ML20102C315
| ML20102C315 | |
| 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 8503050487 | |
| Download: ML20102C315 (3) | |
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i UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION s
Before the Atomic Safety and Licensing Board
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In the Matter of
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THE CLEVELAND ELECTRIC
) Docket Nos. 50-440and50-4b ILLUMINATING COMPANY
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(Perry Nuclear Power Plant,
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Units 1 and 2)
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SUNFLOWER'S STATEMENT OF MATERIAL FACTS (CONTENTION JJ)
Now comes Sunflower Alliance and sets forth the following facts in opposition to summary disposition of Contention JJ:
1.
The Grand Yalley School District in Ashtabula County has a policy of refueling school buses only when the tanks are 1/4 or less full.
Affidavit'of Barbara Niznik accompanying Sunflower's responses to summary dis-position of Contention Q.
2.
Niznik has not been instructed of her specific duties during an emergency at PNPP. Id.
Respectfully submitted, By hrry J. Lodge
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Wite 105 Toledo, Ohio 43624 Phone: (419) 255-7552 Counsel for Sunflowcr i
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8503050487 850302 PDR ADOCK 05000440 0
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UNITED STATES OF AMERICA jj NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board 3,Mi -4 ;g 33
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In the Matter of
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sAA.\\;h THE CLEVELAND ELECTRIC
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Docket Nos. 50-440 and 50-441 ILLUMINATING COMPANY
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(Perry Nuclear Power Plant,
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Units 1 and 2)
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SUNFLOWER'S CERTIFICATE OF SERVICE OF CERTAIN DOCUMENTS I hereby certify that a copy of the following documents was served by me this 2nd day of March, 1985 by regular U.S. Mail, postage prepaid, upon the parties appearing on the attached " Service List", except that those parties having an asterisk (*) by their names were served by express mail on this date. The documents are:
Sunflower's Memorandum in Opposition to Summary Disposition of Contention J; Sunflower's Statement of Material Facts.(Contention J);
Sunflower's Memorandum in Opposition to Summary Disposition of Contention 0; Sunflower's Statement of Material Facts (Contention 0);
Sunflower's Memorandum in Opposition to Summary Disposition of Contention Q; Sunflower's Statement of Material Facts (Contention Q);
Affidavit of. Barbara Niznik on Contention Q; Sunflower's Memorandum in Opposition to Summary Disposition of Contention U; Sunflower's Statement of Material Facts (Contention U);
Sunflower's Memorandum in Opposition to Summary Disposition of Contention Z; Sunflower's Statement of Material Facts (Contention Z);
Sunflower's Memorandum in Opposition to Summary Disposition of Contention BB;
-Sunflower's Statement of Material Facts (Contention BB);
Sunflower's Memorandum in Opposition to Summary Disposition of Contention CC; Sunflower's Statement of Material Facts (Contention CC);
Sunflower's Memorandum in Opposition to Summary Disposition of Contention JJ; Sunflower's Statement of Material Facts (Contention JJ).
Respectfully s bmitted,
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6/ j Seite 105 Toledo, Ohio 43624 Phone: (419) 255-7552
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SERVICE LIST James P. Gleason Atomic Safety and Licensing Board
- 513 Gilmoure Drive Silver Spring, MD 20901 Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Colleen P. Woodhead, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Jay Silberg, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C. 20036 Sue Hiatt 8275 Mentor Avenue Mentor, Ohio 44060 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555