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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063C9281982-08-23023 August 1982 Motion for Clarification,Or in Alternative,Petition for Reconsideration of Aslab 820811 Memorandum & Order ALAB-686 Re Application of Immediate Effectiveness Regulation. Certificate of Svc Encl ML20062F7751982-08-11011 August 1982 Memorandum & Order ALAB-686 Subsequent to ASLB 820630 decision,LBP-82-49.Immediate Effectiveness Review of Mfg Licenses Not Warranted ML20054L9671982-07-0707 July 1982 Errata Order Furnishing Omissions from ASLB 820630 Initial Decision ML20054L8351982-07-0101 July 1982 Notice of Aslab Reconstituion.Cn Kohl,Chairman & WR Johnson & Ha Wilber,Members ML20039E8941982-01-0505 January 1982 Response to NRC 811230 Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20062M3171981-12-11011 December 1981 Proposed Findings of Fact & Conclusions of Law in Form of Proposed Initial Decision.Certificate of Svc Encl ML20010C0801981-08-12012 August 1981 Motion for ASLB to Establish Schedule Leading to Completion of Mfg License Proceeding.Hearing Process Should Be Resumed to Address New Matters Contained in Upcoming Ser,Suppl 4. Certificate of Svc Encl.Related Correspondence ML19347B8151980-10-10010 October 1980 Notice of Appearance in Proceeding.Certificate of Svc Encl ML19254D1371979-09-27027 September 1979 Notice of Appearance on Behalf of Nrdc.Certificate of Svc Encl ML19254E4381979-09-14014 September 1979 Response in Opposition to NRC-proposed Mods to 790824 Proposed Partial Findings of Fact in Form of Proposed Initial Decision,Set Forth in Paragraphs 20.D & 20.E.(2), Pages 18-19 of Proposed Findings.Certificate of Svc Encl ML19209C5241979-08-31031 August 1979 Motion for Extension Until 790914 to File Response to NRC 790824 Proposed Partial Findings of Fact.Findings Were Not Received Until 790829.Certificate of Svc Encl ML19225B5541979-06-0101 June 1979 Proposed Partial Findings of Fact in Form of Proposed Initial Decision Submitted by Offshore Power Sys to Aslb. Discusses Each Contention Admitted as Issue in Controversy & ASLB Questions.Certificate of Svc Encl ML19289F2091979-04-0404 April 1979 Motion to Establish Schedule for Filing of Partial Proposed Findings of Fact & Conclusions of Law.Proposed Schedule & Certificate of Svc Encl ML19274E6281979-03-0808 March 1979 Applicant'S Motion 10 to Establish Schedule for Hearing on Contentions 3a & 3c by Atlantic County Citizens Council on the Environ.Requests Parties File an Identification of Evidence.Certificate of Svc Encl ML19281B5151979-03-0808 March 1979 Statement of Matl Facts Which Are Not in Dispute.Applicant Not Able to Build Eight Plants by 1985.Statement Filed in Opposition to NRDC Statement of Matl Facts ML19261C3331979-02-20020 February 1979 Intervenor Withdraws from Active Participation in Licensing Hearings,Due to Util'S Withdrawal of Order for Floating Nuclear Plants Off Nj Coast.Certificate of Svc Encl ML19263D1641979-02-16016 February 1979 NRDC Statement of Matl Facts Which Are Not in Dispute Re Offshore Power Sys'S Intent to Build More than Eight Floating Nuclear Plants.Certificate of Svc Encl ML19263D1621979-02-16016 February 1979 Nrdc'S Memorandum in Support of Summary Disposition Motion. Urges That Programmatic Review of Floating Nuclear Plants Be Conducted.Certificate of Svc Encl ML19263D1601979-02-16016 February 1979 Motion for Summary Disposition Re Failure of Fes to Consider Environ Impact & Alternatives ML19282A6351979-02-12012 February 1979 Informs That Natural Resource Defense Council Missed Filing Deadline,But Plans to File a Brief on Its Contention & Remain in the Proceeding.Certificate of Svc Encl ML19289D1311979-02-0606 February 1979 Motion for Order Dismissing NRDC Programmatic Impact