ML20071B329
| ML20071B329 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/23/1983 |
| From: | Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8302280160 | |
| Download: ML20071B329 (4) | |
Text
(
l 6-20LKETED February 23, 1563^
83 FEB 25 A9:51 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION E Uui Aav Before the Atomic Safety and Licensing Board *f}E mCE In the Matter of
)
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMPANY, et al.
)
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
APPLICANTS' ANSWER IN SUPPORT OF NRC STAFF MOTION FOR A DEADLINE BY WHICH OCRE MUST SPECIFY THE SCENARIO TO BE LITIGATED UNDER ISSUE #8 1/
By motion dated February 8, 1983
, the NRC Staff has 10, 1983 requested the Licensing Board to establish a March deadline by which OCRE must identify with particularity and basis the specific TMI-2 type scenario for Perry that OCRE intends to litigate under Issue #8.
Applicants believe that the Staff's motion is entirely consistent with prior Appeal Board and Licensing Board rulings on Issue #8, as summarized 1 See "NRC Staff Motion For A Deadline by Which OCRE Must Specify The Scenario To Be Litigated Under Issue #8," dated February 8, 1983.
8302280160 830223 PDR ADOCK 05000440 g
PDR o
r p-by the Staff in its motion.
Applicants agree with the arguments set forth by the Staff..Accordingly, Applicants respectfully urge the Licensing Board to grant the Staff's motion.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By:
/lL (1
7 J
E SILBERG, P.C.f Counsel for Applicants 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
February,23, 1983
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p y
February 23, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMPANY, e_t al.
)
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Answer in Support of NRC Staff Motion for a Deadline by Which OCRE must Specify the Scenario to be Litigated under Issue #8" were served by deposit in the United States Mail, first class, postage prepaid, this 23rd day of February, 1983, to all those on the attached Service List.
AG f
JAY' ILBERG
]
DATED:
February 23, 1983
r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
THE CLEVELAND" ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMPANY
)
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
SERVICE LIST Peter B.
Bloch, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel U.S. Nuclear Regulatory Commission U.S._ Nuclear Regulatory Commissi@
Washington, D.C.
20555 Washington, D.C.
20555 Dr. Jerry R.
Kline Docketing and Service Section Atomic Safety and Licensing Board Office of the-Secretary U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commissi@
Washington, D.C.
20555 Washington, D.C.
20555 Mr. Glenn O.. Bright James M.
Cutchin, IV, _ Esquire Atomic Safety and Licensing Bcard Office of the Executive U.S. Nuclear Regulatory Commission Legal Director Washington, D.C.
20555 U.S. Nuclear Regulatory Commissie Washington, D.C.
20555 Christine N.
Kohl, Chairman Atomic ~ Safety and Licensing Ms. Sue Hiatt Appeal Board OCRE Interim. Representative U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D.C.
20555 Mentor, Ohio 44060 Dr. John H.
Buck Daniel D. Wilt, Esquire Atomic Safety and Licensing Post Office Box 08159 Appeal Board Cleveland, Ohio 44108 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Donald T.
Ezzone, Esquire Assistant Prosecuting Attorney Gary J.
Edles, Esquire Lake County Administration Cente Atomic Safety and Licensin'g 105 Center Street Appeal Board Painesville, Ohio 44077 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 John G.
Cardinal, Esquire Prosecuting Attorney Atomic Safety and Licensing Ashtabula County Courthouse Board Panel Jefferson, Ohio 44047 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Terry Lodge, Esquire 915 Spitzer Building Toledo, Ohio 43604
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