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| | issue date = 03/19/1980 | | | issue date = 03/19/1980 |
| | title = Motion for 30-day Extension to File Testimony Re Consequences of Water Loss from Spent Fuel Storage Pool. Urges Postponement of 800422 Evidentiary Hearing, Accordingly.Notice of Appearance & Certificate of Svc Encl | | | title = Motion for 30-day Extension to File Testimony Re Consequences of Water Loss from Spent Fuel Storage Pool. Urges Postponement of 800422 Evidentiary Hearing, Accordingly.Notice of Appearance & Certificate of Svc Encl |
| | author name = AYRES S T, COLEMAN, VAN NESS S C | | | author name = Ayres S, Coleman, Van Ness S |
| | author affiliation = AFFILIATION NOT ASSIGNED, NEW JERSEY, STATE OF | | | author affiliation = AFFILIATION NOT ASSIGNED, NEW JERSEY, STATE OF |
| | addressee name = | | | addressee name = |
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| =Text= | | =Text= |
| {{#Wiki_filter:U\ITED S'f:\Tf:S OF _-\_'.fERrc:\ | | {{#Wiki_filter:U\ITED S'f:\Tf:S OF _-\_'.fERrc:\ |
| \lJCLL-\.R REGUL\TORY SS1 ex BEFCJRC: THE ATO;,JI C | | \lJCLL-\.R REGUL\TORY co:\~:-II SS1 ex BEFCJRC: THE ATO;,JI C S_-\fl.~TY -~\D !.. I CE\:S IXG BOARD IN THE ;'.iATTER OF |
| !.. I CE\:S IXG BOARD IN THE ;'.iATTER OF ) PUBLIC SERVICE ELECTRIC ) GAS cm-iPAXY ) ) ) ) DOCKET NO. 50-272 (SALE:\1 :\UCLEAR GENERATI;\G STATION, UNIT NO. 1) | | ) |
| COLEMANS MOTION FOR EXTENSION OF THIE TO FILE TESTIMO:'.\Y OF THEREON This to consider the application of Pub lie Service Electric and Gas Comp.any, et .. al -(hereinafter. "Licensee") | | PUBLIC SERVICE ELECTRIC A~D ) |
| for an amended operating licens_e to permit .. increased storage of spent fuel in the Salem Generating | | GAS cm-iPAXY ) |
| *Station Unit 1. On February 22, 1980, the Atomic Safety and Licensing " i no arc. (hereinafter "Board") issued a and Order i. .. -h.ich, among other things, required consideration of the qt:cstion: | | ) DOCKET NO. 50-272 (SALE:\1 :\UCLEAR GENERATI;\G ) |
| In the event of a gross loss of water from the spent fuel storage poo1, would be the difference | | STATION, UNIT NO. 1) ) |
| *in consequences those occasioned by the pool with expanded storage and those occ:isioned by the prese*nt pool? (?-!er.10randum and Order:. at 18). The Board further directed evidentiary hearings on this set for April 22, 1980. Te.stimony r.rnst be filed by March 24, 19SO. | | INTERVE~ORS COLEMANS MOTION FOR EXTENSION OF THIE TO FILE TESTIMO:'.\Y A~D POSTPONE~1 IENT OF HEARI~G THEREON This proceedin~ i~ to consider the application of Pub lie Service Electric and Gas Comp.any, et .. al - (hereinafter. |
| This motion respectfully requests an extension of r,.1.;!12 file testimony on the questj on cited above> for thirty (:)0) 6ays, u.nd postponement of tl:e e*:identiary hearing thereon, accordingly.
| | "Licensee") for an amended operating licens_e to permit .. |
| The is made for several compelling reasons. FoT one, the Memorandum and Order of the Board 1-:as not docketed until February 25, 1980, and was not in this office until :on or about February 28, i980. Thus, little airer three weeks provided for response.
| | increased storage of spent fuel in the Salem Generating *Station Unit 1. On February 22, 1980, the Atomic Safety and Licensing no |
| Such a limited time is inadequate to properly address the important question taised"by the Board. This is particularly so where intervenors' expert, musr be consulted on the question, is located in More-0ver, .the attorney from this .office, Keith ; Onsdorff, Esquir*e, 1.:ho was respresenting the Colernans in these proceedings recently resigned, as indicated by his March 19, 1980 withdrawal of appearance.
