|
---|
Category:Legal-Intervention Petition
MONTHYEARML18026A0622018-01-26026 January 2018 Petition for Intervention ML0725603582007-09-10010 September 2007 Susquehanna - Eric Joseph Epstein'S Notice of Appearance, Data Requests, and Motion to Postpone Final Determination of PPL Susquehanna, Llc'S Application for Surface Water Withdrawal Request to Modify Application 19950301-EPU-0572 ML0724203542007-08-22022 August 2007 Susquehanna - Eric Joseph Epstein'S Affirmative Duty & Obligation to Keep the Nuclear Regulatory Commission, Atomic Safety & Licensing Board Panel, Parties Informed of Significant Developments ML0716904712007-06-12012 June 2007 Susquehanna - Eric Joseph Epstein'S Reply to PPL Susquehanna LLC and the NRC Staff'S Responses to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearings and Contentions ML0716502202007-06-0505 June 2007 Susquehanna - NRC Staff Response to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearing, and Contentions. Notice of Appearance by Susan L. Uttal, OGC and Lloyd B. Subin, OGC ML0714305802007-05-11011 May 2007 Petition to Intervene with Respect to the Proposed Amendment Request for a Thermal Power Increase for the Susquehanna Steam Electric Station, Units 1 and 2 ML0709306092007-03-20020 March 2007 Susquehanna - Eric Joseph Epstein'S Response to the NRC Staff'S Motion to Strikes Portions of Eric Joseph Epstein Response to the Atomic Safety Licensing Board Panel'S Request for Information ML0707803052007-03-11011 March 2007 Susquehanna, LLC - Eric Joseph Epstein'S Response to the Atomic Safety Licensing Board Panel'S Request for Information ML0707404912007-03-0909 March 2007 Susquehanna LLC - Letter to Judges Young, Lathrop and Sager Responding to Judges Requests for Citations to Cases Addressing the Standing of Individuals Who Claim non-residential Activity in Proximity to a Nuclear Facility ML0707903652007-02-28028 February 2007 Susquehanna - Eric J. Epstein Letter to the Parties Notifying Them That U.S. Department of Homeland Security, Oig and OI Acknowledged Receipt of His 1-30-07 Motion ML0706101942007-02-23023 February 2007 Susquehanna - Eric Joseph Epstein'S Response to PPL Susquehanna'S Motion to Strike Portions of Eric Epstein'S Response to Answers to Petition to Intervene ML0705103632007-02-0505 February 2007 Susquehanna - Eric Joseph Epstein'S Response to PPL Susquehanna'S Answer and Petitioners Response to NRC Staff'S Response for Leave to Intervene, Request for Hearing and Contentions ML0703602822007-01-29029 January 2007 Susquehanna - PPL Susquehanna'S Answer to Eric Epstein'S Petition for Leave to Intervene ML0703000522007-01-29029 January 2007 Susquehanna - NRC Staff Response to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearing and Contentions ML0703103302007-01-10010 January 2007 2007/01/10- Susquehanna- Email from Eric Epstein Service to Parties the Supplemental Filing Relating to SAMA Requirements ML0701704852007-01-0202 January 2007 2007/01/02- Susquehanna- Legal-Intervention Petition PPL Susquehanna LLC Application for Susquehanna Steam Electric Station'S Renewed Operating Licenses ML18025A0211979-10-13013 October 1979 Encp Response to Staff Motions Dated October 9, 1979 ML18025A0231979-10-12012 October 1979 Applicant'S Motion to Dismiss Environmental Coalition on Nuclear Power and Certain Contentions from This Proceeding ML18025A6901979-10-12012 October 1979 Applicants' Motion to Dismiss Environmental Coalition on Nuclear Power and Certain Contentions from This Proceeding and Attaching Contention to Be Dismissed ML18025A6841979-09-18018 September 1979 Correction to Ecnp Intervenors' Response to Board Memorandum and Orders ML18025A6811979-09-17017 September 1979 Applicant'S Answer to Citizens Against Nuclear Dangers' Supplemental Appeal Regarding Discovery Request Number 18 ML18025A6831979-09-17017 September 1979 Responses of Ecnp Intervenors to Board Memorandum and Order Compelling Intervenors to Answer Applicant and Staff Interrogatories ML18025A6791979-09-10010 September 1979 Ecnp Intervenors' Second