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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20209H6691999-07-12012 July 1999 Comment Supporting Proposed Rule 10CFR50 Re Elimination of Requirement for Licensees to Update Inservice Insp & Inservice Testing Programs Beyond Baseline Adition & Addenda of ASME BPV Code ML20203G6131998-01-26026 January 1998 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Interim Rept 739459-97,dtd 971015 Be Withheld from Public Disclosure ML20203G6031997-12-0404 December 1997 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 Be Withheld from Public Disclosure PLA-4330, Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control1995-06-0808 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control PLA-4193, Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety1994-08-31031 August 1994 Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety ML20046A9531993-07-20020 July 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rule ML20045F7971993-06-21021 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule in Part & Opposes Rule in Part ML20045D7461993-06-21021 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Disagrees W/Maintaining 100% Rate for Contractor & Vendor Employees ML20044F8361993-05-24024 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rules ML20044F7511993-05-24024 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. PLA-3744, Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners1992-03-0909 March 1992 Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners PLA-3568, Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a1991-04-0808 April 1991 Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a PLA-3462, Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants1990-10-15015 October 1990 Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants ML19332G5261989-12-0606 December 1989 Comments on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Industry Has Made Substantial Progress Re Maint Performance as Indicated by Respective Performance Indicators,Commission Insps & Plant Conditions PLA-3175, Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants1989-03-29029 March 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235V4001989-03-0202 March 1989 Comment on Proposed Rule 10CFR50 Re Maint Program at Nuclear Plants.Proposed Maint Rule Has Potential to Significantly Undermine Util Initiatives & Direct Limited Resources Away from Real Improvements in Maint PLA-3157, Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained1989-02-24024 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained PLA-3118, Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule1988-11-17017 November 1988 Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons PLA-3019, Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking1988-04-15015 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking PLA-2726, Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift1986-09-25025 September 1986 Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift ML20138A9521985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20027D4441982-11-0202 November 1982 Response to Aslab 821026 Order Requesting Info on RCS Leak Rate Detection.Util Preparing Tech Spec to Limit Increase in Unidentified RCS Leakage to 2 Gpm within 4-h Period ML20027D4471982-11-0101 November 1982 Affidavit of Wj Rhoades Correcting Response to Hearing Question on Leak Rates.Leak Rate Sys Capable of Detecting 1 Gpm Per Hour.Tech Specs Will Require Shutdown for Unidentified Leakage of 5 Gpm.Certificate of Svc Encl ML20069D8321982-09-0909 September 1982 Original Signature Page to Sh Cantone Affidavit.Svc List Encl ML20027B2291982-09-0909 September 1982 Stipulation of Withdrawal of Commonwealth of PA 820428 Exceptions Re Supply of TLD ML20065A9541982-09-0909 September 1982 Affidavit of Sh Cantone Re Dosimetry for Emergency Workers at Plant.Prof Qualifications Encl ML20027B2231982-09-0909 September 1982 Motion to Withdraw Commonwealth of PA 820428 Exceptions to Initial Decision,Contingent Upon Approval of Util & Commonwealth of PA 820909 Stipulation ML20027B2351982-09-0808 September 1982 Affidavit of AL Belser & Rj Hippert Responding to Questions in Aslab 820820 Order & Supporting Stipulation Withdrawing Exceptions.When Stipulated Number of Dosimeters Available, Emergency Workers Will Be Protected.W/Certificate of Svc ML20027B2331982-09-0808 September 1982 Affidavit of Ma Reilly Responding to Question in Aslab 820820 Order & Supporting 820909 Stipulation. TLD Necessary to Document Exposure of Officials Helping Contaminated Evacuees ML20063A4041982-08-18018 August 1982 Petition for Reconsideration of