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Category:INTERVENTION PETITIONS
MONTHYEARML20059L9391993-11-12012 November 1993 Petitioners Supplemental Petition for Leave to Intervene.* Court Held That NRC May Not Eliminate Public Participation on Matl Issue in Interest of Making Process More Efficient. W/Certificate of Svc ML20101M7061992-06-30030 June 1992 Applicant Answer in Opposition to Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Untimely Intervention Petition Should Be Denied.W/Certificate of Svc ML20101E1261992-06-15015 June 1992 Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Should Be Granted Discretionary Intervention & Amended Petition for Leave to Intervene Granted for Listed Reasons.W/Certificate of Svc ML20086G6401991-11-22022 November 1991 Petitioners Amended Petition for Leave to Intervene.* Amended Petition of Ohio Citizens for Responsible Energy,Inc for Leave to Intervene to Respond to Arguments Made in Licensee & NRC Intervention Petition.W/Certificate of Svc ML20083B7981991-09-16016 September 1991 Answer of Util to City of Brook Park,Oh Suppl to Petition for Leave to Intervene.* Concluded That City Petition Failed to Satisfy Any of Three Criteria for Intervention,Therefore Leave to Intervene Should Be Denied.W/Certificate of Svc ML20083B7901991-09-16016 September 1991 Answer of Util to Petition of City of Brook Park,Oh for Leave to Intervene & Suppl Thereto.* Petition Should Be Denied Based on Listed Reasons.W/Certificate of Svc ML20083B3581991-09-0404 September 1991 City of Brook Park Suppl to Petition for Leave to Intervene.* in Consideration of Foregoing,Petition of City of Brook Park,Oh for Leave to Intervene Should Be Granted. W/Certificate of Svc & Svc List ML20082P1611991-08-23023 August 1991 Petition for Leave to Intervene & Request for Hearing.* Petitioners Have Demonstrated Right to Be Made Parties to Proceeding and Instant Petition for Leave to Intervene Should Be Granted & Proposed Contention Admitted ML20082G8921991-07-31031 July 1991 Petition of City of Brook Park,Oh for Leave to Intervene.* City Requests That NRC & ASLB Deny Applicant Request for Hearing.W/Svc List & Certificate of Svc ML20082D4411991-07-10010 July 1991 Supple by American Municipal Power-Ohio,Inc to Petition for Leave to Intervene.* Facility Requests Addl Time to Mod Suppl.W/Certificate of Svc ML20082B5111991-07-10010 July 1991 10CFR2.714(b)(1) Suppl to Conditional Petition to Intervene of City of Cleveland,Oh Submitted in Connection w/910725 Prehearing Conference.W/Certificate of Svc & Svc List ML20082B2511991-07-0303 July 1991 Petition of Util for Leave to Intervene.* If License Conditions Can Disappear & Reappear W/Shifting Economics of Electric generation,AMP-Ohio Future Will Be Seriously Jeopardized.W/Certificate of Svc ML20077G2661991-05-30030 May 1991 Petition of Alabama Electric Cooperative,Inc for Leave to Intervene.* Util Requests Intervention in Further Proceedings on Applications of Ohio Edison & Other Applicants.W/Certificate of Svc ML20043D6751990-06-0101 June 1990 Ocre Response to Licensee & NRC Staff Answers to Ocre Contention.* Ocre Contention Should Be Granted Since NRC Has No Valid Argument to Preclude Admission of Contention & 10CFR2.714(b)(2) Requirements Met.W/Certificate of Svc ML20012E6901990-03-23023 March 1990 Licensee Answer to Ocre Petition for Leave to Intervene & Request for Hearing.* Concludes That Ocre Lacks Requisite Interest in License Amend Proceeding & Requests That ASLB Rule on Ocre Petition.W/Certificate of Svc & Svc List ML20012E6771990-03-0808 March 1990 Petition for Leave to Intervene & Request for Hearing.* Ocre Requests Hearing on Util 891219 Amend Request & Submits Petition W/Intention of Becoming Full Party.Petition Should Be Granted Since Ocre Demonstrated Right to Be Made Party ML20148D0511988-01-0707 January 1988 Petition for Leave to Intervene & Request for Formal Adjudicatory Hearing.* Ocre Demonstrated Right to Be Made Party in Proceeding & Petition Should Be Granted ML20214W6371987-06-0505 June 1987 Petition of Toledo Coalition for Safe Energy,Sunflower Alliance,Inc,S Sass & SB Carter for Revocation,Mod or Suspention of OL Per 10CFR2.206.* No Regulatory Review Has Taken Place at Plant in Response to Reed Rept.W/Svc List ML20215N2451986-10-29029 October 1986 Second Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State Emergency Evacuation Review Team Not Convinced Plan Adequate.Certificate of Svc Encl ML20215H6861986-10-21021 October 1986 Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State of Oh Emergency Plan Should Be Reviewed Before Full Operation Granted.Certificate of Svc Encl ML20214U9901986-09-29029 September 1986 Reply to Licensee Response to State of Oh 860904 Petition for Leave to Intervene.State Seeking Opportunity to Advise Commission as to Serious Safety Concern Re Eventual Full Power Licensing.W/Certificate of Svc ML20214R3381986-09-23023 September 1986 Response Granting State of Oh Petition to Intervene as Interested State,To Allow Entering Proceeding to Advise Commission on Pending Immediate Effectiveness Review.W/ Certificate of Svc ML20214R5671986-09-19019 September 1986 Response to State of Oh 860904 Petition for Leave to Intervene & Request That Petition Be Denied.Certificate of Svc Encl ML20212Q8461986-09-0404 