| | " arc.i (hereinafter "Board") issued a ~Iemorandur.1 and Order i...-h.ich, among other things, required consideration of the qt:cstion: |
| Thus, counsel had to be appointed, and famlliarized with the case and the issue at hand in order to prepare and file the testimony requested by the Board. In addition, the attorney assigned to handle the hearings has other commitments at and arou:nd the April 22d date set for For the reasons set forth.above, intervenors urge '. that the Board grant this motion, In light of the Licensee's recent i'-lotion for Directed Certification on the Yali<lity of the Board's question, and Stay of Board proceedings pending decision thereon, intervenors' request for additional time
| | In the event of a gross loss of water from the spent fuel storage poo1, ~d1at would be the difference |
| | *in consequences bet~een those occasioned by the pool with expanded storage and those occ:isioned by the prese*nt pool? (?-!er.10randum and Order:. |
| | at 18). |
| | The Board further directed evidentiary hearings on this question~ |
| | set for April 22, 1980. Te.stimony r.rnst be filed by March 24, 19SO. |
|
| |
|
| not appear to unduly prejuiice the Licensee: | | This motion respectfully requests an extension of r,.1.;!12 ~o file testimony on the questj on cited above> for thirty |
| f.la r ch 19, 19 8 0 Re.spectfull;-_
| | (:)0) 6ays, u.nd postponement of tl:e e*:identiary hearing thereon, accordingly. The ~otion is made for several compelling reasons. |
| sub:ii_i t ted, STAXLEY C. NESS PUBLIC Aff\"OCATE | | FoT one, the Memorandum and Order of the Board 1-:as not docketed until February 25, 1980, and was not receiv~d in this office until :on or about February 28, i980. Thus, little airer three weeks ~ere provided for response. Such a limited time is inadequate to properly address the important question taised"by the Board. This is particularly so where intervenors' expert, |
| -.r B v. t ,'.' 1( / / * //,*.,,-1 * *-t-(L..-*.U'----'* | | ~lo musr be consulted on the question, is located in California~ |
| ' * '..-.1--;''/(: c.. | | More-0ver, .the attorney from this .office, Keith Onsdorff, Esquir*e, 1.:ho was respresenting the Colernans in these proceedings recently resigned, as indicated by his March 19, 1980 withdrawal of appearance. Thus, ne~ counsel had to be appointed, and famlliarized with the case and the issue at hand in order to prepare and file the testimony requested by the Board. In addition, the attorney no~ assigned to handle the hearings has other commitments at and arou:nd the April 22d date set for For the reasons set forth.above, intervenors urge that the Board grant this motion, In light of the Licensee's recent i'-lotion for Directed Certification on the Yali<lity of the Board's question, and Stay of Board proceedings pending decision thereon, intervenors' request for additional time hcul~ not appear to unduly prejuiice the Licensee: |
| * S'"DR1
| | Re.spectfull;-_ sub:ii_i t ted, STAXLEY C. VA~ NESS PUBLIC Aff\"OCATE |
| *, *'* \ .: ' i . l
| | - .r t ,'.' 1( .~ |
| * J Assistant Deputy *Public Advocate Counsel for Intervenors Colemans U I *r EI> S.1 .. _.l.:i' S C: F _:\.;\ i F P. I C_-'\_ XlJCLE..\R REGUL..!. | | Bv. |
| TOf:.Y CiJ'.'.:-11SST0:\ | | 1 * *-t-(L..-*.U'----'* -~''--~ |
| BEFORE THE ATO:<IC s_.\r_. . '*--. _..:i .. .:.'.l..) | | / / * //,*.,,- |
| IN THE MATTER OF PUBLIC SERVICE ELECTRIC Al\'D GAS co:*.;p J\:\Y :1 (SALEM i\UCLEAR GPH:RAT I\G STATIOX, UNIT 1) 3 DOCKET NO. 50-272 NOTICE OF APPEARANCE SANDRA T. AYRES, Assistant Deputy Public Advocate hereby notices the parties and licensing board in the above-captioned proceeding of her appearance as co-counsel, Kith Raymond E. Makul, Assistant Deputy Public Advocate, for the Intervenors: | | ' * '..-.1- -;''/(: c.. * |
