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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072B8521994-08-0505 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission ML20065P4121994-04-25025 April 1994 Comment on Proposed Rule 10CFR50 Rule Re Code & Stds Re Subsections IWE & Iwl.Expresses Deep Concern About Ramifications of Implementing Proposed Rule ML20058G6211993-12-0606 December 1993 Comment on Draft NUREG/BR-0058, Regulatory Analysis Guidelines,Rev 2. Concurs W/Numarc & Nubarg Comments ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 ML20058B6891993-05-0707 May 1993 Affidavit of RP Barkhurst to File W/Nrc Encl TS Change Request NPF-38-135 ML20058E0251990-10-12012 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20055E9871990-06-29029 June 1990 Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity ML19353B2241989-12-0101 December 1989 Comments on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. Util Endorses NUMARC Comments W3P89-0196, Comment Opposing Proposed Rule 10CFR50 Re Maint Programs at Nuclear Plants.Proposed Rule Would Require Establishment of Maint Programs Based on Reg Guides That Have Not Been Developed,Proposed or Approved1989-02-28028 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint Programs at Nuclear Plants.Proposed Rule Would Require Establishment of Maint Programs Based on Reg Guides That Have Not Been Developed,Proposed or Approved ML20235V4571989-02-27027 February 1989 Comment Supporting Proposed Chapter 1 Re Policy Statement on Exemption from Regulatory Control.Agrees W/Recommendations & Limits Proposed by Health Physics Society in L Taylor Ltr to Commission ML20205P9691988-10-26026 October 1988 Comment Supporting Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear License Renewal. Supports Contents of NUREG-1317 & Endorses NUMARC Comments on Rulemaking & Position Paper by NUMARC Nuplex Working Group W3P88-1366, Comment Supporting Proposed Rule 10CFR50 Conserning Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants or Utilization Facilities1988-07-13013 July 1988 Comment Supporting Proposed Rule 10CFR50 Conserning Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants or Utilization Facilities ML20135F0931987-04-0909 April 1987 Testimony of Bb Hayes Before Senate Government Governmental Affairs Committee on 870326 Re Discovery of Sensitive NRC Document in Files of Senior Official of Louisiana Power & Light Co ML20212N5781986-08-27027 August 1986 Order Imposing Civil Monetary Penalty in Amount of $50,000 Based on Violations Noted in Insp Conducted on 860101-31. Violation Noted:Plant Entered Mode 3 While Relying on Action Requirements of Tech Spec 3.6.2.1 ML20202G3811986-04-10010 April 1986 Order Imposing Civil Penalties in Amount of $130,000,based on Safety Insps of Licensee Activities Under CPPR-103 Conducted from June 1983 - Sept 1985.Supporting Documentation Encl ML20210B9141986-02-0505 February 1986 Notice of Publication of Encl 841219 Order.Served on 860206 ML20198H4461986-01-30030 January 1986 Memorandum & Order CLI-86-01 Denying Remaining Portion of Joint Intervenors 841108 Fifth & Final Motion to Reopen Record Re Character & Competence of Util Per 850711 Decision ALAB-812.Dissenting View of Palladino Encl.Served on 860130 ML20137J3531986-01-17017 January 1986 Order Extending Time Until 860214 for Commission to Act to Review ALAB-812.Served on 860117 ML20138P5301985-12-20020 December 1985 Order Extending Time Until 860117 for Commission to Review ALAB-812.Served on 851220 ML20137U4821985-12-0505 December 1985 Order Extending Time Until 851220 for Commission to Act to Review ALAB-812.Served on 851205 ML20138S0051985-11-15015 November 1985 Order Extending Time Until 851206 for Commission to Review ALAB-812.Served on 851115 ML20138H2451985-10-24024 October 1985 Order Extending Time Until 851115 for Commission to Act to Review ALAB-812.Served on 851024 ML20133F2711985-10-0404 October 1985 Order Extending Time Until 851025 for Commission to Act to Review ALAB-812 .Served on 851007 ML20134L5981985-08-28028 August 1985 Notice of Appearance of R Guild & Withdrawal of Appearance by L Bernabei & G Shohet for Joint