ML20030C352
| ML20030C352 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/21/1981 |
| From: | Blake E ARKANSAS POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20030C353 | List: |
| References | |
| NUDOCS 8108260010 | |
| Download: ML20030C352 (2) | |
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UNITED STATES OF AMERICA ND ll 1
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NUCLEAR REGULATORY COMMISSION f m ee= %.
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%mun Before the Atomic Safety and Licensing Board 4
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LOUISIANA POWER & LIGHT COMPANY
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Docket No. 50-382
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(Waterford Steam Electric
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i' APPLICANT'S MOTION FOR
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DISPOSITION OF JOINT INTERVENORS'
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" I'J CONTENTION 22 (SAFETY-RELATED CONCRETE;)'s.
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e Louisiana Power & Light Company
(" Applicant") h es the Atomic Safety and Licensing Board pursuant to section 2.749 of the Commission's Rules of Practice, 10 C.F.R. S 2.749, for summary disposition in Applicant's favor of Joint Intervenors' Contention 22, which alleges that " Applicant has failed to discover, acknow-ledge, report or remedy defects in safety related concrete con-struction."
As grounds for this motion, Applicant states that there is no genuine issue as to any fact material to Contention 22 and that i
Applicant is entitled to a decision in its favor.on Contention 22 as a matter of law.
This motion is based upon Applicant's Brief In Support, Applicant's Statement Of Material Facts, and the Affidavit Of Thomas F.
Gerrets, all submitted herewith, and upon all the pleadings and I
other papers previously filed in this proceeding.
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-8108260010 010821
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DATED:
August 21, 1981.
Respectfully submitted, SHAW, PITTMAN, FOTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000
'k BY:
Ernest L.
Blake, Jr.
James B.
Hamlin Counsel for Applicant Louisiana Power & Light Company i
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