Statement Contention as an Issue Due to Nrdc'S Failure to Comply w/780801 ASLB Order Filing a Motion by 790129.Related Papers & Certificate of Svc Encl ML19274D6971979-02-0606 February 1979 Applicant'S Rept to ASLB Re Status of Hearings & Motion to Establish Schedule.Proposed Schedule Encl ML19259B2891979-01-31031 January 1979 Presentation on ALAB-489(8 NRC 194),NRC Class 9 Accident Reviews,Given at 790114-17 Conference on Legal & Legislative Affairs in Las Vegas,Nv ML19270F2171979-01-22022 January 1979 Reply Amicus Curiae Brief of Union of Concerned Scientists. Believes Applicant'S Facility Should Receive Special Treatment Since It Is Fundamentally Different.Hopes NRC Will Decide Issues in Public.W/Certificate of Svc ML19289C9451979-01-22022 January 1979 Brief by NRDC in Response to Opening Briefs.Case Comes Down to 1 of 3 Conclusions.Deciding Which of These Conclusions Is Correct Is the Heart of Applicant'S Case.Certificate of Svc Encl ML20099A3241979-01-22022 January 1979 Applicant'S Reply Brief Re Mfg License for Floating Nuclear Plant.Decision ALAB-489 Withholding Applicability of Annex to Floating Plant Cannot Stand ML19259B2971979-01-16016 January 1979 Brief by Intervenor State of Nj Urging Commission to Answer in the Affirmative Certified Question Whether Class 9 Accidents Are Proper Subj for Consideration in NRC Environ Statement.Certificate of Svc Encl ML19269C0891979-01-12012 January 1979 NRDC Brief Re Certification of Class 9 Accident Issue. Asserts Commission'S Only Proper Action Is to Order Evidentiary Hearing.Certificate of Svc Encl ML19289C8181979-01-12012 January 1979 Request of the CA Energy Resources Conservation & Development Commission on Issue of Class 9 Accidents. Provides Results of Commission Study of Undergrounding Nuclear Reactors & Class 9 Accidents ML19274D2961979-01-12012 January 1979 Brief of Applicant in Support of Aslab 781221 Order Holding That NRC May Consider Environ Impacts of Consequences of Accidents Beyond Design Basis in Fes.Certificate of Svc Encl ML20083K2881979-01-12012 January 1979 Ucs' Brief Amicus Curiae Re Consideration of Class 9 Accidents.Environ for OPS Proceeding Should Include Evaluation of Probability & Consequence of Class 9 Accidents.Supporting Documentation Encl ML19261A3161978-12-26026 December 1978 Requests Opportunity to Reply to NRC Applicant'S Allegations Re Interpretation of Ltr from Administrator of EPA to Ops. Brief Statement to That Purpose Attached.W/O Encl ML19259B0511978-12-19019 December 1978 Response by Applicant OPS in Opposition to NRDC Request for Directed Certification.Asserts NRDC Has Not Satisfied Criteria for Directed Certification.Epa 781103 Ltr & Certificate of Svc Encl ML20197D9361978-12-0707 December 1978 Pub Meeting in Washington DC on 781207:discussion & Vote on ALAB-500 Offshore Pwr Sys.Pp.1-18 ML20148Q8011978-12-0101 December 1978 Unofficial Transcript of 781201 Affirmation Session 78-30 in Washington,Dc Re OPS Order.Pp 1-3 ML20150E0171978-11-30030 November 1978 NRDC Request for Directed Certification.Expresses Concern Re Inshore Siting of Fnp'S.Finds No Reason to Believe Lic Bd Erred in Rejecting NRDC Contention.W/Encl Related Correspondence ML20204C9851978-11-22022 November 1978 Grants as a Motion, Informal Ltr Request That Bd Extend Deferral of Ruling Until After 781201 on Applicant'S Motion to Plead a Matter in Controversy & Establish a Discovery & Hearing Sched for Such Matter ML20150D0731978-11-21021 November 1978 Time in Which Comm May Determine to Review ALAB-489 & ALAB-500 Is Extended to 781208 ML20148L6161978-11-0909 November 1978 Denies NRDC Motions for Reconsideration of ASLB Order of 780911 & for Certification of 4 Questions to Aslab.Points Out That 10CFR2.758 Prohibits Challenges to NRC Rules & Regs ML19256A2881978-11-0707 