Intervenors.Certificate of Svc Encl ML20137J2801985-08-26026 August 1985 Answer in Opposition to Joint Intervenors 850809 Petition for Commission Review of Aslab 850711 Decision ALAB-812, Which Denied Joint Intervenors 841108 Motion to Reopen Record.Kw Cook 850821 Affidavit Encl ML20137J2941985-08-21021 August 1985 Affidavit of Kw Cook Re Recent Equipment Failures Discussed in Joint Intervenors 850809 Petition for Review.Certificate of Svc Encl ML20136J1961985-08-19019 August 1985 Answer Requesting That Commission Deny Joint Intervenors 850809 Petition for Review of ALAB-812 Denying Motion to Reopen QA & Character Competence Issues.Certificate of Svc Encl ML20133L8901985-08-0909 August 1985 Petition for Review of ALAB-812,denying Joint Intervenor Motion to Reopen Record of OL Hearing to Litigate Util Lack of Character & Inability to Assure Safe Operation in Light of Const QA Breakdown.Certificate of Svc Encl ML20133L0421985-08-0808 August 1985 Order Extending Time Until 850920 for Commission to Act to Review ALAB-812.Served on 850808 ML20128Q1861985-07-23023 July 1985 Request for Extension of Time Until 850809 to File Appeal to 850711 ALAB-812 Denying Joint Intervenors Motion to Reopen Record.Certificate of Svc Encl ML20209F1921985-07-11011 July 1985 Decision ALAB-812 Denying Joint Intervenors 841108 Motion to Reopen Record on Const QA & Mgt Character & Competence, Except Insofar as Issues Re Matters Under Investigation by Ofc of Investigation Are Raised.Served on 850711 ML20116P1931985-05-0606 May 1985 Response to NRC & Util Responses to Aslab 850322 Memorandum & Order ALAB-801.Motion to Reopen Record of Licensing Proceedings for Litigation of Util Competence Should Be Granted.Supporting Documentation & Svc List Encl ML20116H3341985-04-30030 April 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20100K3221985-04-10010 April 1985 Supplementary Comments Attesting to Validity of Statements of Fact in Sser 9 & Clarifying & Explaining Current Position on Resolution of Allegation A-48.Util Can Safely Operate & Manage Facility.Certificate of Svc Encl ML20111C7021985-03-14014 March 1985 Affidavit of RP Barkhurst Re Power Ascension Testing Program to Be Performed at Levels Above 5% of Rated Power.Facility & Operating Staff in Excellent State of Readiness to Proceed W/Power Ascension ML20112A9381985-03-14014 March 1985 Affidavit of RP Barkhurst Re Power Ascension Testing Program Performed at Levels Above 5% Rated Power & Delay in Issuance of Full Power Operating Authority.Related Correspondence ML20111B6541985-03-12012 March 1985 Motion for Leave to File Reply to Applicant Answer to Joint Intervenors Motion for Leave to File Supplemental Memorandum & Applicant Response to Supplemental Memorandum.Svc List Encl ML20102C1351985-02-28028 February 1985 Response Opposing Joint Intervenors 850225 Motion for Leave to File Supplemental Memorandum & Response to Suppl.Suppl Untimely Filed.Allegations Unsupported.Certificate of Svc Encl ML20195F5871985-02-25025 February 1985 Affidavit of Rk Kerr Re 841120 Meeting W/Cain,Dd Driskill, R Barkhurst,Admiral Williams & Rs Leddick to Discuss Licensee 1983 Drug Investigation 05-001-83(966) & 841206 Meeting Between Licensee & NRC in Arlington,Tx ML20107M7461985-02-25025 February 1985 Supplemental Memorandum in Support of Joint Intervenors Motion to Reopen.Determination by Aslab That Joint Intervenors Met Burden to Reopen Record for Litigation of Contention That Util Mgt Lacks Competence Requested ML20107M7321985-02-25025 February 1985 Motion for Leave to File Supplemental Memorandum in Support of Motions to Reopen.Request Based on Recent Public Repts Re Instability & Lack of Independence of Mgt of Applicant & Lack of Respect for NRC ML20101T3701985-02-0101 February 1985 Answer Opposing Joint Intervenors 850125 Motion for Leave to File Reply to Applicant 841130 & Staff 841221 Answers.Motion Should Be Denied & Reply Brief Rejected.Certificate of Svc Encl ML20101U3411985-01-25025 January 1985 Joint Intervenors Motion for Leave to File Reply to Applicant & NRC 841221 Responses to Joint Intervenors 841108 Motion to Reopen Three QA & Mgt Integrity Contentions for Litigation ML20101U3511985-01-25025 January 1985 Joint Intervenors Reply to Applicant & NRC 841221 Responses to Joint Intervenors 841108 Motion to Reopen Three QA & Mgt Integrity Contentions for Litigation.Certificate of Svc Encl 1996-08-07
