ML20033A977
| ML20033A977 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 11/20/1981 |
| From: | Gallo J ISHAM, LINCOLN & BEALE, PUBLIC SERVICE CO. OF OKLAHOMA |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20033A956 | List: |
| References | |
| NUDOCS 8111300242 | |
| Download: ML20033A977 (3) | |
Text
GOCKETED O_
U3NRC 11/20/81 I
'81 NOV 23 PS:20
-. CE J SECRETARYUNITED STATES OF AMERICA N C6EipiG & SERVy6 CLEAR REGULATORY COMMISSION oPANCH BEFORE THE ATOMIC SAFET,Y AND LICENSING BOARD In the Matter of the Application of
)
Public Service Company of Oklahoma,
)
Associated Electric Cooperative, Inc. )
Docket Nos. STN 50-556 i
and
)
GTN 50-557 Western Farmers Electric Cooperative
)
)
l (Black Fox Station, Units 1 and 2)
)
APPLICANTS' RESPONSE TO NRC STAFF MOTION TO REOPEN HEARING RECORD On November 5, 1981, the NRC Staff moved to reopen the hearing in this proceeding for the purpose of updati.ng the Staff's previous testimony on unresolved generic safety
!a issues from the standpoint of satisfying the requirements established by the Atomic Safety Licensing and Appeal Board in the River Bend decision.*
It is expected that the NRC Staff will also address four new unresolved safety issues which apparently have been identified since the close of the record.
Motion, p.
9, n.
16.
Public Service Company of Oklahoma, Associated Electric Cooperative, Inc., and Western Farmers Electric Gulf States Utilities Company (River Bend, Units 1 and 2), ALAB-444, 6 NRC 760 (1977).
8111300242 81112h PDR ADOCK 05000556 0
a
. Cooperative ("Appli ints") support the grant of the NRC Staff's motic' However, the NRC Staff seems to suggest that their updated presentation of the generic unresolved I
safety issues in the TMI Supplement to the Safety Evaluation Report would not qualify as a matter in controversy.
- Motion, pp. 9, 11.
Applicants, assuming their interpretation is correct, disagree.
The River Bend treatment of the various unresolved generic safety issues was a matter in controversy in this proceeding.
Intervenors Citizens' Action for Safe Energy, Mr. Burrell, and Ms. Younghein placed this issue'into controversy during the prehearing phase of the proceeding, -
and they conducted extensive cross-examination at the health and safety hearings.
Tr. 8291-8564.
It necessarily follows that said Intervenors have a continuing right, as well as Applicants, to participate in the reopened phase of the River Bend treatment of the unresolved generic safety issues.
Respectfully submitted, un eph gallo One of the Attorneys for Applicants ISHAM, LINCOLN & BEALE Suite 325 1120 Connecticut Avenue, N.W.
Washington, D.
C.
20036 (202) 833-9730 Dated:
November 20, 1981
00LKE ED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
%) NW 23 P5:20 In the Matter of the Application os
)
Dobk!e$fhb3gERk 3 SE Public Service Company of Oklahoma,
)
Associated Electric Cooperative, Inc.
)
- a. STN 50-556 and
)
STN 50-557 Western Farmers Electric Cooperative
)
}
(Black Fox Station, Units 1 and 2
)
NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the captioned matter.
In accordance with 10 CRF g2. 713 (a), the following information is provided:
j Name:
Philip P.
Steptoe Address:
Isham, Lincoln & Beale One First National Plaza Suite 4200 Chicago, Illinois 60603 l
Telephone:
312/558-7500 Admissions:
Supreme Court of Illinois Supreme Court of Virginia District Court for the Northern District of Illinois Name and Address of Party:
Public Service Company of Oklahoma l
l 212 East 6th Street l
Tulsa, Oklahoma 74119 i
1 I
- M t/_
f PhilipjP. Step @o Dated:
November 20, 1981 i
Y