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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20063N7591982-10-0606 October 1982 Withdrawal of Application for CP ML20055A7221982-07-15015 July 1982 Memorandum & Order Denying Jf Doherty 820615 Submittals, Treated as Motion to Reconsider ASLB 820602 Order.Motion Untimely Filed & Failed to Show Significance or Gravity of Issues ML20055A3551982-07-12012 July 1982 Amended Contention 59.Certificate of Svc Encl ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20052D1221982-04-29029 April 1982 Findings of Fact on Supplemental Issues to Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20052A4541982-04-22022 April 1982 Submittal of Contention 58 Re Applicant Conduct on Reporting Violations at Plant.Certificate of Svc Encl ML20054E0561982-04-21021 April 1982 Supplemental Findings of Fact on Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20049K0671982-03-25025 March 1982 Reply to Tx Pirg 820315 Addl Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20042B2451982-03-15015 March 1982 Motion for Subpoena of Quadrex Corp Employees.Testimony Necessary for Clear Understanding of Brown & Root Deficiencies Despite Util Supervision & Specific Steps Needed to Correct & Prevent Problems.W/Certificate of Svc ML20042B2381982-03-15015 March 1982 Sixth Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20041F0761982-03-10010 March 1982 Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence ML20041F0871982-03-10010 March 1982 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Addl Time Needed to Complete Discovery.Certificate of Svc Encl ML20049J6571982-03-0808 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl ML20041E1741982-03-0505 March 1982 Brief Opposing R Alexander Appeal from ASLB 820112 Order Denying Petition to Intervene.Aslb Did Not Abuse Discretion in Denying Petition.Certificate of Svc Encl ML20041E1201982-03-0505 March 1982 Motion for Order Directing Applicant to Provide Forthcoming Bechtel Quadrex Rept Review.Rept Pertinent to Remaining Issue.Certificate of Svc Encl.Related Correspondence ML20041E1181982-03-0505 March 1982 Third Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept Matters.Related Correspondence ML20041E1071982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl ML20041E1001982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20041E0711982-03-0404 March 1982 Second Set of Interrogatories Re Tx Pirg Contention 21 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20049H8881982-03-0101 March 1982 Response Opposing D Marrack 820213 Motion for Review of Dates for Reopening Hearings & Continuance.No Commission Regulations or Atomic Energy Act Provisions Require Applicant Irrevocable Commitment.Certificate of Svc Encl ML20041B5381982-02-22022 February 1982 Reply to Intervenors Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20041C0671982-02-22022 February 1982 Response Opposing Tx Pirg 820209 Motion for Addl Time to File Proposed Findings of Fact & Conclusion of Law.Motion Mooted by Tx Pirg Filing Proposed Findings on 820212. Certificate of Svc Encl ML20041B5421982-02-17017 February 1982 First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl.Related Correspondence 1982-07-02
[Table view] Category:PLEADINGS
MONTHYEARML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20041F0871982-03-10010 March 1982 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Addl Time Needed to Complete Discovery.Certificate of Svc Encl ML20041E1201982-03-0505 March 1982 Motion for Order Directing Applicant to Provide Forthcoming Bechtel Quadrex Rept Review.Rept Pertinent to Remaining Issue.Certificate of Svc Encl.Related Correspondence ML20041E1741982-03-0505 March 1982 Brief Opposing R Alexander Appeal from ASLB 820112 Order Denying Petition to Intervene.Aslb Did Not Abuse Discretion in Denying Petition.Certificate of Svc Encl ML20049H8881982-03-0101 March 1982 Response Opposing D Marrack 820213 Motion for Review of Dates for Reopening Hearings & Continuance.No Commission Regulations or Atomic Energy Act Provisions Require Applicant Irrevocable Commitment.Certificate of Svc Encl