ML20080B518

Motion for Leave to File Reply to Util & NRC Answers to Joint Intervenors 840109 Petition for Review of ALAB-756

ML20080B518
Person / Time
Site:	Diablo Canyon
Issue date:	02/03/1984
From:	Reynolds J CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON
To:	NRC COMMISSION (OCM)
Shared Package
ML20080B522	List: ML20080B518 ML20080B541
References
ALAB-756, ISSUANCES-OL, NUDOCS 8402070177
Download: ML20080B518 (2)

Text

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00CKETED US'!RC UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION T4 FEB -6 N0 :49 BEFORE THE COMMISSION 7.- y ,, c., ,.

/ .

)

In the Matter of )

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.

) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

)

)

JOINT INTERVENORS' MOTION FOR LEAVE TO FILE REPLY The Joint Intervenors hereby move the Commission for leave to file the attached reply to PGandE and NRC Staff Answers to the Joint Intervenors' January 9, 1984 Petition for Review of ALAB-756.

This reply is necessary because the PGandE and Staff Answers contain errors of fact, which if left uncorrected, will mislead the Commission as to the true state of the record in this proceeding. This brief eight-page reply does not reiterate the substance of the Joint Intervenors' Petition, but rather consists of citations to and excerpts from the record  !

below to assist the Commission in their decision regarding )

review. Although a reply is in some cases not essential, it is critical'where the responses to the initial filings contain 8402070177 840203 PDR ADOCK 05000275 C PDR I

l o l l

inaccuracies that could mislead the Commission. Such is the . )

case here. ' l Accordingly, for the foregoing reasons, the Joint  !

Intervenors respectfully request that the requested leave to file be granted.

Dated: February 3, 1984 Respectfully submitted, JOEL R. REYNOLDS, ESQ.

JOHN R. PHILLIPS, ESQ.

ERIC HAVIAN, ESQ.

Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 DAVID S. FLEISCHAKER, ESQ.

P. O. Box 1178 Oklahoma City, OK 73101 By QEL R. Pg NQyIDS Attorneys for Joint Inter-venors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.

ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APFELBERG JOHN J. FORSTER

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