| | '"DR1 S*'* \ .: ' |
| | ~* |
| | i . |
| | ~".RE:s |
| | ~i. l ~ |
| | * J*, |
| | Assistant Deputy *Public Advocate Counsel for Intervenors Colemans f.la r ch 19, 19 8 0 |
| | |
| | U~.; I *r EI> S.1. _.l.:i' l~ S C: F _:\.;\ i F P. I C_-'\_ |
| | XlJCLE..\R REGUL..!. TOf:.Y CiJ'.'.:-11SST0:\ |
| | BEFORE THE ATO:<IC s_.\r_. ~:Tl- . '*--. |
| | _..:i.. .:.'.l..) |
| | IN THE MATTER OF |
| | ~ |
| | PUBLIC SERVICE ELECTRIC ~ |
| | Al\'D GAS co:*.;p J\:\Y :1 DOCKET NO. 50-272 |
| | ~ |
| | (SALEM i\UCLEAR GPH:RAT I\G ~ |
| | STATIOX, UNIT ~O. 1) 3 NOTICE OF APPEARANCE SANDRA T. AYRES, Assistant Deputy Public Advocate hereby notices the parties and licensing board in the above-captioned proceeding of her appearance as co-counsel, Kith Raymond E. |
| | Makul, Assistant Deputy Public Advocate, for the Intervenors: |
| Colemans, effective immediately. | | Colemans, effective immediately. |
| DATED: March 19, 1980 cc: Service List Respectfully submitted, STANLEY C. NESS PUBLIC ADYOCATE BY: S :\ .'.\ lllZ.:.\ T . .*\ 'i RE S J Assistant Public Division of Public Interest Advocacy 520 East State Street Trenton, Jersey 08625
| | Respectfully submitted, STANLEY C. VA~ NESS occ:~sso PUBLIC ADYOCATE |
| """"------------------------------------------------
| | \J~~'RO BY: |
| -----------------------
| | S :\ .'.\ lllZ.:.\ T . .*\'i RE S J Assistant Dc~uty Public Ad\~ocatc Division of Public Interest Advocacy 520 East State Street Trenton, Xe~ Jersey 08625 DATED: March 19, 1980 cc: Service List |
| r, .A.Iffi GAS r:-1 \ .h.._) * ...;.. I ) ) \ rTJ:J) COR.RESPOl'i.1lENCE | | |
| ..... ---* 50-272 a:::d a notice of Appea.rance by Sandra T .. \:rres, AGsis'ta.nt De:;:iut:r Public Advocate, have* been served upon the by special deli ve-::-y C'ni te:i States this 19th day of Marc,h, 198C. Gery L. Milhollin, Esq. Chair:r:-..a.n, Atomic Safety Licensing Board 1815 Jefferson Street Madison, Wisconsin 53711 Mr. Frederick J. Shon Mer.lber, Ator::ic Safety e.nd Licensing Board Panel U.S.
| | r, rTJ:J) COR.RESPOl'i.1lENCE E~ECTRIC .A.Iffi GAS ) |
| Regulatory Washington, D.C. 20555 D=.* | | ) 50-272 r:- 1 \ \ |
| C. | | .h.._) * ...;.. I a:::d a notice of Appea.rance by Sandra T . .\:rres, AGsis'ta.nt De:;:iut:r Public Advocate, have* been served upon the :folloT,~ing by special deli ve-::-y C'ni te:i States r~ail, this 19th day of Marc,h, 198C. |
| III i*;e:r::be1*, J..to:::nic Safety and 313 Ro!id. Ch::.:;iel Eill, iL C. 27514 Chair.::S1, Atomic Sa.fet:r*
| | Gery L. Milhollin, Esq. Cnair!rran, Atomic Saf"ety Chair:r:-..a.n, Atomic Safety Licensing :Eo:;.rd Panel a~d Licensing Board U .. S. ITuclear P..egrJ.la.tor:.-r 1815 Jefferson Street Co~-ruis3icn Madison, Wisconsin 53711 ;-1ashington, D.C. 20555 Mr. Frederick J. Shon Ja:."1.ice. I-~:Jore, ~.:Jq. |
| a:1d Licensing Appeal Board Panel U.S. :Nuclear Regulatory Co:m.":lission Washington, D.C. 20555 Richard Fryling, Esq. Assistant Solicitor Public Service Electric & G!:..s 80 Park Place Hewark, H.J. 07l0l Cnair!rran, Atomic Saf"ety Licensing | | Mer.lber, Ator::ic Safety e.nd C.:~fice of the Exec-u.ti Ye Licensing Board Panel Lege.l Di2*ector U.S. ~bclear Regulatory u. s. r:uclear B.egUlatory Washington, D.C. 20555 Washi:15\..0!1, D .C. 20555 D=.* Ja::~s C. L.:1..~b, III Richard Fiucha~, ~sq. |
| :Eo:;.rd Panel U .. S. ITuclear P..egrJ.la.tor:.-r | | i*;e:r::be1*, J..to:::nic Safety and Dep~t~r A.t~orr:ey Ge~1eral Depa.r~1~ent of L~;.; er~d P.~"bli.c 313 i,*Jvod.i~a--:rer:. Ro!id. |
| ;-1ashington, D.C. 20555 Ja:."1.ice.
