ML20236D290

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Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl
ML20236D290
Person / Time
Site: Crane Constellation icon.png
Issue date: 03/11/1989
From: Skolnick F
SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA, THREE MILE ISLAND ALERT
To:
NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#189-8287 OLA, NUDOCS 8903230040
Download: ML20236D290 (4)


Text

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March 11'tN.Y989.

NUClIAR REGULAIORY C0H4ISSION

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BEFORE 'DE A'IDMIC SAFE'IY AND LICENSING APPEAL BOARD In the Matter of

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Docket No.50-320-OLA GPU Nuclear Corporation

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(Disposal of Accident

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CIhree Mile Island Nuclear Gem rated dwer)

Station, Unit 2)

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SVA/RilA Motion for Extension of Time to File a Brief in Support of Request for an Appeal in the Matter of the Disposal of 2.3 Million Gallons of Radioactive Water at n!I, Unit 2.

On February 21st.1989,SVA/IMIA (JI) filed a Notice of Appeal of the Final Initial Decision, February 2nd.1989. A supporting brief is due on March 23rd.1989.

For the reasons stated below JI is requesting an extension of two weeks to prepare this brief.

The extension in time is required because JI representative in these proceedings, Frances Skolnick,was on vacation from February 19th 1989 until March 10th 1989. This vacation had been planned for many months prior to receipt of the Final Initial Decision. It was impossible to change the arrangements at such short notice. As a result,there remains a mere 13 days for the representative to prepare this Brief. The representative finds this to be an incredible burden and is therefore respectfully requesting this extension in time which is felt to be of the utmost meessity for proper preparation of this documnt.

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Thank you.

Respectfully Submitted,

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Frances Skolnick l

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t4:n xc CERTIFICATE OF SERVICE

'89 ftAR 15 P4 :03

'Ihis is to certify that"SVA/EIA Motion for Extension of Tints.to Files.

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a Brief in Support of Request for an Appeal in the Matter of the Disposal of 2.3 Million Gallons of Radioactive Water at IMI, Unit 2" has been sent by prepaid first class mail on March 13th.1989 to the parties on the enclosed Service List.

Frances Skolnick l

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4 SERVICE LIST l'.

Christine N. Kohl, -

Stephen H. Lewis, Esq Atomic Sefety and Of fice of the General Counsel Licensing Appeel Board U.S. Nuclear Reguletory Commission U.S.N.R.C.

Washington, D.C. 20555 Washington, D.C. 20555 Thomes S. Moore Ms. Vere Stuchinski Atomic Safety end Three Mile Islend Alert Licensing Appeel Boero 315 Pef fer Street U.S.N.R.C.

Harrisburg, P 17102 Washington, D C 20555 Howerd A. Wilber Richerd P. Mother Atomic Sefety end Dept. of Environmental Resources Licensing Appeel Board 505 Executive House U.S.N.R.C.

Herrisburg, PA 17120 Weshington, D.C. 20555 Mr. Lee Thoris

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Three Mile Island Cleenup Project P.O. Box 311 Middletown, PA 17057 Adjudicatory Fils ASLB Penel Docket U.S.N.R.C.

I Weshingion, D.C. 20555 i

Docketing & Services Branch Secretary of the Commission U.S.N.R.C.

Washington, D.C. 20555 R. Rogen, Director Licensing and Nuclear Safety Frances Skolnick l

TMI 2 i.

Middletown, PA 17057 l

Thomes A. Bexter, Esq

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Shew, Pittmen, Potts & Trowbridge 1

2300 N. Street, N.W.

Washington, D C. 20037 L

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