ML20099B869

Motion for Extension of Time Until 850307 to File Proposed Findings on Offsite Emergency Planning.Certificate of Svc Encl

ML20099B869
Person / Time
Site:	Limerick
Issue date:	02/26/1985
From:	Ferkin Z PENNSYLVANIA, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
References
CON-#185-960 OL, NUDOCS 8503110144
Download: ML20099B869 (4)

Text

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UNITED STATES OF AMERICA 2MEJES

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIY95B9Af E4 a3 ga

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In the Matter of )

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PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352 0b -

) 50-353O C (Limerick Generating Station, )

Units 1 and 2) )

Motion for Extension of Time in which to File Proposed Findings on Offsite Emergenc/ Planning The Commonwealth hereby requests an additional day in which to file its proposed findings of fact and conclusions of law on offsite emergency planning contentions.

The Commonwealth contends there is good cause for granting this motion. As the Commonwealth has indicated to this Board on prior occasions, Commonwealth filings in this proceeding must undergo several levels of review, Proposed findings on issues as significant as offsite emergency planning merit careful consideration by Commonwealth officials. Moreover, undersigned Commonwealth counsel has been assigned responsibility for preparation of these findings, including incorporation of revisions or comments made in the course of review. At the same time, m

8503110144 050226 -

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e undersigned counsel is faced with the responsibility of presenting part of her agency's direct case in Pennsylvania PUC hearings in Harrisburg on March 4, and spending the next day in preparation for presentation of the remainder of her agency's case on March 7. The demands of this schedule have not been within the control of counsel. The additional day will allow counsel to incorporate the review of the appropriate Commonwealth officials and thereby fairly represent the Commonwealth's position.

Commonwealth counsel has discussed this request with the Applicant. In light of the special circumstances of the undersigned counsel, Applicant has no objection to the requested one-day extension for the Commonwealth.

The Commonwealth requests the Board allow the Commonwealth until March 7, 1985 to file its proposed findings on offsite emergency planning contentions.

Respectfully submitted:

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Zori G. Ferkin Assistant Counsel Dated: February 26, 1985 a

l UNITED STATES OF AMERICA ' l NUCLEAR REGULATORY COMMISSION 2,: - 1

- :i.G b-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) ' 5 ~4 $17 :04

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PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-35ggj"a..?

(Limerick Generating Station, l 50-353 gj4u_2 fEh d

Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that copies of the " Motion for Extension of Time in which to File Proposed Findings on offsite Emergency Planning were served on the following by United States first class mail on the 26th day of February 1985:

Helen F. Hoyt Troy B. Conner, Esq.

Administrative Judge Conner and WLterhahn, P.C.

Atomic Safety and Licensing 1747 Pennsylvania Avenue, N.W.

Board Washington, D.C. 20006 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Richard F. Cole Docketing and Service Section Administrative Judge Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555

. Dr. Jerry Harbour Atomic Safety and Licensing Board j

Administrative Judge Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Atomic Safety and Licensina Benjamin H. Vogler, Esq.

Appeal Panel Counsel for NRC Staff U.S. Nuclear Regulatory Commission Office of the Executive Legal Washington, D.C. 20555 Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 n

.O Robert L. Anthony Philadelphia Electric Company Friends of the Earth of the ATTN: Edward G. Bauer, Jr.

Delaware Valley Vice President & General Counsel P.O. Box 186 2301 Market Street 103 Vernon Lane Philadelphia, PA 19101 Moylan, PA 19065 Joseph H. White, III Angus Love, Esq.

15 Ardmore Avenue 101 East Main Street Ardmore, PA 19003 Norristown, PA 19104 Charles W. Elliott, Esq.

• David Wersan, Esq.

Brose and Postwistilo Assistant Consumer Advocate 325 N. 10th Street Office of Consumer Advocate Easton, PA 18042 1425 Strawberry Square Harrisburg, PA 17120

• Tnomas Gerusky, Director Martha W. Bush, Esq.

Bureau of Radiation Protection Kathryn S. Lewis, Esq.

Dept. of Environmental Resources City of Philadelphia 5th Floor, Fulton Bank Building Municipal Services Building Third and Locust Streets 15Lh and JFK Boulevard Harrisburg, PA 17120 Philadelphia, PA 19107 Phyllis Zitzer

• Director, Pennsylvania Emergency Limerick Ecology Action Management Agency P.O. Box 761 8-151, Transportation & Safety Bldc PotLstown, PA 19464 Harrisburg, PA 17120 Steven P. Hershey, Esq. Spence W. Perry, Esq.

Community Legal Services, Inc. Associate General Counsel Law Center West Federal Emergency Mgmt. Agency 5219 Chestnut Street 500 C. Street, S.W., Rm. 840 Philadelphia, PA 19139 Washington, D.C. 204/2 Timothy R.S. Campbell Jay Gutierrez, Esq.

Director U.S. Nuclear Regulatory Dept. of Emergency Services Commission 14 East Biddle Street Region I West Chester, PA 19380 631 Park Avenue King of Prussia, PA 19406 4

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fri G. Ferkin s ,

A,sistant Counsel overnor's Energy Council Date: February 26, 1985