| | Ch::.:;iel Eill, iL C. 27514 Protection Sec"'cion Chair.::S1, Atomic Sa.fet:r* a:1d 36 1lest State Street Licensing Appeal Board Panel Trer:tcr., iI. rJ. 08625 U.S. :Nuclear Regulatory Co:m.":lission Carl ~..'alore, Esq_. |
| of the Exec-u.ti Ye Lege.l Di2*ector
| | Washington, D.C. 20555 Val.ore, l:*~dU.lister, Aro-:i |
| : u. s. r:uclear B.egUlatory Washi:15\..0!1, D .C. 20555 Richard of Protection Sec"'cion 36 1lest State Street Trer:tcr., iI. rJ. 08625 Carl . .'alore, Esq_. Val.ore, Aro-:i | | ~ ~*7estmoreland Richard Fryling, Jr~, Esq. :.:ainln.nci Professional Pla:::2. |
| :.:ainln.nci Professional Pla:::2. ? . J.
| | Assistant Ge~eral Solicitor ? . J. 38~*= 175 Public Service Electric ~cr~hfiel~, ~-J. 09225 |
| 175 09225 o: Secretary 5e:r-.1'ice U.S.
| | & G!:..s Cor::?.a.~iy 80 Park Place O~~i~e o: t~e Secretary Hewark, H.J. 07l0l Dcc~:etir!b ~:!(l 5e:r-.1'ice Sect.:.o~ |
| I*2.
| | U.S. :*~uc:ec..~ ?:.egtlatoryC~::-=i.ss::.~!1 |
| C.
| | |
| J*2 ... I*1rs. E:..e.s.!!o-c* | | -1 |
| G. Cc*ler:-... an 3 5 B::i PenLs1rille, | | ~ . *'' |
| ;;,-e::--s e:f C 8070 -1 . *'' -*-}} | | I*2. Al~::~:*e.J. C. C*:)l~~:::.r1, J*2... |
| | I*1rs. E:..e.s.!!o-c* G. Cc*ler:-.. an 3 5 n:r~" B::i -~-e PenLs1rille, i*~cw ;;,- e::--s e:f C8070}} |
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[Table view]
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Appeal from ASLB 801027 Initial Decision.Alleges Erroneous Finding of Facts Re Contentions 2 & 6,evaluation of Eia, Acceptance of Pasedag Testimony & Rejection of Benjamin Testimony.Counsel Withdrawal & Certificate of Svc Encl
ML18085A2161980-11-0404 November 1980
Exceptions & Appeal from ASLB 801027 Initial Decision. Exclusion of as Benjamin of Sandia Labs Testimony Is Arbitrary Due to Relevant Evidence Re Oxidation That Could Propagate to Older Fuel.Certificate of Svc Encl
ML18082A5481980-05-23023 May 1980
Proposed Corrections for 800430 Evidentiary Hearing Transcript.Certificate of Svc Encl
ML18082A5281980-05-13013 May 1980
Proposed Corrections to Transcript of 800328-29 Evidentiary Hearings.Certificate of Svc Encl
ML18082A5261980-05-13013 May 1980
Request for Extension Until 800528 to File Transcript Corrections.States No Objection to NRC Motion for Similar Extension.Transcript Not Yet Received in Licensee Newark,Nj Ofc
ML19323A9571980-04-21021 April 1980
Response in Opposition to Webb,Fankhauser & Portion of NRC Testimonies Based on Class 9 Accident Scenarios.Testimony Beyond ASLB Jurisdiction & Should Not Be Admitted Into Evidence.Certificate of Svc Encl
ML18082A5011980-04-18018 April 1980
Reply in Opposition to Licensee Response to ASLB 800222 Memorandum & Order,Question 5,re Spent Fuel Pool Gross Loss of Water.Urges to Strike Testimony W/Appropriate Sanctions
ML18082A4991980-04-18018 April 1980
Motion to Strike Licensee 800410 Response to ASLB 800222 Memorandum & Order,Question 5,re Spent Fuel Pool Gross Loss of Water.Licensee Should Be Barred from Participation or Compelled to File Testimony Due to Dilatory Conduct
ML18082A5021980-04-18018 April 1980
Response in Opposition to NRC Testimony of Wf Pasedag Re ASLB Question 5.Spent Fuel Pool Old Fuel Would Be Involved in Enlargement Case & Would Consequently Increase Radiological Effects.Certificate of Svc Encl
ML19305D7371980-04-11011 April 1980
