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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20141K3801997-05-27027 May 1997 Order Prohibiting Involvement in NRC-licensed Activities (Effective Immediately) for Dr Baudino for Period of Five Years ML20080A6081994-10-24024 October 1994 Refers to Pierce Actions Re Util Failure to Provide Adequate Training or Guidance Concerning Applicability of Doa 300-12 While Expert Present Directing Control Rod Movements ML20070B0081994-06-20020 June 1994 Response to Order Prohibiting Involvement in NRC-licensed Activities.* Informs That Order Will Have Negative Impact on Health & Safety of Public ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20245J0191989-04-14014 April 1989 Comment Re Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20235T9661989-03-0101 March 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Will Reduce Experience Level of Senior Operators ML20235T8251989-02-28028 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Proposed Rules Provide No Enhancement of Reactor Safety ML20235T8701989-02-28028 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Rule Will Cause Career Stagnation & Animosity Among Operators ML20235S8241989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Proposed Rule Alternatives Would Reduce to Nothing Reactor Operators Advancing to Senior Operator ML20235T1551989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Education & Experience Requirements for Senior Reactor Operators & Supervisors.Alternative Provides No Enhancement of Reactor Safety & Will Reduce Experience Level of Senior Operators ML20235T1231989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Reduce Experience Level of Senior Operators ML20235S9791989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Both Alternatives Would Eventually Reduce to Nothing Reactor Operators Advancing to Senior Operator ML20235S8371989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235T8381989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235T1361989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternative Provides No Enhancement of Reactor Safety & Will Reduce Experience Level of Senior Operators ML20235T7951989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Both Alternatives Do Not Provide Enhancement of Reactor Safety ML20235T7041989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235T0911989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Reduce Experience Level of Senior Operators ML20235T0461989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Both Alternatives Would Reduce Number of Reactor Operators Advancing to Senior Operator to Nothing ML20235S9541989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Reduce Experience Level of Senior Operators ML20205T0891988-10-28028 October 1988 Comment Opposing Proposed Rule 10CFR26 Re Fitness for Duty Program.Proposed Rule Unnecessary as Utils Have Effective Fitness for Duty Program ML20205N0941988-10-24024 October 1988 Comments on Petition for Rulemaking PRM-50-50 Re Authorization of Reactor Licensees to Depart from License Conditions & Tech Specs in Emergency Situations.Young Criticism of Inerting Practices at Plant W/O Credence ML20155A6591988-09-0303 September 1988 Comment Supporting Petition to Rescind Paragraphs (X)(Y) of Section 10CFR50.54 Re Cases of Hazardous Practices Including Util Authorizing Senior Operator to Turn Off Safety Sys in Emergency Before Sys Has Finished Job 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 ML20207T2351987-02-16016 February 1987 Endorsement 16 to Maelu Policy MF-114 ML20207T2281987-01-28028 January 1987 Endorsement 21 to Nelia Policy NF-277 ML20213D3501986-08-11011 August 1986 Endorsement 95 to Nelia Policy NF-187 ML20213D3491986-08-11011 August 1986 Endorsement 94 to Nelia Policy NF-187 ML20213D3461986-08-11011 August 1986 Endorsement 78 to Maelu Policy MF-54 ML20213D3421986-08-11011 August 1986 Endorsement 79 to Maelu Policy MF-54 ML20213D3511986-08-0808 August 1986 Endorsement 179 to Nelia Policy NF-43 ML20213D3521986-08-0808 August 1986 Endorsement 153 to Maelu Policy MF-22 ML20213D3591986-08-0808 August 1986 Endorsement 154 to Maelu Policy MF-22 ML20213D3681986-08-0808 August 1986 Endorsement 73 to Maelu Policy MF-64 ML20213D3791986-08-0808 August 1986 Endorsement 178 to Nelia Policy NF-43 ML20213D3761986-08-0808 August 1986 Endorsement 