ML19340A308
| ML19340A308 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/24/1976 |
| From: | Bell R, Charno S JUSTICE, DEPT. OF |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8003050889 | |
| Download: ML19340A308 (2) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION-1 Before the Atomic Safety and Licensing Appeal Board In the Matter of
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THE TOLEDO EDISON COMPANY AND
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THE CLEVELAND ELECTRIC ILLUMINATING ) NRC Docket No. 50-346A CO!!PANY
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(Davis-Besse Nuclear Power Station, )
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MOTION FOR PERMISSION TO FILE AN
.OTHERWISE UNAUTHORIZED PLEADING The Department of Justice hereby moves this Board for permission to file the attached pleading, entitled " Supple-mental Memorandum of the Department of Justice" in order to bring to the attention of ~ this Board material which is directly responsive to, and dispositive of certain important questions raised by the Board during oral argument-on !! arch 11, 1976.
.The specific questions raised by the Board at oral argument were not among those which the Board, in its Order of _ January. 8,1976, had requested the parties to be prepared i
to address.
Because the matters set forth in the attached memorandum are, we believe, dispositive of the questions i
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raised by the Board, we respectfully request the Board to consider them in the course of its deliberations.
If this Motion is granted, the Department would not.have objection-to the filing of a responsive pleading by' Applicants.
Respectfully submitted, Steven M. Charno
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Ruth Greenspan Bell Attorney Department of Justice
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i Dated:
March 24, 1976
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