ML20102C139
| ML20102C139 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/02/1985 |
| From: | Lodge T LODGE, T.J., SUNFLOWER ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20102C140 | List: |
| References | |
| CON-#185-874 OL, NUDOCS 8503050288 | |
| Download: ML20102C139 (2) | |
Text
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~ : sf D UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
!35 Before the Atomic Safety and Licensing Board 7
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,0:4,A In the Matter of
)
3
)
THE CLEVELAND ELECT.IC
) Docket Nos. 50-440 and 50-441 #b ILLUMINATING COMPANY
)
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
)
SUNFLOWER'S MEMORANDUM IN OPPOSITION TO
SUMMARY
DISPOSITION OF CONTENTION J By 10 CFR Section 2.749 (d), Applicant must show that there is no genuine issue as to any material fact and that it is entitled to a decision as a matter of law.
The record is to be viewed in the light most favorable to the party opposing the motion.
Poller v. Columbia Broadcasting System.
Inc., 368 U.S. 464. 47_3 (1962); Pennsylvania Power & Light Co. and Allegheny Electric Cooperative. Inc.
(Susquehanna Steam Electric Station, Units 1 and 2), LBP-81-8, 13 NRC 335, 337 (1981).
1 To this point in this proceeding, Applicant has failed by its own admission to supply 13 individual Emergency Action Level (EAL) indications.
Hulbert Affidavit, para. 4.
Sunflower, and presumably the public, must be content with Applicant's bland assurances that "the ' missing' values will be included in the PNPP Emergency Plan prior to fuel load." Hulbert Affidavit, para. 7.
Pertinent regulatory guidance mandatorily requires completed EALs.
See 10 CRF Part.50, App. E. Sect IV (C); See also Nureg-0654, Criterion D.1, Criterion D.2.
i Applicant's " trust me" approach is baffling. "ithe r the PNPP Plan 8503050288 850302 nm PDR ADOCK 05000440 Q
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