ML20102C308
| ML20102C308 | |
| 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 | |
| OL, NUDOCS 8503050477 | |
| Download: ML20102C308 (2) | |
Text
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r-NUCLEAR RECULATORY COMMISSION Before the Atomic Safety and Licensing Boari g ;,,.
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In the Matter of
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)
THE CLEVELAND ELECTRIC
) Docket Nos. 50-440 and 50-441 ILLUMINATING COMPANY
)
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
)
SUNFLOWER'S MEMORANDUM IN OPPOSITION TO
SUMMARY
DISPOSITION OF CONTENTION CC 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, 473 (1962); Pennsylvania Power & Light Co. and Allegheny Electric Cooperative, Inc.
(Susquehanna Steam Electric Station, Units 1 and j
2), LBP-81-8, 13 NRC 335, 337 (1981).
i Applicant refers to " letters" and other correspondence having i
l been sent to the Nuclear Regulatory Commission clarifying changes to the I
PNPP plan. Applicant's " Statement of Material Facts," para. 3.
To date, while ostensibly these items are purportedly to be included in a fourth revision of the PNPP plan, such has not appeared in any public fashion.
Inasmuch as the modifications must be made to the plan, it would be
.quite premature to grant summary disposition until the changes claimed 8503050477 850302 PDR ADOCK 05000440 0
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have been verified.
WliEREFORE, Sunflower Alliance prays the Board to deny summary disposition of Contention CC.
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Respectfully submitted.
By
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llrry J() Lodge jT 618 N. Michigan Street Suite 105 Toledo, Ohio 43624 Phone: (419) 255-7552 Counsel for Sunflower Alliance