ML20099E582

Motion for Leave to File Reply to NRC Brief in Opposition to 841109 Request for Stay.Denied by Aslab on 841120

ML20099E582
Person / Time
Site:	Limerick
Issue date:	11/09/1984
From:	Sugarman R SUGARMAN & ASSOCIATES
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#484-256 OL, NUDOCS 8411210430
Download: ML20099E582 (2)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '

'04 M7 20 P3:05 ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of  : E _

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' Philadelphia Electric Company  : Docket No. 50-352-OL .

50-353-OL (Lim ~erick Generating Station, Units I and II)  :

MOTION FOR LEAVE TO FILE REPLY Appellant, by its counsel, move that the Appeal Board permit it to file a reply to the staf f brief in opposition to its request for stay, and aver as the basis thereof the following:

1. In its brief opposing the stay, the staff unjustifiably and inexplicably completely failed to address the applicant's reliance on the supplemental cooling water system for safety related purposes. .

2. In f act, not only did the staf f have the September 4 letter referred to in the Motion, but also had before it a letter dated October 19, 1984, addressed by Vincent Boyer to Harold Denton, requestia.g an exemption under the provisions of 10 CFR Section 50.12, based, in part, on an undisclosed " number of other sources". This letter Exemption Request is attached to the Reply.

3. It is necessary to permit reply in order to bring these matters to the attention of the Appeal Board.

8411210430 841109 DENIED N PDR ADOCK 05000 o For the Appeal Board N

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n.- Mi-ao-e Secrel ry to the AppealBoard

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' WHEREFOR the intervenor'-appellant requests that the

' ' Board permit it to file a reply brief as attached hereto.

7 Respectfully submitted, ,

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. ROBERT C'. SUGARMAN -'

Counsel for Intervenor; p

-Of Counsel .

Sugarman,'Denworth & Hellegers 16th Floor, Center. Plaza 101 North Broad Street Philadelphia, PA 19107 -

215-751-9733 DatedNovemberf,1984

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