ML20062A444
| ML20062A444 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 09/29/1978 |
| From: | Hiestand O DAIRYLAND POWER COOPERATIVE |
| To: | |
| References | |
| NUDOCS 7810130229 | |
| Download: ML20062A444 (5) | |
Text
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NRC PUBLIC DOCIDENT ROOM 9/29/78 s
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NUCLEAR REGULATORY COMMISSION i
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In the Matter of
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Docket No. 50-409 DAIRYLAND POWER COOPERATIVE
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Full-Term
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Operating License (La Crosse Boiling Water Reactor)
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APPLICANT' S ANS'wT.R TO REVISED CREC CONTENTIONS Dairyland. Power Cooperative (Dairyland), the Applicant for a full ters operating license in the above-captioned proceeding, hereby submits its answer to the re-vised environmental concentions submitted by the Coulee Region Energy Coalition (CREC) dated Septe=ber 19, 1978.
In support of :his answer, Dairyland states as follows:
1.
In accordance with the request of the Licensing Board nade at the August 17, 1978 Prehearing Conference, the parties to this proceeding (Dairyland, the NRC S taff, and CREC) net in La Crosse, Wisconsin on.
Septenber S,1978 in an attempt :o reach agreenent con-cerning :he adnissibili:y of the environ = ental cen:encions l
which CREC had previously filed in this proceeding.
As i
l noted in :he Sep:enber 12, 1973 let:er fr:= counsel for :he t
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NRC Staff to the 3 card, the parties were able :o reach i
LPDR q [r/ bt3 b O S PDE 4 Doc /L o s-D - 401 S-
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-2 agreement on the admission of CREC's revised environmental
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contentions Nos. 9, 19, and 22. -
2.
Since the parties were unable to reach agree-ment on the remaining CREC environmental contentions (i.e.,
Nos. 2, 6, and 8), the parties agreed that CREC could sub-mit its reworded versions of these contentions to the Board.
CREC subsequently submitted revised versions of Contention Nos. 2 and 8.
3.
For the reasons stated in its original answer to Contentions 2, 6, and 8 and during the course of the pre-hearing conference, Dairyland obj ects to the admission of these contenticas.
Moreover, Dairyland specifically objecta to that portion of revised Concention No. 2 which addresses the health and safety i= pacts associated with off gas levels
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at LAC 3WR on clan: ecolovees.
CREC's original Contention No. 2 only addressed the i= pacts on :he general oublic associated with off gas emissions.
As a result, revised Contention No. 23 constitutes an unci =ely attempt by CREC to expand the
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A.sticulation by the parties conc.erning the airissibility or certain contentions cannot, or course, expanc or narrow :he scope of a Licensing Board's organic s:aturary and regula: cry jurisdiction or the scope of the proceeding i:self.
Pursuan: to :his stipulation, Dairyland agreed :o wi:hdraw its earlier obj ections to che ad=ission of :hese contentions.
See e.z.,
Acolicant's Answer To CREC Petition For Leave To IEEarvene (Nay 13, 1978); (Tr. 179-200).
dcwever, if :hese con:enciens are ad=itted by :he 3 card, Dairyland reserves the righ:
- o seek to discose of :hese centen:icns criar Oc hearings in acecrdance wi:h the accreeria:e orece' ures se: forth d
in the Rules of Practice'." I'.g.,
lI CFR 5 2.719.
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-3 scope of its original contention and should be denied for chi's reason as well.
Respectfully submitted, p
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. S. Hiestand Attorney for Dairyland Power Cooperative Of Counsel Kevin P. Gallen Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, D.C.
20036 Dated:
September 29, 1978
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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DAIRYL*diD POWER COOPERATIVE
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Docket No. 50-409
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Full-Term (La Crosse Boiling Water Reactor)
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Operating License CERTIFICATE OF SERVICE Service has on this day been effected by.
personal delivery or first class mail on the following persons:
Ivan W. Smith, Esquire, Chairman Docketing & Service Section Atomic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Cocmission Washington, D.C.
20555 Washington, D.C.
20555 Atomic Safety and Licensing Mr. Ralph S. Decker Board Panel Route 4 U.S. Nuclear Regulatory Box 190D Commission Cambridge, Maryland Washington, D.C.
20555 Dr. George C. Anderson Atomic Safety and Licensing Department of Oceanography Appeal Board University of Washington U.S. Nuclear Regulatory Seattle, Washington 93195 Cc= mission Washington, D.C.
20555
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Colleen Woodhead, Esquire
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Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Richard J. Goddard, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Richard Shi=shak Plant Superintendent Dairylan'd Power Cooperative La Crosse Boiling Water Reactor Genoa, Wiscensin 54632 Frit: Schubert, Esquire Staff Attorney Dairyland Power Cooperative 2615 East Avenue, South La Crosse, Wisconsin 54601 Coulee Region Energy Coalition P. O. Box 1583 La Crosse, Wisconsin 54601 jf
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O. S. Hiestand, Jr.
Dated:
Sep:e=ber 29, 1978 i