Round Discovery Requests of the NRC Staff ML18025A6721979-08-30030 August 1979 Citizens Against Nuclear Dangers (Citizens) Appeal Before the NRC Appeal Board Panel Pertaining to the Licensing Board'S Memorandum and Order on Scheduling and Discovery Notions, August 24, 1979 ML18025A7341979-07-0909 July 1979 Applicant'S Response to Licensing Board Memorandum and Order of June 18, 1979 ML18025A7331979-07-0505 July 1979 Applicants' Answer to Citizens Against Nuclear Dangers' Motion for Board Ruling on Revision of Preliminary Timetable. ML18025A7281979-06-27027 June 1979 Applicant'S Motion to Compel Discovery of Intervenor Citizens Against Nuclear Dangers ML18025A7251979-06-0404 June 1979 Applicants' Answer to Motion of Citizens Against Nuclear Danger ML18025A7211979-05-25025 May 1979 Applicants' First Request to Intervenor Susquehanna Environmental Advocates for the Production of Documents ML18025A0751979-01-17017 January 1979 in the Matter of the Application for an Operating License for the Susquehanna Nuclear Generating Station by PP&L - Amended Petition for Leave to Intervene ML18025A0761979-01-12012 January 1979 Letter Enclosing Supplement to Petition for Leave to Intervene of Colleen Marsh Et Al Outlining and Listing Contentions ML18023B1541978-09-21021 September 1978 Applicant'S Answer to Petition for Leave to Intervene and Request for Hearing Submitted by the Susquehanna Environmental Advocates ML18026A0511978-09-21021 September 1978 Applicant'S Answer to Petition for Leave to Intervene and Request for Hearing Submitted by Susquehanna Environmental Advocates, Citizens Against Nuclear Dangers, and Colleen March and Elven Other Individuals ML18026A0521978-09-20020 September 1978 Applicant'S Answer to Request for an Operating License Hearing and Petition for Leave to Intervene Submitted by the Environmental Coalition on Nuclear Power 2018-01-26
[Table view] Category:Responses and Contentions
MONTHYEARML18026A0622018-01-26026 January 2018 Petition for Intervention ML0725603582007-09-10010 September 2007 Susquehanna - Eric Joseph Epstein'S Notice of Appearance, Data Requests, and Motion to Postpone Final Determination of PPL Susquehanna, Llc'S Application for Surface Water Withdrawal Request to Modify Application 19950301-EPU-0572 ML0724203542007-08-22022 August 2007 Susquehanna - Eric Joseph Epstein'S Affirmative Duty & Obligation to Keep the Nuclear Regulatory Commission, Atomic Safety & Licensing Board Panel, Parties Informed of Significant Developments ML0716904712007-06-12012 June 2007 Susquehanna - Eric Joseph Epstein'S Reply to PPL Susquehanna LLC and the NRC Staff'S Responses to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearings and Contentions ML0716502202007-06-0505 June 2007 Susquehanna - NRC Staff Response to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearing, and Contentions. Notice of Appearance by Susan L. Uttal, OGC and Lloyd B. Subin, OGC ML0714305802007-05-11011 May 2007 Petition to Intervene with Respect to the Proposed Amendment Request for a Thermal Power Increase for the Susquehanna Steam Electric Station, Units 1 and 2 ML0709306092007-03-20020 March 2007 Susquehanna - Eric Joseph Epstein'S Response to the NRC Staff'S Motion to Strikes Portions of Eric Joseph Epstein Response to the Atomic Safety Licensing Board Panel'S Request for Information ML0707803052007-03-11011 March 2007 Susquehanna, LLC - Eric Joseph Epstein'S Response to the Atomic Safety Licensing Board Panel'S Request for Information ML0707404912007-03-0909 March 2007 Susquehanna LLC - Letter to Judges Young, Lathrop and Sager Responding to Judges Requests for Citations to Cases Addressing the Standing of Individuals Who Claim non-residential Activity in Proximity to a Nuclear Facility ML0707903652007-02-28028 February 2007 Susquehanna - Eric J. Epstein Letter to the Parties Notifying Them That U.S. Department of Homeland Security, Oig and OI Acknowledged Receipt of His 1-30-07 Motion ML0706101942007-02-23023 February 2007 Susquehanna - Eric Joseph Epstein'S Response to PPL Susquehanna'S