Commission 820809 Order Rendering ASLB Initial Decision Effective.Exceptions to Decision Require Resolution.Commission Order Premature. Certificate of Svc Encl ML20062J6391982-08-13013 August 1982 Order Directing Parties to Identify Person Presenting Arguments at 820908 Hearing in Bethesda,Md.Response Requested No Later than 820831 ML20058J6651982-08-0909 August 1982 Order Rendering ASLB 820412 Decision Authorizing OL Issuance Effective.Full Power OL Not Yet Authorized ML20054L5081982-07-0606 July 1982 Brief Opposing Commonwealth of PA 820428 & Citizens Against Nuclear Dangers 820421 Exceptions to ASLB 820412 Initial Decision.Pa Fails to Prove Dosimetry Issue Timely Raised. Citizens Failed to Comply W/Procedure.W/Certificate of Svc ML20054L2841982-07-0202 July 1982 Brief Opposing Commonwealth of PA 820428 Exceptions to ASLB 820412 Initial Decision Authorizing OL Issuance.Commonwealth Fails to Justify License Condition Imposition Re Availability of Dosimetry.Certificate of Svc Encl ML20054J5611982-06-25025 June 1982 Brief Opposing Citizens Against Nuclear Danger 820421 Exceptions to ASLB 820412 Initial Decision.Exceptions Fail to Comply W/Commission Regulations & Raise Issues Not Presented Before Aslb.Certificate of Svc Encl ML20053D2191982-05-28028 May 1982 Brief Supporting Commonwealth of PA Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20053D0801982-05-28028 May 1982 Brief in Support of Exceptions to ASLB 820412 Initial Decision Authorizing Issuance of Ols.Shortage in Supply of Dosimeters for Emergency Workers Clear & Uncontroverted. Certificate of Svc Encl ML20052B7461982-04-28028 April 1982 Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20052A2751982-04-21021 April 1982 Exceptions to ASLB Initial Decision.Certificate of Svc Encl ML20054C6551982-04-15015 April 1982 Response Opposing Citizens Against Nuclear Dangers 820402 Proposed Findings of Fact & Conclusions of Law.Requirements for Reopening Record Not Met.No Showing That Allegations Raise Significant Safety Issues.Certificate of Svc Encl ML20050D4191982-04-0202 April 1982 Proposed Findings of Fact & Conclusions of Law Based on Important New Info & Recommendations to NRC Commissioners & Congress.Certificate of Svc Encl ML20042C2701982-03-26026 March 1982 Proposed Findings of Fact & Conclusions of Law Re Emergency Evacuation Plan ML20042C2781982-03-26026 March 1982 Motion for Order That Applicants Conduct Complete Retest of Emergency Plan W/All 20 Communities Participating.Testimony on Contentions 6 & 20 Should Be Reviewed to Identify Perjury by Fema,Applicants & State of Pa.Certificate of Svc Encl ML20069B0301981-12-22022 December 1981 Reply to Parties' Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20039B0791981-12-16016 December 1981 Proposed Transcript Corrections.Certificate of Svc Encl ML20062M2141981-12-0909 December 1981 Proposed Transcript Corrections ML20039A1951981-12-0909 December 1981 Proposed Findings of Fact & Conclusions of Law ML20038C0131981-12-0303 December 1981 Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20038A8891981-11-17017 November 1981 Motion to Take Official Notice of Existence & Content of Listed Documents Relevant to Contention 21.Validity of Info in Documents Could Be Subj to Dispute.Certificate of Svc Encl.Related Correspondence 1999-07-12
[Table view] Category:PLEADINGS
MONTHYEARML20027B2231982-09-0909 September 1982 Motion to Withdraw Commonwealth of PA 820428 Exceptions to Initial Decision,Contingent Upon Approval of Util & Commonwealth of PA 820909 Stipulation ML20063A4041982-08-18018 August 1982 Petition for Reconsideration of Commission 820809 Order Rendering ASLB Initial Decision Effective.Exceptions to Decision Require Resolution.Commission Order Premature. Certificate of Svc Encl ML20052B7461982-04-28028 April 1982 Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20042C2781982-03-26026 March 1982 Motion for Order That Applicants Conduct Complete Retest of Emergency Plan W/All 20 Communities Participating.Testimony on Contentions 6 & 20 Should Be Reviewed to Identify Perjury by Fema,Applicants & State of Pa.Certificate of Svc Encl ML20038A8891981-11-17017 November 1981 Motion to Take Official Notice of Existence & Content of Listed Documents Relevant to Contention 21.Validity of Info in Documents Could Be Subj to Dispute.Certificate of Svc Encl.Related Correspondence ML20011A2321981-10-0101 October 1981 Support for Contention 4 & Position on New Contentions. Motion for Summary Disposition of Contention 4 Should Be Denied Since Util Cancellation of Unit 2 May Be Best Solution.Certificate of Svc Encl ML20011A2121981-09-30030 September 1981 Appeal of ASLB 810924 Memorandum & Order,Section 