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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20209H6691999-07-12012 July 1999 Comment Supporting Proposed Rule 10CFR50 Re Elimination of Requirement for Licensees to Update Inservice Insp & Inservice Testing Programs Beyond Baseline Adition & Addenda of ASME BPV Code ML20203G6131998-01-26026 January 1998 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Interim Rept 739459-97,dtd 971015 Be Withheld from Public Disclosure ML20203G6031997-12-0404 December 1997 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 Be Withheld from Public Disclosure PLA-4330, Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control1995-06-0808 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control PLA-4193, Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety1994-08-31031 August 1994 Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety ML20046A9531993-07-20020 July 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rule ML20045F7971993-06-21021 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule in Part & Opposes Rule in Part ML20045D7461993-06-21021 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Disagrees W/Maintaining 100% Rate for Contractor & Vendor Employees ML20044F8361993-05-24024 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rules ML20044F7511993-05-24024 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. PLA-3744, Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners1992-03-0909 March 1992 Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners PLA-3568, Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a1991-04-0808 April 1991 Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a PLA-3462, Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants1990-10-15015 October 1990 Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants ML19332G5261989-12-0606 December 1989 Comments on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Industry Has Made Substantial Progress Re Maint Performance as Indicated by Respective Performance Indicators,Commission Insps & Plant Conditions PLA-3175, Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants1989-03-29029 March 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235V4001989-03-0202 March 1989 Comment on Proposed Rule 10CFR50 Re Maint Program at Nuclear Plants.Proposed Maint Rule Has Potential to Significantly Undermine Util Initiatives & Direct Limited Resources Away from Real Improvements in Maint PLA-3157, Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained1989-02-24024 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained PLA-3118, Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule1988-11-17017 November 1988 Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons PLA-3019, Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking1988-04-15015 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking PLA-2726, Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift1986-09-25025 September 1986 Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift ML20138A9521985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20027D4441982-11-0202 November 1982 Response to Aslab 821026 Order Requesting Info on RCS Leak Rate Detection.Util Preparing Tech Spec to Limit Increase in Unidentified RCS Leakage to 2 Gpm within 4-h Period ML20027D4471982-11-0101 November 1982 Affidavit of Wj Rhoades Correcting Response to Hearing Question on Leak Rates.Leak Rate Sys Capable of Detecting 1 Gpm Per Hour.Tech Specs Will Require Shutdown for Unidentified Leakage of 5 Gpm.Certificate of Svc Encl ML20069D8321982-09-0909 September 1982 Original Signature Page to Sh Cantone Affidavit.Svc List Encl ML20027B2291982-09-0909 September 1982 Stipulation of Withdrawal of Commonwealth of PA 820428 Exceptions Re Supply of TLD ML20065A9541982-09-0909 September 1982 Affidavit of Sh Cantone Re Dosimetry for Emergency Workers at Plant.Prof Qualifications Encl ML20027B2231982-09-0909 September 1982 Motion to Withdraw Commonwealth of PA 820428 Exceptions to Initial Decision,Contingent Upon Approval of Util & Commonwealth of PA 820909 Stipulation ML20027B2351982-09-0808 September 1982 Affidavit of AL Belser & Rj Hippert Responding to Questions in Aslab 820820 Order & Supporting Stipulation Withdrawing Exceptions.When