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Category:Legal-Petition To Intervene/Request for Hearing
MONTHYEARNRC-2022-0185, Eric Joseph Epstein'S Petition for Leave to Intervene and Hearing Request2022-11-28028 November 2022 Eric Joseph Epstein'S Petition for Leave to Intervene and Hearing Request ML18026A0482018-01-26026 January 2018 Letter Enclosing a Petition for Leave to Intervene and Request for Hearing for Pp&L'S Application for an Operating License ML16365A1962016-12-30030 December 2016 Letter of Concern from Sabatini Monatesti Regarding Due Process ML16350A1962016-12-15015 December 2016 Letter of Concern from Sabatini Monatesti Regarding November 21st Decision ML16309A3412016-11-0404 November 2016 Response of Sabatini Monatesti to Susquehanna Nuclear'S Response Opposing SUNSI Access Request ML16308A1652016-11-0303 November 2016 Sabatini Monatesti'S Submission of Talen Energy Riverside Holdings LLC Vulnerability-Threat Matrix NRC-2016-0187, Sabatini Monatesti'S Submission of Talen Energy Corp Riverstone Holdings LLC Transfer Order 10 CFR 50802016-11-0202 November 2016 Sabatini Monatesti'S Submission of Talen Energy Corp Riverstone Holdings LLC Transfer Order 10 CFR 5080 ML16312A4312016-10-11011 October 2016 Email from Sabatini Monatesti Dated 10/11/16 Regarding Request for Hearing and Access to SUNSI Material ML14308A6832014-11-0404 November 2014 Certificate of Service for Service by the Electronic Information Exchange ML14308A6842014-10-24024 October 2014 Request for NRC Hearing on the Proposed Transfer from PPL to the Future Talen Energy Corporation ML0720101172007-05-11011 May 2007 Susquehanna - Petition for Leave to Intervene, Request for Hearing, and Presentation of Contentions with Supporting Factual Data, Submitted by Eric Joseph Epstein ML18025A6931979-12-11011 December 1979 Citizens Against Nuclear Dangers Petition for a Government Inquiry; Replies to Discovery Order; Motions on Interrogatories Before the Atomic Safety and Licensing Board 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 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 ML18023B1541978-09-21021 September 1978 Applicant'S Answer to Petition for Leave to Intervene and Request for Hearing Submitted by the Susquehanna Environmental Advocates ML18023B1531978-09-21021 September 1978 Applicants' Answer to Petition for Leave to Intervene Submitted by Citizens Against Nuclear Dangers. ML18023B1521978-09-21021 September 1978 Applicant'S Answer to Petition for Leave to Intervene And/Or Request for Hearing Submitted by Colleen Marsh and Eleven Other Individuals ML18023B1551978-09-20020 September 1978 Applicants' Answer to Request for an Operating License Hearing and Petition for Leave to Intervene Submitted by the Environmental Coalition on Nuclear Power ML18026A0471978-09-0707 September 1978 Letter Enclosing Petition for Leave to Intervene And/Or Request for Hearing 2022-11-28
[Table view] Category:Letter
MONTHYEARIR 05000387/20230042024-02-0707 February 2024 Integrated Inspection Report 05000387/2023004 and 05000388/2023004 PLA-8096, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2024-01-0404 January 2024 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval PLA-8077, Emergency Plan Revision 67 (PLA-8077)2023-12-27027 December 2023 Emergency Plan Revision 67 (PLA-8077) IR 05000387/20230102023-12-11011 December 2023 Fire Protection Team Inspection Report 05000387/2023010 and 05000388/2023010 PLA-8089, Submittal of Revision to Inservice Testing Program Plan2023-12-0505 December 2023 Submittal of Revision to Inservice Testing Program Plan PLA-8084, Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.22023-11-29029 November 2023 Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2 ML23345A0682023-11-28028 November 2023 Technical Specification Bases, Manual PLA-8091, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091)2023-11-0808 November 2023 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091) IR 05000387/20230032023-11-0303 November 2023 Integrated Inspection Report 05000387/2023003 and 05000388/2023003 PLA-8082, Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program2023-11-0202 November 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program ML23291A1132023-10-12012 October 2023 Submittal of Revision 71 to Updated Final Safety Analysis Report and Revision 25 to Fire Protection Review Report ML23279A0612023-10-0505 October 2023 Paragon Energy Solutions LLC, Part 21 Final Report Re Potential Defect with Eaton Jd and Hjd Series Molded Case Circuit Breakers (Mccbs) ML23277A0412023-10-0505 October 2023 Notification of Commercial Grade Dedication Inspection (05000387/2024011 and 05000388/2024011) and Request for Information IR 05000387/20233012023-09-20020 September 2023 Initial Operator Licensing Examination Report 05000387/2023301 and 05000388/2023301 ML23254A0242023-09-0606 September 2023 Paragon Energy Solutions LLC, Potential Defect with Eaton Jd and Hjd Series Molded Case Circuit Breakers (Mccbs) IR 05000387/20230052023-08-31031 