Comments in Opposition to Township of Lower Alloways Creek 800325 Request for Suspension of Issuance of OL Per 10CFR2.206.Urges Denial Due to Untimeliness of Petition & Inadequacy of Allegations Re Noncompliance W/Nepa Rules
ML19323D1891980-04-10010 April 1980
Response to ASLB Question 5 Re Gross Loss of Water from Facility Spent Fuel Pool.Loss Will Have No Adverse Consequences on Public Health & Safety Due to Adequate Cooling Achieved in Facility.Prof Qualifications Encl
ML19323D5131980-04-0909 April 1980
Forwards Re Webb Technical Rept,In Response to ASLB 800222 Order Re Consequences of Gross Water Loss from Spent Fuel Storage Pool.Certificate of Svc Encl
ML19305E7281980-04-0909 April 1980
Response Enclosing DB Fankhauser Testimony in Reply to ASLB 800222 Order Re Consequences of Gross Water Loss from Spent Fuel Storage Pool.Certificate of Svc Encl
ML19309A4931980-03-25025 March 1980
Request for Suspension or Moratorium on Issuance of OL for Facility,Pending Conclusion of ASLB Hearing on Safety of Spent Fuel Storage Pool at Unit 1.Notice of Appearance of Cj Valore on Behalf of Intervenor Encl
ML18082A1391980-03-25025 March 1980
Intervenor Request for Suspension or Moratorium on Issuance of Ol.Issuance Would Permit Same Enlarged Spent Fuel Pool That Is Subject of Ongoing Hearing
ML18082A1301980-03-19019 March 1980
Motion for 30-day Extension to File Testimony Re Consequences of Water Loss from Spent Fuel Storage Pool. Urges Postponement of 800422 Evidentiary Hearing, Accordingly.Notice of Appearance & Certificate of Svc Encl
ML18081B0861980-02-14014 February 1980
Request for Taking Official Notice of White House 800212, Fact Sheet,President'S Program on Radwaste Mgt, Due to Relevancy of First Bullet,Page 2 & Third Bullet,Page 6.W/ Certificate of Svc & Fact Sheet
ML18081A8881980-01-10010 January 1980
Opposition to Intervenors Coleman 791018 Request for Action Under 10CFR2.206.NRC Fulfilled Statutory Duty Per Endangered Species Act.No New Matters Raised by Intervenors Request
ML18081A8171979-12-18018 December 1979
Opposition to Public Advocate of State of Nj 791106 Request to Reopen Intervenors Coleman Contention 9.Appeal Is Proper Procedure If Intervenors Dissatisfied W/Aslb Initial Decision.Certificate of Svc Encl
ML18081A7471979-11-13013 November 1979
Response in Opposition to Public Advocate of State of Nj 791030 Supplemental Argument Supporting Motion for Reconsideration of Colemans Contention 13.Colemans Failed to Demonstrate Relevance of Claim.Certificate of Svc Encl
ML18081A6971979-10-30030 October 1979
Supplemental Argument on Behalf of Intervenors Coleman to Reopen Coleman Contention 13 Re Reracking of Spent Fuel Pool.Actual Figures of Radiation Exposure During Reracking of Peach Bottom Nuclear Station Never Received
ML18081A4181979-10-18018 October 1979
Petition Seeking NRC Issuance of Show Cause Order for Suspension &/Or Revocation of Ols.Operation of Facility Would Threaten Local Existence of short-nosed Sturgeon. Affidavit & Certificate of Svc Encl
ML18081A4871979-10-18018 October 1979
Seeks Show Cause Order & Suspension or Revocation of OL for Unit 1 & Stay or Licensing & Suspension or Revocation of CP for Unit 2.No Eia Performed Re Impact on Endangered Fish Species.Certificate of Svc Encl
ML18079A9711979-09-20020 September 1979
Applicant Comments on Request of Intervenors Coleman for Issuance of Order to Show Cause for Stay
ML18079B0891979-08-31031 August 1979
