ML19323B690

Request for Further Extension Until 800529 for Noticing State of PA Depositions & Until 800629 for Completion of Said Depositions,Re Agricultural Plan.Certificate of Svc Encl

ML19323B690
Person / Time
Site:	Three Mile Island
Issue date:	04/07/1980
From:	Aamodt M AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19323B687	List: ML19323B686 ML19323B690
References
NUDOCS 8005140077
Download: ML19323B690 (4)

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APP. 9 1930 ,

h" N hofM-th1 N:ew nr.ke United ftater of America en-4 / Nuclear Regulatory Commicslon Q 5 fore the Atomic Lafety and Licensing beard In the hatter of I..etropolitan Edison Comt.any, 7hree Mile Island Nuclear Ltation, Unit 1, Locket 5(-285 AAkODT REQUELT FOR FURTHER EXTEN:. ION OF TIME RELATIVE TO DETO ITION OF CO:&ON',.EALTH OF i ENAL YLVANIA The motion made of the Board concerning extension of time needed for follow-up interrogatories and depositionc of the Commonwealth was granted ac requested , until April 17,198C ,

however it now appears to be a schedule that cannot be met.

The Commonwealth has supported our motion in a statement dated L. arch 31,198C , however it has been pointed out that the extennion which we requested is too brief to accomplish what was nlanned, and we are now in agreement. The answers to the Aamodt third set of interrogatories have not been received to date, due to several factors that were not within the Commonwealth's control. To develor a complete record, yie wish to follow-up on those responses , if necessary. Additionally, a fourth set of interrogatories served April 7, 198f regarding the agricultural rlan need to be answered-and follow-up may be necessary. Follcwing the reasoning set forth by the Commonwealth, approximately 18 days need to be allowed for receipt of responsec, which includes the lh day deadline nlus two days for each mailing. The Commonwealth's resronses to the fourth set should be received by April 25; if five days are allowed fer our follow-up, restonses should be received frem the Commonwealth within 23 days of April 25, which clcsest postal delivery date is May 15 A110 wine five days for exanination of responses , then we would be able to decide whether the answers provided were sufficient to prepare for the hearing of the related contentions, or if

s derositions were needed. If we then did not wirh tc take de-r ositions of the Ccr.monwealth, we would rrovide notice ac coon ar it became evident te us, but no later than u.ay 25, allowing in addition to five days 'or examination, another five days for t ostal delays not provided for in the " eighteen days" between request and receipt of interrogations of the Commonwealth. If, however, we did need to take depocitions , we would make request of the Cpmmonwealth r romptly, possibly as early as Lay 25, but no later than May 25 The Commonwealth has reminded us of the 30 day Teriod that may be needed for arranging depositions, there-fore, it appears than an extensi on for completion of depositions is needed for 30 days beyond May 25, which is mrrroximately June 29.

Ke .are , therefore , requesting an additional extensi on until Eay 29 for noticing depositions and until June 29, 1580 for completion of depositions of the Commonwealth.

Respectfully submitted,

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Karforie i.. Aamodt Dated: April 7, 198C l

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Nuclear Regulatory Ccaninsion before the Atomic mafety and Licensing Ecard In the I.atter of it.etropolitan Edisen Company. Three I/.ile I.cland Unit 1, Docket Sr_289 CERTIFICATE OF LERVICE I hereby certify that AAKODI INSERROGATIEL OF C01U.OE EAI.TH OF iENN5YLVAIiIA -- FOURTH : ET was served on those persons on the attached service list by deposit in the United ..tates mail, nostage Treraid, this neventh day of April, 198r.

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1.arj orie 1.4. Aamodt Eated: Arril 7, 196C I hereby certify that AAMODT REQUE:.T FOR FURTHER EXTEN:.IrN OF

'iII..E RELATIVE TO DEFO:.ISION OF COL:KDEEALTH OF 1 ENNLYLVANIA was served on those persons on the attached service list by deposit in the United Ltates mail, postage treraid, this seventh day of Arril, lcer,

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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)

SERVICE LIST --

George F. Trowb.ri.ge, d Esquire Shav, Pittnen, Potts & Trowbridge 180s M Street, N.W.

War 'aington, D.C. 20036"'- . . . -

Ivan W. Smith, Esquire_,

Chairman Atomic Safety and Licensing -

Board Panel U.S. Nuclear Regulatory ~

Commission Washington, D.C. 20555 Dr. Walter H. Jordan '

Atomic Safety and Licensing Board Panel (

881 West Outer Drive Oak Ridge, Tennessee 37830 Dr. Linda W. Little Atomic Safety and Licensing Board Panel 5000 Hermitage Drive Raleigh, North Carolina 27612 James A. Tourte11otte, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service'Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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_Karin W. Carter, Esquire .

Assistant Attozney General

505 Executive Ecuse Post Office Box 2357 '

Harrisburg, Pennsylvania 17120'. s