ML20041C0671982-02-22022 February 1982 Response Opposing Tx Pirg 820209 Motion for Addl Time to File Proposed Findings of Fact & Conclusion of Law.Motion Mooted by Tx Pirg Filing Proposed Findings on 820212. Certificate of Svc Encl ML20041B5901982-02-13013 February 1982 Motion for Postponement of All Action on CP Application Until Applicant States That Util Irrevocably Committed to Building Plant If CP Received.Certificate of Svc Encl ML20040H0761982-02-0909 February 1982 Motion for 30 Addl Days to File Proposed Findings of Fact & Conclusions of Law.Length of Record Necessitates Extension. Decision Would Not Be Delayed Since Addl Hearings to Be Held in Apr 1982 ML20040E2781982-01-29029 January 1982 Requests for Clarification Re R Alexander 811130 Petition to Intervene.J Silberg 820122 Ltr Indicates That Order Denying Petition Issued,But No Order Has Been Served.Certificate of Svc Encl ML20039B7481981-12-17017 December 1981 Response Opposing Tx Pirg 811207 Motions for Addl Testimony, Further Development of Record & Admission of New Contention. Motion Superficial Attempt to Delay Proceeding & Totally Devoid of Merit.Certificate of Svc Encl ML20062M6441981-12-14014 December 1981 Response Opposing Doherty 811015 Renewed Motion for Addl Evidence on Tx Pirg Contention 31.Doherty Failed to Comply W/Aslb 811110 Order.Motion Is W/O Merit & Would Cause Unnecessary Delay.Certificate of Svc Encl ML20062M6241981-12-0707 December 1981 Motion for Tx Pirg to Present Addl Evidence,To Order Applicant to Serve Tx Pirg W/Quadrex Rept & to Rule That Need for Power Is Tx Pirg Contention.Alternatively,Requests Admittance as Tx Pirg Contention.W/Certificate of Svc ML20039B0771981-12-0707 December 1981 Renewed Motion for Addl Evidence on Tx Pirg Addl Contention 31 Re Applicant Technical Qualifications.Specifies Portions of Quadrex Rept,Indicating Organizational Changes That Should Be Made.Certificate of Svc Encl ML20038A8841981-11-20020 November 1981 Response Opposing Doherty 811106 Motion for Addl Testimony on Need for Power.Pleading Construed as Motion to Reopen Record.Burden of Explaining Why ASLB Would Reach Different Result Not Met.W/Certificate of Svc.Related Correspondence ML20010F4791981-09-0303 September 1981 Response Opposing Further Consideration of Radon Releases. NRC Analysis of Radon Releases in Final Suppl to Fes Satisfies NEPA Requirements,Complies W/Commission 780414 Order & Supplies Sufficient Info.Certificate of Svc Encl ML20010G1101981-09-0303 September 1981 Response to ASLB Request Re Positions on ALAB-640.Radon Emissions Determined by ALAB-640 Constitute Significant Addl Environ Impact.Certificate of Svc Encl ML20010A1171981-08-0505 August 1981 Motion to Strike Marrack Prefiled Testimony.Testimony Is Not Specifically Responsive to F Sanders 810205-06 Testimony. Certificate of Svc Encl.Related Correspondence ML20009B2031981-07-0707 July 1981 Response in Opposition to Intervenor Doherty 810622 Request for Leave to File Contention 57.No Good Cause Shown for Late Filing & No Specificity Provided.W/Science News Article & Certificate of Svc ML20005B3801981-06-22022 June 1981 Request for Leave to File & Submission of Contention 57 Re Vulnerability of Control Sys to Electromagnetic Pulses. Issue Has Not Been Made Public Until Recently.W/Certificate of Svc ML19347F4941981-05-0808 May 1981 Reply Opposing Doherty 810423 Filing Re Contention 56, If Filing Is Motion to Add Late Filed Contention. Contention Refs Alleged Problem at Browns Ferry Which Is Not Applicable to Mark III Containments.W/Certificate of Svc ML19347F4661981-05-0808 May 1981 Response Opposing Doherty 810423 Motion to Reopen Record on Need for Power Contention.Aslb Should Issue Order That Motion Is Moot & Direct Applicant to Update Testimony on Need for Power Testimony Later.Certificate of Svc Encl ML20003H9551981-04-29029 April 1981 Motion for Order Adopting Specific Procedures to Govern Conduct of cross-examination During Health & Safety Phase of Proceeding.Procedures Will Ensure cross-examination Not Cumulative.W/Proposed Order & Certificate of Svc ML19343D3891981-04-27027 April 1981 Motion to Strike I