November 1978 Intervenor Atlantic County,Nj Response to Memos of 781027 of Hendrie & Gilinsky Re Their Involvement W/Appl Prior to Their Appointments to Nrc.Has No Factual Basis on Which to Object to Commissioners' Participation.Cert of Svc Encl ML20148J5021978-11-0303 November 1978 NRC Staff'S Response to Memo to Counsel Filed by Hendrie & Gilinsky Re Possible Prior Knowledge.Staff Has No Objection to Either Commissioner Participating in Review of ALAB-500. W/Cert of Svc ML20148J2721978-11-0303 November 1978 NRDC Response to Memoranda to Counsel from Hendrie & Gilinsky Re Their Prior Involvement in Issues Re Subj Facil. NRDC Asserts That Disqual of the Commissioners Is Dependent Upon Certain Facts.Cert of Svc Encl ML20148J3381978-11-0202 November 1978 Response of Applicant OPS to Memoranda of Hendrie & Gilinsky to Counsel Re Commissioners' Impartiality in Proceedings Re Subj Facil.Applicant Has No Objection to Either Commissioner Participating in Review of Issues.Cert of Svc Encl ML20150D2381978-10-27027 October 1978 Rev Draft Order in the Matter of Offshore Pwr Sys(Floating Nuc Pwr Plants).Order Was Rev to Clarify That Proposed Review Will Deal W/Class 9 Accidents Only in Context of Floating Nuc Plants & Not as Overall NRC Opinion on Subj ML20197B3941978-10-27027 October 1978 Memo Disclosing Previous Involvement W/Applicant Re Facility During Sept 1974.Author Head of Physical Sciences Dept of Rand Corp.Draft Research Proposal Re Facility Prepared by Physical Sciences Dept in Sept 1974 Encl ML20148E5221978-10-26026 October 1978 Order Extending Time for Commission to Review ALAB-489 & ALAB-500 to 781117 ML20197B0711978-10-23023 October 1978 Grants Applicant 781010 Motion to Defer Ruling Until 781010 Based on Granting Applicant 780905 Motion to Plead Matter in Controversy & Establish Discovery & Hearing Schedule ML20147E0671978-10-0202 October 1978 Opposes Intervenor NRDC 780915 Request for Reconsideration & Certification of ASLB 780911 Order Denying NRDC 780809 Motion to Amend Contentions.Nrdc Has Not Established Grounds for Reconsideration ML20147D6251978-09-29029 September 1978 Applicant'S Motion to Certify to the NRC Question Decided by Aslab in ALAB-489 Is Granted.Held in ALAB-489 That Class & Accidents Are Proper Subj for Consideration in Staff'S Environ Statement Re Floating Nuc Pwr Plant Appl 1982-08-23
[Table view] Category:PLEADINGS
MONTHYEARML20063C9281982-08-23023 August 1982 Motion for Clarification,Or in Alternative,Petition for Reconsideration of Aslab 820811 Memorandum & Order ALAB-686 Re Application of Immediate Effectiveness Regulation. Certificate of Svc Encl ML20010C0801981-08-12012 August 1981 Motion for ASLB to Establish Schedule Leading to Completion of Mfg License Proceeding.Hearing Process Should Be Resumed to Address New Matters Contained in Upcoming Ser,Suppl 4. Certificate of Svc Encl.Related Correspondence ML19254E4381979-09-14014 September 1979 Response in Opposition to NRC-proposed Mods to 790824 Proposed Partial Findings of Fact in Form of Proposed Initial Decision,Set Forth in Paragraphs 20.D & 20.E.(2), Pages 18-19 of Proposed Findings.Certificate of Svc Encl ML19209C5241979-08-31031 August 1979 Motion for Extension Until 790914 to File Response to NRC 790824 Proposed Partial Findings of Fact.Findings Were Not Received Until 790829.Certificate of Svc Encl ML19225B5541979-06-0101 June 1979 Proposed Partial Findings of Fact in Form of Proposed Initial Decision Submitted by Offshore Power Sys to Aslb. Discusses Each Contention Admitted as Issue in Controversy & ASLB Questions.Certificate of Svc Encl ML19289F2091979-04-0404 April 1979 Motion to Establish Schedule for Filing of Partial Proposed Findings of Fact & Conclusions of Law.Proposed Schedule & Certificate of Svc Encl