ML19269D467
| ML19269D467 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 05/01/1979 |
| From: | Sohinki S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7906040114 | |
| Download: ML19269D467 (10) | |
Text
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SRC PUBL!C DCCUMENTID0h l979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l.4 L
"V BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Q'
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In the Matter of HOUSTON LIGHTING & POWER COMPANY
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Docket No. 50-466 S' *
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(Allens Creek Nuclear Generating
)
Station, Unit 1)
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NRC STAFF'S RESPONSt T0 " TEX PIRG'S REQUEST FOR PRODUCTION OF DOCUMENTS PER 2.744, 2.790 The NRC Staff makes the following responses to "TEXPIRG'S Request For Production of Documents Per 2.744, 2.790" filed on April 2,1979. As indicated below, many of the documents requested are widely available to all members of the public and not under the exclusive control of the Staff, and therefore need not be produced.
See, e.g., Keough v. Pearson, 35 F.R.D. 20 (D.D.C. 1964). However, the Staff will make these documents available for inspection and copying in the NRC Public Document Room in Washington, D.C., or at the. office of the counsel for the NRC Staff in Bethesda, Maryland.
In addition, the Staff's Regulatory Guides and -
Reference 29 to Section S.5 of the Final Supplement to the FES in this proceeding are available for inspection and copying at a mutually agreeable time at the Staff's Region IV Office of Inspection and Enforcement, 611 Ryan Plaza Drive, Suite 1000, Arlington, Texas.
2258 285 7 oooor ei,7 3
1.
Section S.2 Peferences Ref. 1.
Available in the Local Public Document Room.
(Abbreviated in following responses as LPDR.)
Ref. 3.
Enclosed.
2.
Section S.4 References Ref. 9.
This is a publicly available copyrighted journal available in most technical libraries.
Ref.14. This is a monograph available to the public by writing to the Printing and Publishing Office, National Academy of Sciences, 2101 Constitution Avenue, Washir.gton, D. C.
20418.
(Also, Library of Congress Catalog Card No. 68-62704).
3.
Section S.5 Peferences Ref. 3.
Available as NUREG/CF-0514 from the National Technical Information Service, U.S. Department of Commerce, 5285 Port Royal Road, Springfield, Virginia 22161.
(Abbreviated as NTIS in subsequent responses).
Ref. 4.
Available from the Ralph M. Parsons Laboratory for Water Resources and Hydrodynamics, Department of Civil Engineering, Massachusetts Institute of Technology, Cambrige, Mass. 02139.
Ref. 7.
This document is available to the public.
(Library of Congress Catalog Card Number 77-2120).
2258 286
~
~ -~
_. - Ref. 8.
This is a publicly available copyrighted journal available in most technical libraries (Applied and Environmental Microbiology, Volume 34, No. 6, December,1977).
Ref. 10. This is a publicly available copyrighted journal available in most technical libraries.
Ref. 11. Available from NTIS.
Ref. 12.
See response to Ref. 7 above.
This is a publicly available journal avaikable in most Ref. 19.
technical libraries.
Ref. 29. Available from NTIS.
4.
Section S.6 References Ref. 1.
Available in the LPDR.
5.
Section S.8 References Ref. 6.
Available from the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C.
20402 (Abbreviated as GP0).
Ref. 8.
Available from NTIS.
Ref. 9.
Available from NTIS.
Ref. 10. Available from NTIS.
2258 287 Ref. 11. Available from NTIS.
Ref. 13. Available from NTIS.
4
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Ref. 14. This is a publicly available copyrighted journal available in most technical libraries.
Ref. 16. This is a publicly available copyrighted journal. available in most technical libraries.
Ref. 18. Available from the U.S. General Accounting Office, Washington, D. C.
20548.
Ref. 19. Available from NTIS.
Ref. 21.
Enclosed.
6.
Section S.9 References Ref. 13. Available from GP0.
Re f. 19. Available from NTIS.
Ref. 27. Available from the American Society of Mechanical Engineers; write to ASME Order Department, United Engineering Center, 345 E 47th Street, New York, NY 10017.
Ref. 28. See response to Ref. 27.
Ref. 29. Available from MIT Energy Laboratory, Massachusetts Institute of Technology, Cambrige, Mass. 02139.
Ref. 45. Available from Illinois Institute of Technology, Technology Center, Chicago, Ill.
60616 (Library of Congress Catalog Card Number 39-5827).
Ref. 55. Enclosed.
Ref. 56. Available from NTIS.
7.
Section S.10 References Ref. 1.
Objection: Cost of decommissioning is not an issite in controversy.
8.
Copies of all Regulatory Guides that relate to any oi' the Parties Contentions such as Regulatory Guide 4.2.
Response
While this request lacks specificity, some Regulatory Guides (e.g., 4.2) are available in the LPDR. Also see response to request 9, below.
9.
A copy of a listing of all USNRC Regulatory Guides.
Response
Copy enclosed.
This list provides instructions on how to obtain copies of individual Guides.
- 10. The Reed Report about problems with General Electric reactors.
Response
The Staff does not have this report.
