ML19260A637
| ML19260A637 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/08/1979 |
| From: | Baxter T, Larson L SACRAMENTO MUNICIPAL UTILITY DISTRICT, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19260A632 | List: |
| References | |
| NUDOCS 7912030034 | |
| Download: ML19260A637 (4) | |
Text
November 8, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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SACRAMENTO MUNICIPAL UTILITY DISTRICT
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Dockat No. 50-312
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(Rancho Seco Nuclear Generating
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Station)
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LICENSEE'S RESPONSE TO CALIFORNIA ENERGY COMMISSION'S RESTATEMENT OF ISSUES AND REQUEST FOR CLARIFICATION California Energy Commission (" CEC") has filed a document dated October 24, 1979 and entitled " Restatement of Issues of Con-cern.and Request for Clarification of Ruling," in which it (1) offers revised versions of CEC issues No. 1-1 and No. 1-12, and (2) requests the Board to clarify its position on the extent to which the loss of off-site power may be considered to be within the scope of the hearing.
The Board's order of October 9, 1979 gave CEC the opportunity to reformulate certain of its issues into succinct contentions.
CEC has chosen to reframe two issues (one of which was rejected earlier by the Board) as questions.
In light of the Board's treatment of other CEC issues in its October 9 order, we have no objection to the Board's ad-mitting these two questions as additional CEC issues.
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. Addressing CEC's second request, Licensee submits that clarification is not necessary for the Board to rule on any contention, and is not warranted at this time.
The precise relationship (if any) of the loss of off-site power to feed-water transients is a matter which can properly be addressed, if necessary, in rulings on evidence.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Thomas n..
Baxter Lex K. Larson Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 331-4100 1461 318
Y UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND 1.ICENSING BOARD In the Matter of
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SACRAMENTO MUNICIPAL UTILITY DISTRICT
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Docket No. 50-312
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(Rancho Seco Nuclear Generating
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Station)
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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "Licen-see's Answer to Motion of the California Energy Commission for Reconsideration or, in the Alternative, for Certification to the Commission" and " Licensee's Response to California Energy Commission's Restatement of Issues and Request for Clarifica-tion" were served this 8th day of November, 1979, by deposit in the United States mail, first class, postage prepaid, upon the parties identified on the attached Service List.
l Thomas A.
Baxter '
1461 319
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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SACRAMENTO MUNICIPAL UTILITY DISTRICT
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Docket No. 50-312
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(Rancho Seco Nuclear Generation
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Station)
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SERVICE LIST Michael L. Glaser, Esquire Gary Hursh, Esquire 1150 17th Street, N.W.
Suite 700 Washington, D.C.
20036 520 Capitol Mall Sacramento, ralifornia 95814 Dr. Richard F. Cole Atanic Safety and Licensing Board Panel Mr. Richard D. Castro U.S. Nuclear Regulatory Ccrmission 2231 K Street Washington, D.C.
20555 Sacramento, ralifornia 95816 Mr. Frederick J. Shon James S. Reed, Esquire Atanic Safety and Licensing Board Panel Michael H. Pany, Esquire U.S. Nuclear Reculatory Ccmnission Reed, Samuel & Rany Washington, D.C.
20555 717 K Street, Suite 405 Sacramento, ralifornia 95814 David S. Kaplan, Esquire Secretary and General Counsel Christopher Ellison, Esquire Sacranento Municipal Utility District Dian Grueneich, Esquire P.O. Box 15830 ralifornia Energy Ccmnission Sacramento, California 95813 1111 Howe Avenue Sacramento, ralifornia 95825 Stephen H. Icwis, Esquire Office of the Executive Iegal Director Herbert H. Brown, Esquire U.S. Nuclear Regulatory Ccmnission Lawrence Coe Lanpher, Esquire Washington, D.C.
20555 Hill, Christopher and Phillips, P.C.
1900 M Street, N.W.
Tinothy V. A. Dillon, Esquire Washington, D.C.
20036 Suite 380 1850 K Street, N.W.
Docketing and Service Section Washington, D.C.
20006 Office of the Secretary U.S. Nuclear Regulatory Ccmnission Washington, D.C.
20555 1461 320