ML20003B085
| ML20003B085 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 02/09/1981 |
| From: | Hiestand O DAIRYLAND POWER COOPERATIVE |
| To: | |
| References | |
| NUDOCS 8102100332 | |
| Download: ML20003B085 (4) | |
Text
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Fi,.m ' $8] y 7 F ',,,i M W 01-p c. 3 J g M * ~,~l NUCLEAR REGULATORY COMMISSION g,
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p u.s.gLame In The Matter Of
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' "sDKIRYfAt ' POWER COOPERATIVE
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Docket No. 50-409 y '
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(Liquefaction /Show (La Crosse Boiling Water
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Cause Order Hearing)
Reactor
)
LICENSEE'S REPLY TO NRC STAFF'S PROPOSED FINDINGS OF FACT, CONCLUSIONS OF LAW AND SUPPORTING BRIEF Pursuant to 10 C.F.R. 5 2.754(a)(3) and the Licensing Board's January 6, 1981 Prehearing Conference Memorandum, Dairyland Power Cooperative (Dairyland), the Licensee in the above-captioned proceeding, hereby submits its reply to the NRC-Staff's pronosed findings of fact, conclusions of law and brief in support thereof, dated January 30, 1981, as follows:
The proposed findings of fact and conclusions of law submitted by the NRC Staff completely support the proposed findings of fact and conclusions of law previously' submitted i
by the Licensee on January 5, 1981, as indicated in the supporting briefs submitted by both the Licensee and the NRC Staff.
The uncontroverted evidence in the record conclusively demonstrates that reasonable assurance exists that LACBWR can continue to operate safely beyond February 25, 1981 without a dewatering system to preclude liquefaction.
Consolidated Intervenors presented no evidence to the contrary, and failed-psO(I 90 8 102100331 6~
. to submit any proposed findings of fact or conclusf.ons of law whatsoever.
For the reasons set forth in the Licensee's initial brief and the NRC Staff's brief, the Board should therefore issue an order in substantially the form proposed by either the Licensee or the Staff as soon as possible.
Respectfully submitted, r
9L-
. S. Mi stand i
Attorney for Dairyland Power Cooperative OF COUNSEL Kevin P. Gallen Steven A. Glazer Morgan, Lewis & Bockius 1800 M Street, N.U.
tiashington, D. C.
20036 Dated:
February 9, 1981
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter C r
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DAIRYLAND POWER COOPERATIVE
)
Docket No. 50-409
)
(Liquefaction /Show (La Crosse Boiling Water
)
Cause Order Hearing)
Reactor
)
CERTIFICATE OF SERVICE Service has on this day been effected by personal delivery or first class mail on the following persons:
Charles Bechhoefer, Esquire Docketing & Service Section Chairman, Atomic Safety and Office of the Secretary Licensing Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C.
20555 Atomic Safety & Licensing Mr. Ralph S. Decker Board Panel Route 4' U.S. Nuclear Regulatory Box 190D Commission Cambridge, Maryland 21613 Washington, D.C.
20555 Dr. George C. Anderson Atomic' Safety & Licensing Department of Oceanography Appeal Board University of Washington U.S. Nuclear Regulatory Seattle, Washington 98195 Commission Washington, D.C.
20555 Steven Burns, Esquire Office of Executive Legal Karen Cyr, Esquire Director Office of Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Mr. Richard Shimshak Plant Superintendent-Fritz Schubert, Esquire-Dairyland Power Cooperative Staff Attorney La Crosse Boilding Water Dairyland Power Cooperative Reactor 2615 East Avenue, South Genoa, Wisconsin 54632 La Crosse, Wisconsin 54601
i 2-Coulee Region Energy Coalition P. O. Box 1583 La Crosse, Wisconsin 54601 Attn:
Ms. Anne Morse Mr. Harold Denton Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Frederick M. Olsen, III 609 N. lith Street La Crosse, Wisconsin 54601
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Hiestand 74
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Dated:
February 9, 1981 4
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