ML20069K969
| ML20069K969 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/11/1982 |
| From: | Sugarman R DEL-AWARE UNLIMITED, INC., SUGARMAN & ASSOCIATES |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20069K972 | List: |
| References | |
| NUDOCS 8211160307 | |
| Download: ML20069K969 (2) | |
Text
-
- - e SUGARM AN & DENWORTH ATTORN EYS AT LAW
] **Jiirz s10, NORTH AM ERICAN SulLDING sustE aos ROBERT J. SUGARM AN JOANNE R.QENWORTH 521 SOUTH BROAD STREET 'aoas est 44eo PHILADELPHIA PENNSYLVANIA 19107 (215) 54 6-0162 ROBERT RAYMOND ELLIOTT, P. C.*
COUNSEL
. eeor Acesivsto ese pa.
November 11, 1982 Mr. Harold Denton Division of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 RE: Application of Philadelphia Electric '
Company No. 50-352, 50-353
Dear Mr. Denton:
Enclosed is Del-AWARE's Supplement to its Petition under Sections 2.202 and 2.206 of the Regulations in the above matter. The Supplement is simple and direct, and the documen-tation attached is all documentation that has been available to the Staff since Del-AWARE filed its Pre-Hearing documents in the OL Preliminary Proceeding.
Once again, as you know, the clock is running, and has been running since January 5, 1981 on the staff's action with regard to depletive effects, and also, sir:ce July 2, 1982 on our Petition. The staff's inaction on this matter and failure to issue an Order to Show Cause, providing opportunity for appropriate and timely adjudication, is indeed unfortunate and intolerable.
In addition to the documents enclosed, I would direct the staff's attention to the testimony at the hearing provided by Messrs. Phillipi, McCoy, Miller, Kaufman and Emery, relating to aquatic impacts, and to the results to the staff's site visits.
As indicated in their reviews, the Corps of Engineers made no review of the effects of construction to the land site of River Road, and completely failed to note the 80 foot high construction less than 100 feet from the National Historic Landmark (the pumphouse).
~
8211160307 821111 PDR ADOCK 05000352 \r@
O PDR ,
Mr. Harold Denton - November.10, 1982 I would appreciate hearing from you, to avoid the necessity for further action.
s Sizi rely,
\
1 Robert J. S arman RJS/vc Enclosures j