ML20205M411
| ML20205M411 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/11/1986 |
| From: | Doroshow J THREE MILE ISLAND ALERT |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#286-753 OLA, OLA-2, NUDOCS 8604150219 | |
| Download: ML20205M411 (3) | |
Text
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e NRJ\\TED COWESPONDENCR 4
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t UNITED STATES OF AMERICA
,EfC3 f
NUCLEAR REGULATORY COMMISSI Before the Atomic Safety and Lib n h e,JBQard
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rw u.q6 hh u.y 9..s In the Matter of
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BRANCH" M i
METROPOLITAN EDISON COMPANY
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Docket No. 50-289 l'
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OLA 1 and OLA 2 l
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(Three Mile Island Nuclear
)
Plugging Criteria)
I Station, Unit 1)
)
i i
MOTION FOR EXTENSION OF TIME OR, IN THE ALTERNATIVE, NOTICE OF WITHDRAW j
TMIA hereby moves for a six month extension of time to J
complete discovery in this proceeding, or in the alternative, withdraws as an intervening party.
The undersigned is forced to end participation in this proceeding in light of new employment.
TMIA lacks the resources to hire a new representative.
However, volunteer TMIA intervenor Louise Bradford is willing and would be able to participate in this i
proceeding at the conclusion of other NRC hearings with which she
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is currently involved on a full-time basis.
She estimates that her responsibilities in that proceeding will end in six months.
a The licensee w'ill not be prejudiced by such an extension ~.
Its requested plugging criteria change t'o 70% throughwall is not'
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proposed to take eff ect until af ter TMI-l's planned six month i
j refueling outage next year.
With regard to the " temporary" plugging change to 50% throughwall, the Staff has already proposed a "no significant hazard consideration" finding which would take 1
l ef fect immediately, no matter when a hearing were eventually held.
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It is crucial that so radical a change in industry standards s
as licensee has proposed in-this case, be examined thoroughly in
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the~ context of a full adjudicatory hearings..TMIA'is simply unable to cont.inue litigating. this case at this time.
If the Board f ails to grant this extension, TMIA hereby l
l-withdraws as a party in this proceeding.
i i
j Respectfully submitted, l
1
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1 Dated: April 11, 1986 oanne Doroshow-l 4
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,i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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METROPOLITAN EDISION COMPANY
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Docket No. 50-289
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OLA-1 and OL A-2 (Three Mile Is. land Nuclear
)
Station, Unit 1)
)
CERTIFICATE OF SERVICE
,5 4'
I hereby certify that one copy of TMIA'S MOTION FOR EXTENSION g OF TIME OR IN THE ALTERNATIVE NOTICE OF WITHDRAW, was served this 10th day of April, 1986, by first class deposit in the U.S.
- mail, postage prepaid, except by express mail where indicated by (*),
to all parties on the service list below.
bb anne Doroshow Sheldon J. Wolfe, Chairman -( * )
Administrative Judge U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Frederick J. Shon (*)
Orcar H. Paris (*)
Administrative Judge Administrative Judge U.S.
Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Washington, D.C. 20555 Washington,-D.C. 20555 Docketing and Service Section Bruce W.
Churhill, Esq.
U.S. Nuclear Regulatory Commission Shaw, Pittman, Potts Washington, D.C.
20555 Trowbridge 1800 M St. N.W.
Washington, D.C.
20036 Mary Wagner Office of the Executive Legal Director U.S Nuclear Regulatory Commission Washington, D.C.
20555 h
Thomas Y. Au, Esq.
Department of Environmental Resources V
Room 505, Executive House P.O.
Box 2357 Harrisburg, PA 17120
.