ML19340D203

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Joint Response to ASLB 801121 Order Requiring Submittal of Environ Contentions & ASLB Questions & Sequence in Which Issues Will Be Heard.Proposed Schedule Is Tentative. Certificate of Svc Encl
ML19340D203
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 12/02/1980
From: Copeland J, Newman J
BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8012290295
Download: ML19340D203 (7)


Text

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UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION W

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 7' In the Matter of HOUSTON LIGHTING & POWER COMPANY S

Docket No. 50-466 5

(Allens Creek Nuclear Generating S

Station, Unit 1)

S JOINT RESPONSE OF APPLICANT AND NRC STAFF TO ASLB ORDER OF NOVEMBER 21, 1980 Houston Lighting & Power Company (Applicant) and

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the NRC Staff (Staff) file this joint response to the Li-censing Board's Order of November 21, 1980, which required submission of a list of environmental contentions and Board questions and the sequence in which these issues will be heard.

The dates listed below for trial of the environ-mental issues have been agreed upon by the Applicant and the Staff and are intended only as a tentative schedule for planning purposes.

Two aspects of the proposed schedule should be kept in mind.

First, the proposed dates are tentative since certain issues may be heard more quickly than the time allotted in the schedule.

As the Board stated in its Order of October 21, 1980, once a particular issue has been heard, the next issue will be taken up thereafter h

e Os 8 0 n 290 1 0 6-

without a pause in the hearing schedule.

In addition, the four days set aside by the Board to hear limited appearance statements (January 12-15) may not take the entire four days in which case the evidentiary hearings would commence earlier than January 16, 1981.

(See Board's Order of November 25, 1980, p.

2, n.

1.).

Secondly, since intervenors have not identified any expert witnesses to date, they have been allocated only one day to present direct testimony on each group of con-tentions.

If intervenors intend to file testimony of expert witnesses, the proposed schedule can be adjusted accord ingly.

The following represent Applicant's and Staff's best estimate for a hearing schedule on the environmental issues:

I.

Cooling Lake.

TexPirg Contentions Nos. 2 and 4 (cooling lake recreational benefits) -1/; Bishop Contentions Nos. 12 and 21 (radioactivity in the cooling lake and seepage from the lake).

Jan. 16,_19 and 20 Applicant's panel of witnesses Jan. 21 and 22 Staff's panel of witnesses 1/

Refers only to contention numbers for the lead party on consolidated contentions. -

Jan. 23 Intervenors' witnesses II.

Energy Alternatives.

TexPirg Contention No. 5 (solid waste combustion),

No. 7 (energy conservation and solar energy), AC 8 (natural gas), AC 12 (interconnection); Doggett Con-tention No. 1(b) (coal vs. nuclear costs); ASLB Ques-2/

tion No. 1 and No. 13 (lignite)

Feb.

2, 3 and 4 Applicant's panel of witnesses Feb. 5 and 6 Staff's panel of witnesses Feb. 9 Intervenors' witnesses III.

Transmission Lines and Barge Slip.,

Rentfro Contention No. 2 (health effects of EHV lines); Marrack Contention No. 2(c) (waterfowl colli-sions); ASLB Question No. 11 (waterfowl) ; TexPirg AC 1 (barge slip); questions raised by ASLB in its order of March 30, 1979 (barge slip).

Feb. 10 Applicant's panel of witnesses on transmission lines and waterfowl Feb. 11 Staff's panel of witnesses on transmission lines and waterfowl Feb. 12 (morning)

Intervenors' witnesses on transmission lines and waterfowl 2/

These questions are numbered in the Board's Order of July 31, 1980.. _ _

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Feb. 12 (afternoon)

Applicant's witness on barge slip Feb. 13 (morning)

Staff's witness on barge slip Feb. 13 (afternoon)

Intervenors' witness on barge slip IV.

Alternative Sites, Population Projections and Health Effects of Low Level Radiation TexPirg Contention No. 1 (STP vs. ACNGS); Hinderstein Contention No. 5 (coastal sites); Bishop Contention No. 1 (population projections); Cumings Contention No. 9 (health effects of low level radiation).-3/

Feb. 23, 24 (morning)

Applicant's panel of witnesses on alternative sites and population projections Feb. 24 (afternoon) and Staff's panel of witnesses 25 on alternative sites and popalation projections Feb. 26 Intervenors' witnesses Feb. 27 Applicant, Staff and Intervenor witnesses on health effects of low level radiation, if necessary 4/

The week of March 2-6 which has been set aside for hearings by the Board in its Order of October 3, 1980, will be reserved to hear any issues not completed by the last week in February.

3/

A lead party for this contention has not yet been designated by the consolidated parties.

-4/

The Staff filed on November 26, 1980, a motion for summary disposition on this issue.

Respectfully submitted,

),

OF COUNSEL:

Grego;pf Cfpeland Thomd Mddle, Jr.

BAKER & BOTTS arrell Hancock 3000 One Shell Pla:a 3000 One Shell Pla:a Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W.

David Raskin Washington, D. C.

20036 1025 Connecticut Ave., N.W.

Washington, D. C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S

S HOUSTON LIGHTING & POWER COMPANY S

Docket No. 50-466 S

(Allens Creek Nuclear Generating S

Station, Unit 1)

S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Joint Response of Applicant and NRC Staff to ASLB Order of November 21, 1980 in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 2nd day of December, 1980.

Sheldon J. Wolfe, Esq., Chairman Hon. Charles J. Dusek Atomic Safety and Licensing Mayor, City of Wallis Board Panel P. O. Box 312 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D.

C.

20555 Hon. Leroy H. Grebe Dr. E. Leonard Cheatum County Judge, Austin County Route 3, Box 350A P. O. Box 99 Watkinsville, Georgia 30677 Bellville, Texas 77418 Mr. Gustave A.

Linenberger Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.

C.

20555 Washington, D. C.

20555 1

i Mr. Chase R.

Stephens Atomic Safety and Licensing Docketing and Service Section Appeal Board Office o' the Secretary U.S. Nuclear Regulatory of the Commission Commission Washington, D.

C.

20555 Washington, D. C.

20555 Susan Plettman Richard Black David Preister Staff Counsel Texas Attorney General's Office U.S.. Nuclear Regulatory P. O.

Box 12548, Capitol Station Commission Austin, Texas 78711 Washington, D. C.

20555

. ~. __

Bryan L.

Baker Brenda McCorkle 1118 Montrose 6140 Darnell Houston, Texas 77019 Houston, Texas 77074 J. Morgan Bishop W. Matthew Perrenod 11418 Cak Spring 4070 Merrick Houston, Texas 77043 Houston, Texas 77025 Stephen A. Doggett F. H. Potthoff P. O.

Box 592 7200 Shady Villa, No. 110 Rosenberg, Texas 77471 Houston, Texas 77055 John F. Doherty Wayne E. Rentfro 4327 Alconbury P. O.

Box 1335 Houston, Texas 77021 Rosenberg, Texas 77471 Carro Hinderstein William Schuessler 609 Fannin, Suite 521 5810 Darnell Houston, Texas 77002 Houston, Texas 77074 D. Marrack James M. Scott 420 Mulberry Lane 13935 Ivy Mount Bellaire, Texas 77401 Sugar Land, Texas 77478

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