Stipulated Number of Dosimeters Available, Emergency Workers Will Be Protected.W/Certificate of Svc ML20027B2331982-09-0808 September 1982 Affidavit of Ma Reilly Responding to Question in Aslab 820820 Order & Supporting 820909 Stipulation. TLD Necessary to Document Exposure of Officials Helping Contaminated Evacuees ML20063A4041982-08-18018 August 1982 Petition for Reconsideration of Commission 820809 Order Rendering ASLB Initial Decision Effective.Exceptions to Decision Require Resolution.Commission Order Premature. Certificate of Svc Encl ML20062J6391982-08-13013 August 1982 Order Directing Parties to Identify Person Presenting Arguments at 820908 Hearing in Bethesda,Md.Response Requested No Later than 820831 ML20058J6651982-08-0909 August 1982 Order Rendering ASLB 820412 Decision Authorizing OL Issuance Effective.Full Power OL Not Yet Authorized ML20054L5081982-07-0606 July 1982 Brief Opposing Commonwealth of PA 820428 & Citizens Against Nuclear Dangers 820421 Exceptions to ASLB 820412 Initial Decision.Pa Fails to Prove Dosimetry Issue Timely Raised. Citizens Failed to Comply W/Procedure.W/Certificate of Svc ML20054L2841982-07-0202 July 1982 Brief Opposing Commonwealth of PA 820428 Exceptions to ASLB 820412 Initial Decision Authorizing OL Issuance.Commonwealth Fails to Justify License Condition Imposition Re Availability of Dosimetry.Certificate of Svc Encl ML20054J5611982-06-25025 June 1982 Brief Opposing Citizens Against Nuclear Danger 820421 Exceptions to ASLB 820412 Initial Decision.Exceptions Fail to Comply W/Commission Regulations & Raise Issues Not Presented Before Aslb.Certificate of Svc Encl ML20053D0801982-05-28028 May 1982 Brief in Support of Exceptions to ASLB 820412 Initial Decision Authorizing Issuance of Ols.Shortage in Supply of Dosimeters for Emergency Workers Clear & Uncontroverted. Certificate of Svc Encl ML20053D2191982-05-28028 May 1982 Brief Supporting Commonwealth of PA Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20052B7461982-04-28028 April 1982 Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20052A2751982-04-21021 April 1982 Exceptions to ASLB Initial Decision.Certificate of Svc Encl ML20054C6551982-04-15015 April 1982 Response Opposing Citizens Against Nuclear Dangers 820402 Proposed Findings of Fact & Conclusions of Law.Requirements for Reopening Record Not Met.No Showing That Allegations Raise Significant Safety Issues.Certificate of Svc Encl ML20050D4191982-04-0202 April 1982 Proposed Findings of Fact & Conclusions of Law Based on Important New Info & Recommendations to NRC Commissioners & Congress.Certificate of Svc Encl ML20042C2781982-03-26026 March 1982 Motion for Order That Applicants Conduct Complete Retest of Emergency Plan W/All 20 Communities Participating.Testimony on Contentions 6 & 20 Should Be Reviewed to Identify Perjury by Fema,Applicants & State of Pa.Certificate of Svc Encl ML20042C2701982-03-26026 March 1982 Proposed Findings of Fact & Conclusions of Law Re Emergency Evacuation Plan ML20069B0301981-12-22022 December 1981 Reply to Parties' Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20039B0791981-12-16016 December 1981 Proposed Transcript Corrections.Certificate of Svc Encl ML20062M2141981-12-0909 December 1981 Proposed Transcript Corrections ML20039A1951981-12-0909 December 1981 Proposed Findings of Fact & Conclusions of Law ML20038C0131981-12-0303 December 1981 Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20038A8891981-11-17017 November 1981 Motion to Take Official Notice of Existence & Content of Listed Documents Relevant to Contention 21.Validity of Info in Documents Could Be Subj to Dispute.Certificate of Svc Encl.Related Correspondence 1999-07-12
[Table view] Category:PLEADINGS