September 1986 Petition of State of Oh for Leave to Intervene.Requests Participation in Evaluating Adequacy of Licensee Offsite Evacuation Plans.Certificate of Svc Encl ML20115A5681985-03-0808 March 1985 Petition for Suspension of CPs & Nuclear Fuel Shipments & Conduct of Investigation to Ascertain Whether Central Area Power Coordinating Group Financially Qualified to Design & Construct Facility ML20078K3501983-10-14014 October 1983 Response to Util & NRC 831003 & 06 Answers,Respectively,To Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2.NRC Misunderstood Thrust of Motion. Contention Should Be Admitted.W/Certificate of Svc ML20078E5161983-10-0303 October 1983 Answer Opposing Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2 Re Diesel Generator Reliability.Motion Fails to Meet Criteria of Adequate Basis & Specificity.Certificate of Svc Encl ML20080H2651983-09-16016 September 1983 Motion to Resubmit Contention 2 on Diesel Generator Reliability.Good Cause Contained in Recent Documents Describing Generator Failure of Type to Be Used at Plant. Certificate of Svc Encl ML20024B7491983-07-0505 July 1983 Reply Opposing Util & NRC Responses Opposing Ohio Citizens for Responsible Energy 830510 Motion to File Contentions on SNM License Application.Certificate of Svc Encl ML20024A2871983-06-13013 June 1983 Answer Opposing Ohio Citizens for Responsible Energy 830510 Motion to Admit Five New Contentions on SNM License Application.Contentions Unjustifiably Late,Outside ASLB Jurisdiction or Moot.Certificate of Svc Encl ML20066B9791982-11-0404 November 1982 Answer to Sunflower Alliance 821019 Reply Brief to NRC & Util Answers to Sunflower Motion to Submit Addl Contention on Shift Rotation.No Support Exists for Sunflower Untimeliness Argument.Certificate of Svc Encl ML20069J9811982-10-19019 October 1982 Reply Brief Supporting Motion to Submit Addl Contention.Good Cause for Late Filing Demonstrated.Applicant Shift Rotation Plans May Not Be Incorporating Circadian Principles ML20027C5851982-10-12012 October 1982 Reply Opposing NRC & Applicant Responses to Oh Citizens for Responsible Energy Motion for Leave to File Contentions 21-26.Good Cause,Specificity & Basis Requirements Met. Certificate of Svc Encl ML20069G0481982-09-24024 September 1982 Answer Opposing Sunflower Alliance 820910 Motion to Submit Addl Contention.Good Cause for Late Filing,Basis for Contention & Nexus Between Contention & Facility Not Shown. Certificate of Svc Encl ML20027B5751982-09-16016 September 1982 Answer Opposing Oh Citizens for Responsible Energy 820818 Motion for Leave to File Contentions 21-26.Adequate Basis, Specificity or Good Cause Not Demonstrated.Certificate of Svc Encl ML20063M6271982-09-10010 September 1982 Motion to Submit Addl Contention Re Unnatural Shift Rotations.Good Cause Shown for Late Filing as Basis of Contention Is Recently Published Research.Certificate of Svc Encl ML20063J4651982-08-31031 August 1982 Answer Opposing Oh Citizens for Responsible Energy 820809 Motion for Leave to File Contention 20 Re Inadequate Consideration of Economic Consequences of Accidents.No Basis for Assertion of Deficiency Shown.Certificate of Svc Encl ML20063D0551982-08-18018 August 1982 Motion for Leave to File Contentions 21-26 Re Turbine Missiles,New Mark III Containment Concerns,Seismic Evaluation of BWR Core Thermal Hydraulics & in-core Thermocouples.W/Certificate of Svc ML20058J8551982-08-0909 August 1982 Motion for Leave to File Contention 20 Re Adequacy of Consideration of Economic Consequences of Accidents.Des (NUREG-0884) Deficient Due to Failure to Include Assessment of Disruption Caused by Accident.Certificate of Svc Encl ML20055A3641982-07-13013 July 1982 Response Opposing Conservation Council of Nc Additions to Suppl to Petition to Intervene.Opposes Contentions Under Same Rationale Identical Contentions of W Eddleman Opposed. Certificate of Svc Encl ML20052A2821982-04-22022 April 1982 Motion for Leave to File Contentions 17,18 & 19.Certificate of Svc Encl ML20004E8381981-06-0808 June 1981 Amended Contention of T Kenney.Facility Evacuation Plan Fatally Defective Since Applicant Definitions of Affected Persons,Contaminated Area,Dose Projection & Emergency Action Levels Are Deficient.Certificate of Svc Encl ML20008G1571981-05-0808 May 1981 Amended Sunflower Alliance,Inc,North Shore Alert & Citizens for Safe Energy Petition for Intervenor Status.Contentions Set Forth in Original Petition Are Adopted by Ref.Svc List Encl ML20003H5211981-04-30030 April 1981 Suppl to Oh Citizens for Responsible Energy 810311 Petition to Intervene,Enumerating Contentions to Be Litigated. Contentions Concern Clam Biofouling,Steam Generator Reliability,Radiation Blocking Agent & Steam Injury ML19345G5941981-03-20020 March 1981 Response in Opposition to Oh Citizens for Responsible Energy 810306 Petition to Intervene in OL Proceeding.Petition Fails to Establish Organizational Interest Required by 10CFR2.714.Certificate of Svc Encl ML19345G5471981-03-20020 March 1981 Response in Opposition to Sunflower Alliance,Inc Et Al 810315 Petition to Intervene in OL Proceeding.Individual Petitioners Satisfy Interest Requirements But Organization Petitioners Do Not.Certificate of Svc Encl ML19343C7791981-03-16016 March 1981 Petition to Intervene in Proceeding ML19350B9871981-03-16016 March 1981 Petition to Intervene in Licensing Proceeding.W/Certificate of Svc ML20126F5351981-03-0606 March 1981 Petition for Leave to Intervene.Util May Not Be Financially Capable to Operate Plant Safely.Requests Fes & Info Re Prehearing Conference ML20126F5291981-03-0505 March 1981 Petition to Intervene in Licensing Proceeding & Request for Hearing.Proof of Svc Encl 1993-11-12
