Similar Documents at Salem |
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Category:Legal-Correspondence
MONTHYEARML0931001372009-11-0505 November 2009
E-mail from Ray P. Kuyler, Counsel for PSEG Nuclear in Response to Petitioner'S Request for Extension of Time to File a Request for Hearing and Petition to Intervene
ML0931001452009-11-0404 November 2009
Letter from Alex Polonsky, Counsel for PSEG Nuclear in Response to Nov. 2, 2009 Request for Extension of Time to File by Delaware Riverkeeper and the New Jersey Environmental Federation
ML0931001552009-11-0404 November 2009
2009/11/04- Notice of Appearances of Vincent C. Zabielski, Kathryn M. Sutton, Alex S. Polonsky, and Raphael P. Kuyler, Counsel for PSEG Nuclear in the Salem 1 and 2 License Renewal Proceeding
ML0931001532009-11-0404 November 2009
2009/11/04- Notice of Appearances by Vincent C. Zabielski, Kathryn M. Sutton, Alex S. Polonsky, and Raphael P. Kuyler, Morgan, Counsel for PSEG Nuclear in the Hope Creek License Renewal Proceeding
ML0931001522009-11-0404 November 2009
2009/11/04- Letter from Alex Polonsky, Counsel for PSEG Nuclear Petitioner'S Request for Extension of Time to File a Request for a Hearing in the Hope Creek License Renewal Proceeding
ML0931006172009-11-0202 November 2009
2009/11/02- Letter to Chairman Jaczko from Jane Nogaki, Nj Environmental Federation Requesting a 60 Day Extension to File a Hearing Request in the Hope Creek and Salem 1 and 2 License Renewal Proceedings
ML0931006042009-11-0202 November 2009
2009/11/02 - Email from Fred Stein, Maya K. Van Rossum, Delaware Riverkeeper Requesting a 60 Day Extension to File a Request for Hearing in the Hope Creek and the Salem 1 and 2 License Renewal Proceeding
ML0309700872003-03-25025 March 2003
Rothschild Inc.'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period February 1, 2003 - February 28, 2003
ML0234003322002-12-0606 December 2002
Memorandum from Emile L. Julian to Recipients of Letter Dated 12/04/02 from Annette L. Vietti-Cook to Norm Cohen Regarding DD-02-03
ML19029A8491981-02-17017 February 1981
02/17/1981 Certificate of Service on Copies of Licensee'S Response to Briefs in Support of Exceptions of Lower Alloways Creek Township and Mr. and Mrs. Alfred C. Coleman, Jr
ML19029A8531980-11-30030 November 1980
11/30/1980 Legal Correspondence Intervenors' Exception to Initial Decision of October 27, 1980
ML19029A8851980-05-13013 May 1980
Certificate of Service of Copies of Licensee'S Request for Extension of Time & Response to NRC Staff Motion for Extension of Time & Licensee'S Proposed Transcript Corrections for the Evidentiary Hearings of 3/28-29/1980.
ML19029A8861980-05-0202 May 1980
05/02/1980 Legal Correspondence Delaware'S Corrections of Transcript
ML19029A8781980-04-10010 April 1980
04/10/1980 Legal Correspondence Licensee'S Response to Licensing Board Question 5 on 'Gross Loss of Water' from the Salem Spent Fuel Pool
ML19029A8811980-04-0909 April 1980
04/09/1980 Legal Correspondence Submittal of Technical Report of Dr. Richard E. Webb in Response to ASLB Order of February 22, 1980
ML19029A8791980-04-0909 April 1980
04/09/1980 Legal Correspondence Written Testimony and Qualifications of Dr. David B. Fankhauser, in Response to ASLB Order of February 22, 1980
ML19029A8821980-04-0707 April 1980
04/07/1980 Legal Correspondence Intervenors' Inability to Prepare Written Testimony in Requisite Time to Most Recent Question Posed by Board
ML19029A7781979-12-13013 December 1979
Informing Licensee'S Installation Procedure for Increased Capacity Spent Fuel Racks Has Been Submitted
ML19029A7651979-08-31031 August 1979
Certify Copies of Licensee'S Response to Motion for Reconsideration of Coleman'S Contention No. 13 & Licensee'S Response to Motion to Re-open Coleman'S Contention 2 & 6 for Receipt of Newly Discovered Evidence.
ML19029A7641979-08-31031 August 1979
Licensee'S Response to Motion for Reconsideration of Colemans' Contention No. Thirteen
ML19029A7551979-08-22022 August 1979
Unit #1 - Intervenors', Coleman, Response to Boards Question Number Four: Was TMI a Class Nine Accident?
