ML20079R212

Response to NRC & Util Answers to First Amended & Supplemental Contentions.Contentions Filed in Timely Manner. Certificate of Svc Encl

ML20079R212
Person / Time
Site:	River Bend
Issue date:	06/13/1983
From:	Falkenheiner D, Irving S, Pierce J, Watkins L FALKENHEINER, D., LOUISIANA CONSUMER'S LEAGUE, INC., LOUISIANIANS FOR SAFE ENERGY, INC., ROTHSCHILD, G.E.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8306220117
Download: ML20079R212 (4)

Text

-

- fl.4 r l} ,,ep s

y neie, g ussac

,, UNITED STATES OF AMERICA g} JUN 2019833 j2 NUCLEAit REGULATORY COMMISSION -

s syn. i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,

In the Matter of GULF STATES UTILITIES CO., et al Docket Nos. 50-458 & 50-459

'(River Bend Station, Units 1 & 2)

JOINT INTERVENORS' RESPONSE TO NRC STAFF AND APPLICANTS' ANSWERS TO FIRST AMENDED AND SUPPLEMENTED CONTENTIONS Both the NRC staff and the applicants are objecting to Joint Inter-venors' first amended'and supplemented contentions which were filed within 15 days prior of the pre-hearing conference.

The authority for the amended and supplemented contentions resides in 10 CFR 2.714(b) reading as follows:

Not later than fifteen (15) days prior to the holding of the special prehearing conference pursuant to 12.751a, or where no special prehearing conference is held, fifteen (15) -

days prior to the holding of the first prehearing conference, the petitioner shall file a supplement to his petition to -

intervene whic., must include a list of the contentions which petitioner seeks to have litigated in the matter, and the bases for each contention set forth with reasonable specificity.

A petitioner who fails to file such a supplement which satis-fies the requirements of this paragraph with respect to at least one contention will not be permitted to participate as a party. Additiona'l time for filing the supplement may be granted based upon a balancing of the factors in paragraph (a)(1) of this section.

Joint Intervenors met the 15-day period stated in this regulation, and the pre-hearing order being silent as to any intent to negate the 1

8306220117 830613 l PDR ADOCK 05000458 1 Q PDR l 9503

/

/

specific previous of 1,0 CFR 2.714(b), the amending and supplementing of the original contentions should be allowed.

The objections filed herein reflect that the NRC staff and the applicants are likely to make an objection to each and every attempt of the Joint Intervenors to amend and to supplement their contentions once new inf t.rmation is obtained, e.g., through the FSAR whenever it

. ,is finally com;.leted. This supports what Joint Intervenors have said about the premato ity of the application.

June 13, 1983 ffl b 71 su! u

' ' Doris Falkenheiner Counsel for Lou siana Consumers' Lea e, Inc.

StTphTn M. Irving Counsel for Louisiana Consumers' League, Inc.

3 CIbdU{ 3 [ ab;< te, Linda B. Watkin Counsel for e chen R. Rothschild 5es W

Pi e rce ,- J r/

el f r Loui d'anians for Safe Energy, In . -

l

! ~

l f

l L

i

I "' f l -

l ' , _ _ _ _

~

' o) uN.

7 ..

s to&(Y

j. u%" q UNITED STATES OF AMERICA f%,

' NUCLEAR REGULATORY COMMISSION -

gn20 g ) [

T ess BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

~ Newsw-

%nd I

IN THE MATTER OF 4 @

{

GULF STATES UTILITIES CO., et al Docket Nos. 50-458 & 50-459 (RIVER BEND STATION, Units 1 & 2)

CERTIFICATE OF SERVICE We hereby certify that copies of " Joint Intervenors' Response to NRC Staff and Applicants' Answers to First Amended and Supplemented Contentions" have been served cn the following by handing them copies on June 13, 1983:

Mr. Troy B. Conner, Jr. and/or Mr. Mark J. Wetterhan Att6rneys At Law 1747 Pennsylvania Avenue Washington, D. C. 200006 Mr. Ian Douglas Lindsey Staff Attorney Louisiana Department of Justice 7434 Perkins Road Baton Rouge, LA 70808 Mr. David A. Repka '

Counsel for NRC Staff U.S. Nuclear Regulatory Commission Washington, D. C. 20555 =

We further certify that copies of the above-referenced document have been served on the following by handing them copies on June 14, 1983:

Dr. Richard F. Cole Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, 0. C. 20555 i

~. 6 B. Paul Cotter, Jr., Chairman Administrative Judge Atomic Safety aND Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Gustave A. Linenberger T

' OF Administrative Judge Atomic Safety and Licensing Board Panel ITIL U.S. Nuclear Regulatory Commission Washington, D. C. 20555 (TAT .

We further certify that copies of the above-referenced document have

' been served on the following by deposit in the U.S. Mail, first class, on 7e the[6f day of June, 1983:

Ap g William J. Guste, Jr.

Attorney General of Louisiana Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission 83;l 2-3-4 Loyola Building Washington, D.C. 20555

. 7th Floor-an New- Orleans , LA 70112 Atomic Safety & Licensing Board Panel

. . Nuc ear egu atory Co W ssion w James E. Booicer ,

asMngton, D.C. 20 W i Gulf States Utilities Conpany Docketing & Service Section Beaumont, TX. 77701 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 .

t

." o r (4d&, '4s t &

Doris Falk4 iner l  ? '

Stephen M. Irvin t

w bl D \/% Mf:IAw Linda B. Watkins f

, James #. Pierce, ..