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| document type = LEGAL TRANSCRIPTS & ORDERS & PLEADINGS, PLEADINGS
| document type = LEGAL TRANSCRIPTS & ORDERS & PLEADINGS, PLEADINGS
| page count = 2
| page count = 2
| project =
| stage = Request
}}
}}


=Text=
=Text=
{{#Wiki_filter:1 l
{{#Wiki_filter:80050h0 /
80050h0 /
UNITED STATES OF AMERICA g
g                                    UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!CilSSION
NUCLEAR REGULATORY C0!CilSSION
                                                                                /
/
                                                                                  /-
/-
l IN THE MATTER OF:                             )
l IN THE MATTER OF:
F"               c-<-
)
JEP.SEY CENTRAL POWER AND LIGHT                       Docket No. 50-363     '
F" c-<-
CCMPANY, r0RKED P,IVER NUCLEAR               )
JEP.SEY CENTRAL POWER AND LIGHT Docket No. 50-363 h '#/
CCMPANY, r0RKED P,IVER NUCLEAR
)
GENERATING STATION, LACEY TOWNSHIP, i
HEW JERSEY
}
~
~
GENERATING STATION, LACEY TOWNSHIP,          i                -              h" '#/
'/i y REOUEST FOR HEARING The people of the State of New Jersey by Stanley C. Van Ness, Public Advocate of the State of New Jersey request that the Nuclear Regulatory Cc=ission (hereinaf ter "NRC" or " Commission") grant a hearing, pursuant to 42 U.S.C. 62239, on the application of Jersey Central Power and Light Company, dated August 31,.1978, for a 5-year extension of the construction permit No.
l HEW JERSEY                                    }
CPPR.95, dated July 10,1973, and issued by the Atomic Energy Commission which expired by i~ts cwn terms on Octob'er 4,1978.
                                                                                                      '/i y REOUEST FOR HEARING The people of the State of New Jersey by Stanley C. Van Ness, Public Advocate of the State of New Jersey request that the Nuclear Regulatory Cc=ission (hereinaf ter "NRC" or " Commission") grant a hearing, pursuant to 42 U.S.C. 62239, on the application of Jersey Central Power and Light Company, dated August 31,.1978, for a 5-year extension of the construction permit No.
By letter dtted August 31, 1978, Jersey Central P'ower and Light Company sought to have the latest c%1ction date for the Forked River Nuclear Generating Station extended to December of 1983.
CPPR.95, dated July 10,1973, and issued by the Atomic Energy Commission which expired by i~ts cwn terms on Octob'er 4,1978.       By letter dtted August 31, 1978, Jersey Central P'ower and Light Company sought to have the latest c%1ction date for the Forked River Nuclear Generating Station extended to December of 1983.
However, by {{letter dated|date=July 30, 1979|text=letter dated July 30, 1979}} Jersey Central Power and i.ight Company indicated that due to the financial crisis suffered by the entire General Public Utilities System following the TMI-2 accident, the completion date for
However, by letter dated July 30, 1979 Jersey Central Power and i.ight Company indicated that due to the financial crisis suffered by the entire General Public Utilities System following the TMI-2 accident, the completion date for
. this nuclear generating station would be pushed back at least 'another two years.
              . this nuclear generating station would be pushed back at least 'another two years.
Adcitionally, Jersey Centrai, in this correspondence of July 30, 1979 reoues:ed tne H.R.C. staff to defer further action on its application for renewal Of constru: tion permit #0?PR-95 due to tne company's unilatersi and in:e'inite sus:ension Of furtne work on this project in light of the absen:e
Adcitionally, Jersey Centrai, in this correspondence of July 30, 1979 reoues:ed tne H.R.C. staff to defer further action on its application for renewal Of constru: tion permit #0?PR-95 due to tne company's unilatersi and in:e'inite sus:ension Of furtne work on this project in light of the absen:e
:f :::i:a1 ne:essary o ::n-inue ::nstruction, engineering or design work.
:f :::i:a1 ne:essary o ::n-inue ::nstruction, engineering or design work.
  .a..T: E C f:r tirect Reply.,5uspense:             Jan 25. Orig o Docket..Cpys to: Chm, Cars , DE,CA,P A
.a..T: E C f:r tirect Reply.,5uspense:
Jan 25. Orig o Docket..Cpys to: Chm, Cars, DE,CA,P A
.._..,.1.