MONTHYEARML20027B2231982-09-0909 September 1982 Motion to Withdraw Commonwealth of PA 820428 Exceptions to Initial Decision,Contingent Upon Approval of Util & Commonwealth of PA 820909 Stipulation ML20063A4041982-08-18018 August 1982 Petition for Reconsideration of Commission 820809 Order Rendering ASLB Initial Decision Effective.Exceptions to Decision Require Resolution.Commission Order Premature. Certificate of Svc Encl ML20052B7461982-04-28028 April 1982 Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20042C2781982-03-26026 March 1982 Motion for Order That Applicants Conduct Complete Retest of Emergency Plan W/All 20 Communities Participating.Testimony on Contentions 6 & 20 Should Be Reviewed to Identify Perjury by Fema,Applicants & State of Pa.Certificate of Svc Encl ML20038A8891981-11-17017 November 1981 Motion to Take Official Notice of Existence & Content of Listed Documents Relevant to Contention 21.Validity of Info in Documents Could Be Subj to Dispute.Certificate of Svc Encl.Related Correspondence ML20011A2321981-10-0101 October 1981 Support for Contention 4 & Position on New Contentions. Motion for Summary Disposition of Contention 4 Should Be Denied Since Util Cancellation of Unit 2 May Be Best Solution.Certificate of Svc Encl ML20011A2121981-09-30030 September 1981 Appeal of ASLB 810924 Memorandum & Order,Section 5,granting Applicant Motion for Summary Disposition of Portion of Contention 2 Re Magnitude of Doses from Releases of Radioactive Matl.No Basis to Decision.W/Certificate of Svc ML20010J6231981-09-30030 September 1981 Response Supporting NRC 810911 Motion for Summary Disposition of Portion of Contention 1 Re Radiological Health Effects of Isotopes Other than Rn-222 & Tc-99.Health Effects Adequately Addressed in Fes ML20010H7931981-09-22022 September 1981 Answer Opposing Citizens Against Nuclear Dangers 810912 Notice of Appearance for Purposes of Presenting Direct Testimony & Motions Before Aslb.Consolidation of Contentions Unnecessary.Certificate of Svc Encl.Related Correspondence ML20140B1981981-09-10010 September 1981 Response Supporting Applicants 810828 Motion for Partial Summary Disposition of Contention 1 Re Fuel Cycle Doses.Also Moves for Summary Disposition of Portion of Contention 1 Re Radiological Health Effects of All Isotopes ML20140B1931981-09-10010 September 1981 Answer Opposing Susquehanna Environ Advocates 810822 Motion for Allowance of New Contention.Motion Is Untimely & Balancing Factors Do Not Weigh in Intervenors Favor. Certificate of Svc Encl ML20140B1651981-09-10010 September 1981 Motion for Summary Disposition of Contention 14 Re cost-benefit Balance.No Genuine Issue of Matl Fact Exists & NRC Entitled to Favorable Decision as Matter of Law ML20010G2271981-09-0808 September 1981 Comments on Susquehanna Environ Advocates 810831 Filing on Expert Witnesses.Filing Inadequate & Fails to Meet ASLB 810814 Mandate.Reserves Right to Seek Relief If Intervenor Files Testimony.W/Certificate of Svc.Related Correspondence ML20010G2981981-09-0808 September 1981 Response to ASLB 810814 Memorandum & Order,Filing Qualifications,Identities,Subj Matter & Substance of Testimony of Expert Witnesses for Contentions 2,6,9,11,14,20 & 21.Certificate of Svc Encl.Related Correspondence ML20140B4381981-09-0202 September 1981 Answer to Citizens Against Nuclear Dangers 810827 Filing. Applicants Oppose Several Motions & Arguments.Allegations Re Chlorine Portion of Contention 2 Are Moot.No Valid Reason for Addl Prehearing Conference.Certificate of Svc Encl ML20010F4541981-08-31031 August 1981 Motion for Summary Disposition of Contention 7C Re BWR Core Spray Nozzle Cracking.No Genuine Issue of Matl Fact Exists. Certificate of Svc Encl.Related Correspondence ML20010F5411981-08-31031 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 7B.Certificate of Svc Encl ML20010F4741981-08-31031 August 1981 Motion for Summary Disposition of Contention 7B Re Cracking of Stainless Steel Piping in BWR Coolant Water Environ Due to Stress Corrosion.No Genuine Issue of Matl Fact Exists ML20010F4431981-08-31031 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 7C.Related Correspondence ML20005B7991981-08-28028 August 1981 Motion for Partial Summary Disposition of Portion of Contention 1 Re Magnitude of Radioactive Doses That Will Be Imparted on Public by Release of All Isotopes During Fuel Cycle.Certificate of Svc Encl.Related Correspondence ML20005B8241981-08-28028 August 1981 Statement of Matl Fact as to Which There Is No Genuine Issue,Supporting Applicants Motion for Summary Disposition of Contention 1 Re Fuel Cycle Doses.Related Correspondence ML20010F4001981-08-27027 August 1981 Response in Opposition to ASLB 810814 Directives & Motions on Testimony & Public Hearings Conference.Date That Correspondence Is Required to Be Mailed Is Incorrect & Only Two Aspects of Contention 2 Are Listed for Consideration