84 to Nelia Policy NF-201 ML20213D3691986-08-0808 August 1986 Endorsement 72 to Maelu Policy MF-64 ML20063M3061982-09-0101 September 1982 Response Opposing Reopening of Record Re Comm Ed Use of 9-ton Auxiliary Hook of Main Overhead Crane Sys During 1981 Installation of High Density Spent Fuel Racks.Incident Not Relevant to Proceeding.Svc List Encl.Related Correspondence ML20063A2551982-08-18018 August 1982 Response to ASLB 820728 Order.Requests Leave to Withdraw Application W/O Prejudice.Need for Transshipment in near- Term Reduced Due to Approval of Installation of High Density Spent Fuel Racks.Certificate of Svc Encl ML20055B4521982-07-20020 July 1982 Transcript of 820720 Hearing in Bethesda,Md Re Spent Fuel Pool Mods.Pp 1,192-1,284 ML20055A6681982-07-14014 July 1982 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20054L9371982-07-0808 July 1982 Memorandum in Response to Applicant Motion for Reconsideration or Clarification of Notice of Hearing Re Issue of Whether Spent Fuel Pool Floor Can Withstand Loads Imposed by New High Density Fuel Racks During Seismic Event ML20054K6511982-07-0101 July 1982 Response Supporting Applicant 820616 Motion for Reconsideration or Clarification of Notice of Hearing.Aslb Should Render Final Decision on Basis of Supplemental SER & ASLB Former Findings.Certificate of Svc Encl ML20054L9591982-07-0101 July 1982 Testimony of Oo Rothberg & G Harstead.Spent Fuel Pool Expansion for Full 33 Rack Installation Is Acceptable.Spent Fuel Pool Floor Can Withstand Impact If All 33 Racks Tip During Seismic Event ML20054G0051982-06-16016 June 1982 Motion for Reconsideration or Clarification of Hearing Scheduled for 820713 by ASLB 820609 Notice of Hearing. Further Evidentiary Sessions Unnecessary & Improper.Final Decision Proper.Certificate of Svc Encl ML20054F5391982-06-0909 June 1982 Notice of 820713 Hearing in Bethesda,Md,To Continue to 0714 If Necessary.Evidence Relevant to Issue of Whether Spent Fuel Pool Floors Can Withstand Loads Which Could Be Imposed by New Fuel Racks During Seismic Event Will Be Taken ML20054F7151982-06-0707 June 1982 Testimony of DB Davidoff & LB Czech on Commission Questions 3 & 4.NY State Radiological Emergency Preparedness Plan Discussed.Certificate of Svc Encl 1999-03-02
[Table view] Category:PLEADINGS
MONTHYEARML20063M3061982-09-0101 September 1982 Response Opposing Reopening of Record Re Comm Ed Use of 9-ton Auxiliary Hook of Main Overhead Crane Sys During 1981 Installation of High Density Spent Fuel Racks.Incident Not Relevant to Proceeding.Svc List Encl.Related Correspondence ML20063A2551982-08-18018 August 1982 Response to ASLB 820728 Order.Requests Leave to Withdraw Application W/O Prejudice.Need for Transshipment in near- Term Reduced Due to Approval of Installation of High Density Spent Fuel Racks.Certificate of Svc Encl ML20054K6511982-07-0101 July 1982 Response Supporting Applicant 820616 Motion for Reconsideration or Clarification of Notice of Hearing.Aslb Should Render Final Decision on Basis of Supplemental SER & ASLB Former Findings.Certificate of Svc Encl ML20054G0051982-06-16016 June 1982 Motion for Reconsideration or Clarification of Hearing Scheduled for 820713 by ASLB 820609 Notice of Hearing. Further Evidentiary Sessions Unnecessary & Improper.Final Decision Proper.Certificate of Svc Encl ML20010C2861981-08-13013 August 1981 Motion for Partial Initial Decision Approving Installation of Five Spent Fuel Storage Racks.Facility Must Begin to Shift Fuel to Prepare for Next Refueling Outage No Later than 810901 Unless Racks Are Approved.W/Certificate of Svc ML20010B2991981-08-0606 August 1981 Response in Opposition to Applicant Motion for Partial Initial Decision Re Issue of Sliding & Tilting of Proposed Spent Fuel Racks During Seismic Events.Certificate of Svc Encl ML19246C0671979-05-22022 May 1979 NRDC Response in Opposition to Comm Ed Motion for Reconsideration Or,In Alternative,For Clarification or Referral Re Adequacy of Safeguards for Spent Fuel Shipments. Motion Is Unwarranted & Inconsistent w/10CFR73 ML19246C0701979-05-18018 May 1979 NRDC Staff Scientist Statement Re Safeguards for Spent Fuel Shipments.Proposed Rule to Protect Spent Fuel Shipments Against Sabotage,Presented in 790429 Memo to Commission,Is Most Likely Adequate.Certificate of Svc Encl ML19241A9891979-05-17017 May 1979 State of Il Opposition to NRC 790504 & Comm Ed 790507 Motions