ML20093H726
| ML20093H726 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/12/1984 |
| From: | Glasspiegel H CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20093H729 | List: |
| References | |
| CON-#484-464 OL, NUDOCS 8410160363 | |
| Download: ML20093H726 (2) | |
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October 12, )pg USNRf UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g DCT15 pyg;4g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter _of
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A N;,i THE CLEVELAND ELECTRIC
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Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL.
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50-441 C) (__
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(Perry Nuclear Power Plant,
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Units 1 and 2)
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APPLICANTS' MOTION FOR LEAVE TO FILE REPLY Applicants respectfully move the Licensing Board pursuant to 10 C.F.R. 52.730(c) to permit the filing of the attached reply to "OCRE Response to Applicants' Motion for Specification of a Credible Accident Scenario Under Issue G8," dated October 3, 1984.1/
In its response, OCRE advances new legal arguments and seeks new relief from the Board, based on SECY-83-357, portions of which are attached to OCRE'S response.
OCRE's selective use of SECY-83-357, and OCRE's new legal argu-ments that the Board should now disregard established Commis-sion, Appeal Board, and Licensing Board precedent governing Issue #8, necessitate that Applicants be permitted a reply.
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OCRE's filing is in response to " Applicants' Motion for Specification of a Credible Accident Scenario Under Issue l
- 8," dated September 18, 1984.
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~For these reasons, Applicants request that its motion be granted.
' Respectfully submited, SHAW, PITTMAN, POTTS & TROWBRIDGE By:
IIY Jay E.
- Eilberg, P.C.'
Harry H. Glasspiegel Counsel for Applicants 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
October 12, 1984 4
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