ML20041F092
| ML20041F092 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/10/1982 |
| From: | Newman J JOINT APPLICANTS - SOUTH TEXAS PROJECT, LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | Bechhoefer C, Eva Hill, John Lamb Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8203160182 | |
| Download: ML20041F092 (5) | |
Text
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RitrATED CORR n~....,_.
LAW OrriCES LOWENSTEIN, NEWMAN, REIs & AXELEAD 1035 CON N ECTICUT AVENUE, N. W.
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- 5. (GSORT BARN E S OF COveeSEL Ausst w.40TTsNOMAM CTCYtM P.FRANTI JsLL E.04 ANT F%$0tRIC s.em Av AWIN M. GuTTg nes An March 10, 1982 mT =. u os-A-DA'MS 3. NASKIN DOLT.LD J. SILygmesAN Charles Bechhoefer, Esquire g
Chief, Administrative Judge g
Atomic Safety and Licensing
- n Board Panel U.S. Nuclear Regulatory Commission DECEIVED 9
Washington, D. C.
20555
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Dr. James C. Lamb, III
{ "QNg Jcts 2 Administrative Judge ro
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313 Woodhaven Road Chapel Hill, North Carolina 27514 Ernest E.
Hill l
Administrative Judge Lawrence Livermore Laboratory l
Post Office Box 808, L-46 Livermore, California 94.550 l
Re:
Houston Lighting & Power Co. et al l
South Texas Project, Units 1 & 2 i
Docket Nos. STN 498 %STN-5,0,-199
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Gentlemen:
When the presentation of the remaining testimony in this proceeding was discussed on! February'10, 1982 (Tr.10379),
it was suggested that the follow {ng sequence would be followed:
(1) testimony on management of operations, first by the Appli-cants, then by the NRC Staff, and"(2)tstimony on the selected architect-engineer and construction' manager and on the selected constructor, the organizational framework for continued con-struction, future QA/QC activities, etc.--(see p. 4 of Fourth Prehearing Conference Order), fikst.by..the Applicants, then by the NRC Staff.
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l P203160182 820310 PDR ADOCK 05000498 l
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Lownwev rw, NzwwA>r, Reis & AmCAD Charles Bechoefer, Esquire Dr. James C. Lamb, III Ernest E. Hill March 10, 1982 Page Two This particular sequence had been sug>gested at a time when it appeared that hearings would be held in March and that only the testimony on operations would have been pre-filed sufficiently in advance to be heard at that time.
However, as events have developed, the testimony on all subjects.will be pre-filed at least 15 days prior to the next hearing (by April 5) */ and there is no need to utilize the foregoing sequence.
Applicants believe that Phase I of the proceeding can be completed more effectively and in a more logical fashion if they would proceed first and present all of their remaining testimony in the following sequence: (1)
HL&P-Bechtel-Ebasco testimony on the selected architect-engineer and construction manager and the selected con-structor, the organizational framework for construction, etc.,
(2) HL&P-Bechtel-Ebasco testirony on the QA/QC pro-gram for the design and constructio., phase, and (3) HL&P testimony on management of operations.
Once the testimony l
of Applicants has been completed,*/, the NRC Staff can then provide all of its testimony on the foregoing subjects.
- /
During the week of March 8, Applicants are filing updated testimony on the management of operations and related FSAR amendments, Revision 3 of the STP Quality Assurance Program Description (including Ebasco's QA program) for design and construction, and a summary of Ebasco's qualifications.
A descrip-tion of the interface among HL&P, Bechtel, and Ebasco will be filed by March 22.
Testimony by all parties concerning the selected contractors, the framework for construction, future QA/QC, etc. is to be filed by April 5.
-*/
The intervenors have not indicated that they intend to present any testimony on these subjects.
If they do file any testimony by the April 5 deadline, it would be presented prior to the NRC Staff's testimony.
LowzwcTz N, Neww AN, Reza O AxzLcAn Charles Bechhoefer, Esquire Dr. James C. Lamb, III Ernest E. Hill March 10, 1982 Page Three Counsel for the NRC Staff and CEU and Mr Sinkin on behalf of CCA1.'P have informed us that they have no objection to the foregoing suggestion.
We respectfully request that the Board inform the parties at its aarliest convenience whether our proposed sequence for the prsjentation of testimony is acceptable.
Very.truly yours, l
[
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ack R. Newban Of Counsel Lowenstein, Newman, Reis
& Axelrad 1025 Connecticut Avenue, N.W.
Washington, D. C.
20036 Baker & Botts 3000 One Shell Plaza Houston, Texas 77002 Attorneys for HOUSTON LIGHTING &
POWER COMPANY, Project Manager of the South Texas Project, acting herein on behalf of itself and the other Applicants, CITY OF SAN ANTONIO, TEXAS, acting-by and through the City Public Service Board of the City of San Antonio, CENTRAL POWER AND LIGHT COMPANY I
1 cc: Certificate of Service l
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G UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'82 Wm 12 P1:15 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD O':Cn_: tid 5 0 0-In the Matter of
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ERM;Ch
)
HOUSTON LIGHTING AND POWER
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Docket Nos. 50-498 OL COMPANY, ET AL.
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50-499 OL
)
(South Texas Project,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of Applicants' letter to the Atomic Safety and Licensing Board dated March 10, 1982, have been served on the following individuals and entities by deposit in the United States mail, first class, postage prepaid, on this 10th day of March, 1982.
Charles Bechhoefer, Esq.
Brian Berwick, Esq.
Chairman, Administrative Judge Assistant Attorney General Atomic Safety and Licensing for the State of Texas Board Panel Environmental Protection U.S. Nuclear Regulatory Commission Division l
Washington, D.C.
20555 P.O. Box 12548, Capitol Station l
(
Dr. James C. Lamb, III Administrative Judge William S. Jordan, III, Esq.
313 Woodhaven Road Harmon & Weiss Chapel Hill, North Carolina 27514 1725 I Street, N.W.
Washington, D.C.
20006 Ernest E. Hill Administrative Judge Kim Eastman, Co-coordinator Lawrence Livermore Laboratory Barbara A. Miller l
University of California Pat Coy i
P.O. Box 808, L-46 Citizens Concerned About Livermore, California 94550 Nuclear Power
'5106 Casa Oro Mrs. Peggy Buchorn San Antonio, Texas 78233 Executive Director Citizens,for Equitable Lanny Sinkin Utilities, Inc.
2207-D Nueces Brazoria, Texas 77422.
Austin, Texas 78705 Route 1, Box 1684 l
l l
r
. Jay M. Gutierrez, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555
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