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ENVIRONMENTAL COALITION ON NUCLEAR POWER Co Duectors: Mr. George Boomsme-R.D. et. Peach Bottom, Pa. 17563 717 548 2836 7r. Judith Johnsrud-433 Orlando Avenue, State College, Pa. 16801 814 237 3900 UNITED STATES OF AMERICA 4                                              NUCLEAR REGULATORY COPHISSION In the Matter of f
ENVIRONMENTAL COALITION ON NUCLEAR POWER Co Duectors: Mr. George Boomsme-R.D. et. Peach Bottom, Pa. 17563 717 548 2836 7r. Judith Johnsrud-433 Orlando Avenue, State College, Pa. 16801 814 237 3900 UNITED STATES OF AMERICA NUCLEAR REGULATORY COPHISSION 4
METROPOLITAN EDISON COMPANY, et al. ) Docket No. 50-289 1
f In the Matter of METROPOLITAN EDISON COMPANY, et al. ) Docket No. 50-289 1
(Thme Mile Island, Unit 1 Restart) )
l (Thme Mile Island, Unit 1 Restart) )
l                                                                      )
)
ECNP INTERYENORS' STATEMENT OF NEED AND REQUEST FOR ADDITIONAL RESPONSE TIME i
ECNP INTERYENORS' STATEMENT OF NEED AND REQUEST FOR ADDITIONAL RESPONSE TIME i
For a variety of reasons, including unavi' f ability of volunteer staff,                                             l unanticipated appointments, travel, other NRC /111ng deadlines, illness, and the loss of the full day at hearing, the ECNP representative has not been able to complete responses to interrogatories on emergency planning mvised contentions as anticipated between October 6 and 16. The lack of some of the necessary documents has greatly exacertated the problem.
For a variety of reasons, including unavi' f ability of volunteer staff, l
unanticipated appointments, travel, other NRC /111ng deadlines, illness, and the loss of the full day at hearing, the ECNP representative has not been able to complete responses to interrogatories on emergency planning mvised contentions as anticipated between October 6 and 16. The lack of some of the necessary documents has greatly exacertated the problem.
ECNP therefore asks the Board to extend the time period for response, including response to Suspended Licensee's motion for sanctions and Staff's opposition to ECNP s contentions on these issues until October 30, 1980.
ECNP therefore asks the Board to extend the time period for response, including response to Suspended Licensee's motion for sanctions and Staff's opposition to ECNP s contentions on these issues until October 30, 1980.
In view of the Licensee's and Staff's failums to meet filing deadlines --
In view of the Licensee's and Staff's failums to meet filing deadlines --
and in '"w of the uncertainties of the hearing schedule over the next several weeks and various changes in deadlines which have caused substantial incon-                                                     '
and in '"w of the uncertainties of the hearing schedule over the next several weeks and various changes in deadlines which have caused substantial incon-venience to intervenors in scheduling their other work loads and obligations,--
venience to intervenors in scheduling their other work loads and obligations,--                                                 '
ECNP believes that this is a reasonable regeests It is clear from the Staff and Licensee comments at the first day of hearing that this delay would not significantly prejudice those parties, both of which appear to be already severely overloaded. The request resembles that granted to Mrs. AAmodt.
ECNP believes that this is a reasonable regeests It is clear from the Staff and Licensee comments at the first day of hearing that this delay would not
;                significantly prejudice those parties, both of which appear to be already severely overloaded. The request resembles that granted to Mrs. AAmodt.
Had the ECNP representative realized how much still remained to be completed, this mquest would have been tendered to the Board at the hearing on October 15; Respectfully submitted,
Had the ECNP representative realized how much still remained to be completed, this mquest would have been tendered to the Board at the hearing on October 15; Respectfully submitted,
;                                                                                        /aAm'9/ed->                     ,      m Judith H. Johnsru                               O Co-Director. EC.                     .,-  ,
/aAm'9/ed->
Dated this /(> (j'day                                                                           ,
m Judith H. Johnsru O
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Co-Director. EC.
: c.         -
/(> (j' day e '" -
of October,1980                                                         -
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Latest revision as of 18:45, 24 December 2024

Request for Extension Until 801030 to Respond to Emergency Planning Interrogatories,To Licensee Motion for Sanctions & to NRC Opposition to Contentions.Reasons Include Unavailability of Volunteer Staff
ML19340B304
Person / Time
Site: Crane 
Issue date: 10/16/1980
From: Johnsrud J
Environmental Coalition on Nuclear Power
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8010210769
Download: ML19340B304 (1)
v • d • e


Text

.

ENVIRONMENTAL COALITION ON NUCLEAR POWER Co Duectors: Mr. George Boomsme-R.D. et. Peach Bottom, Pa. 17563 717 548 2836 7r. Judith Johnsrud-433 Orlando Avenue, State College, Pa. 16801 814 237 3900 UNITED STATES OF AMERICA NUCLEAR REGULATORY COPHISSION 4

f In the Matter of METROPOLITAN EDISON COMPANY, et al. ) Docket No. 50-289 1

l (Thme Mile Island, Unit 1 Restart) )

)

ECNP INTERYENORS' STATEMENT OF NEED AND REQUEST FOR ADDITIONAL RESPONSE TIME i

For a variety of reasons, including unavi' f ability of volunteer staff, l

unanticipated appointments, travel, other NRC /111ng deadlines, illness, and the loss of the full day at hearing, the ECNP representative has not been able to complete responses to interrogatories on emergency planning mvised contentions as anticipated between October 6 and 16. The lack of some of the necessary documents has greatly exacertated the problem.

ECNP therefore asks the Board to extend the time period for response, including response to Suspended Licensee's motion for sanctions and Staff's opposition to ECNP s contentions on these issues until October 30, 1980.

In view of the Licensee's and Staff's failums to meet filing deadlines --

and in '"w of the uncertainties of the hearing schedule over the next several weeks and various changes in deadlines which have caused substantial incon-venience to intervenors in scheduling their other work loads and obligations,--

ECNP believes that this is a reasonable regeests It is clear from the Staff and Licensee comments at the first day of hearing that this delay would not significantly prejudice those parties, both of which appear to be already severely overloaded. The request resembles that granted to Mrs. AAmodt.

Had the ECNP representative realized how much still remained to be completed, this mquest would have been tendered to the Board at the hearing on October 15; Respectfully submitted,

/aAm'9/ed->

m Judith H. Johnsru O

Co-Director. EC.

/(> (j' day e '" -

M Dated this n,?

,c.

2a Li of October,1980 ca.

');

C? ct, %

H il 6

f%

  • p

'c#f f

V qst02/0766 Q

i

_

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