ML19269D963
| ML19269D963 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities  |
| Issue date: | 05/04/1979 |
| From: | Goddard R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML19269D964 | List: |
| References | |
| NUDOCS 7906210337 | |
| Download: ML19269D963 (3) | |
Text
.
~
.,, y i('
' NRC PU'".7 T'. mi.iT 20011 M
N 4././
UNITED STATES OF AMERICA 5/4/79 k
gfd q NilCLEAR REGULATORY COMMISSION f,,n ~/
,A S
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
Docket Nos.
CCMMONWEALTH EDISON COMPANY 2
(Dresden Station, Units 2 and 3, and
)
Quad Cities Station, Units 1 and 2)
)
NRC STAFF f10 TION FOR RECONSIDERATION 0F APRIL 19, 1979 MEMORANDUM AND ORDER FOLLOWING SPECIAL PREHEARING CONFERENCE Pursuant to 10 CFR 52.751a, the Nuclear Regulatory Commission Staff hereby files its objections to the " Memorandum and Order Following Special Prehearing Conference" entered by the Licensing Board on April 19, 1979. The Staff objects to the admission of Contention 6 as ori-ginally drafted.
While NRC Staff no longer opposes the admission of a security contention in the captioned proceeding, as stated by letter of April 6, 1979 (en-closed), the Staff maintains its position opposing the specified threats to irradfated fuel in transit set forth in Contention 6 as originally drafted, as exceeding the physical protection requirements of existing NRC Regulations.
10 CFR 673.55; 10 CFR, Part 71.
2264 255 7906210.33 7
.='.
l Accordingly, the Staff moves the Licensing Board to reconsider admission of Contention 6 as drafted, and to admit an appropriately worded conten-tion for litigation, based upon NRDC's Contention 6 in the Oconee-McGuire_
proceeding,N Docket No. 70-2623, and State of Illinois Contention 11 in the captioned proceeding.
Respectfully submit d,
a..
Richard J.
dda d l
Counsel for NRC Staff i
1 i
Dated at'Bethesda, Maryland this 4th day of May, 1979.
2264 256 1/ Contention 6: Shipmen' af spent fuel from Oconee to McGuire will be vulnerable to sabotage or other malevolent acts and this represents a serious risk.
- +
s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETf AND LICENSING BOARD In the Matter of
)
Docket Nos.
37 COMMONWEALTH EDIS0N COMPANY (Dresden Station, Units 2 and 3, and
)
Quad Cities Station, Units 1 and 2)
)
i CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF MOTION FOR RECONSIDERATION OF APRIL 19,1979 MEME0RANDUM AND ORDER FOLLOWING SPECIAL PREHEARING CONFERENCE" 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, through deposit in the Nuclear Regulatory Commission's internal mail system, this 4th day of May, 1979.
l
. Gary L. Milhollin, Esq.
1815 Jefferson Street Susan N. Sekuler, Esq.
Madison, Wisconsin 53711 Assistant Attorney General Environmental Control Division i
Mrs. Elizabeth B. Johnson 188 West Randolph Street, Suite 2315 Union Carbide Corporation Chicago, Illinois 60601 Nuclear Division P.O. Box X
- Atomic Safety and Licensing Board Panel Oak Ridge, Tennessee 37830 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Quentin J. Stober Fisheries Research Institute
- Atomic Safety and Licensing Appeal University of Washington Board Panel Seattle, Washington 98195 U.S. Nuclear Regulatory Commission Washington, D. C. 20555
- Philip P. Steptoe, Esq.
- Docketing and Service Section Isham, Lincoln and Beale U.S. Nuclear Regulatory Commission One First National Plaza Washington, D. C. 20555 Chicago, Illinois 60603 Anthony Z. Roisman, Esq.
2264 257 Natural Resources Defense Council 917 15th Street, N.W.'
Washington, D. C. 20005 y _ W,ddard
_ a _9 3 -
Richard o
Counsel f NRC Staff
___