proceeding. In support of this motion, the Commonwealth states as follows:

1. On May 19, 1988, the Commonwealth requested a motion for a second extension of time in which to file its contentions. The motion requested an bxtension of time of thirty days, but incorrectly calculated that thirty days as ending June 20, 1988.

2. The reasons given for the request ware that the Commonwealth and the Philadelphia Electric Company (PECO) -

were trying to resolve their differences and that the potential for doing so without adversarial hearings constituted good cause for an extension.  !

3. On May 20, 1988, this Board granted the motion, thus extending the filing date either to June 20 or June 25. ,

4. The Commonweaith and PECO are still attempting to resolve their differences and need additional time for discussions. It is anticipated that the discussions cannot 8806300275 880617 ADOCK 0500 7 g3

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be completed in thirty days or less. Should they be completed in less then the sixty days being requested by this motion, the parties will promptly notify the Board.

5. The commonwealth is this day filing formal comments on the revised plan for restart of the Peach Bottom plant, which triggers additional matters for discussion.

6. PECO supports this request for an extension of time.

7. The NRC staff does not oppose the relief sought by this motion.

8. The potential benefit from continued discussions still constitutes good cause for an extension of time.

WHEREFORE, the Commonwealth of Pennsylvania requests that this Board grant an additional ex' tension of time of sixty days, until August 24, 1988, for the filing of contentions in this matter.

Respectfully submitted,

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% Qw Richard D'. Spiegelmah Chief Deputy General Counsel Timothy D. Searchinger Deputy General Counsel Commonwealth of Pennsylvania Office of General Counsel '

17th Floor, Harristown II 333 Market Street Harrisburg, PA 17120 (717)783-6563 Dated: June 17, 1988

s 00tkETCP UWc CERTIFICATE OF SERVICE 18 JW122 P3 3.

I hereby certify that I have this day served a truc h d,;;*; gjg-BRLhw correct copy of the attached document by mailing first class mail, postage prepaid, one copy each to the party listed below:

• George C. Freeman, Jr., Esq.

Samuel J. Chilk Office of the Secretary Donald P. Irwin, Esquire U.S. Nuclear Regulatory Comm. Hunton & Williams Washington, D.C. 20555 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 Docketing and Service Section William T. Coleman, Esq.

Office of the Secretary John H. Beisner, Esq.

U.S. Nuclear Regulatory Comm. O'Melveny & Meyers Washington, D.C. 20555 555 - 13th Street, N.W. I Washington, D.C. 20004 I

Atomic Safety & Licensing John H. Frye, III, Chairman Board Panel Atomic Safety & Licensing Board I U.S. Nuclear Regulatory Comm. U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555 Washington, D.C. 20555  :

Glenn O. Bright Eugene J. Bradley Atomic Safety & Licensing Brd. Philadelphia Electric Company i U.S. Nuclear Regulatory Comm. 2301 Market Street Washington, D.C. 20555 Philadelphia, PA 19101 Richard F. Cole Ann P. Hodgdon i Atomic Safety & Licensing Brd. Counsel for NRC Staff I U.S. Nuclear Regulatory Comm. U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555 Washington, D.C. 20555

.' l Atomic Safety & Licensing Jay Gutierrez Appeal Board Panel Regional Counsel U.S. Nuclear Regulatory Comm. U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555 475 Allendale Road King of Prussia, PA 19406

!/ , b Richard 3. Spiegbimin h-Chief Deputy General Counsel Office of General Counsel 17th Floor, Harristown II 333 Market Street Harrisburg, PA 17120 (717)783-6563 DATED: June 17, 1988

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