[Table view] Category:PLEADINGS
MONTHYEARML20137J2801985-08-26026 August 1985 Answer in Opposition to Joint Intervenors 850809 Petition for Commission Review of Aslab 850711 Decision ALAB-812, Which Denied Joint Intervenors 841108 Motion to Reopen Record.Kw Cook 850821 Affidavit Encl ML20136J1961985-08-19019 August 1985 Answer Requesting That Commission Deny Joint Intervenors 850809 Petition for Review of ALAB-812 Denying Motion to Reopen QA & Character Competence Issues.Certificate of Svc Encl ML20133L8901985-08-0909 August 1985 Petition for Review of ALAB-812,denying Joint Intervenor Motion to Reopen Record of OL Hearing to Litigate Util Lack of Character & Inability to Assure Safe Operation in Light of Const QA Breakdown.Certificate of Svc Encl ML20128Q1861985-07-23023 July 1985 Request for Extension of Time Until 850809 to File Appeal to 850711 ALAB-812 Denying Joint Intervenors Motion to Reopen Record.Certificate of Svc Encl ML20116P1931985-05-0606 May 1985 Response to NRC & Util Responses to Aslab 850322 Memorandum & Order ALAB-801.Motion to Reopen Record of Licensing Proceedings for Litigation of Util Competence Should Be Granted.Supporting Documentation & Svc List Encl ML20111B6541985-03-12012 March 1985 Motion for Leave to File Reply to Applicant Answer to Joint Intervenors Motion for Leave to File Supplemental Memorandum & Applicant Response to Supplemental Memorandum.Svc List Encl ML20102C1351985-02-28028 February 1985 Response Opposing Joint Intervenors 850225 Motion for Leave to File Supplemental Memorandum & Response to Suppl.Suppl Untimely Filed.Allegations Unsupported.Certificate of Svc Encl ML20107M7461985-02-25025 February 1985 Supplemental Memorandum in Support of Joint Intervenors Motion to Reopen.Determination by Aslab That Joint Intervenors Met Burden to Reopen Record for Litigation of Contention That Util Mgt Lacks Competence Requested ML20107M7321985-02-25025 February 1985 Motion for Leave to File Supplemental Memorandum in Support of Motions to Reopen.Request Based on Recent Public Repts Re Instability & Lack of Independence of Mgt of Applicant & Lack of Respect for NRC ML20101T3701985-02-0101 February 1985 Answer Opposing Joint Intervenors 850125 Motion for Leave to File Reply to Applicant 841130 & Staff 841221 Answers.Motion Should Be Denied & Reply Brief Rejected.Certificate of Svc Encl ML20101U3411985-01-25025 January 1985 Joint Intervenors Motion for Leave to File Reply to Applicant & NRC 841221 Responses to Joint Intervenors 841108 Motion to Reopen Three QA & Mgt Integrity Contentions for Litigation ML20101U3511985-01-25025 January 1985 Joint Intervenors Reply to Applicant & NRC 841221 Responses to Joint Intervenors 841108 Motion to Reopen Three QA & Mgt Integrity Contentions for Litigation.Certificate of Svc Encl ML20112C0071985-01-0808 January 1985 Applicant Answer to NRC Staff Motion for Clarification &/Or Reconsideration Re Concrete Basemat & Qa.Qa Motion Lacks Presentation of Matters.Decision on QA Motion Should Be Reconsidered.Certificate of Svc Encl ML20100B0251984-11-30030 November 1984 Response to Joint Intervenors Protective Order to Shield Identity of Several Individuals Having Executed Affidavits in Support of Concurrent Motion to Reopen Record.Motion Must Be Denied ML20100B0481984-11-30030 November 1984 Response to Joint Intervenors 841108 Motion to Reopen Record & Admit Contentions Alleging QA Failures,Applicant Lack of Character & Competence to Operate Plant & Inadequate Review. Certificate of Svc Encl ML20099D2861984-11-16016 November 1984 Motion for Extension of Time to 841130 for Filing Answers to Joint Intervenors 841108 Motions Due to Vol of Matl & Thanksgiving Holiday.Certificate of Svc Encl ML20107K6651984-11-0606 November 1984 Motion for Protective Order to Shield Identity of Individuals Who Signed Affidavits Providing Portion of Basis for Joint Intervenors 841107 Motion to Reopen Record on QA Breakdown at Plant