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| ML18079A762 |
| Person / Time |
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| Site: |
Salem  |
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| Issue date: |
07/09/1979 |
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| From: |
Valore C
VALORE, C. |
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| To: |
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| References |
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| NUDOCS 7908080007 |
| Download: ML18079A762 (5) |
|
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1984-01-25
[Table view] |
Text
- UNITED STATES OF AME RI CA NUCLEAR REGULATORY COMMISSION.
Before the* Atomic Safety and Licensing Board Doeket No. 50-272 In the Matter of Proposed Issuance of Amendment to Facility PUBLIC SERVICE ELECTRIC Operating License
& GAS COMPANY to DPR-70 (Salem Nuclear Generating Station, Unit #1)
~-... .......~.~. . ,.. ~~ -*
rj>* u~~~;~:i,-:::~~2~:. '* ..
- * * . THE. TOWNSHIP OF LOWER ALLOWAYS CREEK
- RESPONSE TO NRC STAFF OBJECTIONS AND MorION TO STRIKE PORTIONS OF TESTIMONY FILED BY INTERVENOR TOWNSHIP OF LCMER ALLOWAYS CREEK IN RESPONSE TO QUESTIONS POSED BY THE LICENSING BOARD BY ORDER OF APRIL
- 19 , 1979 The Township of Lower Alloways Creek opposes the NRC Staff Motion to Strike testimony of Dr. Richard E. Webb and Dr. Ear 1 A. Gulbransen. Annexed hereto is the Affidavit of Dr. Earl A. Gulbransen.
The Attorney for Township of Lower Alloways Creek requests oral argument to oppose _the Motion to Strike the testimony of Dr. Richard E. Webb in that said Motion to Strike is in the nature of legal argument and does not require an Affidavit in rebuttal.
ial r the Intervenor r Alloways Creek July 9, 1979 I
- UNITED' STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
, ?
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Docket No. 50-272 .....*..
In the Matter of:*-~
Proposed Issuance of PUBLIC SERVICE ELECTRIC Amendment to Facility
& GAS COMPANY Operating License .
No. DPR-70 (Salem Nuclear Generating Sta*t~on,. Unit #1)
.*.* ..
Earl A. Gulbransen, of full age, upon his oath deposes and says:
- 1.
- I have reviewed the NRC Staff Motion to Strike my testimony dated June 29, 1979.
- 2. The purpose of my testimony*was to indicate:
a} A melt down or explosion in the containment building could involve the spent fuel pool by means
. of a pool fracture or other mechanism causing loss of water.
~ *. '
---~--~~*
- b) An explosion or melt down as posed in the Board's question could create maintenance or accessbility problems due to radioactivity* or.
loss of power:.,.
- EARL A. GULBRANSEN
. ~ .....
Sworn to and sub~ed to before me this</'~ of July, 1979.
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"e UNITED STATES OF ]\MERICA_
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NUCLEAR REGULATORY COMMISSION *.v~~**.-,
"'-..*4,i Before the* Atomic s*af*ety and Licensing Board In the Matter of PUBLIC SERVI <E ELECTRI"C DOCKET NO,
& GAS CO.
(Salem Gene%atin9 Station **
Unit fl)
.*
- CE;RTIFICATE OF SERVICE I hereby certify that copies of TOLAC's NRC Staff Objection & Motion in the above captioned matter have been served upon the* attached list by deposit~iri the Utiited States mail at the post office in Northfield, N.J., with proper postage thereon, this 10th day of July , 1979.
/s/ Carl Valore, Jr.
CA:RL VALORE, JR~, Special Nuclear Counsel tor the Intervenor, the Township of Lower Alloways Creek Dated: ,Tuly *10, 1979
,,
fiili Gary L. Milhollin,. Esq. Richard Fryling, Jr., Esquire Chairman, Atomic Safety Assistant General Solicitor
& Licensing Board Public Service Electric &
1815 Jefferson Street Gas Company Madison, Wisconsin 53711 80 Park Place Newark, N. J. 07101 Glen O. Bright Member, Atomic Safety Keith Ansdorff, Esquire
& Licensing Board Assistant Deputy Public Advocate U. s. Nuclear Regulatory ~ommission Department of the Public Advocate Washington, D. C. 20555 Division of Public Interest Advoca P. O. Box 141
- Dr ..James _C. Lamb, -111 ... Trenton, New Jersey 08601 Member, Atomic .. ~af ety _& :, ., . *. .- ...
Licensing. Board Panel :'*?- ,.-; . _-:. *: ;-.:* Sandra T. Ayres, Esquire ... *.
313 Woodhaven Road * * * *- Department of the Public Advocate Chapel Hill, N. C. 27514 520 East State Street Trenton, N. ~* 08625 Chairman, Atomic Safety and Licensing Appeal Board Panel Mr. Alfred C. Coleman, Jr.
U. S. Nuclear Regulatory Commission Mrs. Eleanor G. Coleman Washington, D. C. 20555 35 "K" Drive
- Pennsville, N. J. 08070 Chairman, Aiomic Safety &
Licensing Board Panel Off ice of the Secretary U. S. Nuclear Regulatory Commission Docketing and Service Section _
Washington, D. C. 20555 U. S. Nuclear Regulatory Commissio Washington, D. C. 20555 Barry Smith, Esquire Off ice of the Executive Legal Director June D. MacArtor, Esquire
- u. s. Nuclear Regulatory Commission Deputy Attorney General Washington, D. C. 20555 Tatnall Building, P. o. Box 1401 Dover, Delaware 19901 Mark L. First, Esquire Deputy.Attorney General *Frederick J. Shon Department of Law & Public Safety Atomic Safety & Licensing Board '
Environmental Protection Section U.S. Nuclear Regulatory Commissi 36 West State Street Washingtori, D-.c., 20555 Trenton, N. J. 08625 Mark J. Wetterhahn, Esquire for Troy B. Conner, Jr., Esq.
1747 Pennsylvania Avenue, N. W.
Suite 1050 Washington, D. C. 20006