ML20010C655

Notice That R Alexander Is New Representative for Oh Citizens for Responsible Energy (Ocre).Suppls Ocre Brief on Admissibility of Sunflower Alliance ATWS Contention. Certificate of Svc Encl

ML20010C655
Person / Time
Site:	Perry
Issue date:	08/12/1981
From:	Ryan Alexander OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8108200277
Download: ML20010C655 (2)

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Aug. 12, 1981, y UIIITED STATED 0F A:4 ERICA -

I:UCLEAR REGULATORY C0FJ4ISSI0I: Ne Before the Atomic Safety and Licensinc Board 1

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- In the Matter of ) <fP 3

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CLEVELAND ELECTRIC ILLUMIllATING ) Docket Nos. 50-00:4PANY, et al. ) 50-44 '/s

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Units 1 and 2) ) E C

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I. OMIO CITIZENS FOR RESPONSIBLE EIiERGY N 08I > 2

("OCRE") NOTICE OF CHAIIGE OF REPRESENTATIVE 7 Dirce ci tu s:ym;y g Us & S : a Sanica .

The consensus among current OCRE representative Jeff f * :h m

e Alexander and OCRE members is that OCRE's participation in this adjudicatory proceeding would be conducted most expeditiously .

by designating fellow OCRE member Robert Alexander as the new Interim Representative. Effective immediately and for as long nn he is able, all correspondence and communications to CCRE should be directed to the undersigned address of Robert Alexa.nder.

II. SUPPLEMENT TO OCRE'S BRIEF

,ON ADMISSIBILITY OF ATNS CONTENTION Five days earlier, OCRE filed its brief on the admissibility of the Sunflower Alliance' ATWS contention. The following supplenent to that brief is seasonable per the Board's request and must be considered.

The most compelling argument for admission of the ATNS contention into this proceeding is chat of time. The Staff and

-industry have quarreled for eleven years over the requirements to be imposed and, given the current progress of the rulemaking on ATWS, it is not likely a final resolution will'oe had prior ,

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to PHPP initial decision.- At-that point, conflicts between Applicant's Ldesign and the final' rule will inure little to the health and safety of OCRE mer.bers.

And should a final rule'be reached prior to initial decision, any required nodifications to hardware .would be very costly, if-

. feasible at all.

To conclude, a rulemaking can be an adequate substitute for the individual litigation of an issue. But it is not adequate when

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the rulemaking has reached.an impasse. Industry will continue to balk at a recomrendation for autonatic SLCS that can result in a;nuch safer plant but which entails the risk of costly false

-actuation 3. This issue must be heard and tried.in the above-captioned proceeding.

" spectfully. submitted, A

Robert Alexandbr, OCRE Interim Renresentative

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2030 Portsmouth Street #2 Houston, TX 77098 CERTIFICATE OF SERVICE This is to certify that copier of OCRE's Notice of Change of Representative / Supplement to ATWS Admissibility Brief, dated Aug. 12, 1931, were served upon those persons on the service list below by deposit in the United States mail, postege prepaid, this th day of Auguet, 1981.

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Robert Alexander ,

Peter 3. B'.och, Chairman, ASLB Dr. Jerry R. Kline, ASLB Mr. Frederick J. " hon, ASLB DecketingLand Secvice Section, Office.of the Secretary Charles A. Barth, Office of the Executive Legal Director Jay E. Silberg, Applicant

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