ML20010C9811981-08-19019 August 1981 Statement of Issues for Commonwealth of PA Participation,Per ASLB 810727 Memorandum & Order.Particular Interest Shown in Contentions 5,7(D),11 & 21.Related Correspondence ML20010C8631981-08-18018 August 1981 Renewed Motion for Summary Disposition of Contention 17.No Genuine Issue of Matl Fact to Be Heard.Applicants Are Entitled to Favorable Decision as Matter of Law ML20010C8671981-08-18018 August 1981 Memorandum Supporting Applicants' 810818 Renewed Motion for Summary Disposition of Contention 17.Michaelson Affidavit Sufficiently Addresses Issues & Constitutes Adequate Basis for Granting Motion ML20010C9491981-08-18018 August 1981 Statement of Matl Facts as to Which There Is No Geniune Issue to Be Heard Re Contention 17.Certificate of Svc Encl ML20010C0771981-08-13013 August 1981 Motion for Partial Summary Disposition of Contention 2 Which Questions Magnitude of Facility Low Level Radioactive Releases.Certificate of Svc Encl ML20010C1471981-08-13013 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 2 on Source Term ML20010C9781981-08-10010 August 1981 Memorandum of Law in Response to Applicants' 810727 Ltr.All Parties in Proceeding Have Right to Present Rebuttal Evidence.Related Correspondence ML20010B3971981-08-0707 August 1981 Memorandum in Support on 810807 Motion for Summary Disposition of Contention 1 Re Quantity of Rn-222 to Be Released During Fuel Cycle ML20010B4091981-08-0707 August 1981 Statement of Matl Fact as to Which There Is No Genuine Issue Re Contention 1 Concerning Rn-222 ML20010B4041981-08-0707 August 1981 Motion for Summary Disposition of Contention 1 Re Rn-222. Issue Should Not Be Relitigated Under Accepted Principles of Collateral Estoppel & Stare Decisis.No Genuine Issue to Be Heard ML20009H2281981-08-0404 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard in Support of Motion for Summary Disposition of Contention 7(a).Related Correspondence ML20009H2301981-08-0404 August 1981 Motion for Summary Disposition of Contention 7(a).No Genuine Issue of Matl Fact Exists.Certificate of Svc Encl. Related Correspondence ML20009G9951981-08-0303 August 1981 Memorandum Supporting Applicant Motion for Summary Disposition of Contention 3.Assertions Refuted in Jm Vallance Affidavit & Some Assumptions Are Contrary to Aslab Rulings ML20009H0251981-07-30030 July 1981 Motion for Summary Disposition of Contention 3.No Genuine Issue of Matl Fact Exists & Applicants Are Entitled to Decision as Matter of Law.Certificate of Svc Encl ML20009F8371981-07-28028 July 1981 Statement of Matl Fact as to Which There Is No Genuine Issue to Be Heard Re Contention 11 on Onsite Storage of Spent Fuel ML20009F8431981-07-28028 July 1981 Motion for Partial Summary Disposition of Contention 11 Re Onsite Storage of Spent Fuel.No Genuine Issue of Matl Fact Exists.Motion Supported by C Herrington & DW James Affidavits.Certificate of Svc Encl ML19345G8391981-04-0909 April 1981 Answer Opposing Citizens Against Nuclear Danger 810327 Motion Requesting Hearing on Applicants' 801223 SNM License Application.Motion Does Not Comply W/Commission Regulations. Certificate of Svc Encl ML19290G6301980-11-24024 November 1980 Request to Deny Applicants' Motion for Summary Disposition of Contention 2 Re Chlorine Due to Studies Demonstrating Relationship Between Cancer Rates & Chlorinated Compounds in Drinking Water.W/Certificate of Svc ML18030A4731980-11-0606 November 1980 Motion for Partial Summary Disposition of Contention 2 Re Health Effects of Discharged Chlorine.Responses Due within Three Wks from Present Filing ML18030A4131980-11-0606 November 1980 Statement of Matl Facts Re Absence of Issue to Be Heard,In Support of Motion for Partial Summary Disposition of Contention 2 on Health Effects of Discharged Chlorine ML18030A0181980-11-0606 November 1980 Pleading in Support of Motion for Partial Summary Disposition of Contention 2 Re Health Effects of Discharged Chlorine.Issue Narrowed by Intervenor/Sponsor Via Response to NRC Interrogatories.W/Certificate of Svc ML18030A1621980-10-29029 October 1980 Response in Opposition to Environ Coalition on Nuclear Power Petition for Commission Review of ALAB-613.Intervenor Petition Sets Forth Nothing Which Warrants Different Conclusion.Certificate of Svc Encl ML18030A1591980-10-27027 October 