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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 Docket No. 50-272 In the Matter of Proposed Issuance of Amendment PUBLIC SERVICE ELEcrRIC to Facility Operating License
& GAS CO. No. DPR-70 (Salem Nuclear Generating Station, Unit #1)
OUTLINE OF CROSS-EXAMINATION OF EVIDENCE SUBMITTED BY~THE NUCLEAR REGULATORY COMMISSION Pursuant to the Pretrial Order of March 29 1 1979 as amended, the Intervenor, Township of Lower Alloways Creek, submits the following outline of proposed cross-examination.
- 1. Have modifications been considered to the purification system in the event of a loss of water accident in the spent fuel pool at full capacity for storage without room for a full core discharge through 1996?
- 2. The basis for the statement in the Environmental Appraisal that the major portion of the radioactivity decays in the first 150 days following removal from the reactor core.
- 3. The basis. for the statement in the Environmental Appraisal that the proposed modification of the spent fuel pool will not change the basic land use of the spent fuel pool.
- 4. Whether there will be a change in the plant water consumption in the event of a loss of water accident in the spent fuel pool with the pool full without core discharge by the year 1996.
- 5. That the potential off-site radiological environmental impact associated with the expansion of the spent fuel storage capacity do not consider a loss of water accident in the spent fuel pool or a Class 9 accident or melt down or explosion in the reactor which would involve the spent fuel pool.
- 6. Has the Environmental Appraisal considered the potential radioactive release of Krypton P.9 and its daughter Strontium 89?
- 7. Since the NRC has calculated five years would be required to construct. an .. Independent Spent Fuel Storage Installation, (ISFSI), why hasn't the NRC staff taken a position tha;t increased capacity may not be required (given I
expected plant down time) since an ISFSI could be available prior to 264 fuel assemblies being stored in the spent fuel pool.
- 8. Is the five year estimate for an ISFSI by the NRC in the Environmental Appraisal realistic?
- 9. How many metric tons of uranium (MTU) are 264 fuel assemblies? 1 1 170 ~uel assemblies?
Page 2
- 10. The validity of the statement in the Environmental Appraisal that on a* short term basis, i .. e., prior to 1985, an ISFSI is not available for an alternative.
- 11. In evaluating alternatives in the Environmental Appraisal and the conclusion that the environmental impacts of new storage would be less than the environmental impacts of an ISFSI excludes from its consideration a serious accident involving the* reactor and spent fuel pool at full storage.
- 12. In considering alternatives, did the NRC consider the ¢!anger to the safety and health of the public ip.
accumulating large amounts of radioactive fuel assemblies in the.spent fuel pool in close proximity to the nuclear reactor considering the probable risks and- consequences that could be associated with those risks.
Estimated time for cross-examination - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> - 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> CREEK April 25, 1979
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.. ttUNITED STATES OF AMERICA tt NUCLEAR REGULATORY COMMISSION Before the Atomic Safet and Licensin In the Matter of Docket No.
PUBLIC SERVICE ELECTRIC Proposed Issuance of Amendment
& GAS CO. to Facility Operating License (Salem Nuclear Generating No. DPR-70 Station, Unit #1)
INTERVENOR TOWNSHIP OF LOWER ALLOWAYS CREEK OUTLINE: OF CROSS-EXAMINATION' OF EVIDENCE SUBMITTED BY THE LICENSEE*, PUBLIC-SERVICE ELECTRIC &. GAS' CO.
- 1. What information has the Licensee provided as to the Licensee's activities to obtain and construct an ISFSI?
- 2. Has the Licensee performed a real estate survey as to the available tracts of ground in dry unpopulated areas of the United. States available for an ISFSI?
.3. Has the Licensee.developed a timetable acquisition, license and/or construction of an ISFSI?
- 4. Has the Licensee. performed a detailed cost analysis of the ISFSI alternative as compared to the proposed action?.
Estimated time for cross-examination 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> TOWNSHIP OF LOWER ALLOWAYS CREEK I~terv --......_
April 25, 1979
~UNITED STATES OF ]\MERICA~
NUCLEAR REGUIJ\TORY COMMISSION
- Before the* Atomic s*afety and Licensing Board In the Matter of PUBLIC SERVI ~ ELECTRIC DOCKET NO.
& GAS CO. .
(Salem Generating Station Unit #1)
CE;RTIFICATE OF SERVICE I hereby certify that copies of Intervenor's Township of Lower Alloways Creek's outline of cross-examination of evidence sumitted by the licensee and NRC in the *above captioned matter have been served upon the*.attached list by deposit.iin.the United States mail at the post office* in N~rthfield, N.J., with proper postage* thereon, this
~
~ . . .
25th *day of April , 1979. . . . . * *
. CARL V~Special Nuclea Counsel tor the Intervenor, the Township of Lower Alloways Creek Dated: *, April. 25, 1979.
Gary L. Milhollin, Esq.
Chairman, Atomic Safety
& Licensing Board 1815*Jeffersb~ Street Madison, Wisconsin 53711 Glen O. Bright Member, Atomic Safety
& Licensing Board U. S. Nuclear Regulatory Commission Washington,*D. C. 20555 Dr. James c. Lamb, III Member, Atomic Safety &
Licensing Board Panel 313 Woodhaven Road Chapel Hill, N. C~: 27514
- Chairman, Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D. c. 20555
- Chairman, Atomic Safety &
. Licensing Board Panel U. S. Nuclear Regulatory Commission Washingtori, D.* c. 20555 Barry Smith, Esquire .
Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington; D. c. 20555 M~rk.L~ *First, E~quire Deputy Attorney General*
Department of Law & Public Safety
- Environmental Protection Section 36 West State Street Trenton,* N.. J ..
- 08625 Mark J. Wetterhahn, Esquire
. for Troy B. Conner, Jr. , Esq.
1747 Pennsylvania Avenue, N. W.
Suite 1050
- Washington, D. C. 20006 Richard* Fryling', -Jr., Esquire*
Assistant General Solicitor Public Service Electric &
- Gas Company 80 Park Place Newark,*N. J . . 07101
Keith Ansdorff, Esquire Assistant Deputy Public Advocate Department of the Public Advocate Division of Public Interest Advocacy P. o. Box 141 Trenton, New Jersey 08601 Sandra T. Ayres, Esquire Department of the Public Advocate 520 East State Street Trenton, N. J. 08625 Mr. Alfred C. Coleman, Jr.
Mrs. Eleanor G. Coleman 35 "K" Drive Pennsville, N. J.- 08070 Office of the Secretary Docketing and Service Section U. S. Nuclear Regulatory Commission Washington, D. C. 20555 June D. MacArtor, Esquire Deputy Attorney General Tatnall Building, P. O. Box 1401 Dover, Delaware 19901