5,granting Applicant Motion for Summary Disposition of Portion of Contention 2 Re Magnitude of Doses from Releases of Radioactive Matl.No Basis to Decision.W/Certificate of Svc ML20010J6231981-09-30030 September 1981 Response Supporting NRC 810911 Motion for Summary Disposition of Portion of Contention 1 Re Radiological Health Effects of Isotopes Other than Rn-222 & Tc-99.Health Effects Adequately Addressed in Fes ML20010H7931981-09-22022 September 1981 Answer Opposing Citizens Against Nuclear Dangers 810912 Notice of Appearance for Purposes of Presenting Direct Testimony & Motions Before Aslb.Consolidation of Contentions Unnecessary.Certificate of Svc Encl.Related Correspondence ML20140B1981981-09-10010 September 1981 Response Supporting Applicants 810828 Motion for Partial Summary Disposition of Contention 1 Re Fuel Cycle Doses.Also Moves for Summary Disposition of Portion of Contention 1 Re Radiological Health Effects of All Isotopes ML20140B1931981-09-10010 September 1981 Answer Opposing Susquehanna Environ Advocates 810822 Motion for Allowance of New Contention.Motion Is Untimely & Balancing Factors Do Not Weigh in Intervenors Favor. Certificate of Svc Encl ML20140B1651981-09-10010 September 1981 Motion for Summary Disposition of Contention 14 Re cost-benefit Balance.No Genuine Issue of Matl Fact Exists & NRC Entitled to Favorable Decision as Matter of Law ML20010G2271981-09-0808 September 1981 Comments on Susquehanna Environ Advocates 810831 Filing on Expert Witnesses.Filing Inadequate & Fails to Meet ASLB 810814 Mandate.Reserves Right to Seek Relief If Intervenor Files Testimony.W/Certificate of Svc.Related Correspondence ML20010G2981981-09-0808 September 1981 Response to ASLB 810814 Memorandum & Order,Filing Qualifications,Identities,Subj Matter & Substance of Testimony of Expert Witnesses for Contentions 2,6,9,11,14,20 & 21.Certificate of Svc Encl.Related Correspondence ML20140B4381981-09-0202 September 1981 Answer to Citizens Against Nuclear Dangers 810827 Filing. Applicants Oppose Several Motions & Arguments.Allegations Re Chlorine Portion of Contention 2 Are Moot.No Valid Reason for Addl Prehearing Conference.Certificate of Svc Encl ML20010F4541981-08-31031 August 1981 Motion for Summary Disposition of Contention 7C Re BWR Core Spray Nozzle Cracking.No Genuine Issue of Matl Fact Exists. Certificate of Svc Encl.Related Correspondence ML20010F5411981-08-31031 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 7B.Certificate of Svc Encl ML20010F4741981-08-31031 August 1981 Motion for Summary Disposition of Contention 7B Re Cracking of Stainless Steel Piping in BWR Coolant Water Environ Due to Stress Corrosion.No Genuine Issue of Matl Fact Exists ML20010F4431981-08-31031 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 7C.Related Correspondence ML20005B7991981-08-28028 August 1981 Motion for Partial Summary Disposition of Portion of Contention 1 Re Magnitude of Radioactive Doses That Will Be Imparted on Public by Release of All Isotopes During Fuel Cycle.Certificate of Svc Encl.Related Correspondence ML20005B8241981-08-28028 August 1981 Statement of Matl Fact as to Which There Is No Genuine Issue,Supporting Applicants Motion for Summary Disposition of Contention 1 Re Fuel Cycle Doses.Related Correspondence ML20010F4001981-08-27027 August 1981 Response in Opposition to ASLB 810814 Directives & Motions on Testimony & Public Hearings Conference.Date That Correspondence Is Required to Be Mailed Is Incorrect & Only Two Aspects of Contention 2 Are Listed for Consideration ML20010C9811981-08-19019 August 1981 Statement of Issues for Commonwealth of PA Participation,Per ASLB 810727 Memorandum & Order.Particular Interest Shown in Contentions 5,7(D),11 & 21.Related Correspondence ML20010C8631981-08-18018 August 1981 Renewed Motion for Summary Disposition of Contention 17.No Genuine Issue of Matl Fact to Be Heard.Applicants Are Entitled to Favorable Decision as Matter of Law ML20010C8671981-08-18018 August 1981 Memorandum Supporting Applicants' 810818 Renewed Motion for Summary Disposition of Contention 17.Michaelson Affidavit Sufficiently Addresses Issues & Constitutes Adequate Basis for Granting Motion ML20010C9491981-08-18018 August 1981 Statement of Matl Facts as to Which There Is No Geniune Issue to Be Heard Re Contention 17.Certificate of Svc Encl ML20010C0771981-08-13013 August 1981 Motion for Partial Summary Disposition of Contention 2 Which Questions Magnitude of Facility Low Level Radioactive Releases.Certificate of Svc Encl ML20010C1471981-08-13013 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 2 on Source Term ML20010C9781981-08-10010 August 1981 Memorandum of Law in Response to Applicants' 810727 