ML20031E712
| ML20031E712 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/09/1981 |
| From: | Halligan T CITIZENS AGAINST NUCLEAR DANGERS |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8110160337 | |
| Download: ML20031E712 (2) | |
Text
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9 UNITED ST ATES OF AMERICA
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BEtORE tee ATOMIC SAFETY & LTCENSING APPEALkg BOARM. W Y.b,. ~#
IN THE MATTER OF
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J$.i CITIZENS AGAINST NUCLEAR DANGERS A
APPEAL 1OR A STAY OF A ASLB ORDER 7
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CONCEENING CONTENTIONS 2 AND 4 01 u.s.u gxtup g
The Citizens Against Nuclear Dan 6ers (Citizens) be'rgby appeal thej/
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d e, decision of the ASLB served September 30, 1981, wherein a m644 @ d led by the NRC staff for summary disposition of Contention 2 relating to the risks of low-level radiation tas approved; and also wherein a NRC-staff motion for summary disposition on Contention 4 was also approved as it applies to Contention 4 (c) and 4 (d).
The Citizens move the Appeal Board to stay the ASLB Order or September 30th.
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Just prior to the issuance of that order, the complete direct testimony on the contentions in question was distributed to all the parties.
The NRC staff and the Applicants have their witnesses prepared to testify.
The interveners are reviewin6 the submitted documents and are prepared for cross-examination.
The ASLB's last minute, unorthodox and arbitrary decision of september 30th is untimely, unfair, and certainly not in the public interest.
The transcript or them proceedin5s, to date, will show that the j
issues already under litigation, namely Contentions 17 and 9, (both of which were also_ challenged via summary disposition) have been dealt with expeditiously, and without delayin6 tactics by the interveners.
Therefore, in order to compile as complete a. record on'~
the material facts in dispute on the aforementioned contentions, the 503 9
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2 Citizens petition the Appeal Board to reinstate these two contentions for litigation.
Fa111n6 to do so would invite possibic injunctive relief somewhere down the road.
This would be counter productive to the NRC'.
Moraally, sum. mary disposition is cut off 45 days p. lor to the start or hearings.
Bu_, the Berwick case in not being run entirely in accord with due process, to say the least!
The rero re, the Citizens move the Appeal Board to do unatever is necessary to insure hence-forth that the ASLB will cease and desist from proceeding by leaps and bounds, and otherwise stirlin8 First Amendment r16 hts.
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Respiecir611y submitted
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Dated: October 9, 1981 Co rre sponden.t CERTIFICATE DE SERVICE I hereby certiry that copies or Citizens AFainst Nuclear DanFers Appeal For A Stay Of A ASLB Order Conca ning Contentions 2 And 4 Eave been, or will be, served on all parties to this proceeding by deposit in the U.S. mail and/or hand delivered, this 9th day of October,1981, and on October 13, 1981.
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