ML19260C714
| ML19260C714 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/20/1979 |
| From: | Kepford C Environmental Coalition on Nuclear Power |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8001080491 | |
| Download: ML19260C714 (4) | |
Text
ENVIRONMENTAL COALITION ON NUCLEAR POWER Co Ditosters. Mr. oeorge Boomwne-R.o. et, Peeen Sottom, Pe.17563 717 548 2836 or. Judith Johnsrud-433 oriendo Avenue. State College. Pe.16801 814 237 3900 UNITED STATES OF AMERICA NUCLEAR REGULATORY C0ffilSSION fd 19 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD d
In the Matter of
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8 NETROPOLITAN EDISON C0t1PANY Docket No. 50-289 d
(Three Mile Island Nuclear
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(License Suspension)
Station, Unit No.1)
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ECNP Intervenor's Reouest for an Extension of Time to File a Revised Contention In the October 31, 1979, response of the Suspended Licensee to the final contentions of ECNP, the Suspended Licensee offered no opposition to ECNP contentions concerning evacuation planning and emergency preparedness (October 31, 1979, filing, p. 9-10). However, the lack of opposition was qualified with a request that the Board require a subsequent resubmission of a contention on this subject with specific reference to the updated Emergency Plan of the suspended licensee. At the Prehearing Conference, the Board gave ECNP until December 20, 1979, to submit this revision.
Coincident with the Prehearing Conference, came the Emergency Plan.
- However, early in December, ECNP received Amendments 6 and 7 to the TMI-l Restart Report. 'Ayundment 6 was a revision of the earlier Emergency Plan.
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About the same time ECNP received a communication from the Architect-Engineer for TMI-1, Gilbert Associates, requesting confirmation of receipt by ECNP of TMI-l Restart Report Amendments Nos. 6, 7, and 8.
We replied that as of then, and now, we had received only Amendments 1, 2, 6, and 7.
Then, in a letter to the Board dated December 17, 1979, and received December 19, 1979, counsel for the Suspended Licensee advised the Board that 1703 277 80010804'//
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"a complete and up to date cooy of the [ suspended] Licensee's Emergency Plan..." has been forwarded under separate cover. This letter also suggests the possibility of further revisions of this Emergency Plan.
ECNP has been placed in a very awkward position in not knowing which Emergency plan to review for the revised contention.
- Clearly, the most recent Emergency plan, dated November 1979, renders the initial plan (October, 1979) obsolete. However, the letter of December 17, 1979, suggests the possibility of a third Emergency plan, since it did not specifically refer to the November,1979, version.
In addition, ECNP is ignorant of what changes to the existing Emergency Plan (November,1979), if any, are contained in the Amendments not yet received by ECNP. Furthennore, the suggestion of the possibility of still further revisions to the Plan indicates that the Plan is in a state of flux.
As a result, ECNP is presented with a rapidly changing target, containing possibly unknown changes, with the hint of future changes.
Therefore, ECNP requests an extention of time for submission of its revised contention on emergency planning and emergency prepardedness until such time at counsel for the suspended Licensee can give ECNP assurance that (a)
ECNP has in its possession a complete, up-to-date Emergency Plan, and (b) there will be no further substantive changes to said Plan prior to the comencement of the TMI-l proceedings.
ECNP would then serve its revised contention within 10 days of such notification.
If Counsel for the Suspended Licensee feels these conditions are met now with what ECNP has now (Amendments 1, 2, 6 and 7 only), a phone call to ECNP.would serve to trigger the 10 day period. The reason for this request, then, is based upon the very confusing state of the Emergency 1703 278 Plan and the desire of ECNP to avoid efforts which may subsequently be rendered obsolete or in need of another revision.
ECNP does not have the resources for such needless wastes of time and effort.
Respectfully submitted,
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x< K ' 4 Chauncey Kepford Representative of the ECNPrIntervenor 433 Orlando Avenue State College, Pennsylvania 16801 (814) 237-3900 Dated this 20th day of December, 1979.
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J.S. NUCLIM. RCCC' A'ORY COMMISSloti DOCKET!NG a SET / ICE SECTIOt4 OFF'"I C7 I"5 S:C*ETARY CF !!:S CCMMISS.ON
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l CERTIFICATE OF SERVICE _
i I hereby certify that copies of ECflP Intervenor's Request for. an Extension win of Time to File a Revised Contention has been served upon the folg#g by deposit in the U.S. Mail, First Class, postage paid, on this day of December, 1979.
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Ivan W. Smith, Esquire James A. Tourtellotte, Esquire Office of the Executive Legal Chairman Atomic Safety and Licensing Director Board Panel U.S. Nuclear Regulatory Conssission U. S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington,.D.C.
20555 Docketing and Service Section i
Office of the Secretary Dr. Walter H. Jordan U.S. Nuclear Regulatory Cosmaissios-Atomic Safsty and Licensing Washington, D.C.
20555 Board Panel
.g 881 West Outer Drive Oak Ridge, Tennessee 37830 George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge Dr. Linda W. Little 1800 M Street, N.W.
Atomic Safety and Licensing Washington, D.C.
200M Board Panel 5000 Hermitage Drive
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