ML20092B6371984-06-15015 June 1984 Response to NRC Motion for Addl Extension of Time Until 840706 to Respond to Joint Intervenors Amended & Supplemental Motion to Reopen Contention 22.No Objection Offered.Certificate of Svc Encl ML20084P7961984-05-17017 May 1984 Response to NRC 840515 Motion for Further Extension of Time Until 840615 to Respond to Joint Intervenors Amended & Supplemental Motion to Reopen Contention 22.Motion Should Be Granted.Certificate of Svc Encl ML20087P8541984-04-0606 April 1984 Answer Opposing Joint Intervenors Motion for Extension of Time.Intervenors Have Had Two Chances to Present Adequate Motion to Open Record on QA Allegations.Certificate of Svc Encl ML20087N0871984-03-28028 March 1984 Motion for Extension of 6 Months to File Motion.Certificate of Svc Encl ML20080R9611984-02-20020 February 1984 Motion to Open QA Contention,Based in Part on Encl Article Re Doctored Records.Certificate of Svc Encl ML20079F3241984-01-13013 January 1984 Answer Opposing Joint Intervenors 831212 Amended & Supplemental Motion to Reopen Contention 22 & Request for Public Hearing.Certificate of Svc Encl ML20083D9361983-12-22022 December 1983 Motion for Extension of Time Until 840113 to File Answer to Joint Intervenors 831212 Motion to Reopen Record to Consider Contention 22.Extension Needed Due to Holidays.Certificate of Svc Encl ML20082T9991983-12-12012 December 1983 Amended & Supplemental Motion to Reopen Contention 22 in Light of Newly Discovered Evidence.News Article & Certificate of Svc Encl ML20080R1851983-10-12012 October 1983 Response to NRC 831007 Motion for Further Extension to 831121 to File Response to Joint Intervenors Motion to Reopen Contention.Motion Not Opposed.Certificate of Svc Encl ML20076G8881983-08-29029 August 1983 Request for Extension to File Answer to Joint Intervenors Motion to Reopen Contention 22,to 10 Days After Util Receipt of Consultant Analysis Rept.Granted by Aslab on 830829 ML20024E2861983-08-0404 August 1983 Request for Extension Until 830909 to Allow Response to Joint Intervenor 830722 Motion to Reopen Record on Basis of Moisture Found on Foundation Mat Floor.Engineering Rept Due 830901.Certificate of Svc Encl ML20072N8331983-07-15015 July 1983 Motion to Associate Author as co-counsel W/L Fontana for Intervenors ML20072N8591983-07-15015 July 1983 Motion to Reopen Contention 22 in Light of Newly Discovered Evidence ML20072N8821983-07-15015 July 1983 Memorandum in Support of Motion to Reopen Contention 22 Re Available Info on Slab Cracks Initially Reported in 1977, Reappearing on 830511.New Hearing Requested to re-review Deficiencies in Plant Design ML20024A0661983-06-10010 June 1983 Exceptions to ASLB 830526 Partial Initial Decision. Certificate of Svc Encl ML20073Q4591983-04-26026 April 1983 Supports NRC 830415 Motion to Correct Hearing Transcript. Certificate of Svc Encl ML20069H4771983-03-29029 March 1983 Request for 1-wk Extension of Filing Date for Findings of Fact & Conclusions of Law on Evacuation Brochure.No Opposition Expressed to Granting Applicant Reasonable Extension ML20069G4041983-03-22022 March 1983 Response Opposing State of La 830311 Motion for Leave to File Amicus Curiae Brief on Issue of DHR Capability.Motion Untimely & No Good Cause Shown.Issue Abandoned by Parties Cannot Be Briefed.Certificate of Svc Encl ML20069E9681983-03-18018 March 1983 Request for Enlargement of 70-page Limit on Brief Opposing Joint Intervenors exceptions.Sixty-one Exceptions Cannot Be Addressed in 70 Pages.Certificate of Svc Encl ML20069C2691983-03-11011 March 1983 Motion to File Brief Amicus Curiae,Per 10CFR2.715,re Feed & Bleed Capability.Issue Must Be Presented to Aslab. Certificate of Svc Encl ML20083Q5371983-02-23023 February 1983 Request for Extension Until 830325 to File Brief in Opposition to Joint Intervenors Exceptions.Extension Necessary Because of Time Needed to Prepare for Three Other NRC Proceedings.Certificate of Svc Encl ML20070T1991983-02-0404 February 1983 Brief Supporting Joint Intervenors Exceptions Re Contentions 8/9 & 17/26 (1) & (2).Certificate of Svc Encl ML20070L4921982-12-27027 December 1982 Exceptions to 821103 Partial Initial Decision