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20059L9391993-11-12012 November 1993 Petitioners Supplemental Petition for Leave to Intervene.* Court Held That NRC May Not Eliminate Public Participation on Matl Issue in Interest of Making Process More Efficient. W/Certificate of Svc ML20101M7061992-06-30030 June 1992 Applicant Answer in Opposition to Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Untimely Intervention Petition Should Be Denied.W/Certificate of Svc ML20101E1261992-06-15015 June 1992 Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Should Be Granted Discretionary Intervention & Amended Petition for Leave to Intervene Granted for Listed Reasons.W/Certificate of Svc ML20086G6401991-11-22022 November 1991 Petitioners Amended Petition for Leave to Intervene.* Amended Petition of Ohio Citizens for Responsible Energy,Inc for Leave to Intervene to Respond to Arguments Made in Licensee & NRC Intervention Petition.W/Certificate of Svc ML20083B7981991-09-16016 September 1991 Answer of Util to City of Brook Park,Oh Suppl to Petition for Leave to Intervene.* Concluded That City Petition Failed to Satisfy Any of Three Criteria for Intervention,Therefore Leave to Intervene Should Be Denied.W/Certificate of Svc ML20083B7901991-09-16016 September 1991 Answer of Util to Petition of City of Brook Park,Oh for Leave to Intervene & Suppl Thereto.* Petition Should Be Denied Based on Listed Reasons.W/Certificate of Svc ML20083B3581991-09-0404 September 1991 City of Brook Park Suppl to Petition for Leave to Intervene.* in Consideration of Foregoing,Petition of City of Brook Park,Oh for Leave to Intervene Should Be Granted. W/Certificate of Svc & Svc List ML20082P1611991-08-23023 August 1991 Petition for Leave to Intervene & Request for Hearing.* Petitioners Have Demonstrated Right to Be Made Parties to Proceeding and Instant Petition for Leave to Intervene Should Be Granted & Proposed Contention Admitted ML20082G8921991-07-31031 July 1991 Petition of City of Brook Park,Oh for Leave to Intervene.* City Requests That NRC & ASLB Deny Applicant Request for Hearing.W/Svc List & Certificate of Svc ML20082D4411991-07-10010 July 1991 Supple by American Municipal Power-Ohio,Inc to Petition for Leave to Intervene.* Facility Requests Addl Time to Mod Suppl.W/Certificate of Svc ML20082B5111991-07-10010 July 1991 10CFR2.714(b)(1) Suppl to Conditional Petition to Intervene of City of Cleveland,Oh Submitted in Connection w/910725 Prehearing Conference.W/Certificate of Svc & Svc List ML20082B2511991-07-0303 July 1991 Petition of Util for Leave to Intervene.* If License Conditions Can Disappear & Reappear W/Shifting Economics of Electric generation,AMP-Ohio Future Will Be Seriously Jeopardized.W/Certificate of Svc ML20077G2661991-05-30030 May 1991 Petition of Alabama Electric Cooperative,Inc for Leave to Intervene.* Util Requests Intervention in Further Proceedings on Applications of Ohio Edison & Other Applicants.W/Certificate of Svc ML20043D6751990-06-0101 June 1990 Ocre Response to Licensee & NRC Staff Answers to Ocre Contention.* Ocre Contention Should Be Granted Since NRC Has No Valid Argument to Preclude Admission of Contention & 10CFR2.714(b)(2) Requirements Met.W/Certificate of Svc ML20012E6901990-03-23023 March 1990 Licensee Answer to Ocre Petition for Leave to Intervene & Request for Hearing.* Concludes That Ocre Lacks Requisite Interest in License Amend Proceeding & Requests That ASLB Rule on Ocre Petition.W/Certificate of Svc & Svc List ML20012E6771990-03-0808 March 1990 Petition for Leave to Intervene & Request for Hearing.* Ocre Requests Hearing on Util 891219 Amend Request & Submits Petition W/Intention of Becoming Full Party.Petition Should Be Granted Since Ocre Demonstrated Right to Be Made Party ML20148D0511988-01-0707 January 1988 Petition for Leave to Intervene & Request for Formal Adjudicatory Hearing.* Ocre Demonstrated Right to Be Made Party in Proceeding & Petition Should Be Granted ML20214W6371987-06-0505 June 1987 Petition of Toledo Coalition for Safe Energy,Sunflower Alliance,Inc,S Sass & SB Carter for Revocation,Mod or Suspention of OL Per 10CFR2.206.