Opposes Intervenors Coleman 790801 Request That ASLB Reopen Record for Newly Discovered Evidence Re Contentions 2 & 6. Insp Document Has No Relevance & No Significance to Proceeding
ML19249B8201979-08-31031 August 1979
Petition to Amend 790802 Motion for Issuance of Show Cause Order & Stay of Licensing Procedure.Adds Addendum 7A & Contentions 8-10.Certificate of Svc Encl
ML19209C3871979-08-31031 August 1979
Motion,Submitted by Intervenors Coleman,That NRC Amend Request for Order to Show Cause & Stay Licensing.Seek Addl Contentions Re Cost/Benefit Analysis,Seismic Analysis & Class 9 Accidents
ML18081A4141979-08-31031 August 1979
Seeks Denial of Intervenors Coleman 790802 Motion for Reconsideration of Contention 13 Re Release of Radioactive Matl.No Justification for Late Filing.Criteria for Compliance W/Operation Objectives Defined in 10CFR50,App I
ML18079B1161979-08-29029 August 1979
Request by Intervenors Coleman That ASLB Accept Addl Argument on ASLB Question 4 Re Consideration of Class 9 Accidents.Nrc Admits That TMI Accident Was Class 9. Certificate of Svc Encl
ML18079B1151979-08-27027 August 1979
Response to ASLB Question 4 Re Class 9 Accidents.Tmi 790328 Accident Was Class 9,constituting Successive Failures of Operator Procedures & Equipment.Testimony in Present Proceedings Requires Wide Latitude.Certificate of Svc Encl
ML18079B0881979-08-21021 August 1979
Response to ASLB Question 4,submitted on Behalf of Intervenors Coleman.Alleges TMI Accident Was Class 9 Accident.Accident Posed Significant Risk to Health & Safety of Population & Environ.Certificate of Svc Encl
ML18079B0611979-08-20020 August 1979
Responds to Question 4 of ASLB 790710 Order.Forwards C Kepford Rept on TMI Accident.Prof Qualifications & Certificate of Svc Encl
ML18081A4111979-08-10010 August 1979
Requests That ASLB Order Extension Until 790831 for Response to Intervenors Coleman Request to Reopen Consideration of Contentions 2 & 6
ML18079B0461979-08-0303 August 1979
Forwards Re Webb 790723 Rept, TMI Accident:Was It Class 9 Accident, in Response to ASLB 790710 Question 4
ML19208C3681979-08-0202 August 1979
Requests Issuance of Order to Show Cause & Stay of Licensing Per 10CFR2.202 & 2.206.NRC Has Failed to Act on Info Re PA-NJ-MD Grid,Cost/Benefit Analysis,Expansion of Spent Fuel Pool & Lessons Learned Re TMI
ML18079B0851979-08-0202 August 1979
Request by Intervenors Coleman That ASLB Reconsider Dismissal of Contention 13.Intervenor State of Nj Supports Motion.Util Is Obliged Per 10CFR50 to Explore Alternatives to Spent Fuel Pool Expansion
ML19225D1441979-08-0202 August 1979
Request That NRC Issue Order to Show Cause & Request to Stay Licensing.Requests Intervenor Status.Submits List of Contentions & Partial List of Resouce Documents.Certificate of Svc Encl
ML18079B0871979-08-0101 August 1979
Request by Intervenors Coleman That ASLB Reopen Record Re Contentions 2 & 6.Intervenor State of Nj Supports Motion. Experiences at Northern State Power Co Are Pertinent to Proceedings
ML18079A7621979-07-0909 July 1979
Response Submitted by Intervernor Township of Lower Alloways Creek to NRC Motion to Strike Portions of Re Webb & EA Gulbransen Testimony Re ASLB 790418 Order. Affidavit of EA Gulbransen & Certificate of Svc Encl
ML18079A8311979-07-0606 July 1979
Request Submitted by Util for Denial of Intervenors Coleman 790625 Request for Reconsideration of Dismissal of Coleman Contention 7.NRC Must Remand Matter to Aslb. Certificate of Svc Encl