ML19281B5151979-03-0808 March 1979 Statement of Matl Facts Which Are Not in Dispute.Applicant Not Able to Build Eight Plants by 1985.Statement Filed in Opposition to NRDC Statement of Matl Facts ML19274E6281979-03-0808 March 1979 Applicant'S Motion 10 to Establish Schedule for Hearing on Contentions 3a & 3c by Atlantic County Citizens Council on the Environ.Requests Parties File an Identification of Evidence.Certificate of Svc Encl ML19261C3331979-02-20020 February 1979 Intervenor Withdraws from Active Participation in Licensing Hearings,Due to Util'S Withdrawal of Order for Floating Nuclear Plants Off Nj Coast.Certificate of Svc Encl ML19263D1601979-02-16016 February 1979 Motion for Summary Disposition Re Failure of Fes to Consider Environ Impact & Alternatives ML19263D1621979-02-16016 February 1979 Nrdc'S Memorandum in Support of Summary Disposition Motion. Urges That Programmatic Review of Floating Nuclear Plants Be Conducted.Certificate of Svc Encl ML19263D1641979-02-16016 February 1979 NRDC Statement of Matl Facts Which Are Not in Dispute Re Offshore Power Sys'S Intent to Build More than Eight Floating Nuclear Plants.Certificate of Svc Encl ML19282A6351979-02-12012 February 1979 Informs That Natural Resource Defense Council Missed Filing Deadline,But Plans to File a Brief on Its Contention & Remain in the Proceeding.Certificate of Svc Encl ML19274D6971979-02-0606 February 1979 Applicant'S Rept to ASLB Re Status of Hearings & Motion to Establish Schedule.Proposed Schedule Encl ML19289D1311979-02-0606 February 1979 Motion for Order Dismissing NRDC Programmatic Impact Statement Contention as an Issue Due to Nrdc'S Failure to Comply w/780801 ASLB Order Filing a Motion by 790129.Related Papers & Certificate of Svc Encl ML19269C0891979-01-12012 January 1979 NRDC Brief Re Certification of Class 9 Accident Issue. Asserts Commission'S Only Proper Action Is to Order Evidentiary Hearing.Certificate of Svc Encl ML19289C8181979-01-12012 January 1979 Request of the CA Energy Resources Conservation & Development Commission on Issue of Class 9 Accidents. Provides Results of Commission Study of Undergrounding Nuclear Reactors & Class 9 Accidents ML19261A3161978-12-26026 December 1978 Requests Opportunity to Reply to NRC Applicant'S Allegations Re Interpretation of Ltr from Administrator of EPA to Ops. Brief Statement to That Purpose Attached.W/O Encl ML19259B0511978-12-19019 December 1978 Response by Applicant OPS in Opposition to NRDC Request for Directed Certification.Asserts NRDC Has Not Satisfied Criteria for Directed Certification.Epa 781103 Ltr & Certificate of Svc Encl ML20150E0171978-11-30030 November 1978 NRDC Request for Directed Certification.Expresses Concern Re Inshore Siting of Fnp'S.Finds No Reason to Believe Lic Bd Erred in Rejecting NRDC Contention.W/Encl Related Correspondence ML19256A2881978-11-0707 November 1978 Intervenor Atlantic County,Nj Response to Memos of 781027 of Hendrie & Gilinsky Re Their Involvement W/Appl Prior to Their Appointments to Nrc.Has No Factual Basis on Which to Object to Commissioners' Participation.Cert of Svc Encl ML20148J5021978-11-0303 November 1978 NRC Staff'S Response to Memo to Counsel Filed by Hendrie & Gilinsky Re Possible Prior Knowledge.Staff Has No Objection to Either Commissioner Participating in Review of ALAB-500. W/Cert of Svc ML20148J2721978-11-0303 November 1978 NRDC Response to Memoranda to Counsel from Hendrie & Gilinsky Re Their Prior Involvement in Issues Re Subj Facil. NRDC Asserts That Disqual of the Commissioners Is Dependent Upon Certain Facts.Cert of Svc Encl ML20148J3381978-11-0202 November 1978 Response of Applicant OPS to Memoranda of Hendrie & Gilinsky to Counsel Re Commissioners' Impartiality in Proceedings Re Subj Facil.Applicant Has No Objection to Either Commissioner Participating in Review of Issues.Cert of Svc Encl ML20197B0711978-10-23023 October 1978 Grants Applicant 781010 Motion to Defer Ruling Until 781010 Based on Granting Applicant 780905 Motion to Plead Matter in Controversy & Establish Discovery & Hearing Schedule ML20147E0671978-10-0202 October 1978 Opposes Intervenor NRDC 780915 Request for Reconsideration & Certification of ASLB 780911 Order Denying NRDC 780809 Motion to Amend Contentions.Nrdc Has Not Established Grounds for Reconsideration 1982-08-23
