ML19029A863
| ML19029A863 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/25/1979 |
| From: | Degnan J, Hluchan R State of NJ, Office of Attorney General |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| Download: ML19029A863 (4) | |
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I UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE ELECTRIC &
GAS COMPANY (Salem Nuclear Generating Station, Unit No. 1
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Docket No. 50-272 Proposed Issuance of Amendment to Facility Operating License No. DPR-70 STATE OF NEW JERSEY'S OUTLINE OF CROSS-EXAMINATION The State of New Jersey, a party to this proceeding by virtue of 10 C.F.R. §2.715(c), hereby gives notice, pursuant to the Board's directive, of the areas in which it expects to conduct cross-examination of witnesses at the hearing connnencing May 2, 1979.
- 1.
Colemans' Contentions 2 and 6:
The State expects to cross-examine all witnesses as to:
density of proposed
~torage of spent fuel; past experience at other reactor sites, and results of testing, respecting rack degradation and storage of spent fuel; licensee's proposed surveillance techniques; and leaking of fuel storage cells, resultant effects, consequences and proposed remedial measures.
Estimated time:
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
- 2.
Lower Alloways Creek Township *contention 1:
The State expects to cross-examine all witnesses as to:
cost and feasibility of ISFI construction; P.S.E.&G. 's efforts to construct ISFis; and feasibility of license amendment with conditions should availability of AFR-ISFI be demonstrated in the future.
Estimated time:
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
The State reserves the right to cross-examine witnesses who testify on the "Three Mile Island" issues raised by the Board in its Order dated April 18, 1979.
The State also reserves the right to engage in any cross-examination which may be necessary to address relev~nt and probative points raised at the hearing, without regard to the above outline.
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DATED:
April 25, 1979 2 -
JOHN J. DEGNAN Attorney General of New Jersey Attorney for State of New Jersey
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Richard M *. Hluchan Deputy Attorney General
CERTIFICATE OF SERVICE I hereby certify that copies of State of New Jersey's Outline of Cross-Examination have been served upon each of the addressees on the attached list by deposit in the U.S. mail this 25th day of A~ril, 1979.
Richard M. Hluchan Deputy Attorney General
Gary L. Milhollin, Esquire Chairman, Atomic Safety and Licensing Board 1815 Jefferson Street Madison, Wisconsin 53711 Mr. Lester Kornblith, Jr.
Member, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Dr. James C. Lamb, III Member, Atomic Safety and Licensing Board Panel 313 Woodhaven.Road Chapel Hill, No. Carolina 25714 Chairman, Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Comm.
Washington,.D.C.
20555 Richard Fryling, Jr., Esquire Assistant General Solicitor Public Service Electric and Gas Company 80 Park Place Newark, New Jersey 07101 Eleanor G. Coleman Alfred c. Coleman 35 "K" Drive Pennsville, New Jersey 08070 Janice E. Moore*
Counsel for NRC Staff U.S. Nuclear Regulatory Comm.
Office of the Executive Legal Director Washington, D.C.
20555 Office of the Secretary Docketing and Service Section U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Troy B. Conner, Jr., Esquire Suite 1050 1747 Pennsylvania Ave., N.W.
Washington~ D.C.
20006 Barry Smith, Esquire Off ice of *the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 June D. MacArtor, Esquire Deputy Attorney General Tatnall Bldg.
P. O. Box 1401 Dover, Delaware 19901 Carl Valore, Esquire 535 Tilton Road Northfield, New Jersey Dale Bridenbaugh Gregory Minor 08225 M.H.B. Technical Associates 366 California Avenue, Suite 6 Palo Alto, California 95306 Keith A. Onsdorff, Esquire Asst. Deputy Public Advocate Dept. of the Public Advocate 520 East State Street Trenton, New Jersey 08625