ML20107M732
| ML20107M732 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/25/1985 |
| From: | Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT, JOINT INTERVENORS - WATERFORD |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20107M736 | List: |
| References | |
| CON-#185-796 OL, NUDOCS 8503010410 | |
| Download: ML20107M732 (2) | |
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NUCLEAR REGULATORY COMMISSION-D3C;KEijg wAA Before the Atomic Safety and Licensing Appeal Board
'd3 GB 28 No:49 In the Matter of
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LOUISIANA POWER & LIGHT COMPANY)
Docket No. S0 382GOIcEM d
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UhAhCri (Waterford Steam Electric
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JOINT INTERVENORS' MOTION FOR LEAVE TO FILE SUPPLEMENTAL MEMORANDUM IN SUPPORT OF MOTION TO REOPEN Joint Intervenors request leave to file the following Supplemental Memorandum in Support of their Motion to Reopen.
The request is based on recent public reports concerning the instability and lack of independence of the management of applicant Louisiana Power and Light Company ("LP&L");
1 mismanagement or deliberatively wrongful management conduct demonstrated by a recent blackout of the City of New Orleans; misleading statements Middle South has made in its most recent offering statement; and statements of top LP&L management showing i
a general lack of respect for Nuclear Regulatory Commission ("NRC")
regulation.
These reports provide compelling support for Joint Intcrvenors' proposed contention that LP&L lacks the requisite character and competence to operate Waterford 3 safely.
As can be seen from the exhibits supporting their Supplemental Memorandum, Joint Intervenors have learned of this new information only within the last few weeks.
8503010410 850225 PDR ADOCK 05000382 G
, 5 For the foregoing reasons and for good cause shown, Joint Intervenors request that this Atomic Safety Licensing and Appeal Board (" Appeal Board") grant leave for the filing of this Supplemental Memorandum in Support of Joint Inter-venors ' Motion to Reopen.
Respectfully submitted, A du
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'L nhe Bernabei Go ernment Accountability Project
'155 Connecticut Avenue N.W.
Suite 202
-Washington, D.C. 20036 (202) 232-8550 Attorney for Joint Intervenor Dated:
February 25, 1985
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