* No Regulatory Review Has Taken Place at Plant in Response to Reed Rept.W/Svc List ML20215N2451986-10-29029 October 1986 Second Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State Emergency Evacuation Review Team Not Convinced Plan Adequate.Certificate of Svc Encl ML20215H6861986-10-21021 October 1986 Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State of Oh Emergency Plan Should Be Reviewed Before Full Operation Granted.Certificate of Svc Encl ML20214U9901986-09-29029 September 1986 Reply to Licensee Response to State of Oh 860904 Petition for Leave to Intervene.State Seeking Opportunity to Advise Commission as to Serious Safety Concern Re Eventual Full Power Licensing.W/Certificate of Svc ML20214R3381986-09-23023 September 1986 Response Granting State of Oh Petition to Intervene as Interested State,To Allow Entering Proceeding to Advise Commission on Pending Immediate Effectiveness Review.W/ Certificate of Svc ML20214R5671986-09-19019 September 1986 Response to State of Oh 860904 Petition for Leave to Intervene & Request That Petition Be Denied.Certificate of Svc Encl ML20212Q8461986-09-0404 September 1986 Petition of State of Oh for Leave to Intervene.Requests Participation in Evaluating Adequacy of Licensee Offsite Evacuation Plans.Certificate of Svc Encl ML20115A5681985-03-0808 March 1985 Petition for Suspension of CPs & Nuclear Fuel Shipments & Conduct of Investigation to Ascertain Whether Central Area Power Coordinating Group Financially Qualified to Design & Construct Facility ML20078K3501983-10-14014 October 1983 Response to Util & NRC 831003 & 06 Answers,Respectively,To Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2.NRC Misunderstood Thrust of Motion. Contention Should Be Admitted.W/Certificate of Svc ML20078E5161983-10-0303 October 1983 Answer Opposing Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2 Re Diesel Generator Reliability.Motion Fails to Meet Criteria of Adequate Basis & Specificity.Certificate of Svc Encl ML20080H2651983-09-16016 September 1983 Motion to Resubmit Contention 2 on Diesel Generator Reliability.Good Cause Contained in Recent Documents Describing Generator Failure of Type to Be Used at Plant. Certificate of Svc Encl ML20024B7491983-07-0505 July 1983 Reply Opposing Util & NRC Responses Opposing Ohio Citizens for Responsible Energy 830510 Motion to File Contentions on SNM License Application.Certificate of Svc Encl ML20024A2871983-06-13013 June 1983 Answer Opposing Ohio Citizens for Responsible Energy 830510 Motion to Admit Five New Contentions on SNM License Application.Contentions Unjustifiably Late,Outside ASLB Jurisdiction or Moot.Certificate of Svc Encl ML20066B9791982-11-0404 November 1982 Answer to Sunflower Alliance 821019 Reply Brief to NRC & Util Answers to Sunflower Motion to Submit Addl Contention on Shift Rotation.No Support Exists for Sunflower Untimeliness Argument.Certificate of Svc Encl ML20069J9811982-10-19019 October 1982 Reply Brief Supporting Motion to Submit Addl Contention.Good Cause for Late Filing Demonstrated.Applicant Shift Rotation Plans May Not Be Incorporating Circadian Principles ML20027C5851982-10-12012 October 1982 Reply Opposing NRC & Applicant Responses to Oh Citizens for Responsible Energy Motion for Leave to File Contentions 21-26.Good Cause,Specificity & Basis Requirements Met. Certificate of Svc Encl ML20069G0481982-09-24024 September 1982 Answer Opposing Sunflower Alliance 820910 Motion to Submit Addl Contention.Good Cause for Late Filing,Basis for Contention & Nexus Between Contention & Facility Not Shown. Certificate of Svc Encl ML20027B5751982-09-16016 September 1982 Answer Opposing Oh Citizens for Responsible Energy 820818 Motion for Leave to File Contentions 21-26.Adequate Basis, Specificity or Good Cause Not Demonstrated.Certificate of Svc Encl ML20063M6271982-09-10010 September 1982 Motion to Submit Addl Contention Re Unnatural Shift Rotations.Good Cause Shown for Late Filing as Basis of Contention Is Recently Published Research.Certificate of Svc Encl ML20063J4651982-08-31031 August 1982 Answer Opposing Oh Citizens for Responsible Energy 820809 Motion for Leave to File Contention 20 Re Inadequate Consideration of Economic Consequences of Accidents.No Basis for Assertion of Deficiency Shown.Certificate of Svc Encl ML20063D0551982-08-18018 August 1982 Motion for Leave to File Contentions 21-26 Re Turbine Missiles,New Mark III Containment Concerns,Seismic Evaluation of BWR Core Thermal Hydraulics & in-core Thermocouples.W/Certificate of Svc ML20058J8551982-08-0909 August 1982 Motion for Leave to File Contention 20 Re Adequacy of Consideration of Economic Consequences of Accidents.Des (NUREG-0884) Deficient Due to Failure to Include Assessment of Disruption Caused by Accident.Certificate of Svc Encl ML20055A3641982-07-13013 July 1982 Response Opposing Conservation Council of Nc Additions to Suppl to Petition to Intervene.Opposes Contentions Under Same Rationale Identical Contentions of W Eddleman Opposed. Certificate of Svc Encl ML20052A2821982-04-22022 April 1982 Motion for Leave to File Contentions 17,18 & 19.Certificate of Svc Encl ML20004E8381981-06-0808 June 1981 Amended Contention of T Kenney.Facility Evacuation Plan Fatally Defective Since Applicant Definitions of Affected Persons,Contaminated Area,Dose Projection & Emergency Action Levels Are Deficient.Certificate of Svc Encl ML20008G1571981-05-0808 May 1981 Amended Sunflower Alliance,Inc,North Shore Alert & Citizens for Safe Energy Petition for Intervenor Status.Contentions Set Forth in Original Petition Are Adopted by Ref.Svc List Encl ML20003H5211981-04-30030 April 1981 Suppl to Oh Citizens for Responsible Energy 810311 Petition to Intervene,Enumerating Contentions to Be Litigated. Contentions Concern Clam Biofouling,Steam Generator Reliability,Radiation Blocking Agent & Steam Injury ML19345G5941981-03-20020 March 1981 Response in Opposition to Oh Citizens for Responsible Energy 810306 Petition to Intervene in OL Proceeding.Petition Fails to Establish Organizational Interest Required by 10CFR2.714.Certificate of Svc Encl ML19345G5471981-03-20020 March 1981 Response in Opposition to Sunflower Alliance,Inc Et Al 810315 Petition to Intervene in OL Proceeding.Individual Petitioners Satisfy Interest Requirements But Organization Petitioners Do Not.Certificate of Svc Encl ML19343C7791981-03-16016 March 1981 Petition to Intervene in Proceeding ML19350B9871981-03-16016 March 1981 Petition to Intervene in Licensing Proceeding.W/Certificate of Svc ML20126F5351981-03-0606 March 1981 Petition for Leave to Intervene.Util May Not Be Financially Capable to Operate Plant Safely.Requests Fes & Info Re Prehearing Conference ML20126F5291981-03-0505 March 1981 Petition to Intervene in Licensing Proceeding & Request for Hearing.Proof of Svc Encl 1993-11-12