ML19029A7601979-08-10010 August 1979
Applicant'S Request for an Extension of Time to Respond to Intervenors' Motion to Reopen Coleman'S Contentions Two & Six for Receipt of Newly Discovered Evidence & Motion for Reconsideration of Dismissal of Coleman'S Contention No. 13.
ML19029A8181979-06-26026 June 1979
06/26/1979 Licensee'S Answer to Motion by Intervensors, Coleman, to Compel Supplementation of Answers to Interrogatories by Licensee
ML19029A8211979-06-25025 June 1979
Intervenor Township of Lower Alloways Creek Response to NRC Staff Objection to Board Question
ML19029A8231979-06-18018 June 1979
Licensee'S Response to NRC Staff Objection to Board Question and Motion for Extension of Time to File Response to Board Question Relating to Class 9 Accidents
ML19029A8251979-06-14014 June 1979
Enclosed Brief on Behalf of Interveners in Opposition to Staff'S Objection to Board'S Consideration of Impacts of Class Nine Accident on Salem Spent Fuel Pool
ML19029A8281979-06-12012 June 1979
06/12/1979 Legal Correspondence Response to the Atomic Safety and Licensing Board Order Dated April 18, 1979
ML19029A8301979-06-11011 June 1979
06/11/1979 Legal Correspondence Intervenor Township of Lower Alloways Creek Motion for Extension of Time to Respond to NRC Staff Objection to Board Question
ML19029A8541979-04-26026 April 1979
04/26/1979 Legal Correspondence Professional Qualifications of Warren S. Nechodom
ML19029A8631979-04-25025 April 1979
04/25/1979 State of New Jersey'S Outline of Cross-Examination
ML19029A8611979-04-25025 April 1979
04/25/1979 Licensee'S Outline of Cross-Examination
ML19029A8601979-04-25025 April 1979
04/25/1979 Legal Correspondence Outline of Cross-Examination of Evidence Submitted by the Nuclear Regulatory Commission
ML19029A8581979-04-25025 April 1979
04/25/1979 Legal Correspondence Outline of Areas of Cross-Examination
ML19029A8571979-04-25025 April 1979
04/25/1979 Intervenors' Response to ASLBP Order Dated April 18, 1979
ML19029A8561979-04-25025 April 1979
04/25/1979 Outline of Intervenors, Colemans, Cross-Examination; Contentions Two and Six
ML19029A8641979-04-24024 April 1979
04/24/1979 Legal Correspondence Non-Proprietary Version of Exxon Nuclear Company'S Report on Fuel Storage Racks Corrosion Program
ML19029A8671979-04-23023 April 1979
04/23/1979 Licensee'S Objections to Intervenors' Profferred Testimony
ML19029A8731979-04-12012 April 1979
04/12/1979 Legal Correspondence Application for Stay by the Township of Lower Alloways Creek
ML19029A8741979-04-11011 April 1979
04/11/1979 Legal Correspondence Intervenors Submit Their Proposed Direct Testimony to Be Elicited from Robert M. Crockett, Vice President for Fuel Supply, Public Service Electric and Gas Company
ML19029A8771979-04-0707 April 1979
04/07/1979 Legal Correspondence Township of Lower Alloways Creek Objections to Prehearing Order and Requests for Revision of Order or Recertification
ML19029A4421979-04-0202 April 1979
Letter Re Prehearing Conference to Fulfill the Requirements by the ASLBP for the Identification of Written Testimony and the Proposed Order or Proof
ML19029A8471979-04-0202 April 1979
04/02/1979 Legal Correspondence Identification of Written Testimony to Be Filed
ML19029A4541979-03-26026 March 1979
Interveners, Colemans' Memorandum in Opposition to the Licensee'S Motion for Summary Disposition, Interveners' Statement of Material Facts in Dispute Pertaining to Contention Two
ML19029A4571979-03-20020 March 1979
Interested State of Delaware'S Answer to Licensee'S Motion for Summary Judgment
ML19029A4591979-03-12012 March 1979
Intervenor Township of Lower Alloways Creek'S Answer to Motion for Summary Disposition
ML19029A4601979-03-12012 March 1979
Request for Report & Correspondence for Constituent'S Inquiry
ML19029A4641979-03-0707 March 1979
Intervenors, Colemans, Motion to Consolidate Prehearing Conference with Special Prehearing Conference for Purposes of Prehearing Order
ML19029A4651979-03-0606 March 1979
Letter Re Resolution Which Was Approved & Adopted by Township Committee of Township of Pennsville
ML19029A4691979-02-27027 February 1979
Public Service Electric & Gas Co. - Licensee'S Memorandum in Support of Its Motion for Summary Disposition
ML19029A4731979-02-16016 February 1979
Resolution Opposing Storage of High Level Radioactive Wastes in Lower Alloways Creek Township
2009-11-05
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ) Docket No. 50-272
)
PUBLIC SERVICE ELECTRIC & GAS COMPANY) Proposed Issuance of
) Amendment to Facility (Salem Nuclear Generating Station, ) Operating License Unit 1) ) No. DPR-70 OUTLINE OF THE AREAS OF CROSS-EXAMINATION In response to the Pretrial Order of March 29, 1979, as clarified in the conference call* of April 13, 1979, which was memorialized by Lower Alloways Creek Township on April 16, 1979, the following outline of the areas of cross-exnmination is filed.