Bross 810331 Affidavit.Affidavit Does Not Respond to Ld Hamilton Supplemental Affidavits But Constitutes Personal Attack of Affiant.Certificate of Svc Encl.Related Correspondence ML20126J9451981-04-24024 April 1981 Motion Opposing Applicant 810422 Motion to Preclude Jm Scott Testimony.Tx Pirg & Intervenor Doherty Are Separate Parties ML20003H7981981-04-22022 April 1981 Motion for Addl Testimony & cross-examination on Conservation Techniques,Interconnection & Effects of Const Delay.Proceedings Have Not Addressed These Issues. Certificate of Svc Encl ML20003H7471981-04-22022 April 1981 Motion to Preclude Jm Scott Testimony.Intent of ASLB 810407 Order Was to Preclude Scott from Having Dual Role of Atty & Witness for Any Other Party.Certificate of Svc Encl. Related Correspondence ML20126H9601981-04-0707 April 1981 Request for Order Directing Util to Reissue 810331 Pleading W/Correct Title.Defective Title Did Not Put All Parties on Notice ML20126H9641981-04-0707 April 1981 Response in Opposition to Util & NRC 810330 Motions to Disqualify Tx Pirg Counsel,Jm Scott.Counsel Will Appear as Expert Witness.Public Interest Requires Counsel Presence. Certificate of Svc Encl ML19347D9721981-03-31031 March 1981 Response to NRC & Applicant Responses to J Doherty 810222 Motion for Reconsideration of Admission of Contention 21. Filing of Motion Was Timely Under Circumstances. Certificate of Svc Encl ML19345G4941981-03-30030 March 1981 Brief,In Form of Pleading,Addressing Need to Disqualify Tx Pirg Counsel Per Disciplinary Rules 5-101 & 5-102.Having Chosen to Appear as Witness,Scott Should Be Barred from Participation as Atty.Certificate of Svc Encl ML19345G5831981-03-24024 March 1981 Response for Order Allowing Intervenors to File Id Bross Supplemental Affidavit to Respond to Ld Hamilton Affidavit on Behalf of Util.One Day Delay Should Be Excused Due to Intervenor Attempt to Comply W/Rules.W/Certificate of Svc ML20003D2161981-03-0404 March 1981 Response Opposing Tx Pirg 810217 Motions on Procedural Matters,Referral of Interlocutory Appeal,Certification of Various Issues & Removal of Aslb.Motion Contains Misrepresentations of Alab Rulings.W/Certificate of Svc ML19341D4801981-02-25025 February 1981 Response to Intervenor Doherty Third Supplemental Response to Motion for Summary Disposition.Intervenor Has No Right to File Late Responses,Shows No Good Cause & Info Has No Relationship to Affected Contentions.W/Certificate of Svc ML20003C3161981-02-17017 February 1981 Requests to ASLB for Interlocutory Appeal & Certification of Questions & to ASLAP for Direct Certification of Question Re Ability of Intervenors to cross-examine Witnesses. Certificate of Svc Encl ML20003B0771981-02-0505 February 1981 Response in Opposition to Intervenor Jf Doherty Contention 55.Contention Does Not Address 10CFR2.714 Requirements & No Good Cause Established for Late Filing.Certificate of Svc Encl ML19345E8521981-01-30030 January 1981 Suppl to 810129 Motion Requesting Reversal of 810123 Ruling Denying Intervenor Rentfro cross-examination Opportunity.Evidence Supporting Intervenor Discernible Interest in Issues Outlined.W/Certificate of Svc ML19345E5721981-01-29029 January 1981 Requests ASLB Reconsider Ruling Restricting cross-examination,for Interlocutory Appeal & Certification of Questions.Also Moves Aslab for Directed Certification of Questions & Appointment of New Aslb.W/Certificate of Svc ML19341B6021981-01-29029 January 1981 Response Opposing Intervenor Doherty 810123 Motion to Change Cross Examination Procedures.Repetitious cross- Examination Would Be Avoided If All Intervenors Attended All Proceedings.Certificate of Svc Encl 1982-07-02
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U3I S D STACES SUC13AE REGUIAOCHY CC)GIISSICK 217C25 "__"e ATCMIC SAJITT AH3 I:::::BIIG 3CA23 g *g g *t In the Mattar of ECUSTCN LIGET!33 AND PCYER CCEANT Q Decket Yo. :C h66 -
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Pusuant to- 10 C73 2 71' 4 (a)(3), the petitioners' sententions of April 13, 1979, relative to a eyent fuel meltteva (SIM) that is possible at ACNGS, are herewith amanist and 8nfized8* .
- 1. Tuther rubstantiaties of the yestslatism of a SIM at AGNG3 is the doeuaxs prepaLred fer the USERC, " Spent Tuol Heatup 7en evisc Less of Vater During Storags8 (3U33G/CL C6k9 SA:iD 77-1371. This study, which supports maar of the fi241xgs of the WEST Ger=ma lepert 13 290, Angsst,1976, someus that the yeesibility that a 37M ses11 eeen uless sigxifisant Masign modifications 8 er 8effsetive emergsmay eeutarzessures" are instituts&. 3eththeNU25G/Ch C6h91sprt and the first and second Vest Germaz 2eyerts 13 290, August 1976 and November 1977, de met negate the yeesibility of a S2M, but sinyly rely, in such an event, that plaat persommel could pressed with eeunternessues in reylasement of eselant to datar a SIM. It sammet be debated that such a possibility of a 32M saa essu.
As previously stated 12 ear sententions of April 13th, 8Aside frem the mena=4 su et sabotage, huan amt mechanisal error, termadees amt earthqsakes causing a spent fuel yeel meltteva, there is an alarming posibility of a roaster maltteva preelyitating a fuel nel meltdeva.
This is a yessibility because the eseling systems of the roaster and the spat fuel yeel are lished together.* 7enevizg sush scenaries, there is every pebability that radiation deses veult reach such levels that plant persemasi vesli be sempned to evasuste ami abandex the roaster. Sizes the caeling system for the syest fuel pel (37P) beoemas mem-famatiemal, the S7P rapidly heats sin amt yreeeeds to beildeva ama meltteva sassing massive releases of lethal radienstivity. ,
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Neither the applicant mer' the staff have adequately esasitared the aests in terms of health as ven, as the seezemis sests of a yeesible aseident in th ex-site stomage of syest fuel.
The Timal Supplement to the 733 (EU23G-0470) fails to discuss the pssibility of a S2M ami what measures vesis be instituted to provsat such escurrames. Neither the ayylisant mer the staff have taksa inte seasideraties the requisita of plant design modificatism to help imped.e a SIM as resemmended by 3UEEG/CLC6h9
- 2. Additionany, the syylisant has met dealt adequtely with th additiemal hazard involved ix the yessible storage of spent fuel is eleser yrszimity than originam plammed. Hammfae-tuers of high-tensity storage racks which significantly imersase existing storage sayability aise have met dealt with this additiemal hazard. I2 Jazuary 23, 1979 Prospectus of Texas Utilities Co. , it stated, 8...thare vill be en-site storage sayasity for spent fuel to asses-medate the operation of the uits ama this storage sayasity eam be ixeressed if needed."
While yetitiemars de met have assess te e, earrant EI&P Prospetus, there is me desht AC3GS vin be seastrusted to have a senatant imersment storags sayasity.
If the methat to be used for 12ersasing sseh storage sayasity is by the sse of high-Lensity storage rasks, this particular qsestien needs to be addressed by the syylisant.
3 The- spent fuel melttava esatsation has already been asseytet by various Atomie amt Safety Lisemetzc 3 marts en other Deekets. Inslosed is a list of some musisar plant heariscs ami their rosyestive 3eekst Yumbers vhare the sentantism has already boom asesytet as valid amt yestiment ts hearing preseedings. Alse emelssed are sayiss of two sets of sententions, forma-lated by an esiment muelear seientist with rztensive lengsvity experienee W.th the Atente Zaergy Commission amt the suelear 12dastry in sommercial amt military reaetors, that have been eAyyliaant's terminolog7 re 8Ayyliaant's 2sspass to Texpirg's Amends 4 Cententions", hly 10, 979-p((q { g ]y j 79 0050 M 6
asseytet by the Atomie Safety a.ad Liseme12c 3.ards em two deer.sts, he testimesy of asether
.emissat muelear setentist (biography enslesed) em the S2M centention, reyresent124 a State en ene of these Deskats is aise ensleest. Wat is eyes more signifisant to the validity of this sententism is the fast that the ASL3 en ens of the Deckats,12 assept12g the sententisa, vent further and isesed its eva suse12st qseettoms relevant to a S2N to be disasseed 12 the hea 12g preeeedings. A copy of these AEL3 qssetiens are aise emelesed, ha enslosed esatea-tiema em the other Deeksts, the related testisemy b7 the expert vitsees, the yeigzaat qsse-tiens yesos by the ASL3 en the other Deekst are all relevant and ayylisable to ACEGS. Se overriding eensara of the ayylisant ama the USSEC should be safety.
It would ayyear to be s. great ixseagruity if the esent fuel meltdawn sententiens that are already asseyted by the US33C is ammeress other Deeksts, met be seasidered apsesite to the Alleas Creeic HGS heariscs. It is 12sumbeat spea the ayylisaat and the UEH2C 12 its shartered duty to allev this eardi 321 safety issue to be deliberated om in the AC3GS heariss yreseedi .gs.
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Esbert 3. Framaea Madelina 3 ass Fraasem D Wayamebers Drive Houstom, l'azas 77035 Served to:
Chase 3. Stephens Atomie Safety amt Licensixg 3sart Steve Sekinki, Zeq. -
- 2. Gerden Gesch, Isq. - '
Jash E. Nevann, Esq.
11ehart I.everre, 3sq.
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Carre Hizdarstela 3renda Macerkle James Seatt, Jr.
F. H. Petthoff, III Dr. David Marrask Wayne 3. HeAtir*
Iatherize Eseker Dr. Jean-Claude de3remaseker Nattomal Lawyers Guilt
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Lisensing 3eard, Salsa Statina Unit 1. Deeket No. 50-272, issued em April is,1979, the follow 12g questions to be part of the hearisg:
- 1. To what extent did the assissut at Three Mile Islaat affect the spent fuel peel at that sitet
- 2. If there had bees, an oxy'Issies er 'melttava 8 at Three Mile Island, what affset vesid that have had upet the eyeat. fuel peel? To s at extent wes11 it have mattered hev such fuel was Jgesent at the yeelt 3 If an asti&ent esch as the one at Three Mile Island eesurred at Sales, te what extent veszt the seei[emt affset the syeat fuel peelf If an erylosion er duelt-4ewa8 escurret at the Salsa Station, to what extent ves1A it have mattered how h f.., w.. ,r....t . t . ,.e1 . t. 31 S,.t , e.,
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s CONTENTIONS REGARDING THE ACCIDENT HAZARDS OF SPENT FUEL STORAGE AT THE SALEM NUCLEAR POWER PLANT SALEM, NEW JERSEY d BY :
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)'RTCilARD Februar" E. WERB, 27, 1979 DUPLICATE DOCUMENT Entire document previously entered into system under:
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An Analysis of the Accident Hazards of Storing Highly Radioactive, Spent Fuel Rods in Spent Fuel Storage Pools at Nuclear Pov(er Plants and at Other Off-Site, Storage Facilities: 'elith Special Reference to the Zion Nuclear Power Plant near Chicago, Iuinois
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- by Richard E. 'ilebb , Ph. D.