August 2023 Updated Inspection Plan for Susquehanna Steam Electric Station, Units 1 and 2 (Report 05000387/2023005 and 05000388/2023005) ML23228A1952023-08-21021 August 2023 Summary of August 10, 2023, Public Observation Meeting Re. Proposed Alternative PLA-8080, Proposed Relief for Valve 251130 (PLA-8080)2023-08-14014 August 2023 Proposed Relief for Valve 251130 (PLA-8080) PLA-8074, Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2023-08-0303 August 2023 Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval IR 05000387/20230022023-08-0101 August 2023 Integrated Inspection Report 05000387/2023002 and 05000388/2023002 ML23195A1852023-07-27027 July 2023 Correction to Technical Specifications Page 3.3-73 in Amendment No. 265 PLA-8076, Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076)2023-07-20020 July 2023 Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076) ML23201A0152023-07-20020 July 2023 Operator Licensing Examination Approval ML23200A1012023-07-19019 July 2023 Notification of Conduct of a Fire Protection Team Inspection ML23193A0062023-07-12012 July 2023 Requalification Program Inspection PLA-8078, Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-80782023-07-0505 July 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-8078 ML23163A1012023-06-12012 June 2023 10 CFR 50.46 Annual Report (Pla 8065) PLA-8054, Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence2023-06-0808 June 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence IR 05000387/20234012023-06-0707 June 2023 Security Baseline Inspection Report 05000387/2023401 and 05000388/2023401 PLA-8073, Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval2023-06-0101 June 2023 Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval PLA-8064, Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064)2023-05-17017 May 2023 Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064) ML23132A3212023-05-17017 May 2023 Associated Independent Spent Fuel Storage Installation - Issuance of Amendment Nos. 285 and 269 Related to Order Approving Transfer of Licenses PLA-8067, Notification of Completion of Emergence from Bankruptcy (PLA-8067)2023-05-17017 May 2023 Notification of Completion of Emergence from Bankruptcy (PLA-8067) IR 05000387/20230012023-05-12012 May 2023 Integrated Inspection Report 05000387/2023001 and 05000388/2023001 PLA-8066, Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-80662023-05-0808 May 2023 Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-8066 PLA-8053, Radiation Exposure Information and Reporting System2023-04-27027 April 2023 Radiation Exposure Information and Reporting System PLA-8058, Annual Radiological Environmental Operating Report (PLA-8058)2023-04-26026 April 2023 Annual Radiological Environmental Operating Report (PLA-8058) PLA-8041, Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041)2023-04-25025 April 2023 Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041) PLA-8047, 2022 Annual Environmental Operating Report (Nonradiological), PLA-80472023-04-19019 April 2023 2022 Annual Environmental Operating Report (Nonradiological), PLA-8047 PLA-8062, Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-80622023-04-11011 April 2023 Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-8062 PLA-8061, Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-80612023-04-10010 April 2023 Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-8061 ML23090A2302023-03-31031 March 2023 NRC Decommissioning Funding Status Report PLA-8049 PLA-8060, Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060)2023-03-30030 March 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060) ML23095A0572023-03-29029 March 2023 NRC Decommissioning Funding Status Report December 31, 2022 PLA-8057, Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-80572023-03-15015 March 2023 Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-8057 ML23065A1962023-03-0202 March 2023 EN 56387 Paragon - Part 21 Report Re Defect Identified in Automatic Transfer Switch Pn: NLI-ATS480A400X1 IR 05000387/20220062023-03-0101 March 2023 Annual Assessment Letter for Susquehanna Steam Electric Station, Units 1 and 2 (Reports 05000387/2022006 and 05000388/2022006) PLA-8052, (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums2023-02-13013 February 2023 (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums IR 05000387/20220042023-02-0808 February 2023 Integrated Inspection Report 05000387/2022004 and 05000388/2022004 ML23010A0882023-01-15015 January 2023 Summary of Regulatory Audit in Support of License Amendment Request to Revise Control Rod Technical Specifications 2024-02-07
[Table view] |
Text
September 7, 1978 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D, C. 20555 Attention: Docketing and Service Section s6' >>gs >
Executive Legal Director
'U. S, Nuclear Regulatory Commission ~~pl> ~
Wa&ington, D. C. 20555 Jay Silberg, Esq.
Shaw, Pittman, Potts, Trowbridge and Madden 1800 M, Street, N, W, Washington, D. C, 20036 RE: PP5,L Co., et al.
Docket Nos. 50-387 and 50-388.