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212J1581999-09-30030 September 1999 Order Approving Transfer of License & Conforming Agreement. Orders That License Transfer Approved,Subj to Listed Conditions ML20205D4901999-02-22022 February 1999 Transcript of 990222 Informal Public Hearing on 10CFR2.206 Petition in Rockville,Md.Pp 1-105.Supporting Documentation Encl ML20198D9711998-11-0909 November 1998 Petition Per 10CFR2.206 Requesting That Facility Be Immediately Shut Down & OL Be Suspended or Modified Until Such Time That Facility Design & Licensing Bases Properly Updated to Permit Operation with Failed Fuel Assemblies ML20155F4561998-08-26026 August 1998 Demand for Info Re False Info Allegedly Provided by Wh Clark to Two NRC Licensees.Nrc Considering Whether Individual Should Be Prohibited from Working in NRC-licensed Activities for Period of 5 Yrs ML20236V5261998-07-20020 July 1998 Computer Access & Operating Agreement Between Cleveland Electric Illuminating Co & NRC PY-CEI-NRR-2284, Comment Opposing Proposed Generic Communication, Lab Testing of Nuclear-Grade Activated Charcoal1998-05-21021 May 1998 Comment Opposing Proposed Generic Communication, Lab Testing of Nuclear-Grade Activated Charcoal ML20216B5111998-04-0909 April 1998 Order Imposing Civil Monetary Penalty.Denies Request for Remission of Violation C,Ea 97-430 & Orders Licensee to Pay Civil Penalty in Amount of $50,000 within Next 30 Days PY-CEI-NRR-2269, Comment on Proposed Rule 10CFR50.NRC Should Demonstrate That Not Only Is Code Process Flawed,But That Proposed Change Justified from Cost Versus Safety Protective1998-04-0303 April 1998 Comment on Proposed Rule 10CFR50.NRC Should Demonstrate That Not Only Is Code Process Flawed,But That Proposed Change Justified from Cost Versus Safety Protective ML20216G3821998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Duquesne Light Co & Allegheny Power Systems,Inc ML20217J0661998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Dqe, Inc & Allegheny Power System,Inc ML20198P9311997-11-0707 November 1997 Comments of American Municipal Power-Ohio,Inc.NRC Should Require Allegheny Power Sys,Inc to Affirm That Capco Antitrust License Conditions Will Be Followed ML20134L3401997-01-22022 January 1997 Resolution 96-R-85, Resolution Supporting Merger of Centerior Energy Corp & Ohio Edison Under New Holding Co Called Firstenergy ML20133B6941996-12-18018 December 1996 Submits Ordinance 850-96 Re Approval of Merger of Centerior & Oh Edison Into Firstenergy ML20135F4731996-12-0606 December 1996 Memorandum & Order CLI-96-13.* Commission Reverses & Vacates ASLB LBP-95-17 Which Granted Motion for Summary Disposition Submitted by Ocre & Hiatt.W/Certificate of Svc.Served on 961206 ML20132A8461996-12-0202 December 1996 Resolution 20-1996 Supporting Merger of Ohio Edison & Centerior Corp Under New Holding Company Called Firstenergy ML20134M6191996-10-28028 October 1996 Proclamation of Support by City of Sandusky,Oh Re Merger of Ohio Edison and Centerior Energy Corp ML20112J8281996-06-18018 June 1996 Licensee Reply Brief on Review of Licensing Board Decision LBP-95-17.* W/Certificate of Svc ML20112D8721996-05-29029 May 1996 Intervenor Brief in Support of Commission Affirmation of LBP-95-17.* Commission Should Affirm Licensing Board Decision.W/Certificate of Svc ML20108D9571996-05-0303 May 1996 CEI Response to City of Cleveland 2.206 Petition.Nrc Should Deny Petition ML20108B7571996-04-26026 April 1996 Licensee Brief on Review of Licensing Board Decision LBP-95-17.* Recommends That Commission Reverse Board Memorandum & Order Issued 951004.W/Certificate of Svc & Svc List PY-CEI-NRR-2034, Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matl1996-03-11011 March 1996 Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matl ML20101B5841996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement Or,In Alternative,For Severance of Issue & Expedited Hearing Procedures.W/Certificate of Svc ML20097B8721996-01-23023 January 1996 Petition of City of Cleveland,Oh for Expedited Issuance of Nov,Enforcement of License Conditions & Imposition of Appropriate Fines,Per 10CFR2.201,2.202,2.205 & 2.206 ML20097B8911996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement or in Alternative,For Severance of Issue & Expedited Hearing Procedures ML20096E2471996-01-0303 January 1996 Comment on PRM 50-64 Re Stockpiling Ki for Use as Thyroid Protectant in Event of Nuclear Accident.Supports Distribution of Ki to Public ML20094N1951995-11-17017 November 1995 Oh Edison Application for License Transfer in Connection W/ Sale & Related Transactions ML20094M5941995-11-15015 November 1995 Intervenors Answer to Licensees Petition for Review.