ML19312C793

Forwards Schedule of Documentary Proof as Indication of Type of Documentary Evidence to Be Adduced Per 670830 Order. Reaffirms Statement from 670905 Motion Re Filing of Competing Application for OLs by 670912

ML19312C793
Person / Time
Site:	Oconee, Indian Point, Turkey Point, Ginna
Issue date:	09/08/1967
From:	Reeder S PIEDMONT CITIES POWER SUPPLY, INC.
To:	Engelhardt T, Grigg W, Horn C DUKE POWER CO., US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 7912191013
Download: ML19312C793 (4)

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11- Sr. MICHAELS, MAREAND SEP111967 >

-5 c:::ca of fan se: ret:iy AacA coon: 301 6 rme rise:c:a: September 8, 1967 #c,yk 743 5031 sma Q j. .

Mr.' Thomas F. Engelhart NP ,/ C/C,,', .

. Mr. Carl Horn  !

Mr. William H. Grigg Mr. Roy B. Snapp

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Gentlemen: 8  ;

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j Re: AEC Docket Nos. 26#, 5 270, 287 t In compliance with the order of Chairman Jensch, made at the close of the hear,ing session on August 30, 1967, that we (1)* opposing counsel today as to the~ general type of evidence which we propose to adduce and (2) serve the direct written testimony of our proposed '

witness on opposing counsel today (Tr. 488-491; 504-505), this letter is written and served by hand on opposing counsel in Washington. -

Attached hereto is a Schedule of Documentary Proof which will indicate the type of documentary evidence which we propose to adduce.

3' If any additions are made to the itemized 1-ist of documentary proof be- .

tween now and the time of the hearing on September 12th, they will be @

the same type, .and opposing counsel will be promptly notified thereof, so that there will be no. surprises.

There is no direct written testimpny to serve for the reason. \

that we were advised yesterday afternoon,, September 7th, that our pro-posed witness could not testify on our behalf, for the reason that-his firm has discovered a conflict of interest which they did rot know I about when employed, which requires them to withdraw from the employ-3 ment. For this reason, we will.have no live witness to present.

In addition to the attached list of documentary proof, it is appropriate to reaffirm here the following statembnt from our " Motion For an O'rder'to Certify Atomic Safety and Licensing Board's Denial of Right of Pie'dmont Cities Po,wer Supply, Inc. to' Participate by Inter-vention'in this Proceeding," filed September 5, 1967, and served on all counsel:

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"2. On or before the .L2th day of September 1967,  ;'

Piedmont Cities Power Supply, Inc. will file j with the Commission a competing application

. 1 for a license for Oconee Nuclear Station Units ,,

1, 2 and 3 appropriate to'its interests and ,j i  ; .,

• n tifY 7912192g/} g i  ;

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' - 2-capabilities and a true copy of said Appli-cation 'will be offered in evidence herein."

Very truly y urs,

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i Sp ncer W. Reeder Spencer Bldg.

St. Michaels, Maryland I

cc: Messrs. Samuel Jensch l Jack R. Harris J. O.. Tally, Jr. -

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SCHEDULE OF DOCUMENTARY PROOP

1. Robert Emmett Ginna Unit 1 -

Docket Nos. 50-244 -

Rochester Gas & Electric Corporation Amendment to Provisional Construction Permit No. CPPR19

• Issued April 10, 1967 (2'pages) ..

Provisional Construction Permit No. CPPR19 (1 page)

In the Matter of Rochester Gas & Electric Corporation ,.

(Brookwood Nuclear Station Unit No.1) t Initial Decision (Samuel W. Jensch, Chairman) (10 pages) i Issued April 14, 1966  !

2. Indian Point 2 i  !

Docket Nos. 50-247 Consolidated Edison of New York -

Indian Point Station Unit 2 i Construction Permit No. CPPR21 (4 pages) i Issued October 14,~ 1966 In the Matter of Consolidated Edison Company of New York I Indian Point Station Unit No. 2 Initial Decision (Samuel W.

Jensch, Chairman)  ;

Issued October 3, 1966 (19 pages) >

3. Turkey Point 3 and 4 I

. 1 Docket Nos. 50-250 i Florida Power and Light ,

Construction Permit No. CPPR27.(2 pages) l Issued April 27, 1967 j

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Docket Nos. 50-251  !

Florida Power and Light F Construction ' Permit No. CPPR28 (2 pages) [

Iss'ued April 27, 1967

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In'the Matter of Florida Power and Light Company ,-

-(Turkey Point Nuclear Generating Units Nos. 3 and 4). '

te Docket Nos. 50-250 (Unit 3) ,

I 50-251 (Unit 4)  :  !

Initial Decision (Samuel W. Jensch, Chairman) (27 pages) [

'4. " Facilities License Anolication Record" (Mimeo) (13 pag.es) l' "Part I -

Operating Licenses and authorization and

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Construction Permits in Effect Plus Applica- -

.'tions Pending.  ;

e l . "Part II' - Applications Withdrawn or Denied, and Licenses o I and Construction Permits Terminated or Revoked. 3 I

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"Part III - Roscarch, Test and Power Roactors for Export.

Date: July 11, 1967

'DRL: NLD/kmt S. " Major Activities in the Atomic Energy Programs _ ,. ,

January - December 1966 (Commission Seal)

United States Atomic Energy Commission 1 January 1967" -

c (U.S. Government Printing Of fice) 1 . .

Appendix 4 4

"Contral Station Nuclear Power Plants" (pages 413-430)

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