ML20107G373
| ML20107G373 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/23/1985 |
| From: | Lodge T LODGE, T.J., SUNFLOWER ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20107G302 | List: |
| References | |
| OL, NUDOCS 8502260401 | |
| Download: ML20107G373 (1) | |
Text
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00ggEO UNITED STATES OF AMERICA NUCLEAR REGULATORY CO.TfISSION Before the Atomic Safety and Licensing Board 5 FG 25 P1 :35 In the Matter of THE CLEVELAND ELECTRIC Docket Nos. 50-440 and 1
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ILLUMINATING COMPANY
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NCH (Perry Nuclear Power Plant, Units 1 and 2)
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SUNFLOWER'S STATEMENT OF MATERIAL FACTS (CONTENTION C)
Now comes Sunflower Alliance and sets forth-the following in j
support of its position that Applicant is not entitled to a decision as a matter of law respecting Contention C:
1.
Indisputably, county commissioners have certain legal authority to implement emergency measures in the event of a disaster at PNPP.
2.
However, county commissioners do not have: clear legal authority under Ohio law to declare an emergency, and all relevant plans fail to establish or acknowledge precisely which public official (s) must first declare an emergency _before! emergency plans may be implemented.
Respectfully submitted, i
By QA
/
W L
/'
forr?'J[ Lodge 6:.8 N. '.$chigan St.
puite 105
%pledo, Ohio 43624 Phone: (419) 255-7552-
' Counsel'for Sunflower Alliance
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