ML20030D130
| ML20030D130 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/25/1981 |
| From: | Silberg J ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8108310419 | |
| Download: ML20030D130 (2) | |
Text
August 25, 1981 UNITED STATES OF AMERICA CWUUISPONDENCE NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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PENNSYLVANIA POWER & LIGHT COMPANY
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and
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Docket Nos. 50-387
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50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC.
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(Susquehanna Steam Electric Station,
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Units 1 and 2)
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AUG 2 71981 > I'-
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0:Cb4 & hWI3 APPLICANTS' MOTION FOR PARTIAL Eid g
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SUMMARY
DISPOSITION OF
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CONTENTION 2 (RADIOACTIVE DOSES)
I D1 Pennsylvania Power & Light Company and Allegheny Electric Cooperative, Inc.
(" Applicants") move the Atomic Safety and Licensing Board, pursuant to S 2.749 of the Commission's Rules of Practice (10 C.F.R.
S 2.749) and the Special Prehearing Conference Order of March 6, 1979), LBP-79-6, 9 NRC 291, 328, for summary l
disposition in Applicants' favor on the portion of Contention 2 i
in this proceeding that questions the magnitude of the doses resulting l
from radioactive releases from the Susquehanna Steam Electric Station
("Susquehanna").
An earlier motion by Applicants, dated August 13, 1981, has sought summary disposition of the source term (i.e.,
the magnitude of those releases).
As grounds for their Motion, Applicants allege that there is no genuine issue of material fact to be heard with respect to go3 s/b 0108310419 810825 PDR ADOCK 05000387 0
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.,g, the magnitude of the doses resulting from radioactive releases from Susquehanna, and Applicants are entitled to a decision in their favor on them as a matter of law.
This Motion is supported by the Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard (Contention 2) (Radioactive Doses), and the Affidavit of Frazier L. Bronson, both filed simultaneously herewith, together with all pleadings and other papers in this proceeding.
As set forth in the March 6, 1979, Special Prehearing Conference Order, supra, 9 NRC at 328, responses to this Motion are due three weeks from its filing date.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE I
f El. Silberg ids F. Travieso-Diaz Counsel for Applicants 1800 M Street, N.W.
Washington, D.
C.
20036 (202) 822-1000 Dated:
August 25, 1981.
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