1980 Statement of Matl Facts Re Absence of Genuine Issue to Be Heard,In Support of Summary Disposition of Contention 16 on Cooling Tower Discharge.Sys Designed to Evaporate Water Daily from Towers W/O Radioactive Releases ML18026A3101980-10-10010 October 1980 Response in Opposition to Applicant Request Re Interrogatories on Safety Issues.Environ Phase Must Take Priority Over safety-related Discovery Per ASLB 791030 Order.Certificate of Svc Encl ML18030A1401980-08-22022 August 1980 Statement of Matl Facts as to Which No Genuine Issue Exists to Be Heard in Support of Request for Summary Disposition of Ozone Portion of Contention 17.Max Ground Level Ozone Concentrations Near Lines Will Be Far Below Allowable Limit ML18030A1431980-08-22022 August 1980 Request for Free Hearing Transcripts Per 800725 Fr Notice Re Procedural Assistance Change in Adjudicatory Licensing Proceedings.Prior Denials Damaged Ability to Properly Litigate Contentions.Certificate of Svc Encl ML18030A4411980-08-22022 August 1980 Request for Summary Disposition of Portion of Contention 17 Dealing W/Ozone.No Genuine Issue of Matl Fact Exists to Be Heard.Responses Due in Three Wks ML18026A3001980-06-13013 June 1980 Response to Aslab 800521 Memorandum & Order ALAB-593, Requesting Environ Coalition on Nuclear Power to Inform Aslab of Extent of Relief Sought.Intervenor 800530 Request Must Be Dismissed as Moot.Certification of Svc Encl 1982-09-09
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I August 4, 1981-EWED ConnESPONDExcp UNITED STATES OF AMERICA G &
NUCLEAR REGULATORY COMMISSION @ y BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- /sVG 51981 > 1 B cfR.cf N sw.aq }
In the Matter of ) 0 1'. gaSeuke B :ce.h
)
7 PENNSYLVANIA POWER & LIGHT COMPANY )
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and ) Docket Nos. 50--J.87
) 50 ~ (D N
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ALLEGHENY ELECTRIC COOPERATIVE, INC. ) [ 13 _
(Susquehanna Steam Electric Station, ) (( -
Units 1 and 2) ) t &p.
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\Q 'll APPLICANTS'
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STATEMENTOFMATERIALFACTSASTOWHIC THERE IS NO GENUINE ISSUE TO BE HEARD Pursuant to 10 C . F . R. S 2.749(a) Applicants state, in support of their Motion for Summary Disposition of Contention 7(a) in this proceeding , that there is no genuine issue to be heard with respect to the following material facts:
- 1. The dynamic loads imparted to the containment structures at the Susquehanna Steam Electric Station ("SSES")
during blowdown are the hydrodynamic loads generated during steam discharge into the water pool used to condense steam within the SSES containment. In order to assess the ability of the containment structures at SSES to withstand the dynamic forces realized during blowdown, one must compare the hydrodynamic loads produced during a steam relief valve ("SRV")
discharge and a loss-of-coolant accident ("LOCA") to the D5p3 g containment design capacity and test level. Affidavit of 7[
8108070060 010804 PDR ADOCK 05000387 Q PDR
George R. Abrahamson in Support of Summary Disposition of Contention 7(a) ("Abrahamson Aff."), para. 3.
- 2. The primary con,tainment at each of the SSES con-tainment structures completely encloses'the reactor vessel. It consists of a base mat, a hollow cylinder, a hollow cone, and a domed cap. The base mat is reinforced concrete 7 feet 9 inches thick and rests on slate-like siltstone. The cylinder and cone are reinforced concrete 6 feet thick; all the inner surface of the concrete is lined witL teel plate 1/4 inch thick. The cap is steel p1tte, 1-1/2 inches thick, held in place by 80 bolts 2-3/4 inches in diameter. Abrahamson Aff., para. 4.
- 3. The containment is divided into two chambers by the horizontal diaphragm slab at the junction between the cy-lindrical and conical sections. The upper chamber is the dry-well and the lower chamber is the suppression chamber or set-well. The drywell contains the reactor vessel and associated piping, valves and equipment; the wetwell is filled to a depth of 24 feet with water used to condense steam. Steam can be discharged into the wetwell water pool by actuation of an SRV or by a LOCA. These are the events that produce hydrodynamic loads in the containment. Id., para. 5.
