ML20070D071

Motion for Leave to File Encl Reply to West Branch Conservation Assoc 821204 Reply to Licensee 821201 Motion to Dismiss Certain Contentions.If Assoc Had Participated in Telcon,Utils Would Have Orally Replied

ML20070D071
Person / Time
Site:	Indian Point
Issue date:	12/10/1982
From:	Brandenburg B, Levin J CONSOLIDATED EDISON CO. OF NEW YORK, INC., MORGAN ASSOCIATES, POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20070D075	List: ML20070D071 ML20070D099
References
ISSUANCES-SP, NUDOCS 8212140439
Download: ML20070D071 (2)

Text

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00tKETED U:WRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMI*8EIOKC 13 N1:i8 ATOMIC SAFETY AND LICENSING _. BOARD.,3 g

- Jg ., 'sp ,, p Before Administrative Judges': UF" James P. Gleason, Chairman Frederick J. Shon Dr. Oscar H. Paris

)

In the Matter of )

) Docket Nos.

CONSOLIDATED EDISON COMPANY OF NEW YORK, ) 50-247 SP INC. (Indian Point, Unit No. 2) ) 50-286 SP _

e

)

POWER AUTHORITY OF THE STATE OF NEW YORK ) December 10, 1982 (Indian Point, Unit No. 3) )

)

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e MOTION FOR LEAVE TO FILE THE ATTACHED REPLY TO WEST BRANCH CONSERVATION ASSOCIATION'S REPLY [SICl TO MOTION OF THE LICENSEES OF DECEMBER 1 TO DISMISS CERTAIN CONTENTIONS Consolidated Edison Company of New York, Inc. and the Power Authority of the State of New York, licensees of Indian Po' int Units 2 and 3, respectively (licensees), hereby move this Atomic Safety and Licensing Board (Board) to issue an order granting the licensees' request to file the attached Reply to West Branch Conservation Association's (WBCA's) Reply [ sic} to Motion of the Licensees of December 1 to Dismiss Certain Contentions (Dec. 4, 1982) (Reply). As grounds for this motion licensees note that had WBCA been available to participate in the conference call of Decem-ber 3, 1982, regarding Licensees' Motion to Dismiss Certain 8212140439 821210 PDR ADOCK 05000247 G PDR

Contentions, the Board would have received orally the same reply which licensees now seek to submit in writing. More-over, as more fully set forth in the licensees' attached Reply, the licensees are concerned that WBCA's " Reply" mis-construes the intent of the Nuclear Regulatory Commission in establishing the Commission Question 2 aspect of this pro-ceeding. . ..

Respectfully submitted, b /

Brent L. Brandenburg' p gyles Morge 7,li Jr.

Assistant General Counsel Wa6 F. Colarol Joseph J. Levin, Jr.

CONSOLIDATED EDISON CO.

OF NEW YORK, INC. MORGAN ASSOCIATES, CHARTERED Licensee of Indian Point 1899 L Street, N.W.

Unit 2 Washington, D.C. 20036 4 Irving Place (202) 466-7000 New York, New York 10003 Stephen L. Baum ,

General Counsel Charles M. Pratt Assistant General Counsel POWER AUTHORITY OF THE STATE OF NEW YORK Licensee of Indian Point Unit 3 10 Columbus Circle New York, New York 10019 (212) 397-6200 Bernard D. Fischman Michael Curley Richard F. Czaja David H. Pikus SHEA & GOULD 330 Madison Avenue New York, New York 10017 (212) 370-8000 Dated: December 10, 1982