Focus of cross-exam & Expert Witnesses.No Expert Witnesses Will Be presented.Cross-exam Will Be Limited to Contentions 4,9,14,20 & 21.Certificate of Svc Encl.Related Correspondence| ML20011A236 |
| Person / Time |
|---|
| Site: |
Susquehanna  |
|---|
| Issue date: |
09/29/1981 |
|---|
| From: |
Schultz G
SUSQUEHANNA ENVIRONMENTAL ADVOCATES |
|---|
| To: |
|
|---|
| References |
|---|
| NUDOCS 8110080351 |
| Download: ML20011A236 (3) |
|
|
|---|
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
ML20053D2191982-05-28028 May 1982
Brief Supporting Commonwealth of PA Exceptions to ASLB 820412 Initial Decision.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
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
ML20042C2701982-03-26026 March 1982
Proposed Findings of Fact & Conclusions of Law Re Emergency Evacuation Plan
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
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:OTHER LEGAL DOCUMENT
MONTHYEARML20138A9521985-10-0909 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
ML20052A2751982-04-21021 April 1982
Exceptions to ASLB Initial Decision.Certificate of Svc Encl
ML20011A2361981-09-29029 September 1981
Focus of cross-exam & Expert Witnesses.No Expert Witnesses Will Be presented.Cross-exam Will Be Limited to Contentions 4,9,14,20 & 21.Certificate of Svc Encl.Related Correspondence
ML20011A2181981-09-29029 September 1981
Submittal of J Amory Affidavit Opposing Applicants' Motion for Summary Dispositon of Contention 17.Certificate of Svc Encl.Related Correspondence
ML20010F3641981-08-31031 August 1981
Submission of Safe Energy Alliance List of Proposed Expert Witnesses,Per ASLB 810814 Order.Certificate of Svc Encl. Related Correspondence
ML20010C9701981-08-10010 August 1981
Certifies 810812 Svc of Commonwealth of PA Disaster Operations Plan,Annex E,Comments Re Contention 20,memorandum Responding to Util 810727 Ltr,& Luzerne County Facility Emergency Response Plan.Related Correspondence
ML18026A5081980-10-27027 October 1980
Certifies Svc of Applicants' Motion for Summary Disposition of Contention 16 W/Supportive Statement of Matl Facts & Wj Rhoades Affidavit,On 801027
ML18030A5161980-10-21021 October 1980
Notice of Address Change
ML18030A1391980-08-22022 August 1980
Certifies Svc of Motion for Partial Summary Disposition of Contention 17,statement of Matl Facts as to Which No Genuine Issue of Fact Exists,Brief in Support of Motion & Rf Lehman Affidavit on 800822
ML19259B3121979-01-15015 January 1979
Provides Notice That Ba Snapp Will Represent Licensee in Proceedings
ML19274D2501978-12-28028 December 1978
Provides Notice That AR Yuspeh Will Appear on Behalf of PA Power & Light in Proceedings.Certificate of Svc Encl
ML19274D2431978-12-28028 December 1978
Provides Notice That Je Silberg Will Appear on Behalf of PA Power & Light in Proceedings.Certificate of Svc Encl
1985-10-09
[Table view] |
Text
e
- n. -.,, ,
O p
.( o , Doc e i
- Pn
- - . . . . . . 1 tcmc e
'%_ ~J OCT 5fgSf>h -
UNITED STATES OF AMERICA $$((;'[j?""irty i .
1 NUCLEAR REGULATORY CCIGIISSION e i d . c. ** -
Secte:ber G .i w' t
BEFCRE THE ATOMIC SAFETY AND LICENSING EOARD -
[IntheMatterof ggj l PENNSYLVANI A P0k'IR & LIGHT CO.
and Docket Nos. 50-387 50-3 , m ALLEGHENY ELECTRIC CCOPERATIVE, )
1 (Susquehanna Steam Electric INC.
Station Units 1 & 2) ) x
,e (
/C ,
J (
l 4
] OCT 7 nggh :
! SUSQUEHANN A ENVIRONMENTAL ADVCCATES
- 23/" ;" *8 Q t FOCUS OF CROSS EIAMINATICN/ EXPERT WITNESSESy ggV i
1 EXPERT WITNESSES Q!b I
l Due mainly to lack of funds, Susquehanna Environmental ,
3 Advocates will present no expert witnesses to testify.
f 2. FOCUS OF CROSS EX/JIINATION
The f ocus of Susquehanna's Environmental Advocates
- cross examination on various contentions is as f611ows:
, Contention t.: l
'l q Cn past growth of electric usage and potential for future 3
growth j i
j On the alleged savings to consumers from Susquehanna ,
On PPL's censervation programs, including conservation efforts that have been ignored by PPL.
On PPL's solar programs, including those not in use by
- PPL.
On alternatives to the plant. ,
l Contention 9:
Cn the methodology, cost, and financial ability of FPL to pay for decoccissioning. !
l On the long ter= storage or disposal of the pcwer plant. I 0 h
'8110000351 810929
'PDR ADOCK 05000387 PDR
$ g\
3 '
l l
[
! Contention 14:
~: Cn past performance of similiar power plants.
On perfor=ance of the plant as it grows cider.
Contention 20:
On specific sections of the e=ergency plan that we centend do not conform to the regulations.
On the ability of the county to carry out the plan.
On the location of e=er6ency evacuation centers.
.I t On past state =ents of county officials concerning nuclear 1 power and evacuation. '
Il
- ( Contention 21 :
1 On the re=edial =easures perscribed by the NRC - their i
adequacy. Do they provide a sufficient =argin of. safety?
1 -
Respectfully sub=itted:
I m: hvoel S '
G k-1 5
I
~
i GERAIS R. SCHULTZ ;
4
c S gC.Q _ 'N _
. ; y s C ..e g7 -
- 0 9 L, 51C M.> Q>i-OlW E E D 'Y' UNITED STATES OF AMERICA 9 Cie '.di:i'"
t NUCLEAR REGULATORY COIEISSION ,
Septe=ber 29,Q- > ,
EEFORE THE ATOMIC SAFETY AND LICENSING E0ARD 1IntheMatterof:
t PENNSYLVANIA POWER & LIGHT CO.
and ) Docket Nes. 50-367 ;
) 50 388
~
ALLEGHENY ELECTRIC CCOFERATIVE, )
- INC. )
] (Susquehanna Steam Electric )
il Station Units 1 & 2) )
el
! CERTIFICATE OF SERVICE g .
l'
- ,1,
- I t
This is to certify that copies of the foregoing"Suscuehanna
?
1 Environmental Advocates Focus of Cross Examination / Expert Witnesses"
'l IIwere served by First Class Mail September 30, 1981 to all parties.
.1 4
Dated: September 29, 1981 DD N c - .
GERALD R. SCHULTZ
)
l i
i e
-