    ,',  i, The interests of the People of New Jersey which may be affected by this renewal proceeding are shown and established in documents in the Comission's docket in this matter and may be sumarized briefly to include 1
i, The interests of the People of New Jersey which may be affected by this renewal proceeding are shown and established in documents in the Comission's docket in this matter and may be sumarized briefly to include the concern for public safety, health and welfare implicated by this applica-tion for a 7-year extension of a construction permit, first issued by the now defunct A.E.C. in 1973.
the concern for public safety, health and welfare implicated by this applica-tion for a 7-year extension of a construction permit, first issued by the now defunct A.E.C. in 1973.                                                                 l Under all of the facts and circumstances, it is respectfully urged
Under all of the facts and circumstances, it is respectfully urged that the NRC cannot properly determine that the requested permit renewal involves no significant hazards consideration. Moreover, even in the event that the Commission determines that this application does not involve a significant hazards consideration pursuant to 10 C.F.R.150.91, the Director of Nuclear Reactor Regulation, in the exercise of his discretion, should afford a public hearing under the authority vested in him by 10 C.F.R. 52.105(a)(4).
            . that the NRC cannot properly determine that the requested permit renewal involves no significant hazards consideration. Moreover, even in the event that the Commission determines that this application does not involve a significant hazards consideration pursuant to 10 C.F.R.150.91, the Director of Nuclear Reactor Regulation, in the exercise of his discretion, should afford a public hearing under the authority vested in him by 10 C.F.R. 52.105(a)(4).
(See " Notice of Opportunity for Hearing on Construction Permit Extension,"
(See " Notice of Opportunity for Hearing on Construction Permit Extension,"
                                                ^
^
Northern Indiana Public Service Company, Bailey Generating Station, Nuclear 1, Occket No. 50-367, dated November 26, 1979; copy' attached hereto as Exhibit 0).
Northern Indiana Public Service Company, Bailey Generating Station, Nuclear 1, Occket No. 50-367, dated November 26, 1979; copy' attached hereto as Exhibit 0).
Jersey Central Fower and Light Company has failed to slww good cause for the requested permit renewal   and that the failure to ccmplete construction
Jersey Central Fower and Light Company has failed to slww good cause for the requested permit renewal and that the failure to ccmplete construction by October 4,1978 deadline resulted frcm events beyond its control as required by 42 U.S.C.12235 and 10 C.F.R. 550.55.
:              by October 4,1978 deadline resulted frcm events beyond its control as required by 42 U.S.C.12235 and 10 C.F.R. 550.55.
Therefore, prior to acting upon this request for an extension of construction pennit CPPR-86, the Nuclear Regulatory Consnission should require the applicant to demonstrate its entitlement to this extraordinary relief in a plenary proceeding which affords due process of law to those persons whose j
Therefore, prior to acting upon this request for an extension of construction pennit CPPR-86, the Nuclear Regulatory Consnission should require the applicant to demonstrate its entitlement to this extraordinary relief in 1
substantial interests will be affected thereby.
a plenary proceeding which affords due process of law to those persons whose           j substantial interests will be affected thereby.                                       '
Respectfully submitted, i
i Respectfully submitted,                 ,
STANLEY C. VAN NESS, PUBLIC ADVOCATE r-Q
STANLEY C. VAN NESS, PUBLIC ADVOCATE r- Q
*:ATO: Jer.ua:/ 4,19SO BY:
                *:ATO: Jer.ua:/ 4,19SO                 BY:           ?         ,      .I KEITH A. CNSCCFFF             ,i -
?
.I KEITH A. CNSCCFFF
,i -
Assistant Ceputy Puclic Advocate
Assistant Ceputy Puclic Advocate
              -}}
--}}

