ML19323D732

Response in Opposition to Ucs Motion Contained in Ucs 800418 Reply to NRC 800415 Request for Addl Time to Respond to ASLB Class 9 Questions.Enlargement of Discovery Opportunities Is Premature & W/O Good Cause.Certificate of Svc Encl

ML19323D732
Person / Time
Site:	Three Mile Island
Issue date:	04/22/1980
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8005220238
Download: ML19323D732 (5)

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NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD \'E &

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In the Matter of )

METROPOLITAN ET'. SON COMPANY Docket No. 50-289

) (Restart)

(Three Mile Is. r.d Nuclear )

Station, Unit Nc. 1) )

LICENSEE'S RESPONSE TO UCS' MOTION CONTAINED IN UCS' RESPONSE TO STAFF MOTION FOR EXTENSION OF TIME TO RESPOND TO THE BOARD'S CLASS 9 QUESTIONS On April 15, 1980, the NRC Staff requested an extension of hime to June 1, 1980, to answer the Board's Memorandum and Order to NRC Staff Regarding Class 9 Events, dated March 31, 1980. On April 18, 1980, UCS filed a response requesting the Board to permit the extension "on the basis that the parties will have until June 15, 1980, to file discovery requests on the staff's response."

The UCS response, while couched in terms of a response to the Staff request, amounts to a motion by UCS to enlarge the discovery opportunities previously provided by the Board.

UCS' request should be denied as premature and for failure-to show good cause. It cannot now be presumed that the Staff response to the Board will produce new grounds for discovery.

l 80052202 3 7

Further, any request which UCS may maka to extend recuests for discovery as late as June 15, 1980, should be considered by the Board in the context of the hearing schedule at that time, including the need for discovery adequately to prepare for the hearing and the impact which UCS claims its discovery should have on the hearing schedule.

Respectfully submitted, SHAW, PI TMAN, POTTS & TROWBRIDGE By MJ '

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'V ' / George SY. ' fr'owbridge Dated: April 22, 1980 l

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l Lic 4/22/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE J

I hereby certify that copies of " Licensee's Response To UCS' Motion Contained In UCS' Response To Staff Motion For Extension of Time To Respond To The Board's Class 9 Questions" were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 22nd day of April, 1980.

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/ George F. Trowbr[dge  !

I Dated: April 22, 1980

w UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Res tart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire John A. Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm'n Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General .

Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 881 West Guter Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 John E. Minnich Dr. Linda W. Little Chairnan, Dauphin County Board Atomic Safety and Licensing of Commissioners Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Esquire (4) Walter W. Cohen, Esquire Office of the Executive Legal Director Consumer Advocate U. S. Nuclear Regulatory Commission Office of Consumer Advocate Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section (21)

Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Jordan D. Cunningham, Esquire Karin P. Sheldon, Esquire Attorney for Newberry Township Attorney for People Against Nucles T.M.I. Steering Committee Energy 2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006 Theodore A. Adler, Esquire Widoff Reager Selkowitz & Adler Robert Q. Pollard Post Office Box 1547 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Union of Concerned Judith H. Johnsrud Scientists Environmental Coalition on Nucleag Sheldon, Harmon & Weiss Power 1725 Eye Street, N.W., Suite 506 433 Orlando Avenue Washington, D.C. 20006 State College, Pennsylvania 16801' Steven C. Sholly Marvin I. Lewis 304 South Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149 Gail Bradford Marjorie M. Aamodt Holly S. Keck R. D. 5 Legislation Chairman Coatesville, Pennsylvania 19320 Anti-Nuclear Group Representing York 245 West Philadelphia Street

, York, Pennsylvania 17404 l

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