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UNITED STATES OF AMERICA ,
p'l 3 jj ' fp NUCLEAR REGULATORY COMMISSION [: q"p .[
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Nej, x
In the Matter of :
OFFSHORE POWER SYSTEMS : Docket No. STN 50-437
(Manufacturing License for :
Floating Nuclear Power Plants) :
RESPONSE OF APPLICANT TO NRC STAFF'S PROPOSED PARTIAL FINDINGS OF FACT offshore Power Systems (" Applicant") submits the following response to the " Nuclear Regulatory Commission Staff's Proposed Partial Findings of Fact in the Form of a Proposed Initial Decision" (" Staff's Proposed Findings")
dated August 24, 1979:
- 1. Applicant objects to the NRC Staff's proposed modifications to " Appl _ cant's Proposed Partial Findings of Fact in the Form of a Proposed Initial Decision" ("Appli-cant's Proposed Findings") which are set forth in paragraphs 20.D. and 20.E.(2) of the Staff's Proposed Findings at pp. -
18-19. The modifications proposed by the Staff pertain to the Atlantic County Bodrd of Chosen Freeholders (" Atlantic County") resort economics contention. At the outset it should be noted that the Staff agrees that the record fully _
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supports Applicant's proposed finding of fact in paragraph 400 (Applicant's Proposed Findings, p. 173) that:
"the potential impact of siting an FNP on a resort economy which is charac-terized by the presence of tourists and leisure seekers is very small and well within the year to year fluctua-tions in the local economic activity of the coastal resort area."
While the Staff agrees with the foregoing proposed finding, it has proposed findings of fact in paragraphs 20.D. and 20.E.(2) which request the Board to disregard or discount certain testimony of Applicant relating to the Las Vegas weapons testing experience which Applicant submits adds additional support to Applicant's proposed finding of fact paragraph 400 quoted above. Applicant submits that the Board should reject the Staff's proposal in paragraph 20.D.
and the Staff's proposed finding of fact in paragraph 20.E.(2).
In paragraph 20.D., the Staff has requested the Board to delete paragraphs 391 through 394 of Applicant's Proposed Findings, wherein Applicant requested the Board to find that the presence of nuclear weapons testing at
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the Nevada Test Site in the vicinity of a resort area (Las Vegas, Nevada) made Las Vegas analogous to a resort community having a nuclear plant nearby. Further, Appli-gant requested the Board to find that the evidence Appli-
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cant presented established that despite the presence of 1283 986
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nuclear weapons testing near Las Vegas, its resort economy had flourished. The record fully supports these proposed findings (see, e.g., " Applicant's Testimony Regarding XVI.
Impact on aesort Economics" at pp. 8-10).
Applicant notes that intervenor Atlantic County Citizens Council on Environment ("ACCCE") made a motion at the hearing on May 17, 1977 to exclude from admission into evidence Applicant's testimony concerning the Las Vegas-nuclear weapons testing analogy (Tr. 6233-35).