Ltr.All Parties in Proceeding Have Right to Present Rebuttal Evidence.Related Correspondence ML20010B3971981-08-0707 August 1981 Memorandum in Support on 810807 Motion for Summary Disposition of Contention 1 Re Quantity of Rn-222 to Be Released During Fuel Cycle ML20010B4091981-08-0707 August 1981 Statement of Matl Fact as to Which There Is No Genuine Issue Re Contention 1 Concerning Rn-222 ML20010B4041981-08-0707 August 1981 Motion for Summary Disposition of Contention 1 Re Rn-222. Issue Should Not Be Relitigated Under Accepted Principles of Collateral Estoppel & Stare Decisis.No Genuine Issue to Be Heard ML20009H2281981-08-0404 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard in Support of Motion for Summary Disposition of Contention 7(a).Related Correspondence ML20009H2301981-08-0404 August 1981 Motion for Summary Disposition of Contention 7(a).No Genuine Issue of Matl Fact Exists.Certificate of Svc Encl. Related Correspondence ML20009G9951981-08-0303 August 1981 Memorandum Supporting Applicant Motion for Summary Disposition of Contention 3.Assertions Refuted in Jm Vallance Affidavit & Some Assumptions Are Contrary to Aslab Rulings ML20009H0251981-07-30030 July 1981 Motion for Summary Disposition of Contention 3.No Genuine Issue of Matl Fact Exists & Applicants Are Entitled to Decision as Matter of Law.Certificate of Svc Encl ML20009F8371981-07-28028 July 1981 Statement of Matl Fact as to Which There Is No Genuine Issue to Be Heard Re Contention 11 on Onsite Storage of Spent Fuel ML20009F8431981-07-28028 July 1981 Motion for Partial Summary Disposition of Contention 11 Re Onsite Storage of Spent Fuel.No Genuine Issue of Matl Fact Exists.Motion Supported by C Herrington & DW James Affidavits.Certificate of Svc Encl ML19345G8391981-04-0909 April 1981 Answer Opposing Citizens Against Nuclear Danger 810327 Motion Requesting Hearing on Applicants' 801223 SNM License Application.Motion Does Not Comply W/Commission Regulations. Certificate of Svc Encl ML19290G6301980-11-24024 November 1980 Request to Deny Applicants' Motion for Summary Disposition of Contention 2 Re Chlorine Due to Studies Demonstrating Relationship Between Cancer Rates & Chlorinated Compounds in Drinking Water.W/Certificate of Svc ML18030A4731980-11-0606 November 1980 Motion for Partial Summary Disposition of Contention 2 Re Health Effects of Discharged Chlorine.Responses Due within Three Wks from Present Filing ML18030A4131980-11-0606 November 1980 Statement of Matl Facts Re Absence of Issue to Be Heard,In Support of Motion for Partial Summary Disposition of Contention 2 on Health Effects of Discharged Chlorine ML18030A0181980-11-0606 November 1980 Pleading in Support of Motion for Partial Summary Disposition of Contention 2 Re Health Effects of Discharged Chlorine.Issue Narrowed by Intervenor/Sponsor Via Response to NRC Interrogatories.W/Certificate of Svc ML18030A1621980-10-29029 October 1980 Response in Opposition to Environ Coalition on Nuclear Power Petition for Commission Review of ALAB-613.Intervenor Petition Sets Forth Nothing Which Warrants Different Conclusion.Certificate of Svc Encl ML18030A1591980-10-27027 October 1980 Statement of Matl Facts Re Absence of Genuine Issue to Be Heard,In Support of Summary Disposition of Contention 16 on Cooling Tower Discharge.Sys Designed to Evaporate Water Daily from Towers W/O Radioactive Releases ML18026A3101980-10-10010 October 1980 Response in Opposition to Applicant Request Re Interrogatories on Safety Issues.Environ Phase Must Take Priority Over safety-related Discovery Per ASLB 791030 Order.Certificate of Svc Encl ML18030A1401980-08-22022 August 1980 Statement of Matl Facts as to Which No Genuine Issue Exists to Be Heard in Support of Request for Summary Disposition of Ozone Portion of Contention 17.Max Ground Level Ozone Concentrations Near Lines Will Be Far Below Allowable Limit ML18030A1431980-08-22022 August 1980 Request for Free Hearing Transcripts Per 800725 Fr Notice Re Procedural Assistance Change in Adjudicatory Licensing Proceedings.Prior Denials Damaged Ability to Properly Litigate Contentions.Certificate of Svc Encl ML18030A4411980-08-22022 August 1980 Request for Summary Disposition of Portion of Contention 17 Dealing W/Ozone.No Genuine Issue of Matl Fact Exists to Be Heard.Responses Due in Three Wks ML18026A3001980-06-13013 June 1980 Response to Aslab 800521 Memorandum & Order ALAB-593, Requesting Environ Coalition on Nuclear Power to Inform Aslab of Extent of Relief Sought.Intervenor 800530 Request Must Be Dismissed as Moot.Certification of Svc Encl 1982-09-09
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~~g~po~~ ~11 4 ( /Q .~ ~4 ooce UNITED STATES OF AMERICA usmc.
