ML19210B495
| ML19210B495 | |
| Person / Time | |
|---|---|
| Site: | Crane, Saint Lucie  |
| Issue date: | 09/25/1973 |
| From: | Sager L, Trowbridge G, Wilchins H CITIZENS FOR SAFE ENVIRONMENT, SHAW, PITTMAN, POTTS & TROWBRIDGE, US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML19210B492 | List: |
| References | |
| NUDOCS 7911080724 | |
| Download: ML19210B495 (7) | |
Text
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UNITED STATES OF A!!FRICA ATOMIC ENERGY COMt11SSION BEFORE Ti!E ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITANEDISONCOMPANY,et_al.
Docket No. 50-289 (Three Mile Island Ituclear Station, )
Unit 1)
,)
STIPULATION RELATING TO THE INTRODUCTION OF DOCUMENTS INTO EVIDENCE IT IS HEREBY STIPULATED by and among the attorneys for Metropolitan Edison Company, et al. (" Applicant"), Citizens for a Safe Enviroment and the Environmental Coalition on Nuclear Power
("Intervenors"), and the Regulatory. Staff of the Atomic Energy Commission, subject to the approval of the Atomic Safety and Licensing Board (" Board") duly appointed in this proceeding, that:
1.
The record in this proceeding shall include the following documents:
(a)
Amended and Subst.ded Application for Licenses, filed by Applicant on March 2,1970, including all exhibits thereto; (b)
Applicant's Final Safety Analysis Report, as amended by Amendment Nos.1-41; (c)
Applicant's Revised. Environmental ' Report as supplemented,
' including Appendices; (d)
Applicant's Responses to Federal and State Agency Comments on AEC Draft Detailed Statement set forth in Appendix D to the AEC Final Environmental Statement.'
7 9110 8 0 72p' 1584 194
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(e)
Safety Evaluation by the Directorate of Licensing, U. S. Atomic Energy Comission, dated July 11, 1973; (f)
Final Environmental Statement issued byf the Directorate of Licensing, U. S. Atomic Energy Comission in December 1972, including Appendices A and B; and (g) Technical Report on Densification of Light Water Reactor Fuels, by the Regulatory Staff, U. S. Atomic Energy Comission dated November 14, 1972.
2.
Each of the documents identified in paragraph 1 as items (a) through (g) shaIl be admitted into evidence at the comencement of the evidentiary hearing without being sponsored by any witness and e'
mut further formality.
Applicant will be the proponent of items (a) through (d) and the Regulatory Staff will be the proponent of items (e)through'(g).
3.
Each of the foregoing documents was prepared by persons qualified by education and experience to express the opinions and conclusions set forth therein.
If called as witnesses and sworn,
'su,ch persons would testify that all of the facts set forth in such documents are as they found them, and that all of the opinions and conclusions set forth therein are their opinions and conclusions based upon such facts.
4.
Within the scope of the specific issues defined and set for hearing by the Board (a) any party other than the proponent of any of the foregoing documents shall b'e entitled to (i) require the proponent to produce witnesses to be, cross-examined concerning the 1584 195
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facts, opinions, and conclusions set forth in any such document, and
.(b) the proponent of any of the foregoing documents shall be entitled to present evidence to (i) support the facts, opinio,ns, and conclusions set forth in any such document, and (ii) rebut any evidence presented' to controvert the facts, opinion, and conclusions set forth in any such document.
The record in this proceeding shall f[2rther include the 5.
following documents:
(a)
Letter from the Advisory Committee on Reactor Safeguards to Honorable Dixy Lee Ray, dated August 14,19)3,
Subject:
RL?U T ON THREE MILE ISLAND NUCLEAR STATION,' UNIT 1; an/.
(b) Appendix C to the Final Environmental Statement issued by the D_irectorate of Licensing, U. S. Atomic Energy Commission in December,1972.
6.
The documents listed in paragraph 5 are authentic and shall be admitted in evidence at the comencement of the evidentiary hearing without being sponsored by any witness and without further formality.for the limited purpose of showing compliancewith Section 182(b) of the Atomic Energy Act of 1954' and Section 102(2)(C) of the National Environmental Policy Act of 1969, but 'not for the truth or accuracy of facts, opinions, or conclusions et forth in the documents so admitted.
However, these documents may be used for cross examinaticn of the witnesses of any party within the scope of the specific issues defined and set for hearing by the Board.
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.7.
Following approval of this Stipulation by the Board, it shall be made a part of the record in this proceeding and shall govern the conduct of the proceeding unless modified by the Board upcn its
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own mction or for good cause shown.
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ra Date Attorney for the Regulatory Staff J "
G 1584 197
UNITED STATES OF AMERICA ATOMIC ENERGY C0 ' MISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITAN EDISON COMPANY, ET_ AL_.
Docket No. 50-289 (Three Mile Island Nuclear Station,.
)
Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " MOTION FOR APPROVAL BY THE ATOMIC SAFETY AND LICENSING BOARD OF A STIPULATION RELATING TO THE INTRODUCTION OF DOCUMENTS INTO EVIDENCE," in the above-captioned matter, have been served on the following by deposit in the United States mail, first class or air mail, this 28th day of September,1973:
Charles H. Haskins, Esq.
