ML20097F360

Transmittal of Testimony & Proposed Findings of Fact & Conclusions of Law Re Contentions 1 & 2,per ASLB 840622 Memorandum.Related Correspondence

ML20097F360
Person / Time
Site:	River Bend
Issue date:	09/17/1984
From:	CONNER & WETTERHAHN, GULF STATES UTILITIES CO.
To:
Shared Package
ML20097F363	List: ML20097F360 ML20097F366 ML20097F380 ML20097F383 ML20097F395
References
OL, NUDOCS 8409180498
Download: ML20097F360 (3)

Text

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U UNITED STATES OF AMERICA '8 4 S P 1 7 'n .f I NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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Gulf States Utilities Company, ) Docket No. 50-4580L et al. )

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(River Bend Station) )

TRANSMITTAL OF APPLICANTS' TESTIMONY AND PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW WITH RESPECT TO CONTENTIONS 1 AND 2 Gulf States Utilities Company, et al. (" Applicants"),

in accordance with 10 C.F.R. S2.754 and the Atomic Safety and Licensing Board's " Memorandum" (June 22, 1984), hereby serve upon the Atomic Safety and Licensing Board:

(1) Testimony of John V. Conner, Philip D. Graham, and Joanne G. Morris, Gulf States Utilities Company, Regarding Asiatic Clams (Corbicula) ;

(2) Testimony of Willian J. Cahill, Jr.,

Gulf States Utilities Company, and Brian G. Schultz, Stone and Webster Engineer-ing Corporation, Relating to Contention 2 (O? d River Control Structura);

(3) Applicants' Proposed Findings of Fact and Conclusion of Law Related to Contention 1 (Asiatic Clams (Corbi-cula));

(4) Applicants' Prcposed Findings of Fact and Conclusions of Law Related to Contention 2 (Old River Control Struc-ture); and (5) Professional Qualification State-ments of William J. Cahill, Jr., Brian G. Schultz, John V. Conner, Philip D.

Graham, and Joanne G. Morris.

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I The Proposed Findings of Fact and Conclusions of Law contain lhO

'V minor editorial' changes from the Draft Proposed Findings of Fact and Conclusions of Law sent to the parties on August 31, 1984 in order to conform to the testimony. Addition- <

ally, pursuant to the Licensing Board's " Memorandum" (June-22, 1984), Applicants submit a copy of the NRC Staff's Proposed Preliminary Findings of Fact and Conclusions of Law (Safety Contentions) on which has been marked Applicants' position with respect to each' finding.

Respectfully submitted, CONNER & WETTERHAHN, P.C. -

Mark J. Wetterhahn Jessica H. Laverty Counsel for Applicants O September 17, 1984 i

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TABLE OF CONTENTS

-1. Testimony of John V. Conner, Philip D. Graham, and Joanne G. Morris, Gulf States Utilities Company, Regarding Asiatic Clams (Corbicula).

2.- Testimony of William J. Cahill, Jr., Gulf States Utilities Company, and Brian G. Schultz, Stone and Webster Engineering Corporation, Relating to Contention 2 (Old River Control Structure).

3. Applicants' Proposed Findings of Fact and Conclusions of Law Related to Contention 1 (Asiatic Clams (Corbicula)).

4. Applicants' Proposed Findings of Fact and Conclusions of Law Related to Contention 2 (Old River Control 4

Structure).

5. Staff's Proposed Findings of Fact and Conclusions of Law - Marked by Applicants.

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