Motion to Strike Portions of Eric Epstein'S Response to Answers to Petition to Intervene ML0705103632007-02-0505 February 2007 Susquehanna - Eric Joseph Epstein'S Response to PPL Susquehanna'S Answer and Petitioners Response to NRC Staff'S Response for Leave to Intervene, Request for Hearing and Contentions ML0703602822007-01-29029 January 2007 Susquehanna - PPL Susquehanna'S Answer to Eric Epstein'S Petition for Leave to Intervene ML0703000522007-01-29029 January 2007 Susquehanna - NRC Staff Response to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearing and Contentions ML0703103302007-01-10010 January 2007 2007/01/10- Susquehanna- Email from Eric Epstein Service to Parties the Supplemental Filing Relating to SAMA Requirements ML0701704852007-01-0202 January 2007 2007/01/02- Susquehanna- Legal-Intervention Petition PPL Susquehanna LLC Application for Susquehanna Steam Electric Station'S Renewed Operating Licenses ML18025A0211979-10-13013 October 1979 Encp Response to Staff Motions Dated October 9, 1979 ML18025A0231979-10-12012 October 1979 Applicant'S Motion to Dismiss Environmental Coalition on Nuclear Power and Certain Contentions from This Proceeding ML18025A6901979-10-12012 October 1979 Applicants' Motion to Dismiss Environmental Coalition on Nuclear Power and Certain Contentions from This Proceeding and Attaching Contention to Be Dismissed ML18025A6841979-09-18018 September 1979 Correction to Ecnp Intervenors' Response to Board Memorandum and Orders ML18025A6811979-09-17017 September 1979 Applicant'S Answer to Citizens Against Nuclear Dangers' Supplemental Appeal Regarding Discovery Request Number 18 ML18025A6831979-09-17017 September 1979 Responses of Ecnp Intervenors to Board Memorandum and Order Compelling Intervenors to Answer Applicant and Staff Interrogatories ML18025A6791979-09-10010 September 1979 Ecnp Intervenors' Second Round Discovery Requests of the NRC Staff ML18025A6721979-08-30030 August 1979 Citizens Against Nuclear Dangers (Citizens) Appeal Before the NRC Appeal Board Panel Pertaining to the Licensing Board'S Memorandum and Order on Scheduling and Discovery Notions, August 24, 1979 ML18025A7341979-07-0909 July 1979 Applicant'S Response to Licensing Board Memorandum and Order of June 18, 1979 ML18025A7331979-07-0505 July 1979 Applicants' Answer to Citizens Against Nuclear Dangers' Motion for Board Ruling on Revision of Preliminary Timetable. ML18025A7281979-06-27027 June 1979 Applicant'S Motion to Compel Discovery of Intervenor Citizens Against Nuclear Dangers ML18025A7251979-06-0404 June 1979 Applicants' Answer to Motion of Citizens Against Nuclear Danger ML18025A7211979-05-25025 May 1979 Applicants' First Request to Intervenor Susquehanna Environmental Advocates for the Production of Documents ML18025A0751979-01-17017 January 1979 in the Matter of the Application for an Operating License for the Susquehanna Nuclear Generating Station by PP&L - Amended Petition for Leave to Intervene ML18025A0761979-01-12012 January 1979 Letter Enclosing Supplement to Petition for Leave to Intervene of Colleen Marsh Et Al Outlining and Listing Contentions ML18023B1541978-09-21021 September 1978 Applicant'S Answer to Petition for Leave to Intervene and Request for Hearing Submitted by the Susquehanna Environmental Advocates ML18026A0511978-09-21021 September 1978 Applicant'S Answer to Petition for Leave to Intervene and Request for Hearing Submitted by Susquehanna Environmental Advocates, Citizens Against Nuclear Dangers, and Colleen March and Elven Other Individuals ML18026A0521978-09-20020 September 1978 Applicant'S Answer to Request for an Operating License Hearing and Petition for Leave to Intervene Submitted by the Environmental Coalition on Nuclear Power 2018-01-26
[Table view] Category:Legal-Petition to Intervene