* Intervenor Conclude That Commission Should Not Review Board Decision.W/Certificate of Svc ML20094J9141995-11-0707 November 1995 Petition for Review.* Submits That Commission Review of Board Decision Appropriate Under 10CFR2.786. W/Certificate of Svc & Svc List ML20093N9491995-10-23023 October 1995 Licensee Request for Extension of Time to File Petition for Review.* Requests That Commission Grant Extension Until 951107 of Deadline for Filing Petition for Review. W/Certificate of Svc ML20065L3571994-04-0505 April 1994 Intervenors Answer to NRC Staff Response to Intervenors Motion for Summary Disposition & Licensees Cross Motion for Summary Disposition.* Urges Board to Deny Licensee Cross Motion.W/Certificate of Svc ML20064N6341994-03-21021 March 1994 Affidavit of RW Schrauder in Support of Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition.W/Certificate of Svc ML20064N6081994-03-21021 March 1994 Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition.* Moves for Decision in Licensee Favor on Ocre Contention ML20064N9201994-03-21021 March 1994 Affidavit of RW Schrauder in Support of Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition. W/Svc List ML20063L4621994-02-0707 February 1994 Motion for Summary Disposition.* Intervenors Request That Board Grant Summary Disposition Favorably & Issue Declaratory Relief by Finding Challenged Portion of Amend 45 to Be in Violation of Aea.W/Certificate of Svc ML20058P4451993-12-13013 December 1993 Licensee Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Supplemental Petition for Leave to Intervene.* W/Certificate of Svc ML20059L9391993-11-12012 November 1993 Petitioners Supplemental Petition for Leave to Intervene.* Court Held That NRC May Not Eliminate Public Participation on Matl Issue in Interest of Making Process More Efficient. W/Certificate of Svc ML20059B1421993-10-19019 October 1993 Order.* Petitioners Shall File Supplemental Petition in Accordance W/Schedule in 931018 Order.W/Certificate of Svc. Served on 931020 ML20059B1761993-10-18018 October 1993 Order.* Informs That for Each Contention,Petitioners Shall Comply Fully W/Requirements of 10CFR2.714(b)(2)(i),(ii) & (III) & Their Filing Should Address Requirements Set Forth in Regulations.W/Certificate of Svc.Served on 931019 ML20059B0701993-10-12012 October 1993 Motion to Defer Consideration of Remanded Issue.* Requests That Licensing Board Defer Consideration of Remanded Issue Pending Outcome of Commission Review of 2.206 Process.W/ Certificate of Svc ML20058M8761993-09-30030 September 1993 Memorandum & Order CLI-93-21.* Appeal for Hearing Re Amend to Plant OL Denied.W/Certificate of Svc.Served on 930930 ML20057C0461993-09-21021 September 1993 Supplemental Director'S Decision DD-93-15 Involving 920929 Request for Certain Actions to Be Taken Re Proposed Construction of Interim onsite,low-level Radioactive Waste Facility at Plant.Request Denied ML20056C8951993-07-19019 July 1993 Order Extending Time within Which Commission May Rule on Petitions for Review of LBP-92-32.W/Certificate of Svc. Served on 930720 ML20045B5661993-06-0707 June 1993 Comment Re Proposed Generic Communication on Mod of TS Administrative Control Requirements for Emergency & Security Plans,As Published in Fr on 930401 (58FR17293).Believes Concept of Technical Review Not Addressed by STS ML20044E2781993-05-13013 May 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re VEPCO Petition to Change Frequency of Emergency Planning Exercise from Annual to Biennial ML20127A6171993-01-0606 January 1993 Order.* Time within Which Commission May Rule on Petitions for Review of Board Order LBP-92-32,dtd 921118,extended Until 930208.W/Certificate of Svc.Served on 930106 ML20126D5171992-12-23023 December 1992 City of Brook Park Answer to Petitions for Review.* Opposes Applicants 921208 Petitions for Review Based on Fact That ASLB Decision in proceeding,LBP-92-32,adequately Addressed Issues Raised in Petitions.W/Certificate of Svc ML20126F6501992-12-23023 December 1992 Answer of City of Cleveland,Oh,Intervenor,In Opposition to Petitions for Review of 921118 Decision of Aslb.* Petitioners Petitions for Review Should Be Denied. Certificate of Svc Encl ML20126D5461992-12-23023 December 1992 Answer of Cleveland Electric Illuminating Co & Toledo Edison Co to Limited Petition for Review of City of Cleveland,Oh of 921118 Decision of Aslb.* Commission Should Deny City of Cleveland Petition.W/Certificate of Svc ML20126D5781992-12-23023 December 1992 Answer of American Municipal Power-OH,Inc in Opposition to Petitions for Review of Oh Edison Co & Cleveland Electric Illuminating Co/Toledo Edison Co.* W/Certificate of Svc ML20126D5801992-12-23023 December 1992 NRC Staff Answer in Response to Petitions for Review Filed by Oh Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & City of Cleveland.* W/Certificate of Svc 1999-09-30
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h UNITED STATES OP AMERICA NUCLEAR REGULATORY COMMISSION DOCKETED l USNRC
, Before the Atomic Safety and Licensing Board r
/[; In the Matter of ) % JN -6 P2 :48 L )
Tile CLEVELAND ELECTRIC ILLUMINATING ) ,-f g ,c: 3 y 3 gg y
/ COMPANY, CT AL. ) Docket No. 50-449aOLA,c .Lovn
) N:t@!
