ML19029A668

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Answer by the Township of Lower Alloways Creek to Notice of Hearing on Amendment of Facility Operating License
ML19029A668
Person / Time
Site: Salem  PSEG icon.png
Issue date: 05/13/1978
From: Horner W
Lower Alloways Creek Township, NJ
To:
Atomic Safety and Licensing Board Panel
References
Download: ML19029A668 (3)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In The Matter of Docket No. 50-272 PUBLIC SERVICE ELECTRIC & Proposed Issuance GAS COMPANY of Amendment to Facility Operating (Salem Nuclear Generating License No. DPR-70.

Station, Unit No. 1)

ANSWER BY THE TOWNSHIP OF LOWER ALLOWAYS CREEK TO NOTICE OF HEARING ON AMENDMENT OF FACILITY OPERATING LICENSE Pursuant to the provisions of 10CFR 2.705 and pursuant to the Notice of Hearing on Amendment of Facility Operating License docketed in this proceeding on April 27, 1978 th~ Township of Lower Alloways Creek, a party to this proceeding by virtue of its admission as an intervenor, hereby states by way of Answer to said Notice of Hearing a's follows:

1. The nature of its position is that it continues to seek the admission of each of the eleven ( 11) cx:mtentions

.,...\,.J.A that it set forth in its Petition for Intervention as specific issues to be considered in the hearings on the application by Public Service Electric & Gas Company for its requested amendment to its facility operating license No. DPR-70 which is the subject of this proceeding.

2. Since the L.icensing Board has not yet determined the specific issues to be considered at the hearing and since these specific issues are not set forth in the Notice of Hearing the Township of Lower Alloways Creek at this time cannot state the items of the specification of issues it controverts and those it does not controvert.

, 3. The Township of Lower Alloways Creek intends to appear at the hearing and present evidence.

4. Since the issues have not yet been specified there are no facts alleged which can be admitted or denied in this Answer nor affirmative defenses or positions to

/be stated other than the eleven (11) contentions set forth in the Petition to Int'ervene by the Township of Lower Alloways Creek, which eleven (11) contentions are hereby incorporated by reference as its position.

5. The Township of Lower Alloways Creek does not oppose the holding of a pre-hearing conference followed by a hearing on the proposed amendment of the facility operating license.
6. The Township of Lower Alloways Creek does oppose the views of the Atomic Safety and Licensing Board designated to rule over Petitions for Leave to Intervene pertaining to its contentions 2, 4, 5, 6, 7, 8, 9, 10 and 11 as expressed in said Board's Memorandum and Order dated April 26, 1978 and plans to address those views and to defend and further develop and clarify its contentions and to urge thei~ acceptance, in modified form where necessary, as contentions and specific issues to be considered at the hearing.

Respectfully submitted, Dated: LOWER ALLOWAYS CREEK TOWNSHIP By:_ l1t1::iL c~

William C. Horner Its Attorney 67 Market Street Salem, NJ 08079