|
---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20204F4511999-03-22022 March 1999 Comment Supporting Petition for Rulemaking PRM-50-64 Filed by Atlantic City Electric Co,Austin Energy,Central Maine Power Co,Delmarva Power & Light Co,South Mississippi Electric Power Assoc & Washington Electric Cooperative,Inc ML18016A8071999-02-12012 February 1999 Comment Opposing Significant Hazards Determination & Conditional Request for Stay of Effectiveness Re Proposed License Amend to Permit Expansion of Sf Storage Capacity at Plant NPP ML18016A8031999-02-12012 February 1999 Comment on CP&L Application Dtd 981223.Proposed Finding of No Significant Hazard Wrong & Must Be Rejected for Stated Reasons ML18016A8291999-02-11011 February 1999 Comment Re Proposed Expansion of high-level Radwaste Storage Capacity at CP&L Shearon Harris Npp.Advises NRC to Consider Request from Durham County Board of Commissioners for 30-day Extension of Comment Period ML18016A8151999-02-11011 February 1999 Comment Opposing Expansion of Shearon Harris Facility Re Storage of Spent Nuclear Fuel Rods or Acceptance of Addl Nuclear Waste ML18016A8081999-02-11011 February 1999 Comment on Licensee 981223 Application & NRC 990113 Fr Re NRC Proposed Finding of NSHC ML18016A8161999-02-10010 February 1999 Comment Opposing CP&L Request to Store Spent Fuel Rods from All Three NPPs at Two New Waste Pools at Shearn Harris NPP (Bringing Total Number of Pools to Four) ML18016A8131999-02-10010 February 1999 Comment on Encl Resolution Re Proposed Expansion of high-level Radwaste Storage Facilities at Cp&L,Shearon Harris NPP in Wake County,Nc.Requests 30 Days Extension for Public Comment Period ML18016A8061999-02-10010 February 1999 Comment Regarding Proposed Amend by Util to Increase Sf Storage Capacity at Plant.Believes That Meeting to Help Alleviate Concerns Regarding Protection of Personnel Health & Safety Should Be Scheduled ML18016A8271999-02-0808 February 1999 Comment Opposing Petition from Carolina Power & Light Co to Allow Transport,For Long Term Storage,Spent Fuel Elements Licensee Other Plants to Harris Plant ML18016A8221999-02-0606 February 1999 Comment Opposing Proposal by Shearon Harris to Increase Capacity of High Level Nuclear Waste Storage Pools ML18016A8281999-02-0505 February 1999 Comment Opposing Shearon Harris Nuclear Plant Be Used for Addl Storage of Nuclear Waste ML18016A8311999-02-0505 February 1999 Comment Opposing Shearon Harris NPP Being Used for Addl Storage of Nuclear Waste ML18016A8141999-02-0404 February 1999 Comment Opposing Proposal by Shearon Harris to Increase Capacity of High Level Nuclear Wastes,Publication,Dtd 990113 ML18016A8301999-01-22022 January 1999 Comment Opposing License Amend Application Dtd 981223 Submitted by CP&L Involving Spent Storage at Harris NPP & Subsequent Proposed No Significant Hazards Consideration Determination ML18011A6261994-10-31031 October 1994 Comment Opposing Proposed Amend to Plant Re Relaxation of Requirements to Annual Monitoring ML20150F7561987-02-27027 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning 1999-03-22
[Table view] |
Text
ORY 2 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9902260124 DOC.DATE: 99/02/08 NOTARIZED: NO DOCKET N FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION LUBEROFF,B.J. Affiliation Not Assigned RECIP.NAME RECIPIENT AFFILIATION THE CHAIRMAN Commissioners (Post 750119)
JACKSON,S.A. Commis'sioners (Pos't 750119)
SUBJECT:
Comment opposing petition from Carolina Power & Light Co to allow transport, for long storage, spent fuel elements from licensee other plants to Harris Plant.
DISTRIBUTION CODE: DS09D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: SECY/DSB Dist: Public Comment on Proposed Rule (PR)-Misc Notice;Reg G NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL: 1 NMSS/IMOB T8F5 OGC/DR 15-B-18 RES DIR RES/DRA/DEPY 1- RES/DST EXTERNAL: NRC PDR 0
N NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR FROM'DISTRIBUTION LISTS ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 7 ENCL
Benjamin J. Luberoff, Ph.D., P.E. (ret.)
261 Fearrington Post Pittsboro NC 27312-8556 Voice: 919 545 0692 Fax: 919 545 9988 e-mail:B JLPHDaol.corn Februaiy S 1999 o i o: a s a"a ~Chairman Shirley A Jackson Commissioner Nils J. Diaz Commissioner Greta J. Dicus Commisioner Edward McGaf5n, Jr.
Commisioner Jeffery S. Merrifield United States Nuclear Regulatory Commission Washington DC 20555-0001 Gentlefolk, You have before you a petition &om Carolina Power & Light (1) to allow them to transport, for long term storage, spent fuel elements &om their other plants to their Harris Plant. That plant lies proximate to my home, to Raleigh, to Durham, to Chapel Hill and to the Research Triangle. As you consider this petition we who live here would appreciate it ifyou would consider the foHowing logic.
> There is a possibility, albeit smaV, that spent fuel can cause an event that would be devastating to its neighbors. We thus face the situation Dr. Edward Teller characterized as follows, in talking about siting of nuclear plants (Yes, that Dr. Teller.):
The probability that something willgo seriously wrong is real. But the damage that ~ould be causedis infinite. So you have the peculiar problem ofmultiplying zero times infinity. (2)
> The greater the concentration of nuclear material the greater the risk of an untoward occurrence and the greater its damage potential. (3)
> In this country one has a right to expect a benefit comensurate with whatever risk he/she is asked to assume.
I 9'P02260igg 990g08 PDR ADQCK 05000q00 P PDR
r Our Commissioners, herc in Chatham County, have. asked you to delay your decision beyond the February 12 deadline so that they can evaluate the opinion of consultants they hired to assist them in assessing the risk benefit/equation. Such a delay
'ould help all of us to appreciate the impact of alternate solutions to the problem before us. However the logic above is all any fair minded person needs to arrive at the conclusion that the fuel rods rightfully belong just where they are. The beneficiaries of a risk are the ones who, fairly, should assume that risk. It's that simple!
Since we, living near Harris, see no such benefit from assuming the risks the petition before you places on us, we respectfully request that you deny that petition irrevocably.
Sine
'in J. roff Notes:
- 1. Application of December 23 1998 by CF&L: Fed. Beg. Jan. 13 1999, Vol. 64, No. 8
- 2. CBS-TV August 10 1970 as cited by B. J. Luberoff Editor, CHEMTKCH May 1973, 257
- 3. Neither probabilities of untoward occurrences nor the degree of their devastating effects are linearly related to concentration.
cc: Senator Jesse Helms Senator John Edwards Representative David Price
, Governor James Hunt Senator Ellie Kinnaird Senator Howard Lee Representative Joe Hackney Chairman Rick Givens Dr. David A. Lochbaum
p%
6 ~
/
I