ML20090F334

From kanterella
Jump to navigation Jump to search
Response in Opposition to Applicant Motion for Particularization of Issue 1.Motion Should Be Denied. Certificate of Svc Encl.Related Correspondence
ML20090F334
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 07/16/1984
From: Lodge T
SUNFLOWER ALLIANCE
To:
Atomic Safety and Licensing Board Panel
References
OL, NUDOCS 8407200252
Download: ML20090F334 (3)


Text

[

g.g r ".C T W' July 16, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensirig, Board n:. ~.

In the Matter of

)

THE CLEVELAND ELECTRIC ILLUMINATING)

Docke No h.2527 g(

COMPANY, et. al,

)

50-441 6i

)

.0,,..

(Perry Nuclear Power Plant, Units,)

-Y' 1 and 2)

)

~,_'s.

)

SUNFLOWER'S RESPONSE IN OPPOSITION TO PARTICULARIZATION OF ISSUE NO. 1 Now ccmes Sunflower Alliarre, by and through counsel, and enters its opposition to the " Motion for Particularization of Issue No.1" filed by Applicant.

Applicant's claim that sunnary dispositicn is "inpossible" without particularization should collapse cn its own lack of merit. It is not this Board's responsibility to give Applicant a helping hand in setting up broad issues of fact for an attenpt at sunnary proceedings.

The offisit emergency respcnse plans being ccrnpiled by the State of Ohio are not ccuplete' they are not finally approved; and in fact at this point the PNPP offsite plan is uncorgoing public cwnerat until September 1, as evidenced by Attachnent A hereto.

No party hereto will be pmjudiced by denying the " Motion" pending finalizaticn of draft plans and an opportunity for Sunflower to frame any possible stipulaticns as to pmparaticns or issues within this ccntention.

Wht.te2vRE, Stnflower rupectfully prays the Board to deny Applicant's "Itticn."

~

Terry p.{ Lodge Counsel or S.nflower Alliance 9407200252 618 N.I

_chikfanSt., Suite 105 0

gDRADOCK0 PDR Toledo', Ohio 43624 (419) 255-7552 CERTIFICATION I hereby certify that a ccpy of the foregoing was sent to each party cn the attached " Service List" this 18th day of Jul, 1 via regular U.S. Mail.

\\-

g n 1

_........u-i NI.

STATE OF OHIO

~

ADJUTANT GENERAL'S DEPARTMENT Attachmnt A 2825 WEST GRANVfLLE ROAD WoRTHINGToN. oHoo 43085 DISASTER SERVICES AGENCY

.7 AGOH-DS Ng July 3, 1984 jA 20 AU 27

.. o..

TO THE READER:

e Transmitted herewith is one copy of the State of Ohio Plan for Response to Radiologica! Emergencies at Licensed Nuclear Facilities (Edition of.1984),

which is intended to replace the existing edition of 1980.

This Plan was submitted in June 1984 to the Regional Assistance Committee of the Federal Emergency Management Agency, Region V in Chicago, Illinois for review and comment.

In as much as the reviewing process is not yet complete and the document has not received full Federal approval, it is necessary that both editions of the Plan be filed together until approval for final publication has been obtained.

for the preparation of this document, public health and safety c require that a copy of the Plan be made available for public review and comment in appropriate public document rooms of specified libraries sited in the vicinity of a nuclear power facility.

Members of the general public desiring to submit comments regarding this document may do so not later than September 1,1984 to ensure prompt receipt and action by this office.

Thank you for your cooperation.

FOR THE DIRECTOR A, g 4

[

RICHARD M. LOCKHART Deputy Director JAS:kjs l

l 6

-.4

  • ~ '

.~

i ru 4 -. :.....:.:r;;;cs. tcg UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board _

O d'

80,.

)

y w.a In the Matter of Y

}

Docket No's. 504440

)

THE CLEVELAND ELECTRIC 50-4'41 PO

)

ILLUMINATING COMPANY EMS.

)

b.

$ @? e O (Perry Nuclear Power ' Plant,

)

)

Units 1 and 2)

SERVICE LIST _

Peter B.

Bloch, Chairman I

Atomic Safety & Licensing Board

/

U.S. Nuclear Regulatory Comm.

I Washington,'D.C.

20555 Dr. Jerry R. Kline Ato'mic Safety.& Licensing Scard.

U.S., Nuclear. Regulatory Commission

,6 Ms. Sue Hiatt Washington,-D.C.

20555 8275 Munson Avenue Mentor, Ohio 44060 Mr..Glenn O. Bright Atomic Safety G. Licensing Board U.S. Nuclear Regulatory Commission Washincton, D.C.

20555 l

Colleen P. Woodhead, Esq.

\\

Office of the Executive Legal Director l

U..S. Nuclear Regulatory Commission Washington,. D.C.

20555 Jay.Silberg, $sq.

\\ Shaw, Pittman, Potts, & Trowbridge 1800 M Street, NW

. Washington, D.C.

20036 y

Docketing'& Service Branch

.Offi'ce of'the Secretary U.S.. Nuclear Regulatory Commission N

Washington, D.C.

20555 Atomic. Safety.&, Licensing Appeal Board Panel

~

U.S. Nuclear Regulatory Commission Washington, D.C.

20555

  • '9-@

WW mmo e

" - - - - - - - - - - - _ _ _ - _ -. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _