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Category:AFFIDAVITS
MONTHYEARML20079J1811982-12-21021 December 1982
Affidavit of ML Smith Re Transshipment of Spent Fuel.Unless VEPCO Can Secure Addl Storage Space for Surry Spent Fuel, Surry Will Lose Full Discharge Capability
ML19322B8961979-07-23023 July 1979
Affidavit Attesting That No Credible Analysis of Potomac Alliance Alternatives May Be Undertaken W/O Examination of Greater Body of Facts.Prof Qualifications Encl
ML19209B9251979-05-30030 May 1979
Affidavit of EA Baum Re Util Schedule for Refueling Unit 1 & Importance of Installation of New Racks at Unit 2
ML19289C4821978-12-13013 December 1978
Affidavit of Rd Pollard.Certifies That Author Has Reviewed Staff Submissions Re Protection Against low-trajectory Turbine Missiles & Provided the Technical Analysis in the Ucs Reply Brief.Certificate of Svc Encl
1982-12-21
[Table view]
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20148M6511997-06-18018 June 1997
Comment Opposing Proposed Suppl to Bulletin 96-001 That Would Request Licensees to Take Action to Ensure Continued Operability of Control Rods
L-95-045, Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors1995-10-19019 October 1995
Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors
ML20080M1121995-02-27027 February 1995
Comment Re Proposed Suppl 5 to GL 88-20 IPEEE for Severe Accident Vulnerabilities. Proposed GL Suppl Should Indicate That Licensees Can Use Llnl Hazard Results of NUREG-1488 Re Revised Hazard Estimates Instead of NUREG/CR-5250
ML20073M0751994-09-23023 September 1994
Comment on Proposed Rules 10CFR30,40,70 & 72 Re Clarification of Decommissioning Funding Requirements. Permitting Access to Funds Only on Semiannual Basis Seems Unnecessarily Restrictive
ML20069L5291994-06-13013 June 1994
Comment Supporting Proposed Rulemaking 50-60 Re Petition for Rulemaking & Changes to 10CFR50.54
ML20029D8251994-04-29029 April 1994
Comment Supporting Elimination of Proposed 5-yr Implementation Schedule & Believes That Current Programs Adequate to Maintain Containment Integrity
ML20044G1971993-05-24024 May 1993
Comment Supporting Draft Insp Procedure Re Commercial Grade Procurement & Dedication
ML20044E5721993-05-19019 May 1993
Comment Supporting Proposed Generic Ltr for Relocation of TS Tables on Instrument Response Time Limits
ML20044D3271993-05-0707 May 1993
Comment Opposing Proposed GL Availability & Adequacy of Design Bases Info
ML20125B6141992-12-0303 December 1992
Exemption from Requirements of 10CFR50,app a Re GDC-2 & 10CFR50.49 Re Environ Qualification of Electric Equipment Important to Safety for Nuclear Power Plants
ML20095J6881992-04-23023 April 1992
Comment Opposing Draft Reg Guide DG-1022, Emergency Planning & Preparedness for Nuclear Power Plants
ML20077R5161991-08-14014 August 1991
Comment Supporting Petition for Rulemaking PRM-20-20 Re Reduced Total Effective Dose Equivalent to Individual Members of Public from 0.5 Rem (5 Msv) to 0.1 Rem (1 Msv)
ML20235N8531989-02-14014 February 1989
Comment Supporting Chapter 1 Re Policy Statement on Exemptions Below Regulatory Concern.Policy Development for Criteria for Release of Radioactive Matl Needed for Development of Consistent Waste Mgt Practices
ML20235P3311989-02-0808 February 1989
Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants
ML20236P5851987-11-0909 November 1987
Transcript of 871109 Briefing in Washington,Dc Re Facility Steam Generator Tube Rupture Event.Pp 1-56.Supporting Documentation Encl
ML20138N5311985-11-0101 November 1985
Memorandum & Order Affirming ASLB 850903 Initial Decision Authorizing Director of NRR to Issue License Amend for North Anna to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry Power Station.Served on 851101
ML20133K7171985-10-18018 October 1985
Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl
ML20133K6801985-10-18018 October 1985
Forwards Notice of Withdrawal of Appearance in Proceeding. Requests Svc List Be Revised to Include Client Under Listed Address.W/O Encl
ML20133F4241985-10-0909 October 1985
Order Stating That ASLB 850903 Initial Decision Authorizing NRR to Amend OL to Permit Receipt & Storage of Spent Fuel Should Not Be Deemed Final,Pending Further Order. Served on 851009
ML20138A9521985-10-0909 October 1985
Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl
ML20134N6981985-09-0303 September 1985
Initial Decision LBP-85-34 Authorizing NRR to Issue Amends to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry.Initial Decision Effective Immediately.Served on 850904
ML20134N4381985-09-0303 September 1985
Order Granting Licensee 850621 Request to Correct Transcript.Proposed Transcript Corrections & Certificate of Svc Encl.Served on 850904
ML20129K1251985-07-18018 July 1985
Brief in Support of NRC 850718 Proposed Findings of Fact & Conclusions of Law in Form of Initial Decision Authorizing Issuance of Amend to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies
ML20129K1281985-07-18018 July 1985
Proposed Findings of Fact & Conclusions of Law in Form of Initial Decision Authorizing NRR to Issue Amend to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies
ML20129F8231985-07-12012 July 1985
Reply Opposing Concerned Citizens of Louisa County post- Hearing Brief.Licensee Proposed Findings of Sabotage & Human Error Not Addressed.Challenge of NRC EIS Conclusion Unnecessary.Certificate of Svc Encl
ML20209F0021985-07-0808 July 1985
Post-hearing Brief Re Issues Raised at ASLB 850521 & 22 Evidentiary Hearings.Nrc Required by NEPA to Evaluate Alternative of Constructing & Operating Dry Cask Storage Facility,But Failed to Perform Even Cursory Review
ML20209F2041985-07-0808 July 1985
Proposed Findings of Fact & Conclusions of Law Re Application for Amend to Ol,Authorizing Licensee to Ship 500 Spent Nuclear Fuel Assemblies from Surry Power Station to North Anna Station.Certificate of Svc Encl
ML20128H0791985-07-0808 July 1985
Order Granting Concerned Citizens of Louisa County 850627 Motion for 7-day Extension Until 850708 to File Proposed Findings of Fact & Conclusions of Law.Served on 850708
ML20128G9471985-06-27027 June 1985
Motion for Extension of 850701 Deadline to File Proposed Findings of Fact & Conclusions of Law.Addl Wk Required Due to Addl Legal Duties.Certificate of Svc Encl
ML20127F0511985-06-21021 June 1985
Proposed Findings of Fact & Conclusions of Law Re Util 820713 Application to Amend Ol,Authorizing Receipt & Storage of Up to 500 Spent Nuclear Fuel Assemblies.Unsigned,Undated Order & Certificate of Svc Encl
ML20127F0451985-06-21021 June 1985
Post-hearing Brief Requesting Board Find in Util Favor Re Proposed OL Amend Authorizing Receipt & Storage of Up to 500 Spent Nuclear Fuel Assemblies.No Basis from Sabotage or Human Error Considerations for Denying Proposed Amend
ML20128A7731985-05-22022 May 1985
Transcript of 850522 Hearing in Charlottesville,Va.Pp 313-364.Supporting Documentation Encl
ML20125C4081985-05-21021 May 1985
Applicant Exhibit A-H-11,consisting of Undated,Untitled Photograph H
ML20125C3601985-05-21021 May 1985
Applicant Exhibit A-B-5,consisting of Undated,Untitled Photograph B
ML20125C4221985-05-21021 May 1985
Applicant Exhibit A-J-13,consisting of Undated,Untitled Photograph J
ML20125C3471985-05-21021 May 1985
Applicant Exhibit A-3,consisting of SAND82-2365, Assessment of Safety of Spent Fuel Transportation in Urban Environs, Dtd June 1983
ML20125C4301985-05-21021 May 1985
Applicant Exhibit A-K-14,consisting of Undated,Untitled Photograph K
ML20125C3941985-05-21021 May 1985
Applicant Exhibit A-F-9,consisting of Undated,Untitled Photograph F
ML20125C4361985-05-21021 May 1985
Applicant Exhibit A-L-15,consisting of Undated,Untitled Photograph L
ML20125C3101985-05-21021 May 1985
Staff Exhibit S-1,consisting of Undated Environ Assessment & Finding of Proposed No Significant Impact Re 820713 & 0820 Applications for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7,allowing Receipt & Increased Storage of Spent Fuel
ML20125C3411985-05-21021 May 1985
Applicant Exhibit A-2,consisting of 830915 Procedure 1-OP-4.19, Receipt & Storage of Spent Fuel TN-8L Shipping Cask Unloading & Handling Procedures
ML20125C3291985-05-21021 May 1985
Staff Exhibit S-3,consisting of Forwarding NMSS Apr 1985 Environ Assessment Re 821008 Application for Authority to Construct & Operate Dry Cask ISFSI at Surry Power Station
ML20125C4001985-05-21021 May 1985
Applicant Exhibit A-G-10,consisting of Undated,Untitled Photograph G
ML20125C3381985-05-21021 May 1985
Applicant Exhibit A-1,consisting of 831104 Procedure OP-4.3, Shipping of Spent Fuel TN-8L Shipping Cask Loading & Handling Procedures, for Surry Power Station
ML20125C3711985-05-21021 May 1985
Applicant Exhibit A-C-6,consisting of Undated,Untitled Photograph C
ML20125C3791985-05-21021 May 1985
Applicant Exhibit A-D-7,consisting of Undated,Untitled Photograph D
ML20125C3821985-05-21021 May 1985
Applicant Exhibit A-E-8,consisting of Undated,Untitled Photograph E
ML20125C3501985-05-21021 May 1985
Applicant Exhibit A-A-4,consisting of Undated,Untitled Photograph a
ML20125C3191985-05-21021 May 1985
Staff Exhibit S-2,consisting of Undated Safety Evaluation Re Increasing Spent Fuel Storage Capacity.Proposed Mods to Spent Fuel Pool & Transshipment/Storage of Spent Fuel Acceptable
ML20125C4131985-05-21021 May 1985
Applicant Exhibit A-I-12,consisting of Undated,Untitled Photograph I
1997-06-18
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Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFET.Y AND LICENSING BOARD O
)
)
In the Matter of ) Docket Nos. 50-332 SP
) 50-339 SF VIRGINIA ELECTRIC AND POWER COMPANY )
) (Proposed Amendment to
-(North anna Power ) Operating License'NPT-4)
Station ~, Units 1 and 2) )
)
AFFIDAVIT'OF DR. PHILLIP M. WEITZMAN My name is Phillip M. Weitzman. A statement of my professional qualifications is attached to this affidavit. ;
I have examined, in relevant part, the following documents submitted by the Virginia Electric and Power Company (VEPCO) in the above-captiened proceeding:
- 1. Summary of Proposed Modifications to t'he Spent Fuel Storage Pool Associated with Increasing Storage Capacity for North Anna Power Station Units 1 and 2, Virginia Electric and Power Company (revision 1, May 1979) (Hereinaf ter cited as Summary; subsequent paragraph citations. refer to this document).
- 2. Affidavit of H. Stephen McKay (May 11, 1979)
- 3. Affidavit of Dr. Morris Brehmer.(May'll, 1979)
- 4. Affidavit of Robert W. Calder (May 11, 1979) f
e l
79///:Zo/*f3 -
_2 .
., 4. Environmental Impa t Appraisal of the Office of Nuclear Reactor Regulation Relative to a Proposed Increase in Storage Capacity of the Spent Fuel Pool, North Anna Power Station, Units 1 and 2 (April 2, 1979).
- 3. VEPCO'S STATEMENT OF~ MATERIAL FACTS AS TO WH'ICH THERE IS NO GENUINE ISSUE TO BE HEARD (May 11, 1979)
- 6. VEPCO'S ANSWERS TO POTOMAC ALLIANCE INTERROGATORIES (June 2 0 ', 1979)
- 7. NRC STAFF SUPPLENENTAL RESPONSE TO INTERROGATORIES FROM CITIZENS' ENERGY FORUM AND POTOMAC ALLIANCE (July 13, 1979).
It is my professional opinion that the facts and analyses contained.in the materials listed above provide an inadequate factual and analytical basis on which to determine whether VEPCO's proposed modification of the spent fuel pool at North Anna Units 1 and 2 is economically more advantageous than any of the three alternative proposals contained in the Potomac Alliance's contention labelled " Alternatives."
A thorough and professional analysis of the relative costs and benefits of the three alternative proposals is ,
impossible because the conclusions presented and the under'-
lying cost estimates are not documented or e.yplained adequately.
Economic and practical constraints which purportedly limit the viability of particular proposals P've in some cases not l
.been systematically demonstrated to be real or insurmountable.
The conclusions reached ar'e based on critical assumptions and 1
's l 1
, methodologies which are not stated, or if stated, are not sufficiently justified.
Specifically, with respect to the proposed con-struction of a new storage pool, VEPCO nas provided a cost
" estimate" of "approximately $25,000,'000." (S4.5) No support for or detailed evaluation of this figure.is provided, nor are comparative design estimadbs provided. This figure therefore amgunts to a bald assertion which lacks sufficient basis to be used in any professional analysis. In addition, the following calculation of $22,007 per fuel assembly is apparentl'y based on the assumption that the new pool would contain 1,136. fuel assemblies. VEPCO ha s provided no cost or engineering data which would permit an unquestioning acceptance of this assumption. It is not clear nor has any analysis been offered to determine whether a new spent fuel pool might not safely hold many times that number of assem-blies and thereby lower substantially the per-assembly cost of this alternative.
With respect to the alternative of physically expanding the existing spent fuel pool, the estimates provided by VEPCO are even less complete and precise than those described above.
(54. 9) . It is impossible to form a professional opinion on the ec'onomic advantages or disadvantages of this alternative based j upon the information provided. -
l 1
4 5
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F As to the alternative of using the currently ~ uncompleted spent fuel a.t North Anna Units 3 and 4, VEPCO has stated simply that this pool will not be completed until it is "too late," and.that it is " difficult" to accelerate the construction schedule. (S 4.10) . In response to interrogatories submitted by the Potomac Alliance, VEPCO stated that it was '
unable to estimate ither the coses of or time required to accelerate the construction of this pool (answer to question
.#6). These statements contain inadequate information on which to render a meaningful opinion as to the economic justification, or lack thereof, for selecting this alternative.
In addition, it should be noted that no substantiation whatever was provided by VEPCO in support of its assertion '
that no additional operating costs will be incurred as a result of the propose ~d modification. (54.1). This assertion should be explored more fully in li'ght of the probable in-cremental costs arising from additional shipments of solid ,
waste, increased' maintenance activities, and increased occupational radiation exposures.
In conclusion, I have reviewed the relevant materials and have concluded tha.t no credible analysis of the three alternatives raised by the Potomac Alliance has been under-taken nor is possible without the presentation and examin-ation of a substantially greater body of facts, assumptions,
/
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l Respectfully submitted, m 1
( (..rc. %r( , ( t, F W'(
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Dated this 23d day of Phillip M. Weitzman ( l July, 1979- -
t l
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. ~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
, )
)
In the Matter of ) Docket Nos. 50-339 SP
) 50-339 SP VIRGINIA ELECTRIC AND POWER COMPA?W )
) (Proposed Amendrent to (North Anna Power ) Operating License NPF-4)
Station, Units 1 and 2) ) .
)
. STATE'4ENT OF PROFESSIONAL QUALIFICATIONS OF DR. PHILLIP M. hTITZMAN My name is Phillip M. Weitzman. I reside at 1931 California St., tiW , Washington, D.C. 20009. I am an indep-endent economic consultant in the fields of research methodology and data analysis, housing and community development, and energy. '
. hold the following degrees in ,
economics: B.A.-(Tulane University 1964); M.A. and Ph.D.
(University of Michigan 1967 and 1969) . I have also received the J.D. degree (Fordham University 1975). I am a member of the American Economic Association and have been admitted to the Bar in New York State and the District of Columbia.
I am the author of numerous publications in professional journals and have done research and consulting work in the areas of cost analysis a'nd energy. I have testified before 6
d
'~ ~--- - -' - ' - ~
5 the Pennsylvania Public Utility Commission, the Philadelphia Gas Commission, and the Public Service Commission of West Virginia on matters concerning the setting of utility rate structures.
t I now hold consulting contracts with the Legal Services
~
Corporation and Rural America,.Inc.
e I have formerly been employed as Assistant Professor of Economics at New York University and the' City University of New York, Senior Research Associate with the National Social Science and ;
l
, Law Project in Washington, D.C., and Research Director with the National Citizens Monitoring Project on Community Dev-elopment Block Grants in Washington, D.C.
l
-A .h k n *,
Phillip M.'Weitzman C'.,' .s 1
l k
- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
) .
In the Matter of ) Docket Nos. 50-338 SP
) 50-339 SP VIRGINIA ELECTRIC AND POWER COMPANY )
) (Proposed Amendment to .
(North Anna Power ) Operating License NPF'-4)
Station, Units 1 and 2) )
. )
AFFIDAVIT OF PHILLIP M. WEITZMAN -
I, Phillip M. Wei t:: man , hereby affirm that the facts and opinions contained in the foregoing affidavit and statement of qualifications are true and correct to the best of my information and knowledge.
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Appendix G Potomac Alliance's Pleadings on Service Water Cooling System