Dear Gentlemen:
Enclosed please find a copy of Petition for Leave to Intervene and/or Request for Hearing in thc above matter.
Sincerely,
In He: l~cnnsylvania Vow<<r 8. Light. Co. C LE A R RL'G U J ATORY and Allegheny Electric cooperative, Inc. COMMISSION Susquehanna Steam Electric Station, Units 1 and 2. DOCKET NOS, 50-387 and 50-388 PETITION FOR LEAVE TO INTERVENE AND/OR REQUEST FOR HEARING
. NOW come Petitioners, in accordance with 10 CFR Section 2. 714 et seq and Petition the United States Nuclear Regulatory Commission as follows:
1., Petitioners, adult individuals and sui juris, are residents of the Commonwealth of Pennsylvania, whose names and addresse's are more par-ticularly set forth in Schedule ".A", attached hereto and made a part hereof by r'eference thereto.
- 2. Petitioners reside in or about the County of Luzerne, Pennsyl-vania within a 50-mile radius of the proposed premises situate Salem Town-ship, Luzerne County, Pennsylvania whereupon Pennsylvania Power and Light Company and Allegheny Electric Cooperative, Inc. (hereinafter referr-ed to as "Applicants" ) desire to possess, use and operate two.boiling water nuclear reactors known as the Susquehanna Steam Electric St'ation,. Units 1:
and 2 (hereinafter referred to as "Facilities" ).
- 3. Petitioners are proper parties to this proceeding under the Atomic Energy Act of 1954 (the'"Act") as the nature of their right is based upon con-siderations of health, safety to persor'r and property, finance and environment not only of Petitioners, but of those members of the public who reside in Un-restricted Areas (as defined by the Act) in and about and/or surrounding', and in all events within 50 miles of the geographic area of the Facilities proposed by Applicants.
- 4. 'The interests of Petitioners which would be affected by the Appli-cants'ossession, use and operation of the proposed Facilities are as follows, to wit:
A. An unreasonable risk of harm to the'health and safety'of,Petition'crs, and other membersr.of the public as hereinbefore'stated; B. An unreasonable risk of harm to the safety of the private property of Petitioners and others, and the public property located with th6 50-mile radius of Facilities; C. The increased cost of electricity, to be borne by Petitioners and others of the public who are customers of Applicants. is far greater than other electr'icity produced by existing forms of energy;
e page 2 D. The outPut of elect,ricity to be Produced by the Pr Qposed Iiacji ities of Applicants, in relation to cost, will be lower than electricity gener ated by existing forms of energy and therefore more expensive to Petitioners and others; E. The environment within the aforesaid geographic area of 50 miles may be contaminated and square miles of land and water may become useless all to the detriment of Petitioners and others.
- 5. The facts nnd circumstances upon which Petitioners hase thrit Petition are's follows:
'A. Applicants'roposed Facility violated this Commissions Standards for Protection Against Radiation set forth in 10 CFR 20. 1 et seq., and in par-ticular, 10 CFR Section 20. 105 (a) which provides for permissible levels in unrestricted areas and the envi'ronment around the Facilities.
B., Applicants'Summary of Environmental Consequences" (full range of accidents reported under N. R. C. =guidelines), filed with this Commission, sets forth in its Table 7. 1-17 "Assessment of Likelihood of Event" that 'ass
- 8. 1" accidents involving "small pipe" or "large pipe" are "extremely rare" whereas these accidents are common to the design of Applicants'acilities, the probability or likelihood is great, and the effluents emitted into the sur-rounding geographis areas would be in amounts and quantities prohibited by 10 CFR 20. 1 et scq..
C. Applicants design of &acilitics fails to resolve the problem of re-actor coolant pump overspeed in thc boiling water reactors, and thereby poses an unreasonable risk of harm to the health and safety of Petitioners and others.
D. Applicants have failed to ad quately respond to and,comply with this Commission's Notice of Violation issued to Applicants by letter of May 10, 1978, stemming from inspection of Facilities March 20-23, 19~V8, involving preliminary alignment of safety related core insolation= tolerance exceeding . 002 inches estab-lished by field engineer supervisor.
E. Applicants have failed to adequately respond to, and comply with letter of June 27, '1978 directing response to I. E. Bulletin.Number this'ommission's 78-10 in Re: Bergen Paterson product defects.
F. Applicanth'peration and use of Facilities i,s more costly and less efficient than the generation of electricity by existing forms of energy.
G. Applicants'peration and use of Facilities as proposed creates an unreasonable risk of har'm to Petitioner s and the public which outweighs those
pAgo benefits derived by permitting the Applicants to proceed with the Facilities.
V H. The applicants fail to adequately provide plans for informing. the public as to evacuation. proceduzes including drills and warnings in the event of radiation leakage.
