ML19225A236

Request Submitted by Intervenor Lower Alloways Creek That Aslb Grant Extension Until 790626 to File Response to NRC 790601 Objection to Aslb Question.Affidavits of Rn Mcallister & SE Donaldson & Certificate of Svc Encl

ML19225A236
Person / Time
Site:	Salem
Issue date:	06/15/1979
From:	Mcallister R VALORE, C.
To:
References
NUDOCS 7907180676
Download: ML19225A236 (7)

Text

-tV'cp , UNITED STATES OF AMERICA gayn3 NUCLEAR RECULATORY COMMISSION fj*useen: , BEFORE THE ATOMIC SAFETY AND LICENSING BOARD"I JUN 151979 7 ogjj's&W D&In the Matter of

)g)PUBLIC SERVICE ELECTRIC

)Docket No. 50-272

& CAS COMPANY

)Proposed Issuance of Amendment

)to Facility Operating License (Salem Nuclear Generating

)No. DPR-70 Station, Unit No. 1)

)9.G PUBLIC DOCUEE b INTERVE'iOR TO'a?iSHIP OF LOWER ALLOWAYS CREEK MOTION FOR EXTENSION OF TIME TO RESPOND TO NRC STAFF OBJECTION TO BOARD OUESTION The Intervenor, the Township of Lower Alloways Creek, hereby moves the Atomic Safety and Licensing Boaru for an Order granting an extension of tima to respond to the NRC Staf f Objection to Board question which was filed on June 1,1979 by the NRC Staf f presumably under Rule 10 CFK, Sec. 2.730, which would require the Township of Lower Alloways Creek to lfile an appropriate response to the NRC Staf f Objection within 10 days after service of same.

The Township of Lower Alloways Creek requests an extension to respond

!to the aforementioned NRC Staff Objection to June 26, 1971 lIn support of this motion, the Intervenor. Township of Lower Alloways Creek shall rely on the attached Af fidavits.

Respect fully submitted, ,"ALORE. McALLISTER. ARCN &

(WES"0RELAND , P.A.bht D BY: i ROBERT N.McALLISTER.

FOR CARL VALORE, JR. , Special Nuclear Counsel for the Township of Lover Alloways Creek b 790718 wg 321 335..

e

• 4r'UNITE] STAT.IS OF AMERICA

.NUCLEAR REGULATORY COMMISSION

%c'*d,.A..g J 1973 >

h BEFORE THE ATOMIC-SAFETY AND LICENSING BOARD 5 p .a q $p b@6 In the Matter of

)Docket No. 50-272 m fTrG Proposed Issuance of Amendment TUBLIC SERVICE ELECTRIC

)"" 7 E "'"E"*"'#& CAS COMPANY No. DPR-70

)(Salem Nuclear Generating Station Unit No. 1)

)AFFIDAVIT OF ROBERT N. hCALLISTER STATE OF NEW JEK.'EY:

SS COUNTY OF ATLANTIC:

ROBERT N. McALLISTER, of full age, being duly sworn ace ding to law upon his oath deposes and says:

1.I am an Attorney of the State of New Jersey and a partner in the firm of Valore, McAllister Aron & Westmoreland, P. A.

2.On June 5,1979, our of fice received the NRC Staf f Objection to the Board Question #3, which was presumably filed under 10 CFR, Sec. 2.730 requiring an appropriate response within 10 days af ter service.3.My partner, Carl Valore, Jr. , is the Attorney of Record for the Intervenor, the Township of Lower Alloways Creek.

Mr. Valore has been out of the country from June 1, 1979 and will not return to our office entil June 18, 1979.

4.At present Mr. Valore is the only m mber of our fir = with sufficient kn'wledge of the intervention prcceedings to appropriately o address the issues raised in the NRC Staf f Objection to che Board Question

, I#3.32)[> J b

....5.Under these circumstances, it is requested that the Intervenor, the Township of Lower A110 ways Creek, be granted an e.h'1sion of ti=e to June 26, 1979, to respond to the NRC Staff Objection to Board Questien #3.

C%S'Y/{ROBERT N. McALLISTER.

Sworn to and subscribed to before me this //

day of June, 1979,/O l'1c.D*'/ 7 o,.ug.,u//I ,e . c .,, , ,.-.,-

s., I.. il t.4 s.f:0T K " r t -

'T"JEP.SEY

'MY C0... : sic.. E::. i.d5 2-11-81

, i!321 33 ,

UNITED STATES OF AMERICA NUCLEAR RECULATORY COMMISSION BEFORE THE ATOMIC SAFE 1. AND LICENSING BOARD In the Matter of

))PUBLIC SERVICE ELECTRIC

)& GAS COMPANY Docket No. 50-272

)}(Salen Nuclear Generating Station, Unit No. 1)

}+THE TOWNSHIP OF LOWER ALLOWAYS CREEK N cog-AFFIDAVIT IN SUEPORT OF ITS MOTION

//4 g 19"[8 h FOR AN EXTENSION OF TIME. = W=6 s. wa.e.o STATE OF NEW JERSEY:

• SS D 6 6J COUNTY OF SALEM:

ctr # lSAMUEL E. DONELSON, of full age, being duly sworn according to law upon his oath deposes and says:

1.I am the duly elected Mayor of the Township of Lover Alloways Creek, an intervenor in the above captioned matter.