- 4. As a result of a 1972 event at the German Wurgassen boiling water reactor, dynamic loading conditions l
were identified which had not been fully considered in the i design of the Mark II containment used at SSES. Since that time, extensive studies and tests (both generic and i
SSES-specific) have been conducted to quantify those loads and design modifications have been implemented to assure that these loads can be accommodated by the SSES containments. Id.,
paras. 8-19.
SRV discharge loads.
- 5. There are 16 SRVs in the containment; each has a discharge line that extends downward from a main steam line at the top of the reactor vessel to the bottom of the water pool.
Actuation of one or more SRVs results in steam discharge to the pool. Id_. , para. 6.
- 6. Each discharge line has a device at the discharge end to enhance steam condensation. These devices, called quenchers, have been specifically designed for SSES to minimize hydrodynamic loads. The SSES quencher design greatly enhances the water surface exposed to steam and thereby increases the rate of condensation and eliminates the types of loads encoun-tered at Wurgassen. Id., para. 20.
- 7. Prior to SRV actuation, the steam discharge line contains air down to the water level. Upon SRV actuation, steam enters the line and compresses the air. As the water clears the discharge line, compressed air emerges into the pool (air clearing phase), followed by steam (condensation phase).
Id., para. 21.
- 8. During air clearing, air enters the pool at a pressure substantially higher than the local hydrostatic
pressure and forms a bubble adjacent to the quencher. The excess pressure causes the bubble to expand, giving an outward velocity to the water . Due to the inertia of the water, the bubble expands beyond its equilibrium volume at the local hydrostatic pressure, and is eventually driven back again compressing the air in the bubble. Thus the bubble oscillates, l producing a periodic pressure history. Id., para. 22.
- 9. To determine the pressure on the pool boundary, which is the hydrodynamic load on the containment, an extensive test program was undertaken by Pennsylvania Power & Light Co.
("PP&L") at Kraftwerk Union ("KWU"), the German firm with extensive experience in nuclear reactor steam discharge phenomena that designed the SSES quenchers. Tests were performed using an actual SSES steam relief valve, actual steam line diameters and line lengths, and an actual quencher. The tests simulated the simultaneous actuation of all sixteen SRVs, which is the case that gives the highest loads on the contain-ment structure. Id., para. 23.
- 10. To permit calculations of containment response to proceed in parallel with the test program, KWU provided PP&L with an SRV load specification based on data taken by KWU in previous in-plant quencher tests. The load specification gives l the pressure amplitude and distribution on the pool boundary, ,
and the frequency range of the oscillations. The pressure l
measurements obtained in the SSES quencher tests verified the l validity of the load specification. Id., para. 24.
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l l
l I I
- 11. The tests covered the range of reactor operating conditions. Tests were performed with the longest and shortest discharge lines, with different temperatures of the air in the discharge line (temperature affects the total air mass in the line), different water levels in the discharge line, vacuum breaker open and closed, various pool temperatures, various steam pressures, and different numbers of actuations. Id.,
para. 26.
- 12. The main data relating to hydrodynamic loads on the containment are the pressure measurements. The peak over-pressures are of the order of 15 psig, and the main frequency about 6 Hz. Id., para. 29. The pressure amplitudes observed during condensation tests were small compared to those occurring during air clearing. Id., para. 30.
- 13. For actuation of less than all 16 SRVs, the pressure measurements were adjusted for the larger area in the SSES pool to obtain the pool boundary pressures. Id,., para.
31.
- 14. The pressure histories on the pool boundary were used as input to a computer model of the containment. The computer code calculations show that the SRV loads (pressure and frequency) on the pool boundary produce stresses in the containment floor and walls that are within the structures' design values. Id., paras. 31, 48.
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l
~,
i
- 15. A test program to measure loads on submerged structures for SRV discharge in the SSES pool was undertaken for PP&L by SRI International (" SRI"). SRI designed a device, called a bubble source, that simulates SRV air clearing. The i
source was calibrated in the same tank in which the SRV discharge tests using the SSES quencher were performed. The calibration consisted of matching the peak pressure and oscillation frequency of the bubble source to the values observed during SRV discharge. This assured that the submerged structure loads found by using the bubble source in the SSES
- pool would be the same as would result from SRV air clearing.
Id., para. 33.