NUCLEAR REGULATORY COMMISSION JUL 6)97' Sec~@a BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ~@e Sect
@ $ gvY In the Matter of gtanc PENNSYLVANIA POWER AND LIGHT CO. ) Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC. ) 50-388
)
(Susquehanna Steam Electr ic Station, )
Units land 2)
ENVIRONMENTAL COALITION ON NUCLEAR POWER INTERVENORS'NSWERS TO FIRST ROUND APPLICANT INTERROGATORIES The Intervenoes represented by the Environmental Coalition. on Nuclear Power (ECNP Intervenors) in this proceeding hereby move that the Chairman of this Atomic Safety and Licensing Board, ("Board" ) under Part 2.740(c) of the Commission's Rules, issue a Protective order to protect the ECNP from an extrordinarily burdensome, oppressive and utterly pointless number of interrogatories requested by the Applicant in this proceeding.
As a result of the Board's Prehearing Conference Order, the various par ties to this proceeding filed interrogatories and discovery requests. The interrogatories filed by the Applicant go far beyond any conc'eivable level of need for information, however. The basic questionnaire has about 150 questions and parts thereof. While many of these questions parrot those filed by the NRC Staff, and are therefore unduly repetitive, the insidious nature of the problem; lies in the four. "general interrogatories,'omposed of a total of eighteen parts, and the Applicant asks that each of the 150 questions also be answered with respect to the eighteen "general interrogatories".
This would require up to a total of 2700 separate answers. If each question could be researched and answered in just one minute, the job would take forty-five hours, or more =than one whole work week. A far. more realistic value of 10 to 100 minutes to research and write each answer would lead to a time expenditure of 450 to 4500 hours0.0521 days <br />1.25 hours <br />0.00744 weeks <br />0.00171 months <br />.
The ECNP Intervenors object to this enormous drain on their meager resources, expecially since there is so little to be learned by the Applicant, as is demonstrated 7$ Ãg~u >S
~ ~ C 4
by even a cursory reading of ECNP's answers to the NRC Staff's Interrogatories. For the ECNP Intervenors to have to review 10 years or so of "memoranda, correspondence, reports, surveys, tabulations, charts. books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, speeches, articles, transcripts and all other records, written electrical, mechanical or otherwise," would be an intolerable burden whose purpose can only be harrassment. Even if there were some minute value to this enormous undertaking, it would take months of full-time work to accomplish. As 'it is, the ECNP have little to offer the Applicant in the line of information, documents, etc .
that is not already'-.gn the public domain, frequently widely distri4gted. The vast majority of information in the possession of ECNP consists of AEC, NRC, 00E, ERDA, and EPA unclassified publications, GAO reports (all unclassified), and hearings before numerous committees of Congress (all open to the public).
In short,. the ECNP Intervenors request this protective order to prevent the enormous oppression, undue burden, annoyance, and expense that the Applicant would so gleefully inflict upon the ECNP Intervenors for no justifying cause.
The ECNP Intervenors would have no objection to answering a more limited number of pertinent questions, not already answered, provided they are asked for some purpose other than harrassment,. annoyance, and exhaustion, physical and financial, as the present set so obviously are.
The Applicant must have an extremely low opinion of its own ability to present its own case and win if the Applicant feels the need to so exhaust and drain the ECNP Intervenor't would almost suggest that the Applicant expects to be the first applicant to ever lose in a hearing before the NRC or AEC ~ Of course, the ECNP Intervenors have no doubt. that, in a fair hearing where one set of rules were used which applied equally to all parties, the Applicant would lose.