(Perry Nuclear Power Plant, Unit. 1) )
)
_.)
OCRE RESPONSE TO LICENSEE AND NRC STAPP ANSWERS TO OCRE'S CONTENTION The Atomic Safety and Licensing Board in its Memorandum and Order (Scheduling Responses to OCRE's Contention) of May 1, 1990 ordered the Licensee and the NRC Staff to respond to the contention which OCHE filed on April 23, 1990. The Board also permitted petitioner Ohio Citizens for Responsible Energy, Inc. s
("OCRE") to reply to these responses no later than June 1.
The Licensees decided not to obey the Board's Order, preferring--instead to reference their argument, that OCRE lacks standing, raised in their March 23 Answer. " Licensees are not at this time setting forth their substantive response to OCRE's proposed contention. Such response would be premature."
Licensees' Answer to OCRE's Contention at 2.
Ilowever, Licensees do concede that OCRE's contention
" meets the requirements of 10 CPR 2.714 (b) (2) , and, as indicated by OCRE, raises a purely legal issue." Id. Thus, Licensees agree that OCRE has submitted an admissible contention, should the Board find that OCRE has the requisite 1
9006110653 900601 DR ADOCKODOOgO f3 e
}0435 I UNITED STATES OP AMERICA NUCLEAR REGULATORY COMMISSION DOCKETED USNRC Before the Atomic Safety and Licensing Board In the Matter of ) 30 JJ -6 P2 :48
)
Tile CLEVELAND ELECTRIC ILLUMINATING ) .rtirrPF F SOA0Y COMPANY, ET AL. ) Docket No. 50-4 4 Q A OljAC - . LINK L
) H:I tOi (Perry Nuclear Power Plant, Unit 1) )
)
)
OCRE RESPONSE TO LICENSEE AND NRC STAPP A.1SWERS TO OCRE'S CONTENTION The Atomic Safety and Licensing Board in its Memorandum and Order (Scheduling Responses to OCRE's Contention) of May 1, 1990 ordered the Licensee and the NRC Staff to respond to the contention which OCRE filed on April 23, 1990. The Board also permitted petitioner Ohio Citizens for Responsible Energy, Inc. s
("OCRE") to reply to these responses no later than June 1.
The Licensees decided not to obey the Board's Order, preferring instead to reference their argument, that OCRE lacks standing, raised in their March 23 Answer. " Licensees are not at this time setting forth their substantive response to OCRE's proposed contention. Such response would be premature."
Licensees' Answer to OCRE's Contention at 2.
Ilowever, Licensees do concede that OCRE's contention
" meets the requirements of 10 CPR 2. 714 (b) (2) , and, as indicated by OCRE, raises a purely legal issue." Id. Thus, Licensees agree that OCRE has submitted an admissible contention, should the Board find that OCRE has the requisite 1
9006110053 900601 peO3 j
DR ADOCK0500ggo
1 standing to participate in this proceeding.
The NRC Staff, on the other hand, makes the bizarre assertions that "OCRE has not raised an issue of fact or law concerning the instant amendment request" (NRC Staf f Response at.4), "no effort is made by OCRE to comply with 10 CPR
- 2. 714 (b) ( 2) " (Id. at footnote 3), and " simply put, OCRE has not set forth, as required by 10 CPR 2.714, a contention related to the current, proposed license amendment" (Staff Response at 8).
The NRC Utaff also exceeds the bounds of the Board's May 1 Order by.not just responding to OCRE's contention, but also by responding to the arguments made by OCRE in its April 23 filing regarding the standing question. The Board's May 1 Order very clearly states that Licensees and the Staff were to respond to OCRE's contention, not to the standing arguments.
The-Staff has taken two cracke at bat when one would suffice.
OCRE regards the portion of the Staff's Reponse addressing the standing issue to be an unauthorized filing, and does not respond to it herein. In any event, it is OCRE's opinion that nothing in the Staff's Response undermines OCRE's standing arguments raised in its April 23 pleading.