ML18079A8291979-07-0606 July 1979
Request Submitted by Util for Denial of Intervenors Coleman 790626 Request That ASLB Compel Licensee to Suppl Responses to Interrogatories 1,3 & 6.Questions Have No Relation to Grid Strap Problem
1984-01-25
[Table view] |
Text
U\ITED S'f:\Tf:S OF _-\_'.fERrc:\
\lJCLL-\.R REGUL\TORY co:\~:-II SS1 ex BEFCJRC: THE ATO;,JI C S_-\fl.~TY -~\D !.. I CE\:S IXG BOARD IN THE ;'.iATTER OF
)
PUBLIC SERVICE ELECTRIC A~D )
GAS cm-iPAXY )
) DOCKET NO. 50-272 (SALE:\1 :\UCLEAR GENERATI;\G )
STATION, UNIT NO. 1) )
INTERVE~ORS COLEMANS MOTION FOR EXTENSION OF THIE TO FILE TESTIMO:'.\Y A~D POSTPONE~1 IENT OF HEARI~G THEREON This proceedin~ i~ to consider the application of Pub lie Service Electric and Gas Comp.any, et .. al - (hereinafter.
"Licensee") for an amended operating licens_e to permit ..
increased storage of spent fuel in the Salem Generating *Station Unit 1. On February 22, 1980, the Atomic Safety and Licensing no
" arc.i (hereinafter "Board") issued a ~Iemorandur.1 and Order i...-h.ich, among other things, required consideration of the qt:cstion:
In the event of a gross loss of water from the spent fuel storage poo1, ~d1at would be the difference
- in consequences bet~een those occasioned by the pool with expanded storage and those occ:isioned by the prese*nt pool? (?-!er.10randum and Order:.
at 18).
The Board further directed evidentiary hearings on this question~
set for April 22, 1980. Te.stimony r.rnst be filed by March 24, 19SO.
This motion respectfully requests an extension of r,.1.;!12 ~o file testimony on the questj on cited above> for thirty
(:)0) 6ays, u.nd postponement of tl:e e*:identiary hearing thereon, accordingly. The ~otion is made for several compelling reasons.
FoT one, the Memorandum and Order of the Board 1-:as not docketed until February 25, 1980, and was not receiv~d in this office until :on or about February 28, i980. Thus, little airer three weeks ~ere provided for response. Such a limited time is inadequate to properly address the important question taised"by the Board. This is particularly so where intervenors' expert,
~lo musr be consulted on the question, is located in California~
More-0ver, .the attorney from this .office, Keith Onsdorff, Esquir*e, 1.:ho was respresenting the Colernans in these proceedings recently resigned, as indicated by his March 19, 1980 withdrawal of appearance. Thus, ne~ counsel had to be appointed, and famlliarized with the case and the issue at hand in order to prepare and file the testimony requested by the Board. In addition, the attorney no~ assigned to handle the hearings has other commitments at and arou:nd the April 22d date set for For the reasons set forth.above, intervenors urge that the Board grant this motion, In light of the Licensee's recent i'-lotion for Directed Certification on the Yali<lity of the Board's question, and Stay of Board proceedings pending decision thereon, intervenors' request for additional time hcul~ not appear to unduly prejuiice the Licensee:
Re.spectfull;-_ sub:ii_i t ted, STAXLEY C. VA~ NESS PUBLIC Aff\"OCATE
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Assistant Deputy *Public Advocate Counsel for Intervenors Colemans f.la r ch 19, 19 8 0
U~.; I *r EI> S.1. _.l.:i' l~ S C: F _:\.;\ i F P. I C_-'\_
XlJCLE..\R REGUL..!. TOf:.Y CiJ'.'.:-11SST0:\
BEFORE THE ATO:<IC s_.\r_. ~:Tl- . '*--.