- 6. An order by this Commission granting Applicants a facility oper-ating license for the Facilities would adversely affect the interests of Peti-tioners, as herein set forth, by permitting Applicants to possess, use and operate the aforesaid Facilities.
- 7. Petitioners desire to intervene in these proceedings as they re-
)ate to the specific items listed or identified herein.
WHEHEFOHE, the Petitioners respectfully request they be permitted to intervene in these proceedings, or in the alternative, be granted a hearing with respect to the issuance of'the operating license as the same relates to the interests of'Petitioners.
STATE OF PENNSYJ,.VANIA 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~~day of September, 1978.
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THE SECRETARY OF THE COHNISSION
" 'US; NUC'LEAR: REGULATORY COHNISSION 9 DOCKETED USN2C ~ rica ~g ~ rr!<<<<=-
ATTN DOCKET I!NG AND SERVICE SECTION C,
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FO THE CITIZENS AGAINST NUCLEAR DANGERS (THE CI TIZENS) i,BERWICK PENNSYLVANIA HEREBY PETITION To INTERVENE BEFORE THE NUCLEAR REGUlATORY COH~ISSION IN THE APPLICATION FOR 4 FAC LITY OPERATING LICENSE FROH PENNSYLVAN?4 POWER AND LIGHT COHPANY AND 4LLEGHENY ELECTRIC COOPERATIVE INCORPORATED (DOCKET 450"367 4ND 450~368) TO OPERATE THK SUSQUEHANNA STEA<<i FLECTRIC STATIONS UNIT ONE AND TWO (BER~ICK PLANT) LOCATED AT SALEw TowNSHIP PENNSYLVANIA THK CITIZENS ALSO REQUEST THAT. PUBLIC HE4RINGS BE CONDUCTED BY THE NRC Ihl THIS" 'CASE. THE CITIZEtIS HAVE ACTIVELY PURSUED DEVELOPMENTS AT THE BERWICK PLANT FOR SEVERAL YEARS IN THE PUBLIC INTEREST, aND THE PUBLIC INTEREST I'IILL DEFINITELY BE EFFECTED BY THESE PROCEEDINGS, THEREFOREi THE CITIZENS SEEK STANDING IN THIS CASE BEFORE THE NRC ~
THE CITIZENS SPECI'FY THE REASONS WHY INTERVENTION SHOULD BE PERMITTED AS THg FOLLOAINGp
,1, THE MARKET VALUE AND PROPERTY RIGHTS OF CITIZENS IN THE EFFECTED AREAS ARE PLACED It< JEOPARDY BY THE BKRWICK PLANT
- 2. IF THE PUBLIC INTEREST IS To BE SERVED PUBLIC TESTIHONY IS REQUIRED UNDER THE RIGHT OF DUK PROCESS GUARANTEED BY THE US CONSTITUTION 3 THE EFFEcTs oN THE ENvIRONHKNT BY THE BERwicK PLANT HILL LINGER FGR GENERATIONSi AND THE EIS RUST BE CAREFULLY AND SCIENTIFICLY EVALUATED NOWT PL/<<NT THIE SAFETY OF THE SYSTKHS AND WODES OF DELIVERY AT THE BERWICK PLANT ARE THK PROPE;R SUBJECT FOR TESTIMONY BY EXPERTS>> WHICH THE CITIZKNS wILL PRESENT BEFORF THK NRCa THE CITIZENS IDENTIFY THE SPECIFIC ASPECTS OF THE SUBJECT I'IATTER AS THE PROBABLE DANGERS TO PUBLIC HK4LTH AND
- SAFFTY FROW THE OPERATION OF THE BERWICK PLANT CONCERNING>
STORAGE OF RADIOACTIVE FUEL 4ND R4DIOACTIVE WASTE ON THE PREMISES 2, TRANSPORTATION OF RADIOACTIVE MATERIALS TO 4ND FROH THK BERWICK 3 ~ CATASTROPHIC BREAKDOWN<<IN 4T THE BERWICK PI.ANT 4 ~ 'DEQUACY OF EVACUATION PLANS IN CASE OF ENERGENCIES 5 ~ OTHER KNVIRONNKNTAL HEALTH DANGERS c
HRS IRENE LEHANOWICZ CHAIRPERSON TO REPLY BY MAILGRAM, SEE REVERSE SIDE FOR WESTERN UNION'S TOLL - FREE PHONE NUMBERS
PAGE 2 St~+ii ~>>-
THE C IT IZENS AGAINST NUCLEAR DANGERS PO BOX 377 RD i.
BERN I CK PA 18603 22:O5 EST NGNCOt"P HGH TO REPLY BY MAILGRAM, SEE REVERSE SIDE FOR WESTERN UiVION'S TOLL - FREE PHONE blUMBERS