ACCCE claimed, inter alia, that such testimony was not relevant to the Atlantic County contention. That motion, which was opposed by both Applicant and Staff, was rejected by the Board (Tr. 6242). Applicant's testimony concerning the analogy between the Las Vegas-nuclear weapons testing circumstance and the situation of a nuclear plant located near a resort community was presented by a panel of expert witnesses which included experts in demography, Dr. Dennis Mileti and Mr. K. T. Mao (see Tr. 6388, 6679). The Staff did not cross-examine Applicant's panel on the Las Vegas-nuclear weapons testing analogy; and no party presented testimony w'hich challenged the testimony of Applicant's
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panel concerning the Las Vegas-nuclear weapons testing analogy. Applicant submits that this analogy is valid and clearly constitutes additional support for the Board find-ing proposed by both Applicant and Staff that the potential -
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impact of siting an FNP on a resort economy which is characterized by the presence of tourists and leisure seekers is very small and well within the year-to-year fluctuation in the local economic activity of the coastal resort area.
- 2. Applicant also objects to the NRC Staff's proposed finding of fact paragraph 20.E. (1) (p. 18) for the following reasons:
In proposed finding of fact 20.E. (1) , the Staff alleges that Applicant's premise that " growth in popula-tion is an indicator of growth in tourism . . . was never firmly established". Moreover, the Staff claims that on at least two occasions, Applicant's panel contradicted itself on this point and urges the Board to give lesser weight to Applicant's testimony than to the Staff's testi-many on the resort economics contention.
In response to the foregoing, Applicant submits that the testimony of its expert witness panel clearly established that population growth is an indicator of growth in tourism in a resort economy, and that its wit-ness panel.never contradicted itself on this point. .,
The topic of the interrelationship between population growth and tourism in a resort economy was the subject of lengthy cross-examination by counsel for ACCCE (see Tr. 6289-6320). The Staff's proposed finding _
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of fact paragraph 20.E. (1) demonstrates that the Staff is confused about the import of the dialogue which ensued between the Applicant's witness panel and ACCCE counsel on this point. Applicant's panel repeatedly testified that a growth in population is an indicator of a growth in tourism in a resort economy (see Tr. 6313-14, 6318-19).
Contrary to the Staff's understanding, however, Applicant's panel never testified that a " growth in population is an indicator of a growth in tourism" without adding the qualifying words "in a resort economy". Moreover, Appli-cant's witness panel testified at length concerning factors which identify an economy as a resort economy (see Tr.
6320-30). Further, while Applicant's panel did testify that population growth is an indicator of growth in tour-
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ism in a resort economy, it did not testify that population growth in a resort economy causes a growth in tourism in that economy. As explained by Applicant's panel, when an attempt is made to assess the vitality of a resort economy, one looks at the factor of population growth in that econ-omy as a significant factor or indicator which allows one to make a r'easoned judgment as to whether tourism is in-creasing, decreasing or remaining about the same. However, when the Applicant's panel was asked the question of whether a growth in the population of a resort economy would cause an increase in the tourism at that resort, they were being 1283 989
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asked 1 Tignificantly different question, one they an-swered 3 te negative (Tr. 6316). Applicant's panel's answer to this latter question in no way contradicts its expert opinion, repeatedly stated, that population growth in a resort economy is an indicator of growth in tourism in that economy. In its proposed finding, the Staff, be-cause it failed to comprehend the significant difference between the word "cause" and the word " indicate", errone-ously requests a finding that Applicant's panel contradicted itself. The Board should reject such proposed finding.
Furthermore, with regard to the testimony of Applicant's panel on this subject, it should be noted that counsel for ACCCE moved to strike that testimony, based on the same misunderstanding of Applicant's testimony which the Staff has expressed in its proposed finding of fact in paragraph 20.E. (1) (Tr. 6307-12). In fact, Staff counsel supported that ACCCE motion to strike. The Board properly rejected that motion to strike (Tr. 6312). It should also be noted that the Staff never cross-examined Applicant's panel concerning this matter even though Applicant's testi-many on thi,s subject was available to the Staff for more ,
than a year.1 Moreover, no party presented any testimony
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1 Applicant's witness panel on the resort economics con-tention testified on May 17-20, 1977. When the hearing resumed more than a year later on July 10, 1978 with ~
Applicant's panel on the witness stand, the Staff ad-vised that it had no cross-examination (Tr. 6699).
