ML20151T529

Response Supporting Citizens Concerned About Nuclear Power 860114 Motion to Withdraw Pending Contention on Overpressurization of Westinghouse Reactors.Certificate of Svc Encl

ML20151T529
Person / Time
Site:	South Texas
Issue date:	01/03/1986
From:	Gutterman A HOUSTON LIGHTING & POWER CO., NEWMAN & HOLTZINGER
To:	Atomic Safety and Licensing Board Panel
References
CON-#186-987 OL, NUDOCS 8602100295
Download: ML20151T529 (4)

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HOUSTON LIGHTING & POWER COMPANY, ) Docket Nos. 50-498 OL

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APPLICANTS' RESPONSE IN SUPPORT OF CCANP MOTION TO WITHDRAW CONTENTION On January 17, 1986, CCANP filed a motion to withdraw its "pending contention on overpressurization of Westing-house reactors" (Contention 3).

At the time Contention 3 was admitted, the Board noted that it was aware of a new report on the subject (NUREG-0224,

" Reactor Vessel Pressure Transient Protection," dated Septem-ber, 1978), which " purports to resolve the overpressurization generic issue." Prehearing Conference Order Ruling Upon Intervention Petitions, LBP-79-10, 9 NRC 439, 451 (1979).

As stated in NUREG-0224, Task Action Plan (TAP) A-26 was designed to develop acceptance criteria for overpressuriza-tion protection systems for low temperature events, and was completed by the Staff's adoption of Branch Technical Position (BTP) RSB 5-2 "Overpressurization Protection of Pressurized Water Reactors While-Operating at Low Tempera-tures." BTP RSB 5-2 has been incorporated into the NRC B602100295 060103 PDR ADOCK 05000490 0 PDR

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-.1 Standard Review Plan. NUREG-0800 at p. 5.2.2-7 (Rev. O - July 1981). STP is committed to comply with BTP RSB 5-2.

Since there is no matter in controversy under Conten-tion 3, Applicants support CCANP's motion to withdraw said contention.

Respectfully submitted,

'h =w Jack R. Newman Maurice Axelrad Alvin H. Gutterman Donald J. Silverman 1615 L Street, N.W.

Washington, D.C. 20036 Finis E. Cowan 3000 One Shell Plaza Houston, Texas 77002 Dated:' February 3, 1986 NEWMAN & HOLTZINGER, P.C. ATTORNEYS FOR HOUSTON LIGHTING &

1615 L Street, N.W. POWER COMPANY, Project Manager Washington, D.C. 20036 of the South Texas Project acting herein on behalf of itself and the other Applicants,

. BAKER & BOTTS THE CITY OF SAN ANTONIO, TEXAS, 3000 One Shell Plaza acting by and through the City' Houston, TX 77002 Public Service Board of.the city of San Antonio, CENTRAL POWER AND LIGHT COMPANY, and CITY OF AUSTIN, TEXAS

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UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION $} p{g;6198b' -l j BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g b di D #

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HOUSTON LIGHTING & POWER ) Docket Nos. 50-498 OL COMPANY, ET AL. ) 50-499 OL

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(South Texas Project, Units 1 )

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CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response In. Support Of CCANP Motion To Withdraw Contention" have been served on the following individuals and entities by depocit in the United States mail, first class, postage prepaid on this 3rd day of February, 1986.

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 Division Commission P.O. Box 12548, Capitol Station Washington, D.C. 20555 Austin, TX 78711 Dr. James C. Lamb, III Kim Eastman, Co-coordinator Administrative Judge Barbara A. Miller 313 Woodhaven Road Pat Coy Chapel Hill, NC 27514 '

Citizens Concerned About Nuclear Power Frederick J. Shon 5106 Casa Oro Administrative Judge San-Antonio, TX 78233 U.S. Nuclear Regulatory Commission Lanny Alan Sinkin Washington, D.C. 20555 1324 North Capitol Street Washington, D.C. 20002 Mrs. Peggy Buchorn Executive Director Ray Goldstein, Esq.

Citizens for Equitable Gray, Allison & Decker Utilities, Inc. 1001 Vaughn Building Route 1, Box 1684 807 Brazos Brazoria, TX 77422 Austin, TX 78701-2553

t-Oreste Russ Pirfo, Esq.

Robert G. Perlis, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal 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 1