ML19225A494
| ML19225A494 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 06/21/1979 |
| From: | Biddle C, Copeland J, Newman J BAKER & BOTTS, LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | |
| References | |
| NUDOCS 7907190419 | |
| Download: ML19225A494 (5) | |
Text
.
q S?,
=
4 9
ee n>
g NRO PUBLIO D00UMD.'I ROOM g.
Jutl211973 > q UNITED STAiES OF AMERICA NUCLEAR REGULATORY COMMISSION 8
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S
S HOUSTON LIGHTING & POWER COMPANY S
Docket No. 50-466 S
(Allens Creek Nuclear Generating S
Station, Unit 1)
S APPLICANT'S RESPONSE TO "MORE CONTENTIONS SUBMITTED BY F.
H.
POTTHOFF III" Applicar.t files this response to a uccument re-ceived on June 8, 1979, frem the Office of the Secretary and styled "More Contentions Submitted by F.
H. Potthoff III."
This document seeks admission of two additional contentions dealing respectively with conservation (V.) and a biomass production alternative (VI.).
Cc,atention V.
is quite clearly based on a document post dating the Appeal Board's decision affirming the Partial Initial Decision in this matter and, as such, cov'd have been advanced in response to the Board's Order of Sep cer 11, 1973.
It is thus outside the permissible scope of additional contentions as set forth in the Board's Order of April 11, 1979.
Moreover, the contention alleges nothing with respect to the applicability on Applicant's system of a conservation f-f O g 7 9 0719 0 %
W
/
program developed for a Pacific Northwest load center.
Finally, Peticioner would have the Board believe that con-servation was dismissed in one sentence in the FES.
This is incorrect and misleading.
Conservation of all types is dis-cussed 6xtensively in the SFES (pp. S.8-12 to S.8-15) and Petitioner fails to identify in what respect, if any, this analysis is incorrect.
The contention should be dismissed.
Contention VI. relates to a biomass generating alternative.
.It is based on a document for which no date or specific citation is supplied.
Beyond the very vague reference to what appears to be a general study of the subject, the contention boils down to the broadside assertion that "I contend building and operating a marine biomass farm, or other biomass production systems, would be environmentally preferable to ACNGS, and ask the Board to deny the permit under the NEPA."
There is absolutely no description of a
" biomass farm" nor any detail with respect to the meaning cf "other biomass production systems.*
Further, there is no allegation that such biomass generating alternative could be available within the time frame needed for ACNGS.
The con-tention is thus impermissibly vague.
Moreover, it fails to controvert the detailed Staff review of biomass set out at page S.9-7 of the SFES.
Accordingly, the contention should be denied.
Y[h
_2_
185
Respectfully submitted, l&
2 reg 6ry/jC giplana' OF COUNSEL:
o.
homas @i die, Jr.
BAKER & BOTTS rles G. T rash, Jr.
3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R.
Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W.
1025 Conneccicut Ave., N.W.
Washington, D.
C.
20036 Washington, D.
C.
20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY 0f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S (Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing A;olicant's Response to "More Contentions Submitted by F. H. Potthoff III" in the above-captioned proceeding were served on the following by deposit in the United Sta es mqil, postage prepaid, or by hand-delivery this /,f',1 day of /JVfC 1979. ~ ,Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq. Atomic Safety and Licensing Assistant Attorney General Board Panel or the State of Texas U.S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D. C. 20535 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. Charles J. Dusek W,ttkinsville, Georgia 30677 Mayor, City of Wallis P. O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 ' Atomic safety and Licensing Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission County Judge, Austin County Washington, D. C. 20555 P. O. Box 99 Bellville, Texas 77418 Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of the Appeal Board Commission U.S. Nuclear Regulatory U.S. Nuclear: Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 R. Gordon Gooch, Esq. Atomic Safety and Licensing Baker & Betts Board Panel 1701 Pennsylvania Avenue, N. W. U.S. Nuclear Regulatory Washington, D. C. 20006 Commission Washington, D. C. 20555 420 1'?
Steve Schinki, Esq. Staff Counsel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 John F. Doherty 4438 1/2 Leeland Houston, Texas 77023 Madeline Bass Framson 4822 Waynesboro Drive Houston, Texas 77035 Robert S. Framson 4822 Waynesboro Drive Houston, Texas 77035 Carro Hinderstein 8739 Link Terrace Houston, Texas 77025 D. Marrack 420 Mulberry Lane Bellaire, Texas 77401 Brenda McCorkle 6140 Darnell Houston, Texas 77074 F. H. Potthoff, III 1814 Pine Village Houston, Texas 77080 Wayne E. Rentfro P. O. Box 1335 Rosenberg, Texas 77471 James M. Scott, Jr. 8302 Albacore Houston, Texas 77074
- 7. Grego C
lanc/ l 420 188 }}