for Reconsideration &/Or Clarification & Referral of ASLB 790419 Memo & Order Admitting Contentions 6 & 11 ML19241A9781979-05-10010 May 1979 NRDC Opposition to NRC Motion for Reconsideration of ASLB 790419 Memo & Order Following Special Prehearing Conference.Certificate of Svc Encl ML19269D9271979-05-0707 May 1979 Applicant Motion for Reconsideration of 790419 Memo & Order of Clarification of 780419 Order Re Physical Security of Snm.Supporting Documentation & Certificate of Svc Encl ML19274D6911979-01-26026 January 1979 Memorandum Re State of Il Contentions.Withdraws Contentions 10-12,14,15 & 17 & Submits Revised Contentions 3,10,& 11. Related Correspondence,Stipulation of Contentions,State Law & Certificate of Svc Encl ML19282A7571979-01-26026 January 1979 Nrdc'S Response to Applicant'S & Nrc'S Objections to Contentions.Urges That NRC Did Not Validly Challenge Its Contentions & That Its Contentions Should Be Admitted. Certificate of Svc Encl ML19289C9321979-01-12012 January 1979 Applicant'S Answer & Motion to Strike Re Contentions Filed by Petitioners to Intervene Nrdc,Citizens for a Better Environ & State of Il.Contentions Fail to State Claim for Which Relief May Be Granted.W/Certificate of Svc ML19263B5221979-01-0202 January 1979 State of Il Contentions Re Amends to Operating License for Transport of Spent Fuel Between Units.Contentions Assert Applicant'S Submittals Are Insufficient.W/Affidavit & Certificate of Svc ML19269C3001978-12-28028 December 1978 NRDC & Citizens for a Better Environ Statement of Contentions.Asserts Action Would Violate Nepa,Provide No Adequate Analysis of Alternatives & Increase Exposure of Workers to Radiation.W/Certificate of Svc ML19259A9271978-12-19019 December 1978 Reply by NRDC & Citizens for Better Environ to Suppl Brief of Commonwealth Edison Co.Asserts That Util Errs in Claiming That Only Direct Personal case-by-case Authorization of Litigation Can Confer Standing.Certificate of Svc Encl ML19263B5291978-12-0606 December 1978 NRDC & Citizens for a Better Environ Contentions Re Util'S License Amend Re Transport of Spent Fuel Between Units. Asserts Proposed Action Violates NEPA ML20064E5051978-10-30030 October 1978 Request by Comm Ed for Leave to File a Response to NRDC Brief Which Argues That Organizations May Show Standing to Participate in NRC Proceedings Merely by Alleging That They Represent Anonymous Members.Cert of Svc Encl ML20064E2511978-10-23023 October 1978 Natural Resources Defense Council Response to Commonwealth Edison'S & Staff'S Answers to Petition for Leave to Intervene.Intervenor Urges Bd to Establish a Schedule for Briefing Challenges to Contentions ML20062B4171978-10-10010 October 1978 Request for Leave to File Response to Applicant Contention Re Constitutionality of Forced Disclosure of Group Members Names in Order to Operate within State ML20064B9371978-09-18018 September 1978 Applicant'S Answer to Petition for Leave to Intervene Re Proceeding Filed 780908 by Attorney Gen of St of Il.Includes Notices of Appearance for M.I.Miller,J.R.Rowe,& P.P.Steptoe. Includes Designation of Person Upon Whom Svc Shall Be Made ML20058K5131973-12-13013 December 1973 Requests for Decision Re Immediate Derating of Nine BWRs & Implementation of Procedures to Be Followed for Consideration of Any Subsequent Action Concerning Safety Issue Raised About Plants 1982-09-01
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- V UNITED STATES OF AMERICA g .y d }'h..a [,
NUCLEAR REGULATORY COMMISSION 03 psgp - p
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD O> oh In the Matter of )
) Docket No. 50-237-SP COMMONWEALTH EDISON COMPANY ) . 50- >
) (Spent Fue O (Dresden Stations, Units 2&3) )
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p&i LjJ s INTERVENOR'S RESPONSE TO .- -8 APPLICANT'S MOTION FOR A i ,,,1 O I987 A C PARTIAL INITIAL DECISION (f *' *8- Q'*j[grear .gj Although the Poard has reached a deci.sion on the 'kkup Q,>,yl;ticN have been litigated so far in this case, the issue of the sliding and tilting of the proposed spent fuel racks during seismic events-I has not yet been resolved. The Staff estimates that is may take four weeks or more to complete their review (assuming the
'gr.licant promptly provides the information' requested by the Staff) ,
but Applicant believes that the Staff's estimate is optimistic and it may take two months or more to resolve this issue.
