ML19029A863

04/25/1979 State of New Jersey'S Outline of Cross-Examination

ML19029A863
Person / Time
Site:	Salem
Issue date:	04/25/1979
From:	Degnan J, Hluchan R State of NJ, Office of Attorney General
To:	Atomic Safety and Licensing Board Panel
References
Download: ML19029A863 (4)

Text

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I UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket No. 50-272

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PUBLIC SERVICE ELECTRIC & Proposed Issuance of Amendment GAS COMPANY ~

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to Facility Operating License No. DPR-70 (Salem Nuclear Generating )

Station, Unit No. 1 )

STATE OF NEW JERSEY'S OUTLINE OF CROSS-EXAMINATION The State of New Jersey, a party to this proceeding by virtue of 10 C.F.R. §2.715(c), hereby gives notice, pursuant to the Board's directive, of the areas in which it expects to conduct cross-examination of witnesses at the hearing connnencing May 2, 1979.

1. Colemans' Contentions 2 and 6: The State expects to cross-examine all witnesses as to: density of proposed

~torage of spent fuel; past experience at other reactor sites, and results of testing, respecting rack degradation and storage of spent fuel; licensee's proposed surveillance techniques; and leaking of fuel storage cells, resultant effects, consequences and proposed remedial measures. Estimated time: 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

2. Lower Alloways Creek Township *contention 1: The State expects to cross-examine all witnesses as to: cost and feasibility of ISFI construction; P.S.E.&G. 's efforts to construct ISFis; and feasibility of license amendment with conditions should availability of AFR-ISFI be demonstrated in the future.

Estimated time: 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

The State reserves the right to cross-examine witnesses who testify on the "Three Mile Island" issues raised by the Board in its Order dated April 18, 1979. The State also reserves the right to engage in any cross-examination which may be necessary to address relev~nt and probative points raised at the hearing, without regard to the above outline.

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JOHN J. DEGNAN Attorney General of New Jersey Attorney for State of New Jersey

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Richard M*. Hluchan Deputy Attorney General DATED: April 25, 1979

CERTIFICATE OF SERVICE I hereby certify that copies of State of New Jersey's Outline of Cross-Examination have been served upon each of the addressees on the attached list by deposit in the U.S. mail this 25th day of A~ril, 1979.

Richard M. Hluchan Deputy Attorney General

Gary L. Milhollin, Esquire Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Board Licensing Board U.S. Nuclear Regulatory Commission 1815 Jefferson Street Washington, D.C. 20555 Madison, Wisconsin 53711 Mr. Lester Kornblith, Jr. Troy B. Conner, Jr., Esquire Member, Atomic Safety and Suite 1050

• Licensing Board 1747 Pennsylvania Ave., N.W.

U.S. Nuclear Regulatory Comm. Washington~ D.C. 20006 Washington, D.C. 20555 Dr. James C. Lamb, III Barry Smith, Esquire Member, Atomic Safety and Off ice of *the Executive Legal Licensing Board Panel Director 313 Woodhaven.Road U.S. Nuclear Regulatory Commission Chapel Hill, No. Carolina 25714 Washington, D.C. 20555 Chairman, Atomic Safety and June D. MacArtor, Esquire Licensing Appeal Board Deputy Attorney General U.S. Nuclear Regulatory Comm. Tatnall Bldg.

Washington, .D.C. 20555 P. O. Box 1401 Dover, Delaware 19901 Richard Fryling, Jr., Esquire Carl Valore, Esquire Assistant General Solicitor 535 Tilton Road Public Service Electric and Northfield, New Jersey 08225 Gas Company 80 Park Place Newark, New Jersey 07101 Eleanor G. Coleman Dale Bridenbaugh Alfred c. Coleman Gregory Minor 35 "K" Drive M.H.B. Technical Associates Pennsville, New Jersey 08070 366 California Avenue, Suite 6 Palo Alto, California 95306 Janice E. Moore* Keith A. Onsdorff, Esquire Counsel for NRC Staff Asst. Deputy Public Advocate U.S. Nuclear Regulatory Comm. Dept. of the Public Advocate Office of the Executive Legal 520 East State Street Director Trenton, New Jersey 08625 Washington, D.C. 20555 Office of the Secretary Docketing and Service Section U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555