ML20138B891

From kanterella
Jump to navigation Jump to search
Motion for Leave to Reply to Util & NRC 860225 & 0305 Responses,Respectively,To Ocre 860203 Motion to Reopen Record & Submit New Contention Re 860131 Earthquake Near Plant
ML20138B891
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 03/19/1986
From: Hiatt S
OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20138B896 List:
References
CON-#186-497 OL, NUDOCS 8603250212
Download: ML20138B891 (2)


Text

. -

._..~

C(#}

L UNITED STATES OF AMERICA i

NUCLEAR REGULATORY COMMISSIONDOCKETED USHRC

\\

Before the Atomic Safety and Licensing Appeal Board l

Hb Ub$ $b RE:26 In the Motter of

)

i

)

THE CLEVELAND ELECTRIC

)

0FFirDocke t Nos. 50-440 OL l

ILLUMINATING CO. ET AL.

)

00CUINO 50-441 OL

~

car:

y i

(Perry Nuclear Power Plant,

)

Unsts 1 and 2)

)

OCRE MOTION FOR LEAVE TO REPLY TO STAFF AND APPLICANT RESPONSES

~

TO OCRE'S MOTION TO REOPEN THE RECORD AND TO SUBMIT A NEW

)

CONTENTION On February 3, 1986, Intervenor Ohio Citizens for Responsible Energy ('0CRE*) filed a motion to reopen the record j

and to submit a new contention regarding the January 31 earthquake occurring in the vicinity of the Perry facility, i

Applicants filed their answer to OCRE's motion on February 25, j

1986; the NRC Stoff filed zes response on March 5, 1986.

OCRE hereby moves that the Appeal Board grant permission to file the ottoched reply to the filings of Applicants and Stofr.

l It is necessary for OCRE to rep 1 to the Staff and Applicant I

responses ror several reosons.

First, OCRE's motion was admittedly based On preliminary information on the earthquake.

Since February 3, new information has become available (including but not Itmited to the information contoined in the Staff and Applicont responses and SSER 9) which has enabled OCRE to provide better focus for its Proposed seismic contention.

Second, it is necessory to respond to the various allegations and misrepresentations of Stoff and Applicants purporting that OCRE's motion and contention had failed to conform to the oppropriate stondords.

Third, it is the low of this agency that 8603250212 860319 1

[DR ADOCM 05000440 bO 3

PDR

..,__m

, _., _, _ _. _. _ ~ -. _, _ -... -. _

9 h

before any suggestion that a colatention should not be entertained con be acted upon favorably, the proponent of the contention must be give some chance to be heard i n response.

Houston Li9hting and Power (Allens Creek Huclear Generating i

Stat 2on). ALAB-565. 10 NRC 521, 525 (1979).

4 OCRE prays that the Appeal Board is so moved.

Respectfully submitted, Susan L.

Hiatt OCRE Representative 8275 Munson Road Mentor, OH 44060 (016) 255-3158 i

es -

4 - - - es me------me--

)

i

[

i i

l i

e a

.-,,e

,-ms-e.

---r,-,3e,--,--i-,

w

..y--.

~

--..,,y

,.v..-,m

--,-,-m.

-.