Latest revision as of 19:48, 12 December 2024

Request for Hearing Re Util 780831 Application for five-yr Extension of Cp.Util Did Not Demonstrate That Failure to Complete Const Resulted from Events Beyond Its Control. Renewal Involves Significant Hazards Consideration
ML20126D496
Person / Time
Site: 05000363
Issue date: 01/04/1980
From: Van Ness S
NEW JERSEY, STATE OF
To:
NRC COMMISSION (OCM)
Shared Package
ML20126D493 List:
References
NUDOCS 8005020142
Download: ML20126D496 (2)
v • d • e


Text

80050h0 /

UNITED STATES OF AMERICA g

NUCLEAR REGULATORY C0!CilSSION

/

/-

l IN THE MATTER OF:

)

F" c-<-

JEP.SEY CENTRAL POWER AND LIGHT Docket No. 50-363 h '#/

CCMPANY, r0RKED P,IVER NUCLEAR

)

GENERATING STATION, LACEY TOWNSHIP, i

HEW JERSEY

}

~

'/i y REOUEST FOR HEARING The people of the State of New Jersey by Stanley C. Van Ness, Public Advocate of the State of New Jersey request that the Nuclear Regulatory Cc=ission (hereinaf ter "NRC" or " Commission") grant a hearing, pursuant to 42 U.S.C. 62239, on the application of Jersey Central Power and Light Company, dated August 31,.1978, for a 5-year extension of the construction permit No.

CPPR.95, dated July 10,1973, and issued by the Atomic Energy Commission which expired by i~ts cwn terms on Octob'er 4,1978.

By letter dtted August 31, 1978, Jersey Central P'ower and Light Company sought to have the latest c%1ction date for the Forked River Nuclear Generating Station extended to December of 1983.

However, by letter dated July 30, 1979 Jersey Central Power and i.ight Company indicated that due to the financial crisis suffered by the entire General Public Utilities System following the TMI-2 accident, the completion date for

. this nuclear generating station would be pushed back at least 'another two years.

Adcitionally, Jersey Centrai, in this correspondence of July 30, 1979 reoues:ed tne H.R.C. staff to defer further action on its application for renewal Of constru: tion permit #0?PR-95 due to tne company's unilatersi and in:e'inite sus:ension Of furtne work on this project in light of the absen:e

f :::i:a1 ne:essary o ::n-inue ::nstruction, engineering or design work.

.a..T: E C f:r tirect Reply.,5uspense:

Jan 25. Orig o Docket..Cpys to: Chm, Cars, DE,CA,P A

.._..,.1.

i, The interests of the People of New Jersey which may be affected by this renewal proceeding are shown and established in documents in the Comission's docket in this matter and may be sumarized briefly to include the concern for public safety, health and welfare implicated by this applica-tion for a 7-year extension of a construction permit, first issued by the now defunct A.E.C. in 1973.

Under all of the facts and circumstances, it is respectfully urged that the NRC cannot properly determine that the requested permit renewal involves no significant hazards consideration. Moreover, even in the event that the Commission determines that this application does not involve a significant hazards consideration pursuant to 10 C.F.R.150.91, the Director of Nuclear Reactor Regulation, in the exercise of his discretion, should afford a public hearing under the authority vested in him by 10 C.F.R. 52.105(a)(4).

(See " Notice of Opportunity for Hearing on Construction Permit Extension,"

^

Northern Indiana Public Service Company, Bailey Generating Station, Nuclear 1, Occket No. 50-367, dated November 26, 1979; copy' attached hereto as Exhibit 0).

Jersey Central Fower and Light Company has failed to slww good cause for the requested permit renewal and that the failure to ccmplete construction by October 4,1978 deadline resulted frcm events beyond its control as required by 42 U.S.C.12235 and 10 C.F.R. 550.55.

Therefore, prior to acting upon this request for an extension of construction pennit CPPR-86, the Nuclear Regulatory Consnission should require the applicant to demonstrate its entitlement to this extraordinary relief in a plenary proceeding which affords due process of law to those persons whose j

substantial interests will be affected thereby.

Respectfully submitted, i

STANLEY C. VAN NESS, PUBLIC ADVOCATE r-Q

  • ATO: Jer.ua:/ 4,19SO BY:

?

.I KEITH A. CNSCCFFF

,i -

Assistant Ceputy Puclic Advocate

--

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