MONTHYEARML18026A0622018-01-26026 January 2018 Petition for Intervention ML19186A1231979-01-17017 January 1979 Amended Petition for Leave to Intervene ML18025A7051979-01-15015 January 1979 Amendments to the Petition for Leave to Intervene Filed by the Environmental Coalition on Nuclear Power ML18025A0801979-01-15015 January 1979 Amendments to the Petition for Leave to Intervene Filed by the Environmental Coalition on Nuclear Power ML18025A7031979-01-12012 January 1979 Letter Enclosing the Supplement to Petition for Leave to Intervene ML18025A0761979-01-12012 January 1979 Letter Enclosing Supplement to Petition for Leave to Intervene of Colleen Marsh Et Al Outlining and Listing Contentions 2018-01-26
[Table view] |
Text
0 6%~~ Fdic Ek~
January 12, 1979 Secretary of the Commission U, S. Nuclear Regulatory Commission d" Washington, D. C. 20555 Att'n.: Docketing on Service Section Executive Legal Director U. S. Nuclear Regulatory Commission 0po Washingto'n, D. C. 20555 Jay Silberg, Esquire Shaw, Httman, Potts, Trowbridge 8r. Madden 1800 M Street,, N.W.
Washington, D. C. 20036 Re: P, P, 8r,L. Co., et al Docket Nos. 50-387 d 50-388
Dear Gentlemen:
Enclosed please find Supplement to Petition for Leave to Intervene and list of contentions in above matter.
Sincere ly,
< r, In Re: Pennsylvania Power Light C . UC LEAR REGULATORY and Alleghany Electric Cooperative, I Q. COMMISSION Susquehanna Steam Electric Station,
. Units 1 and 2. DOCKET NOS. 50-387 and 50-388 SUPPLEMENT TO PETITION FOR LEAVE TO INTERVENE OF COLLEEN MARSH ET AL,,OUTLING AND LISTING CONTENTIONS NOW come Colleen Marsh and Eleven Others, Petitioners herein, and Supple-ment their Petition For Leave To Intervene to include the following contentions:
- 1. The proposed project creates an unreasonable risk of harm to the health and safety of Petitioners and other members of the public due to the following specific reasons or bases:
A. Applicants design fails to resolve the problem of pump flywheel missiles generated by coolant pump overspeed in the boiling water reactors which poses an un reasonable risk of harm to the health and safety of Petitioners and others. The electrical braking proposed by Applicant is not sufficient to prevent this problem.
B. Applicant fails to provide adequate on-site storage facilities in its design to safely store both high and low level radioactive materials. The disign contemplates tempoxary storage on-site of low level materials, yet since no avenues remain open for applicant to dispose of al1, radioactive waste, spent fuel and materials elsewhere, the Applicant may have to store the spent materials longer, up to 10 to 15 years,,than it is prepared safely to contain and monitor for such a period of time on-site.
C. Applicant has failed to provide, or demonstrate in its application, adequate plans for the safe transportation in connection with the radioactive materials produced in connection with the operation of Susquehanna Steam Electric Station.
D. Applicant's design fails to solve the problem of flow-induced vibration in the core, thereby creating in-vessel sparger failure.
- 2. Applicants proposed facilities creat+an unreasonable risk of harm to the private property of Petitioners and other members of the public located within 50 miles of facilities for all the reasons set for in Paragraph One, A-D of this Supplement to P etition.
- 3. petitioners and the Public are exposed to unreasonable risk of harm to p ersonal safety and property due to the protection of the Power Company under the Federal Price-Anderson Act which limits its liability.
- 4. Due to the facts and circumstances set forth in Paragraph'-One, A-D, Applicants proposed facilities violate this Commission's Standards for protection against radiation set down in 10CFR 20. 1 et seq. and 10 CFR 20. 105 (a) which pro-vides for permissible levels in unrestricted areas and the environment around the Facilities.
0 page 2
- 5. Applicants proposed Facilities are unreasonably costly and uneconomical both to Petitioners and the public due to the following reasons and bases:
A. The output of electricity to be produced by the proposed facilities, in re-lation to cost, willbe lower than electricity generated by existing forms of energy and therefore more expensive to Petitioners and others.