Respectfully submi tted, Sworn to and subscribed to before me Dated this ~s day of June, 1979 Judith H. Johnsrud, CoDirector and Co-Representative of the
. "'My ECNP Interveoors commission expires a
the Matter PENNSYLVANIA POWER G-1.
and (Susquehanna Steam Units 1 5 2)
General The ECNP which contentions
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IIt ALLEGHENY ELECTRIC COOPERATIVE, INC.
BF~y~
UNITED STATES OF AMERICA Electric Station, KN Ps NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING of LIGHT COMPANY p(~<y~
ENVIRONMENTAL COALITION ON NUCLEAR POWER ANSWERS TO FIRST ROUND NRC STAFF INTERROGATORIES uestions Intervenors will be supported by e
(ECNP) have made no BOARD,
~
Docket Nos. 50-387 50-388 s'n oQC5c.
Aui decisions,to date as,to expert witnesses or who might be us~gG g:c'+~"~
~qg7Q r~
~'.sec~e~~
~
0 asked to testify as an expert witness.
G-2. To date, ECNP has not identified any specific documents to be used either as support for the ECNP contentions or for cross-examination.
Contention 1 S-l.l. This w
belief comes from action by the Commissioners themselves in issuing the March 2, 1978, Order in the TMI-2 proceeding.
S-1.2. Above and beyond the errors made in estimating releases of radon-222 from abandoned mines and mill'tailings, the AEC ignored the laws of physics in arriving at its estimate of 74.5 curies per year release attributable to one year's operation of a reference reactor. This mistake was codified when Table S-3 was incorporated into 10 CFR. No supporting evidence has yet. been offered by either AEC or NRC personnel that the 74.5 curie figure was accurate.
S-1.3. The answer to this question is contained in the testimonies of Dr.
Chauncey Kepford offered at the TMI-2 and Perkins proceedings, July 5, 1977, and June 8, 1978, respectively, of which the Staff was provided copies.
S-1.4. ECNP Intervenors believe as many as possible of the assumptions should be replaced with experimentally gathered data.
S-I.S.: Ne do not know what such effects are. That is the reason for the need for experimental evidence.
S-l.6. See answer to S-1.3.
S-1.7. See answer to S-1.3. In addition, Dr . Kepford believes the NRC Staff has chosen a non-representative and non-conservative value in its conversion from radon daughter dose per Working Level Month (WLM). See Draft Generic Environmental Impact Statement on Uranium Milling, NUREG-0511, Vol. 11, page G-44. The 0.5 rad dose to the bronchial epithelia is very near the low end of the range cited in Ref. 9 of the Draft GEIS. This could lead to an underestimation of the dose by a factor of up to 40. Another potential source of error is in the use of an RBE of 10. As specified in the ECNP Petition, evidence has been published which suggests that for high LET radiation.
the RBE may be much greater than 10 at low doses. Here the error may be as large as a factor of 10, or even larger. We could only speculate as to the reasons for the continuing policy of the NRC to underestimate the effects of ionizing radiation on humans.
S-1.8. ECNP Intervenors do not understand the meaning or intent of this question.
S-l.g. See answers to S-1.3 and S-1.7.
S-l.lg. The answer to this question has been presented repeatedly to the NRC Staff in numerous filings on the radon-222 question in the TMI-2 proceeding, NRC Docket 50-320.
S-l.ll. ECNP Intervenors have not made an assessment of the treatment by the NRC of all isotopes, and therefore cannot answer this question.
/s S-1.12. In general,-the NRC has failed to account for the health effects I
of long-lived radioactive isotopes beyond a period of about 50 years. These I
health effects are underestimated for isotopes with half-lives significantly longer -than 50 years. ECNP Intervenors have made no estimates as to the magnitude of such errors, but have every reason to beljeve, in many cases,'the errors are enormous, based on the radon-222 situation as an example. The obvious cause of the "health effect", a euphemism for a premature, avoidable.
.death by cancer, is exposure to ionizing radiation.
S-1.13. See answer to S-1.12.'.
S-I.14. See answer to S-l.13.
S-1.18. Since, as the Staff has known for about 2 years now, Dr. Kepford believes that the inclusion of the full health costs of radon-222 emiss ions (TMI-2 xi testimony) will tip the cost-benefit balance against the operation of any, nuclear power plant, the inclusion of the consistently underestimated health effects due to other long-lived or short-lived radioisotopes will only serve to further sink the nuclear ship.
Contention 2.
