ML19323D837
| ML19323D837 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 05/20/1980 |
| From: | Sohinki S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8005220415 | |
| Download: ML19323D837 (4) | |
Text
05/20/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING & POWER COMPANY
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Docket No. 50-466
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(Allens Creek Nuclear Generating
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l Station, Unit 1)
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NRC STAFF'S RESPONSE TO MOTION TO CONFIRM AGREEMENTS ON CONSOLIDATION AND TO CONSOLIDATE CERTAIN CONTENTIONS For the reasons stated therein, and with one exception, the Staff supports the Applicant's " Motion to Confirm Agreements on Consolidation and to Consolidate Certain Contentions" filed on May 1,1980 in the captioned proceeding. The rules of the Commission provide for the consolidation of parties raising sub-stantially the same issues and for stipulations among the parties concerning pro-cedures to be followed in a hearing.
10 C.F.R.152.715a and 2.753.
The exception to our support of the Motion deals with the Applicant's proposed consolidation and restatement of Doherty Contention 17 and Tex Pirg Additional Contentions No. 51 set forth at pp. 6-7 of the Applicant's pleading.
Mr. Doherty, in a pleading dated April 7,1980 sought to amend his Contention 17 to include the term "ATWS."S In the Staff's response to that motion dated April 28, 1980, we opposed that motion because the proposed amendment was un-timely and because an analysis of the five factors set forth in 10 C.F.R.12.714(a)(1) led us to believe that the amendment had not been justified.S The Board has yet"to rule on Mr. Doherty's motion, and the Staff continues to oppose amendment of the contention.
-l/ " John F. Doherty's Amendment to Contention 17," dated April 7,1980, p.1.
l l
J./ "NRC Staff Response to New Contentions 48 and 49 anf an Amendment to Admitted I
Contention 17 Submitted by Intervenor John F. Doherty," dated April 28, 1980, pp. 1-6.
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. d Therefore, to the extent that the Applicant's restatement of Doherty Contention 17 and Tex Pirg Additional Contention 51 seeks to incorporate Mr. Doherty's proposed amendment, the Staff opposes the motion and urges that it be denied.
Respectfully submitted, W
Stephe[M. Sohinki Counsel for NRC Staff I
Dated at Bethesda, Maryland this 20th day of May, 1980 l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION s
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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H0tiSTON LIGHTING & POWER COMPANY Docket No. 50-466 (Allens Creek Nuclear Generating
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Station, Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S RESPONSE TO MOTION TO CONFIRM AGREEMENTS ON CONSOLIDATION AND TO CONSOLIDATE CERTAIN CONTENTIONS" 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 20th Jay of May,1980:
Sheldon J. Wolfe, Esq., Chairman
- Richard Lowerre, Esq.
Atomic Safety and Licensing Board Panel Asst. Attorney General for the U.S. Nuclear Regulatory Commission State of Texas Washington, DC 20555 P.O. Box 12548 Capitol Station Dr. E. Leonard Cheatum Austin, Texas 78711 Route 3, Box 350A Watkinsville, Georgia 30677 Hon. Jerry Sliva, Mayor City of Wallis, Texas 77485 Mr. Gustr 2 A. Linenberger
- Atomic ^.afety and Licensing Board Panel Hon. John R. Mikeska U.S. t:cclear Regulatory Commission Austin County Judge Washington, DC 20S55 P.O. Box 310 Bellville, Texas 77418 R. Gordon Gooch, Esq.
Baker & Botts Mr. John F. Doherty 1701 Pennsylvania Avenue, N.W.
4327 Alconbury Street Washington, DC 20006 Houston, Texas 77021 J. Gregory Copeland, Esq.
Mr. and Mrs. Robert S. Framson Baker & Botts 4822 Waynesboro Drive One Shell Plaza Houston, Texas 77035 Houston, Texas 77002 Mr. F. H. Potthoff, III Jack Newman, Esq.
1814 Pine Village Lowenstein, Reis, Newman & Axelrad Houston, Texas 77080 1025 donnecticut Avenue, N.W.
Washington, DC 20037 D. Marrack 420 Mulberry Lane l
Carro Hinderstein Bellaire, Texas 77401 l
8739 Link Terrace l
Houston, Texas 77025
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2-Texas Public Interest Margaret Bishop Research Group, Inc.
11418 Oak Spring c/o James Scott, Jr., Esq.
Houston, Texas 77043 8302 Albacore Houston, Texas 77074 Brenda A. McCorkle 6140 Darnell Houston, Texas 770/4 J. Morgan Bishop 11418 Oak Spring Mr. Wayne Rentfro Houston, Texas 77043 P.O. Box 1335 Rosenberg, Texas 77471 Stephen A. Doggett, Esq.
Polian, Nicholson & Doggett Rosemary N. Lemmer P.O. Box 592 11423 Dak Spring Rosenberg, Texas 77471 Houston, Texas 77043 Bryan L. Baker
,1923 Hawthorne Houston, Texas 77098 Robin Griffith Leotis Johnston 1034 Sally Ann 1407 Scenic Ridge Rosenberg, Texas 77471 Houston, Texas 77043 Elinore P. Cummings Atomic Safety and Licensing
- 926 Horace Mann Appeal Board Rosenberg, Texas 77471 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mrs. Connie Wilson 11427 Oak Spring Atomic Safety and Licensing
- Houston, Texas 77043 Board Panel U.S. Nuclear Regulatory Commission Mr. William Perrenod Washington, DC 20555 4070 Merrick Houston, TX 77025 Docketing and Service Section
- Office of the Secretary Carolina Conn U.S. Nuclear Regulatory Commission 1414 Scenic Ridge Washington, DC 20555 Houston, Texas 77v43 Mr. William J. Schuessler r
5810 Darnell f
Houston, Texas 77074 I[
The Honorable Ron Waters
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State Representative, District 79 ffep n
So nk1 3620 Washington Avenue, No. 362 Houston, TX 77007 e
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