April 3, 1979 DUPLICATE DOCUMENT Entire document previously entered into system under:
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I. Introd uc tion Nuclear power plants produce extremely large amounts 'of radioactive substances as a by-product of operation --- substances which emit harmful nuclear radiation and which must be absolutely confined to containers and prevented from escaping into the bio-sphere (the human environment), in order to avoid exposing humans and other life to high levels of radiation and the high risk of cancer and other diseases that would result. These substances are considered as nyclear waste that must be safely disposed of, e.vcept possibly the by-product plutonium, which is a nuclear fuel material that can be further used, but which is also a highly toxic radioactive substance. Even if plutonium were used to fuel nuclear power plants, however, a substantial residue of it would still remain in the waste material, thereby adding to the waste's
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toxicity. It was criginally intended to dispose of high level radioactive waste by placing it deep underground, for isolation from the biosphere in special facilities called teologic reposi-tories". However, there presently exist no such facilities for permanently and safely disposing of nuclear waste; nor is there any assurance that such facilities will exist in the next twenty years, or ever will exist, due to technical problems of assuring isolation of the waste for the hundreds and tens of thousands of years that.will be required for the material to decay to safe levels of radiation. As a consequence, high-level radioactive waste and plutonium is dangerously accumulating in storage pits at nuclear power plants and other places in the form of scent fuel rods (to be described shortly). These " spent fuel storage' pits", though each is enclosed in a building, are creating an
34' Appendix 2 Rasmussen Report's Implicit Strontium-90 ru Release Figure for a Spent Fuel Storage Pool Accident: 2000 curies.
The Rasmussen Report estimates that 1.88 x 10 curies of
" alkaline earths" radioactivity escapes one third of a core load of spent fuel which a has aged for 60 days, and that l's of this rad ioactivity escapes the build ing (Ras. Rpt.,
app. I, p. 103-10ft ) . Alkaline earths consists of Barium-140, strontium-89, and strontium-90, with half lives of 12.8 days, 50 5 days, and 29 years, respectively. The NRC's environmental impact statemen[ for spent fuel (NURIO-0404) tabulates the quantities of these substances per metric ton of spent fuel.
At time o f discharge from the reactor (p. G-ll):
Ba- 140 -<- 1.72 x 10 Ci/MTU Sr 89 ---- 9.47 x 10 5 ci/MTU Sr-90 ---- 6.4 x 10" ci/sTU.
The mass of fuel per assembly is .45 MTU (NURSC-0404, p. G.-5):
and one core contains 193 fuel assemblies: hence 1/3 of a core equals 65 assemblien. From those data one can calculate the release fraction of alkaline earths and then th e raft release quantity of strontium-90. ?Ie can compute the release fraction (F ) implicitly assumed in the Rasmussen's estimate from the following equation fo r radioactive decay: ' 7 5 x .arx ss x 1 7 axio'i $ $$ en n/e y g.a/i " ls a %
Solving for F 7, F72./ A, or roughly 105 Therefore, the asured x2 assumed strontium-90 release from the storage pool building (assusmed a (assumed in the Ras. Report) is
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UNITED STATES OF ASE.O.ICA 1 c'.#'.f d$-
NUCI.IAR REGULATORY CO!GIISSION
%. , y SEFORE TH1' ATOMIC S AFETY Ai'D LICZ::SI'.;G 30ARD I .n. -tr.-
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) DOCKET .JOS. 50-295 CO!O!O'I. EAI.TH EDISON COIiFANY ) 50-304 q 1 .i & S,)
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SPENT FLTL POOL REP 3.CKING TESTIMONY OF, I-iarvin Resnik0 f f, on behalf cf the State of Illinois -
Office of the Attorney General CATED: .May 30, _97e.
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