The ECNP petition makes no reference to cesium-137, cobalt-60, and chlorine discharges from the Susquehanna facility.
r Contention 3.
S-3.1. If it is assumed that there are approximately 890,000 tons of 0308 as known reserves (Draft GEIS, Uranium Mining, Table 3.6) and if it is assumed that 1005 of these reserves can be mined and recovered, then there is fuel for about 150 GW(e) of nuclear generating capacity, assuming a lifetime use of 6000 tons of U308 per 1000 MW(e) reactor. This 148 GW(e) is approximately equal to the operating and being built, generating capacity of the U.S. Since 100K recovery of U308 from these is not realized, and since 100K recovery of the
s
- .*:.: ore from the mines is not always realized, an immediate shortfall- might
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be expected. If more reactors are built, a larger shortfall might occur prior to the end of the lifetime of Susquehanna 1 and 2.
S-3.2. See the portion of the Kepford testimony in the Perkins proceeding entitled "Resource Consumption," and the answer to S-3.1.
S-3.3. No specific assessments have been made.
S-3.4. See answers to S-3.1-3.
S-3.5. See answer to S-1.15.
Contention 5.
S-4.1. The answer to this guestion is largely dependent on the marketing practices of the Applicant. ECNP Intervenors believe that if the Applicant chooses to reduce its annual electricity growth rate to zero, it can do so.
The Applicant can also actively promote electricity sales growth. ECNP Intervenors have no way of knowing what electricity growth rate will occur, but zero can occur, if the 'Applicant will allow it.
S-4.2-4. None have been made.
Contention 5.
S-5.1. ECNP lntervenors are not aware of any dose models used by the NRC that are accurate and are not obsolete. The burden of proof lies upon the Staff of the NRC to ensure that the models used by the Staff are accurate and up to date. If this information is available, we would appreciate its being made available to ECNP on discovery.
S-5.2. Me believe that only accurate and up-to-date models should be used.
S-5.3. ECNP Intervenors have made no such calculations. However, as specified in the ECNP petition, evidence has appeared in the literature that states the NRC has underestimated iodine-131 transfer coefficients. In I
addition, we have requested on discovery upon the NRC Staff a translation of a report from the University of Heidelberg which discusses this very topic.
It has not yet been received.
S.-5.4. See answer to S-5.3.
S-5. 5. None have: been made.
~S-5. . The answer to this question has been answered with particularity to an artie'le in Health ~ph sics. ECNP Intervenors have made no specific calculations to determine the appropriate factors.
S-5.7. See'he answer to S-5.6.
S-5.8. See the.answer to S-5.6.
S-5.9. See the answer to S.5.6.
Contention 6.
S-6.1. This question was phrased to limit the answer to that world of fantasy known as 10 cfr. If there were any reason whatsoever to believe that no accident greater than design basis would ever occur, or that all safety systems would always work as specified, and all operators would always know exactly what to do, and would always, make the right decisions, then this question would be less ludicrous. However, the occurrence of a Class 9 accident at TMI-2 changed things. The long-suppressed update of MASH-740 states that in the event of an uncontained core meltdown, "...there could be deaths out to 150 km". (WASH-740 update, document 84, page 5). The reference here is to deaths due to acute radiation exposure. Such exposures would exceed the U
very liberal radiation standards and protective action guides. These exposure levels have never been acknowledged to be acceptable to those at. risk.
5-6.2. See answer to S-6.1.
S-6.3. ECNP Intervenors have made no such calculations.
S-6.4. ECNP Intervenors have made no such calculations. However, the adequacy of the emergency plan may be assessed by the total inability of the Commonwealth of Pennsylvania and the NRC to react quickly to the real emergency aC TMI-2 in March and April, 1979.
S-6.5:: 'he TM1-2 accident demonstrated that accidents can happen.'at
~I licvensed facilities which are much more severe than contemplated by the yC I
Comoission's regulations. The TMI-2 emergency plan met all applicable NRC regulations, but was found to be unworkable when a real-world accident happened.
Contention 7.
S-7.1. This belief rests with the belief that the structures have never been tested under realistic accident conditions.- I S-7.2. ECNP lntervenors cannot identify these forces, as such a task is far beyond our financial capability. That burden lies with the NRC Staff and the Applicant. Further information on this subject is currently being sought on discovery.
S-7.3. Ne have made no such calculations, but believe that reliance on realistic, experimental data is preferable to reliance on unsupported or even unsupportable, speculative estimations and extrapolations. Thus, until solid evidence shows that any and all b'lowdown forces can be withstood. ECNP Intervenors see no reason to believe they can be.