The Board has invited comments and suggestions as to.what i
should be done in this proceeding.
I As of the date this Response was filed, Intervenor had only received the summary by Paul O'Connor of the June 30, 1981 meeting in Bethesda Maryland and the attached list of additional information requested by'the NRC. Thus, Intervenor does not have adequate knowledge of the relevant facts so as to be-able to comment at this 3
time on the sliding and tipping issue..
()(lou 8108140335 810806 PDR ADOCK 05000237
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'Intervenor objects to Applicants Motion for a artial Initial Decision in this proceeding. There is no specific provision in NRC Rules and Regualtions for this type of a decision, and it certainly has not been the practice of Atomic Safety and Licensing Boards to issue partial decisions.
In Federal Courts, Applicant's Motion would be analagous to a Motion for Summary Judgment or a Motion for Partial Summary Judgment. (cee Rule 56 c', Federal Rules of Civil Procedure) . In either cc.ae, on the facts in this instance, such a motion would be denied, because for summary judgment to be granted, there must be "no genuine issue as to any material fact." (Emphasis supplied) .
That is clearly not the case in this proceeding; although as stated above, Intervenor has no specific knowledge of what the sliding and tipping issues are, there clearly are issues which have yet to be reviewed and resolved. _1/
Intervenor proposes that after
- 1) the Staff issues a supplenental safety evaluation;
- 2) Intervenor comments on that evaluation; and
- 3) the Board makes its determination whether this is a matter of " major significance to plant safety" requiring further hearings, the Board's Initial Decision shou'_ be issued. This procedure would be proper, and would not prejudice any party.
Intervenor appreciates Applicant's desire to know the results and contents of the Initial Decision as soon as possible,but the detriment.s of taking such a novel, unprecedented and unacceptable shor. cut far outweigh the benefits of knowing what the Board has decided so far.
1/ See Applicant's Motion for Partial Initial Decision, p. 2.
4 L Finally, Intervenor would again point out that as of the date of the first hearing, November 19, 1980, it was assumed that Applicant would be ready to proceed with the entire hearing and have ready for submittal all necessary documents associated therewith. It is clear that Applicant was in no such position, and even as of this date, does not have all proper analyses completed.
Applicant obviously was not ready to proceed with the hearing on the proposed spent fuel pool modification in November, and is still completing the steps necessary to be granted a license. Until all the evidence is submitted, the Board should not issue any type of Initial Decision.
Respectfully submitted, PEOPLE OF THE STATE OF ILLINOIS TYRONE C. FAHNER Attorney General State of Illinois i
l BY: d F C'50'
- i MUM WY' h '
Assi tant a dtorney Gene 2 1 Environmental Control Division s/
188 West Randolph Street V Suite 2315 Chicago, Illinois 60601 (312) 793-2491 DATED: August 6, 1981
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UNTIED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter Of Docket Nos. 50-237-SP
)
COMMONWEALTH EDISON COMPANY 50-249-SP (S ent Fuel (Dresden Stations, Units 2 & 3) Modification) l CERTIFICATE OF SERVICE I hereby certify that copies of Intervenor's Response To Applicant's Motion For A TPertial Initial Decision in the above-captioned proceeding have been served on the following by depositing in the United States mail, first class, postage pre-paid: -
John R. Wolf, Chairman Richard Coddard, Esq.
3409 Shepherd Street Office of the General Counsel Chevy Chase, Maryland 20015 U.S. NRC Washington, D.C. 20555 Dr. Linda W. Little 5000 Hermitage Drive Atomic Safety and Licensing Raleigh, North Carolina 27612 Board U.S. NRC Dr. Forrest J. Remick Washington, D.C. 20555 305 E. Hamilton Avenue State College, Pa. 16801 Atomic Safety and Licensing Appeal Board' Panel Phillip P. Steptoe, Esq. U.S. NRC Isham, Lincoln and Beale Washington, D.C. 20555 One First National Plaza Chicago, Illinois 60603 Docketing and Service Section U.S. NRC Washington,! D.C. 20555 I l a lbh MAR 1 JO M : @\Y AlLUM V
Na DATED: August 6, 1981