ML20101U341
| ML20101U341 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/25/1985 |
| From: | Bernabei L, Shohet G GOVERNMENT ACCOUNTABILITY PROJECT, JOINT INTERVENORS - WATERFORD |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20101U343 | List: |
| References | |
| CON-#185-417 OL, NUDOCS 8502070267 | |
| Download: ML20101U341 (2) | |
Text
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oi o-h UNITED STATES OF AMERICA 00LKETED NUCLEAR REGULATORY COMMISSION I'
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL R_ ARygg _6 P4:44 In the Matter of
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LOUISIANA POWER AND LIGHT COMPANY
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Docket No. 50-382 M,;'m
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(Waterford Steam Electric Station,
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Unit 3)-
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JOINT INTERVENORS' MOTION FOR LEAVE TO FILE REPLY TO APPLICANT AND NRC STAFF'S RESPONSES TO JOINT INTERVENORS' MOTION TO REOPEN Joint Intervenors respectfully request leave to file this reply to' Applicant and NRC Staff's Responses to Joint Inter-venors' Motion to Reopen.
Joint Intervenors did not receive until January 11, 1985 a copy of SSER 9 upon which the NRC Staff relied to resolve 23 problem areas of safety significance at Waterford 3.
- Further, Joint Intervenors' counsel has been involved in hearings on the restart of Three Mile Island, Unit 1, only recently completed in Harrisburg, Pennsylvania.
There are a number of misstatements and misleading statements madeLin both applicant and the NRC Staff's briefs which require correction.
Moreover, filing of Joint Intervenors' reply will not prejudice any. party since this Atomic Safety and Licensing Appeal Board has already indicated that it anticipates it will need several months to complete its consideration of this motion.
In consideration of the above, Joint Intervenors respectfully request leave for-filing of their reply.
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-os Respectfully Submitted, J?J 2a Lyn Bernabei
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/JJ George S et Government Accountability Project 1555 Connecticut Avenue,.N.W.
Washington, D.C.
20036 (202) 232-8550 Attorneys for Joint Intervenors DATED:
January 25, 1985 lJoint Intervenors were not served with a copy of SSER 9 and had to request one from the NRC Staff.
The NRC Staff explicitly relied on SSER 9 in its response to Joint Intervenors' Motion but did not provide Joint Intervenors or this Appeal Board with any notico of'its contents.
SSER 9 is a voluminous decament which required a substantial ar.ount of time to analyze.
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