D W
5-7.4. Pipe cracks at other nuclear peer plants may render these plants unsafe to operate,. but, in general, will not affect the Susquehanna facility.
S-7.5. The answer to this question is, by its very nature, far more answerable by the NRC Staff, and the full and complete answers should be supplied to all parties, even without discovery.
S-7.6. See the answer to S-7.5.
'7 '7 II II II II II II II II II II II I~I ~
'7 0~ II II II II II II II II II II
~ V S-7.9. To the best of our knowledge, the'.consequ'ences to the public to date have been small .. However, that is no assurance that the consequences will always remen small.
S-7.10. No calcu'lations have been made.
S-7.11. Nozzle cracks at other facilities do not necessarily render Susquehanna unsafe to operate.
S-7.12. ECNP Intervenors do not know. The NRC Staff should supply the answer to this question to all of the parties in this proceeding.
S-7.'13. See the answer to S-7.12.
5-7.14.
S-7.15. See the answer to S-7.9.
S-7.16. ECNP Intervenors mould have more faith in the safety of nuclear power plants, like Susquehanna 1 8 2, if the owners, designers, and manufacturers also had some such faith. However, as long as those owners, designers, and manufacturers value their individual and collective corporate survival .as more important than the survival of those individuals placed at risk by the entire nuclear fuel cycle, or those thoroughly terrorized by accidents like TMI-2. we will continue to have no faith in the safety of nuclear power plants. That includes no faith in the calculated probabilities of accidents, including contributions to risk from ATMS.
Contention 8.
S-8.1. No such statement alluded to here was made in the ECNP Intervenors'ontention on this subject.
S-8.2. See the answer to S-8.1.
II II 3
S-8.4. The answer to this question is being sought on discovery from the NRC Staff.
Contention 9.
S-9.1-6. The ECNP petition contains no reference to the subject of this ques tion.
3-9.7. See the answer to S-1.15.
Contention 18.
S-18.1. ECNP does not know why other means cannot be- used. It was 'not an ECNP. decision to abandon other means in favor of the use of energy intensive, dangerous chemicals so as to reduce employment rolls.
S-18.2. ECNP has made no such alIegation in its petition.
S-18.3. Irrelevant. See S-18.2.
Dr. Judith H. Johnsrud Co-Director, ECNP Co-Representative of the ECNP Intervenors Sworn to and subscribed to before me this ~> ~ day of June, 1979.
My Commission expires
CERTIFICATE OF SERVICE I hereby certify that copies of ENVIRONMENTAL COALITION ON NUCLEAR POWER INTERVENORS'NSWERS TO FIRST ROUND INTERROGATORIES and ENVIRONMENTAL COALITION ON NUCLEAR POWER ANSWERS TO FIRST ROUND NRC STAFF INTERROGATORIES I
have been deposited in the US Hail, first class, postage paid, this ~p day of June. 1979.
Dr. Judith H. Johnsrud Co-Director, ECNP Co-Representative of the ECNP Intervenors Charles Bechhoefer, Esquire Docketing and Service Section Chairman, ASLB Panel Office of the Secretary US Nuclear Regulatory Comoission US Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Glenn 0. Bright Jay Silberg, Esquir e ASLB Panel .Shaw, Pittman, Potts 8 Trowbridge US Nuclear Regulatory Commission 1800 M Street, NW Washington, DC 20555 Washington, D.C. 20036 Dr. Oscar H. Paris Mrs. Irene Lemanowicz Butz ASLB Panel Citizens Against Nuclear Danger US Nuclear Regulatory Commission PO Box 377 RD 1 Washington, D.C. 20555 Berwick, Pa. 18603 Atomic Safety 8 Licensing Board Mrs. Colleen Marsh US Nuclear Regulatory Commission 558A, RD 4 Washington, D.C. 20555 Mountain Top, Pa. 18707 Atomic Safety 8 Licensing Appeal Board Gerald Schultz, Esquire U.S. Nuclear Regulatory Commission Susquehanna Environmental Advocates Washington, D.C. 20555 500 South River Street Wilkes-Barre, Pa . 18702 Mr. Thomas M. Gerusky, Director James M. Cutchin, IV, Esquire Bureau of Radiological Protection Office of the Executive Legal Director Department of Environmental Resources US Nuclear Regulatory Comission PO Box 2063 Washington, D.C. 205 Harrisburg, Pa. 17120 oocg~
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