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which challenged Applicant's testimony regarding Applicant's panel's professional opinion that population growth in a resort economy is an indicator of an increase in tourism in that economy.
For the foregoing reasons, Applicant submits that -
the Board should reject Staff proposed finding of fact paragraph 20.E. (1) .
Respectfully submitted,
/s/ Barton Z.
Cowan/JR}
/s/ Thomas M. Daugherty/JRK
/s/ John R. Kenrick Counsel for Applicant Offshore Power Systems Dated: September 14, 1979 *
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSICN BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of :
OFFSEORE PCWER SYSTEMS : Docket No. STN 50-437
(Manufacturing License for :
Floating Nuclear Power Plants) :
CERTIFICATE OF SERVICE I hereby certify that copies of the " Response of Applicant to NRC Staff's Proposed Partial Findings of Fact" were served upon the persons listed on Attachment 1 to this Certificate of Service by deposit in the United States mail (First Class), postage prepaid, this 14th day of September, 1979.
/s/ John R. Zenrick John R. Kenrick Counsel for Applicant
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Offshore Power Sys*.en. -
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ATTACHMENT 1 OPS SERVICE LIST Sheldon J. Wolfe, Esq., Chairman Director (2)
Atomic Safety and Licensing Board Division of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. David R. Schink, Member Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary Department of Oceanography U.S. Nuclear Regulatory Commission Texas A & M University Washington, D.C. 20555 College Station, Texas 77840 Stephen M. Schinki, Esq.
Mr. Glenn O. Bright, Member Marc R. Staenberg, Esq.
Atomic Safety and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. David L. Hetrick, Alternate Member Atomic Safety and Licensing Board Barton Z. Cowan, Esq.
Professor of Nuclear Engineering John R. Kenrick, Esq.
The University of Arizona Eckart, Seamans, Cherin & Mellott Tucson, Arizena 85721 600 Grant Street Forty-Second Floor Alan 1. Rosenthal, Esq. , Chairman Pittsburgh, Pennsylvania 15219 Atomic Safety and Licensing Appeal Board Panel Thomas M. Daugherty, Esq.
U.S. Nuclear Regulatory Commission Offshore Power Systems Washington, D.C. 20555 8000 Arlington Expressway P. O. Box 8000 Alternate Chairman Jacksonville, Florida 32211 Atomic Safety and Licensing Appeal Board Panel Carl Valore, Jr., Esq.
U.S. Nuclear Regulatory Commission Valore, McAllister, DeBrier, Aron &
Washington, D.C. 20555 Westmoreland Mainland Professional Plaza Chief Hearing Counsel. 535 Tilton Road Office of the Executive Legal P. O. Box 152 Director Northfield, New Jersey 08225 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1283 993
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Richard M. Hluchan, Esq. Mr. Harold P. Abrams, President State of New Jersey Atlantic County Citizens Council Department of Law and Public Safety on Environment 36 West State Street 9100 Amherst Avenue Trenton, New Jersey 08625 Margate, New Jersey 08402 Anthony Z. Roisman, Esq. Dr. Willard W. Rosenberg, Chairman Natural Resources Defense Council, Inc. Energy Committee 917 Fifteenth Street, N.W. Atlantic County Citizens Council Washington, D.C. 20005 on Environment 8 North Rumson Avenue Keith A. Onsdorff, Esq. Margate, New Jersey 08402 Assistant Deputy Public Advocate State of New Jersey Mr. John H. Williamson Post Office Box 141 Energy Committee Trenton, New Jersey 08601 Atlantic County Citizens Council on Environment Mr. George B. Ward 211 Forest Drive Nuclear Power Plant Committee Linwood, New Jersey 08221 City Hall Brigantine, New Jersey 08203 1283 994
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