- 1. The effect on the Delaware River and Bay and its resources of any potential leakage.
- a. Any methods of detection of containment breaches.
- b. The effects of major or minor ~ccidents.
- 2. The provisions for monitoring any change in material, particulary any material that affects criticality.
- a. The mechanical intergrity of tht boran shi~lding.
- b. The integrity of the welds of sheathing materials.
- c. Changes in material due to corrosion.
- 3. The safety factor allowed in the K eff calculation.
- a. Provisions for replacement of materials if needed.
- b. The potential for criticality under various combinations of problems.
- 4. The containment buildirg:
- a. Environmental monitoring of exit points in view of increased storage.
- b. The possibilities of breach of the containment building assuming various combinations of problems.
- 5. Provisions for ground water monitoring.
- 6. Th2 effects of accidents on the population in Delaware within a five-mi:e circle and a 10-mile circle of the fuel storage building.
A rough estimate of the time needed for Delaware's cross-examination is one hour.
Delaware reserves the right as an Interested State to address all relevant and probative points at the time of the evidentiary hearing.
Respectfully submitted,
~fl~aJ~
une D. MacArtor eputy Attorney General Tatnall Building P. 0. Box 1401 Dover, Delaware 19901 Dated: April 25, 1979
CERTIFICATE OF SERVICE I hereby certify that copies of Delaware's Outline of the Areas of Cr>oss-Exam:ination have been served upon the following by deposit in the U.S. Mail this 25th day of April, 1979:
Gary L. Milhollin, Esq., Chairman Mark J. Wetterhahn, Esq.
Atoir.ic Safety and Licensing Board for Troy B. Conner, Jr. , Esq.
1815 Jefferson Street 1747 Pennsylvania Ave., N. W., Suite 1050 Madison, Wisconsin 53711 Washington, D. C. 20006 Mr. Glenn 0. Bright, Member Richard Fryling, Jr., Esq.
Atomic Safety and Licensing &!. P.:mel Assistant General Solicitor U. S. Nuclear Regulatory Comnission Public Service Electric & Gas Co.
washington, D. C. 20555 80 Park Place Newark, N. J. 07101 Dr. James C. lamb, III, Member Atomic Safety and Licensing B:l. Panel R. William Pot'cer, Esq.
313 Woodhaven Road Assistant Deputy Public Advocate Chapel Hill, N. C. 27514 Division of Public Interest Advocacy P. 0. Box 141 Chairman, Atomic Safety & Licensing Trenton, N. J. 08601 Appeal Board Panel U. S. Nuclear Regulatory Commission Sandra T. Ayres, Esq.
Washington, D. C. 20555 Depar"bnent of the Public Advocate 520 E. State Street Chairman, Atomic Safety and Licensing Trenton, N. J. 08625 Board Panel U. S. Nuclear Regulatory Commission Mr>. Alfred C. Coleman, Jr.
Washington, D. C. 20555 Mr>s. Eleanor G. Coleman 35 "K1 1 Drive Barry Smith, Esq. Pennsville, New Jersey 08070 Office of Executive Legal Director U. S. Nuclear Regulatory Commission Carl Valore, Jr. , Esq.
Washington, D. C. 20555 Valore, McAllister, Aron & WesiJnoreland Mainland Professional Plaza Mark L. First, Esq. P. 0. Box 175 Deputy Attorney General Northfield, N. J. 08225 Department of law and Public Safety Enviro~.Jilental Protection Section Office of the S2cretary 36 West State Street Docketing and Service Section
.Trenton, New Jersey 08625 U. S. Nuclear Regulatory Corrnnission Washington, D. C. 20555 Keith Ornsdorff, Esq.
Assistant Deputy Public Adyocate Department of Public Advocate P. 0. Pox 141 Trenton, New Jersey 08601