In' support of its absurd conclusions regarding the admissibility of OCRE's contention (made all the more unreasonable by the finding of Licensees, the requester of the license amendment at issue here, that the contention is admissible), the Staff attempts to distinguish the cases cited
-by OCRE in support of its legal argument. NRC Staff Response 2
I at 4-5. Regardless of the specific factual backgrounds ot these cases, the fact remains that the D.C. Circuit Court of Appeals in sholly v. NRC, 651 P.2d 780 (1980), vacated on other grounds, 435 U.S. 1194 (1983), clearly found that an order which " granted the licensee authority to do something that it otherwise could not have done under the existing license authority" was a license amendment under Section 189a of the Atomic Energy Act. 651 P.2d at 791. I.e., it matters not what the NRC calls a particular action; it is its effect that determines whether it is an amendment triggering the notice and hearing provisions of the Act. This reasoning was followed by the First Circuit in Commonwealth of Massachusetts v. NRC, 878 P.2d 1516, 1521 (1st Cir. 1989). The Staff states that Sholly does not apply'to this proceeding, since OCRE was afforded an opportunity for hearing. Ilowever, this ignores the fact that the outcome of this proceeding will determine whetner OCRE will retain the right to a hearing under the Atomic Energy Act for future changes to core operating limits. Sholly provides the legal precedent upon which OCRE's contention is based. If the instant amendment is granted, changes to core operating limits will constituto de facto license amendments under Sholly, but there will be no notice and opportunity for hearing, in violation of the Atomic Energy Act. But this is the proceeding which will either permit or enjoin this situation. Sholly is absolutely relevant to this proceeding.
Similarly, OCRE's citation of Union of Concerned Scientists v. NRC, 735 P.2d 1437 (D.C. Cir. 1984), served to 3
establish that public hearing rights are unequivocally within the zone of interests of the Atomic Energy Act. The Staff apparently believes that only contentions raising safety issues can be litigated in license amendment proceedings. NRC Stafi Response at 3, 10. UCS clearly shows that public hearing rights, in addition to health and saf ety inatters, are within the zone of interests established by Congress in the Act. In addition, any doubt as to whether issues of law are admicsible in NRC proceedings should have been dispelled by the NRC's new rules of practico. In promulgating 10 CPR 2.714 (e) , the NRC stated:
The intent of the proposed rule in 2.714 (d) (2) (iv) was that purely legal content $ons, which occur rarely, may be admitted as issues in the proceeding, llowever, they will not be part of an evidentiary hearing, but rather, will be handled on the basis of briefs and oral argument. A new ,
paragraph (c) has been added to 2.714 to clarify this intention. 54 Ped. Reg. 33160, 33172 (August 11, 1989),
" Rules of Practice for Domestic Licensing Proceedings -
procedural Changes in the llearing Process."
The Staff cites Portland General Electric Company (Trojan Nuclear Plant) , ALAB-531, 9 NRC 263 (1979) for the proposition that the Commission's regulations (10 CPR 50.36) do not require that every operational detail be in;:1uded in the technical specifications. Staff Response at 5. Ilowever, in Trojan the intervenor urged the inclusion of additional operational details for the spent fuel pool in the plant technical specifications. Trojan did not address the removal of items from the technical specifications. Nor did Trojan address publiq hearing rights under Section 189a of the Atomic Energy Act. Since public hearing rights under the Act are the crux of
, 4
l 1 . .
OCRE's contention, nothing in Tro$an can render OCRE's l
contention invalid.
The Staff also cites the Commission's policy statement on
" Technical, Specification Improvement Program," S2 Ped. Reg.
3788 (February 6, 1987) (Staf f Response at 7), and attaches a copy of Generic Letter 88-16, " Removal of Cycle-specific Parameter Limits from Technical Specifications" as support for the requested amendment. However, neither a policy statement nor a Generic Letter can superceda a statute.
Finally, the Staff argues that 10 CPR 50.59 will somehow safeguard OCRE's rights in that the Licensees' self-evaluation under that section would result in a license amendment proceeding if it determines that a change in the core operating limits entails an unreviewed safety question. URC Staff ,
Response at 6-7. This is not equivalent to hearing rights under Section 189a. Presently, an operating license amendment proceeding is required for any changes to the core operating limits, not just those changes which the Licensees think are significant.
In conclusion, the HRC Staff has failed to raise any valid arguments which would preclude the admission of OCRE's
, contention. And, since the Licensees concede that OCRE's contention has met the requirements of 10 CPR 2.714 (b) (2) ,
OCRE's contention should be admitted.
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*- c CERTIP3CATE OP S1;RVICE I certifycthat S copies first of the foregoing class, postage were servedby:dieSpit prepaid, this j ;-
in the'U;J.
day of Mail, vME , 1990 to the following:
% JLN -6 P 2 :48 Secretary (of:the Commission ATTN -Docketing and Service Branch U.S. Nuclear' Regulatory Commission F I G Di SiCHfitJY v0CKl itNG 8. ',i irviti Washington, DC- 2055S itk ANL H ,
Administrative Judge Administrative Junge John H. Frye, Ill, Chatraan Jerry R. Kline Atomic Safety snd Licensing Boarc Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washincton DC 20555 Washington, DC 20555 Administrative Judge Colleen Woodneaa Escuire Frederick ~J. Shon Office of the General Counsel Ator.tc Safety and Licensing Boarc U.S. Nuclear Regulatory Commission '
U.S. Nuclear Regulatory Comenssion Washington DC 20555 Washington, DC 20555 Jay E. 911 berg- '
Shan,'Pittaeni.Potte & Trowbridge 2300-(StreetcN.W. s Washin4:tonjDC.'20037 l ,[b 3" , ,
}y ' ' ' i l
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u-Susan L.'lliatt
~
OCRE Representative f-f v}}