_..:i.. .:.'.l..)
IN THE MATTER OF
~
PUBLIC SERVICE ELECTRIC ~
Al\'D GAS co:*.;p J\:\Y :1 DOCKET NO. 50-272
~
(SALEM i\UCLEAR GPH:RAT I\G ~
STATIOX, UNIT ~O. 1) 3 NOTICE OF APPEARANCE SANDRA T. AYRES, Assistant Deputy Public Advocate hereby notices the parties and licensing board in the above-captioned proceeding of her appearance as co-counsel, Kith Raymond E.
Makul, Assistant Deputy Public Advocate, for the Intervenors:
Colemans, effective immediately.
Respectfully submitted, STANLEY C. VA~ NESS occ:~sso PUBLIC ADYOCATE
\J~~'RO BY:
S :\ .'.\ lllZ.:.\ T . .*\'i RE S J Assistant Dc~uty Public Ad\~ocatc Division of Public Interest Advocacy 520 East State Street Trenton, Xe~ Jersey 08625 DATED: March 19, 1980 cc: Service List
r, rTJ:J) COR.RESPOl'i.1lENCE E~ECTRIC .A.Iffi GAS )
) 50-272 r:- 1 \ \
.h.._) * ...;.. I a:::d a notice of Appea.rance by Sandra T . .\:rres, AGsis'ta.nt De:;:iut:r Public Advocate, have* been served upon the :folloT,~ing by special deli ve-::-y C'ni te:i States r~ail, this 19th day of Marc,h, 198C.
Gery L. Milhollin, Esq. Cnair!rran, Atomic Saf"ety Chair:r:-..a.n, Atomic Safety Licensing :Eo:;.rd Panel a~d Licensing Board U .. S. ITuclear P..egrJ.la.tor:.-r 1815 Jefferson Street Co~-ruis3icn Madison, Wisconsin 53711 ;-1ashington, D.C. 20555 Mr. Frederick J. Shon Ja:."1.ice. I-~:Jore, ~.:Jq.
Mer.lber, Ator::ic Safety e.nd C.:~fice of the Exec-u.ti Ye Licensing Board Panel Lege.l Di2*ector U.S. ~bclear Regulatory u. s. r:uclear B.egUlatory Washington, D.C. 20555 Washi:15\..0!1, D .C. 20555 D=.* Ja::~s C. L.:1..~b, III Richard Fiucha~, ~sq.
i*;e:r::be1*, J..to:::nic Safety and Dep~t~r A.t~orr:ey Ge~1eral Depa.r~1~ent of L~;.; er~d P.~"bli.c 313 i,*Jvod.i~a--:rer:. Ro!id.
Ch::.:;iel Eill, iL C. 27514 Protection Sec"'cion Chair.::S1, Atomic Sa.fet:r* a:1d 36 1lest State Street Licensing Appeal Board Panel Trer:tcr., iI. rJ. 08625 U.S. :Nuclear Regulatory Co:m.":lission Carl ~..'alore, Esq_.
Washington, D.C. 20555 Val.ore, l:*~dU.lister, Aro-:i
~ ~*7estmoreland Richard Fryling, Jr~, Esq. :.:ainln.nci Professional Pla:::2.
Assistant Ge~eral Solicitor ? . J. 38~*= 175 Public Service Electric ~cr~hfiel~, ~-J. 09225
& G!:..s Cor::?.a.~iy 80 Park Place O~~i~e o: t~e Secretary Hewark, H.J. 07l0l Dcc~:etir!b ~:!(l 5e:r-.1'ice Sect.:.o~
U.S. :*~uc:ec..~ ?:.egtlatoryC~::-=i.ss::.~!1
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I*2. Al~::~:*e.J. C. C*:)l~~:::.r1, J*2...
I*1rs. E:..e.s.!!o-c* G. Cc*ler:-.. an 3 5 n:r~" B::i -~-e PenLs1rille, i*~cw ;;,- e::--s e:f C8070