Lawrence Sager, Esq.
Atomic Safety and Licensing Board 45 High Street Windy Hill Farm Pottstown, Pennsylvania 19464 Bluemont, Virginia 22012 Frank R. Clokey, Esq.
Max D. Paglin, Esq.
Special Assistant Attorney Atomic Safety and Licensing Board General U. S. Atomic Energy Commission Rocm 219 Washington, D. C. 20545 Towne House Apartments Harrisburg, Pennsylvania 17105 Mr. M. Stanley Livingston 1005 Calle Largo W. W. Anderson, Esq.
Sante Fe, New Mexico 87501 Theodore Adler, Esq.
Office of the Attorney Dr. John R. Lyman General Department of Environmental Department of Justice Sciences and Engineern:g 2nd Floor, Old Museum Building University of North Carolina Harrisburg, Pennsylvania 17120 Chapel Hill, North, Carolina 27514 Herbert C. Goldstein, Esq.
Mr. Ralph S. Decker 133 State Street Route 1, Box 1900 Harrisburg, Pennsylvania Cambridge, Maryland 21613 Miss Mary V. Southard
. George F. Trowbridge, Esq.
Chairman, Citizens for a Safe Shaw, Pittman, Potts & Trowbrioge Environment Barr Building, 910 - 17th Street, N. W.
P. O. Box 405 Washington, D. C.
20006 Harrisburg, Pennsylvania 17108 1584 198
- Mr. Douglas Baker Atomic Safety and Licensing Environmental Coalition on Appeal Board Nuclear Power U. S. Atomic Energy Commission 1919 Sandy 11111 Road Washington, D.C.
20545 Norristown, Pennsylvania 19401 Mr. Frank W. Karas Atomic Safety and Licensing Chief, Public Proceedings Staff Board Panel Office of the Secretary of the U. S. Atomic Energy Commission Commission Washington, D.C. 20545 U. S. Atomic Energy Commission Washington, D. C.
20545 Y" A I
Douglas K'. Olson Counsel for AEC Regulatory Staff h
- 6
<g 1584 199
.s M-PiTun Post Times, Sunday, Septernber 23,11 1
NOTICI 0F OPPORTUNITY FOR PUBilC PARTICIPAT10N IN AIC PU3 tlc HEARING ON ST.LUClE PLANT, UNIT 2
<</
The Atomic Energy Commission willhold a public hearing to
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be conducted by an Atomic Safety and Licensing Board to deter-i mine whether a construction permit should be issued to the Flori-da Power & Light Company, authorizing construction of the pro-aosed St. Lucie Plant, Unit 2 in St. Lt.cie County, Florida. The learing will bo held in the vicinitysof ti.e proposed facility at a time and place to be set later. Innes to be considered at the hearing include both radiological safety and environmental. These issues are specified in a FEDERAL REGISTER notice published i
I l
on September 21,1973.
Members of the public who wish to participate in the hearing l t
l may do so in one of two ways:
- 1. They may make a limited appearance. A person making a j
limited appearance does not become a party to the proceeding but i
may state his position and raise questions which he would like to
-have answered to the extent that the questions are within the i
scope of the hearing and are permitted by the Licensing Board at t
the time of the public hearing. Persons desiring to make a limited appearance are requested to inform the Secretary of the Commis-sion, U.S. Atomic Energy Commission, Washington, D.C. 20545, Attention: Chief, Public Proceedings Staff, by Oct.ob.er 23,1973.
- 2. They may petition for leave to intervene. A person permitt-ed to intervene becomes a party and has a right to participate in -
.the conduct of the hearing. For example, he may present evidence i
and examine and cross-examine witnesses.
Any person whose interest may be affe'cted by the proceeding who wishes to participate as a party must file a petition for leave to intervene under oath or affirmation setting forth the interest of the petitioner in the proceeding, how that interest may be affected by the results of the proceeding, and the petitioner's contentions with respect to the proposed licensing action. Such petition must-be filed in accordance v,ith the above-referenced FEDERAL RE-GISTER Notice and must be filed with the Secretary of the Commission, U.S. Atomic Energy Commission, Washington, D.C.
20545, Attention: Chief, Public Proceedings Staff, by October 23, 1973. A copy of any petition or request for limited appearance should also be sent to the Chief Hearing Counsel, Office of the.
General Counsel, U.S. Atomic Energy Commission, Washington, !
i D.C. 20545 and to Mr. Jack R. Newman, Newman, Reis & Axel-rad,1100 Connecticutf Avenue, N.W., Washington, D.C. 20036, attorney for the applicant.
A petition for leave to intervene rcust be accompanied by a suo aorting affidavit which identifies the specific aspect or aspects 1 of't le proceeding as to which intervention is desired and specifies with particularity the facts on which the petitioner relies as to i both his interest and his contentions with regard to each aspect on which intervention is requested.
All petitions will be acted upon by the Licensing. Board. Those petitions stating contentions relating only to matters outside the Commission's jurisdiction will be denied.
A copy of the FEDERAL REGISTER Notice is on file for 1584 g public inspection at the Indian River Junior College Library,3209 Virginia Avenue, Ft. Pierce, Florida 33450, and the Commission has arranged for other documents and correspondence relating to h l' ensine of this facility to be kept at the same location.