11.
Documents relied on to claim that the S. Texas site is not obviously superior to the Allens Creek site for a third unit.
Response.
a.
HL&P Environmental Report, Operating License Stage, South Texas Project Units 1 and 2.
Available at the LPDR, Matagorda County Court House, Bay City, Texas; or from the Applicant, Houston Lighting & Power Co.
2258 289
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b.
U.S. Nuclear Regulatory Commission Final Environmental Statement, South Texas Project Units 1 and 2, NUREG-75/019. Available at the LPDR (see above) or from NTIS.
12.
Documents relied on to show that there is not enough water, now or later, available for cooling a third unit as the S. Texas site.
Response
It is not the Staff's position that there is not enough water, now or later, available for cooling a third Unit at the S. Texas site.
13.
Documents relied on to claim that it would take 3-1/2 years to prepare a new ER and NRC Supp. to F2S for the construction of a third unit at S. Texas site.
Response
a.
Reference 53 of Section S.9 of the FES Supplement. Available at the LPDR.
b.
Table 2.10 of Reference 56 of Section S.9 of the FES Supplement.
Available at NTIS.
14.
Documents relied on to show that the Allens Creek Lake will be a viable productive fishery.
2258 290
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Response
Staff conclusions are site-specific, represent professional judgment of an aquatic biologist, and oid not " rely" on published documentation.
See, however, Staff response to request for Section S.5 Ref. 3 documentation.
15.
Documents used to prove that 0.2 ppm chlorine will not harm fish.
Response
It is not the Staff's position that 0.2 ppn chlorine will not harm fish.
The effects of chlorine on aquatic biota are discussed in Section 5, pp. S.5-14 to S.5-19.
16.
Documents that show how Applicant could later expand the Allens Creek to handle 4 units and still retain any recreational benefits at the lake.
Respor.se Objection: This is not an issue in controversy.
17.
Documents that show the Applicant has seriously considered using solid waste to generate electricity.
Re.sponse The Staff has no such documents 2
58 291
- 18. Documents that show effects of a large airplane crashing into the containment of Allens Creek.
Response
The Staff has no such documents.
19.
Documents showing that it would be unreasonable to bury the Allens Creek plant at the Allens Creek site.
Response
Objection: This is not an issue in controversy.
20.
Documents used to indicate that conservation measures funded with the funds planned for Allens Creek construction and operation would not eliminate the need for construction of a plant the size of Allens Creek.
Response
The Staff has no such documents.
Respectfully submitte s-L__
Stephen M. Sohinki Counsel for NRC Staff Dated at Bethesda, Maryland, 2258 292 this 1st day of May, 1979.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of'
)
)
HOUSTON LIGHTING & POWER COMPANY
)
Docket No. 50-466 1
(Allens Creek Nuclear Generating Station, Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S RESPONSE T0 ' TEX PIRG'S REQUEST FOR PRODUCTION OF DOCUMENTS PER 2.744, 2.790'" in the above-captioned proceeding have~been served on the following by deposit in the United States mail, first class, or', as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal mail system, this 1st day of May,1979:
Sheldon J. Wolfe, Esq., Chairman
- Jack Newman, Esq.
' Atomic Safety and Licensing Lowenstein, Reis, Newnan & Axelrad Board Panel 1025 Connecticut Avenue, N.'l.
U.S. Nuclear Reaulatory Conmission Washington, D. C.
20037 Washington, D. C.
20555 Richard Lowerre, Esq.
Dr. E. Leonard Cheatum Asst. Attorney General for the Route 3, Box 350A State of Texas Watkinsville, Georgia 30677 P. O. Box 12548 Capitol Station Mr. Gustave A. Linenberger Austin, Texas 78711 Atomic Safety and Licensing Board Panel Hon. Jerry Sliva, Mayor U.S. Nuclear Regulatory Commission City of Wallis, Texas 77485 Washington, D. C.
20555 Hon. John R. flikeska R. Gordon Gooch, Esq.
Austin County Judge Baker & Botts P. O. Box 310 1701 Pennsylvania Avenue, N.W.
Bellville, Texas 77418 Washington, D. C.
20006 Atonic ' Safety and Licensing J. Grecory Cooeland, Esq.
Appeal Board
- Baker & Botts U.S. Nuclear Regulatory Commission One Shell Plaza Washington, D. C.
20555 Houston, Texas 77002 2258 293
Atomic Safety and Licensing Carro Hinderstein Board Panel
- 8739 Link Terrace U.S. Nuclear Regulatory Comission Houston, Texas 77025 Washington, DC 20555 James Scott, Jr., Esq.
Docketing and Service Section Texas Public Interest Office of the Secretary Research Group, Inc.
U.S. Nuclear Regulatory Comission Box 237 UC Washington, DC 20555 University of Houston Houston, Texas 77004 Mr. John F. Doherty 4438 1/2 Leeland Avenue Brenda A. McCorkle Houston, Texas 77023 6140 Darnell Houston, Texas 77074
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f Kepilenfl.Schinki Counsel for NRC Staff 2258 294
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