- 16. The tests performed in the SSES pool with the SRI bubble source confirm that the loads on the submerged l
structures are well below the design loads. Id., para. 34.
LOCA Loads j 17. There are 87 downcomers that connect the drywell to the water pool. The downcomers are.24-inch diameter open pipes with a deflector shield on the top; the deflector shield does not restrict the flow of steam into the pipe. Id., para.
7.
- 18. Release of steam from the reactor is normally accomplished by actuating the SRVs so as to allow steam to enter the water pool through the discharge lines. A LOCA is an I
unscheduled flow of water or steam from the reactor into the
drywell, and then into the wetwell through the 87 downcomers.
The cause of the opening through which the flow occurs is not defined, hence these are called " postulated breaks." Id.,
para. 36.
- 19. Of the postulated breaks, the one that produces th largest steam flow and hence the highest pressure in the SSES containment is a postulated double ended rupture of a 28-inch diameter recirculation line. Such a break results in rapid pressurization of the drywell. This is accompanied by a downward acceleration of the water in the downcomers, followed by discharge of air into the water at the downcomer exit plane and an upward motion of the water above that plane. The upward motion of the water continues until air breaks through the water layer; the water then falls back to rejoin the water below the downcomer exit plane. This phase is' called " pool swell.' Id., para. 37,
- 20. During and after pool swell, the flow through the downcomers decreases in air content and increases in steam content. The steam condenses as it contacts the water, and the air forms small bubbles that rise to the surface in the pool.
i The flow into the pool continues until the pressure in the drywell decreases to the water pressure at the downcomer exit plane. .The phase follcwing pool swell is called the "conden-l ,
! sation phase." Id., para. 38.
- 21. Loads 59 e a containment during pool swell were l
investigated by Sir 2As the auspices of the Electric Power l
! In these tests, the critical load
! Research Institute (EPRI).
l
on the containment it. the differential pressure across the diaphragm slab. The cr tical loads occurred when the differ-ential pressure on the diaphragm slab wts maximum downward and upward. Analyses of the SSES containment show that the critical load stresses were within the allowable range. Id.,
para. 39.
- 22. As with the SRV discharge, a single cell ap-proach was used to determine LOCA loads (pool swell and condensation). An apparatus was constructed that was proto-typical of SSES (same downcomer size, same water depth, etc.)
except that the pool area was 1/87 of the actual pool area.
The single cell approach used results in the highest LOCA loads. Id., paras. 40, 41. Tests were performed with this apparatus by flowing into the drywell 1/87 of the flow that would result from a LOCA in the plant. This is the fraction that would flow titrough each of the 87 downcomers.
Measurements were made of the pressures in the drywell, wo:well air space, and wetwell water space. These measurssients gave the loads on the containment. Id., para. 41.
i 23. A total of 22 tests (11 test conditions, 2 tests each) were performed covering a range of pool temperatures.
steam flows and break sizes, including the break size corre-sponding to the design basis accident, (i.e., the recirculation line ("RCL") break). Id., paras. 43, 44.
- 24. The pressure histories obtained for the wetwell air space and the drywell during an RCL break indicate that the wetwell pressure rises to 25.2 psig and the drywell pressure
.~.
rises to 37.7 psig. The RCL break produces the most rapid flow of steam into the drywell, and the drywell and wetwell pres-sures for the RCL break are greater than for smaller breaks.
Id., para. 47.
Comparison of Hydrodynamic Loads with Containment Design Capacity and Test Level.
- 25. The design pressure for the SSES containment is 53 psig for both the wetwell and drywell. The SSES containment has already been tested by pressurizing it to 61 psig with air.
These pressures are greatly in excess of the maximum pressure of 37.7 psig produced in an RCL break. Id., para. 49. It is also greatly in excess of the maximum prtssure of about 15 psig from an SRV discharge. Id., para. 29,
- 26. The computer calculations and the experimental test results show that the SSES containment can withstand the hydrodynamic loads from both SRV discharges and LOCAs with ample safety margin. Id., paras. 48, 50. Therefore the SSES containment can withstand the dynamic forces realized during blowdown with ample safety margin. Id., para. 2.
Dated: August 4, 1981.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE A_ !
J a p~ f.~ ilberg '~ -
Ma 'as .Travieso-Diak Counsel for Applicants 1800 M Street, N.W.
Washington, D. C. 20036 Telephone: (202) 822-1000
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