B. The projected cost of facilities of Applicant fails to account for, or in-clude, the expected cost of decommissioning the facilities after its estimated useful life of 30 years. Such cost is at least equal to the cost of construction and will be borne by future consumers and taxpayers.
C. The facilities are unnecessary and wasteful as the electric capacity of PP&L in 1977 was 40% greater than customer needs and demands from existing facilities. Latest projections'f energy use and requirements during the next 30 years for the PP8r.L service area, the period equal to the projected plants "useful life", show that PPRL can meet the needs of its customers through existing facili-ties and sources without investing in a costly and unreasonably dangerous nuclear facility.
D. Pennsylvania Utility Commission regulations would permit Applicant to base its rates, in part, according to capital. investment in facilities, and thereby double utility rates for PPRL as its total investment for all facilities will be doubled after completion of the projected facilities. This cost will be borne by local PPRL customers, yet the unneeded electricity will be sold outside of the PPRL service area.
- 6. The Applicants fail to adequately. provide plans for informing the public as to evacuation procedures including drills and warnings in the event of radiation leakage.
A FFIDAVIT STATE OF PENNSYLVANIA SS:
COUNTY OF LUZERNE The undersigned, being duly sworn, deposes and states that she is one of the Petitioners named in the within Petition, and that the facts there-in contained are true and correct to the best of her knowledge and belief.
Sworn to and subscribed before me this/4 day of Janu y -1979.,
~P(
KATHRYN F. FARRELL, Notary Public Wilkes Barre, Pa. 18701 Commission Expires Jan. 29, 1983
UNITED STATES OF AMERICA NUCLEAR R GULATORY CQ.+iISS IO.'n the Hatter of PENNSYLUA¹A POWER AND LXGEZ Docket No.(s) 50-387 CO~ilPA <AY 50-388 (Susquehanna Steam Electric Station, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that 1 have this day served the foregoing document(s) upon each person designated on the official serv'ce list compiled by the Office of the Secretary of the Commission in this proceeding in accordance. with the requirements of Section 2.712 of 10 CFR Part 2-Rules of Practice, of the Nuclear Regulatory Con ission's Rules and Regulations.
D"ted at Washingto , .C. t day of t -
p ffice f the Secretary oz the Commission
UNITED STATES OP AMEP.ICA NUCLEAR REGULATORy COi 1ISS ION In the Matter of )
)
PFNNSVLVANIA POBFR A>D LIGHT ) Docket No. (s) 50 387 COMPANY, ET AL. ) 50-388
)
(Susquehanna Steam Electric . )
Station, Units 1 and 2) )
SERVICE LIST Charles Bechhoefer,'sq., Chairman Dr. Judith H. Johnsrud Atomic Safety and Licensing Board Co. Director, Environmental U.S. Nuclear Regulatory Commission Coalition on Nuclear Power Washington, D.C. 20555 433 Orlando Avenue State College, Pennsylvania 16801 Mr. Glenn O. Bright Atomic Safety and Licensing Board Hs. Colleen Harsh U.S.Nuclear Regulatory Commission 558A Uashington, D.C. 20555 R.D. P4 Mount Top, Pennsylvania 18707 Dr. Oscar H. Paxis Atom"'c Safety and Licensing Board Hrs. Irene Lemano~'icz U.S". Nucl'ear P'egulat'ory Commxssi'on The Citi'zens Against Nuclear Dangers
>iashington, D.C. 20555 P.O. Box 377 RD Counsel-:- for NFC--'t~
- 1'em<ck'; Fenn'syIvani'a" 18603 of the Executive Legal Director
--'ffice U.S. Nucleax Regulatory Commission Gerald Schultz, Fsq.
$ i'ashington, D.C. 20555 Susouehanna Environmental Advocates 500 South. River Street Jay E. Silberg, Esq. hilkes-Barre, Pennsylvania 18702 Shaw, Pittman, Potts 6 Troorbridge 1800 "MY Street, N.H. "
Hr. Thomas H. Gerusky, Director Llashington, D.C. 20036 Bureau of Radiation Protection Department of Environmental Resources Commoncrealth of Pennsylvania P.O. Box 2063 Harrisburg, Pennsylvania 17120