2.The Township of Lower Alloways Creek is in receipt of the NRC Staff's Ojbection to the Board Question #3 dealing with consideration of the ef fect of a Class 9 accident on the Salem Unit #1's spent fuel pool.

i 3.The NRC Staff objection was presumably filed under 10 CFR, Sec. 2.730, which would require an appropriate response to be filed within 10 days after receipt of the same.

4.The Township of Lower Alloways Creek Special Nuclear Counsel, Carl Valore, Jr., has been out of the Country f rom June 1,1979 cud will i not return to his office until June ld, 1979.

52i:d.

.5.The Township of Lower Alloways Creek has not had the oppertunity, to confer with Mr. Valore as to the appropriate course of action whi h should be taken by the Township of Lower Alloway7 Creek concerning the NRC Staff's objection to the Board Question #3 dealing with consideration of the ef fects of an explosion or " meltdown" at the Sale: Unit #1 spent fuel pool.

6.Under these circu.ustances, it is requested that the Intervenor, Township of Lower Alloways Creek, be granted an extension of time to June 26, 1979, to respond to the NRC Staff's Objection.

?Y /r& ~_~,a SrD!UEL E. DONELSON, Mayor Township of Lower Alloways Creek Sworn to and subscribed to before me this ' *. day of June, 1979.

a:/ , t - ,/, W.sQ , . .f *".*.- - -ATTORNEY-AT-LAW i.)\)

v v UNITED STATES OF AMERICA

..,-NUCLEAR REGULATORY COMMISSICH Before the Ator.i..fety and Licensing Board

__In the Matter of

PUBLIC SERVI E: ELECTRIC

DOCKET NO. 50-272

& GAS CO.(Salem Generating Station

Unit 61):.CERTIFICATE OF SERVICE I hereby certify that copies of Intervenor's Township of Lower Allcways Creek Motion to Extension of Tir.e in the above captioned matter have been served upon the attached list by deposit' .. the United States mail at the post office in Northfield, N.J., with prcper postage thereon, this 12th June day of 1979, ,/s / Car 1 Valore , Jr.

CARL VALORE, JR., Special Nuclear Counsel for the Intervenor, the Township of Lower Alloways Creek Dated: June'.2, 1979 ,, ,&'S'lifff dun 15197S > $

w =.a*C Cb 4 321 HD

.., , Gary .L.Mi l hol lin . Esq.

Ri chard Fryl ing, J r. , Esquire Chairman, Atomic Safety Assistant General Soilcitor

& Licensing Board Public Service Electric &

1815 Jefferson Street Cas Company Madison, Wisconsin 53711 80 Park Place Newark, N. J.

07101 Clen 0.Bri ght Mer'her , At omic Sa fety Keith Ansdorff, Esquire

& Licensing Board Assistant Deputy Public Advocate U.S. Nuclear Regulatory Commission Department of the Public Advocate Washington, D. C.

20555 Division of Public Interest Advoc

.P. O. Box 141 Dr. James C.

Lamb, III Trenton, New J 2rsey 08601 Member, Atomic Safety &

Licensing Board Panel Sandra T. Ayre 2, Esquire 113 Woodhaven Road Department of the Public Advocat(Chapel Hi:1, N.

C.27514 52D East State Street

re n t on , t' . J.08625 chairman, Atemic Safety and Licens:n, Appeal Board Panel Mr. Alfred C.

Co l ema n , J r.

1: s.5t.c i . a r -Regul a tory Commiss i on Mrs.leanor G.Coleman W.,shington, D.

C.20555 35"K" Drive l'enn sv ill c , N.J.

08070 cha i rman , Atomic Safety &

' i cens i ng Board Panel of fice of the Secretary 5.Nucl..ir Regulatory Commission Docketing and Service Section

'..riu ngt en .

D.C.*>0555 U.S. Nuclear degulatory Commissi

'Washington, D.

C.20555 L rry Smith. Esqui re aftice ci the Executive Legal Director June D. MacArtor, Esquire U.S. Suclear Regulatory Commission Deputy Attorney General Wa3hington, D.

C.20555 Tatnall BufIding, P. O.Box 1401 Dover, Delaware 19901" ark L.Fi rst, Esqui re De! ut y At t orney General Mr. I.es t er Kornbl i th , .ir.

Department of 1.aw & Public Safety Atomic Safet y and I.icensing Boarc.nvi ronment al Protection Section l'.S.Nuclear Regulatory Commissi m West Siate Street

'.;a s h i ngt on .

D.C.20555 f rent on , N.J.08025 Mark J. Wetterhahn, Esquire f or Trov F.

Conner, Jr., Esq.! 7 '. 7 Pennsvlvania Avenua, N.W.

mite 105D..shir- o D.C.20006.*$g.