ML20079J3491982-12-24024 December 1982 Exception to ASLB 821103 Partial Initial Decision Re Condition 2.Certificate of Svc Encl ML20070H4121982-12-17017 December 1982 Motion for Reconsideration of ASLB 821213 Memorandum & Order.Due to Ill Health of E Duncan,30-day Extension Requested in Which to File Direct Testimony & Commence Hearings ML20067C5171982-12-0707 December 1982 Answer Opposing Joint Intervenors 821130 Motion to Extend Time for Filing Direct Testimony & to Reschedule Hearing on Emergency Brochure.Joint Intervenors Fail to Justify Untimeliness of Motion.Certificate of Svc Encl ML20069N3271982-11-29029 November 1982 Response Opposing Applicant 821112 Motion for Reconsideration & Clarification of Certain Rulings in ASLB 821103 Partial Initial Decision on Conditions for Evacuation & Ltrs of Agreement ML20028A3051982-11-17017 November 1982 Motion for Extension of Time Until 821129 to File Exceptions to ASLB 821103 Partial Initial Decision.Time Needed Due to Research Coordinator Giving Premature Birth & Having Minor Complications ML20066F0271982-11-12012 November 1982 Exceptions to ASLB 821103 Partial Initial Decision & Motion for Extension of Time to File Supporting Brief Until 30 Days After Svc of ASLB Ruling.Certificate of Svc Encl ML20066E9571982-11-12012 November 1982 Motion for Reconsideration or Clarification of Portion of ASLB 821103 Partial Initial Decision Dealing W/Conditions Re State & Local Offsite Emergency Plans & Scope of Contention 2 on Vehicles & Drivers.Certificate of Svc Encl ML20071N4061982-10-0606 October 1982 Erratum to Applicant 821004 Response to Joint Intervenors Motion to Reopen Record.Certificate of Svc Encl ML20071N4111982-10-0606 October 1982 Response Opposing Joint Intervenors 820929 Motion to Dismiss for Failure to Make Discovery & Objections to Request for Production of Documents.Discovery Requests Prohibited by Commission Rules ML20063N7481982-10-0404 October 1982 Response Opposing Joint Intervenors 820929 Motion to Reopen. Requests Not Founded in Fact or Law & Fly in Face of Any Sense of Administrative Discipline & Procedural Regularity. Some Requests Defy Logic.Certificate of Svc Encl 1985-08-09
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6/12/82 UNITED. STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
Louisiana Power &. Light Company )
Docket No. 50-382
)
(Wate'rford Steam Electric )
Station, Unit No.3)
)
JOINT INTERVENORS MOTION TO RECONSIDER ATOMIC SAFETY AND LICENSING DOARD ORDER OF SEPTEMBER 13,1979 AND RULING OF MAY 12,1982, TO REOPEN OPERATING LICENSE HEARINGS AND/OR IIOLD NEW OPERATING LICENSE HEARINGS Now into court comes Joint Intervenors, Save Our Wetlands and Oystershell Alliance, and upon suggesting the Atomic Safety and Licensing Board ( ASLB) that its ruling of September 13, 1979 excluding Joint Intervenors contentions 10,11,13, and 14 and that its ruling of May 12, 1982 overruling Joint Intervenors motions to keep the record open and to hold further hearings on nuclear wastes are erroneous and in violation of the Administrative Procedures Act, the National Environmental Protection Act, The Atomic Energy Act, and all acts amendatory thereof, for reasons including but not limited to all reasons set forth in Natural Resources Defense Council v.
United States Nuclear Regulatory Commission and United States of America; Baltimore. Gas and Electric et a1 [74-1586] and Consolidated Cases nos. 77-1448, 79-2110, and 79-2131, which decision is hereby incorporated herein as if copied and set forth herein in extenso, and were in violation of petitioners 5th Amendment rights to due 82061803pg
process and equal protection of the law.
Joint Intervenors move that said ASLB Order be rescinded and ASLB ruling be overturned, that the ASLB re-open the record of said hearings, and that hearings be held on such contentions in New Orleans, Louisiana.
The contentions stricken in the September 13, 1979 Order are as follows:
- 10. Applicant has failed to properly evaluate radiation emissions which will be created by spent fuel storage due to the underestimation of amounts of spent fuel which will be held in storage during the useful' life of the facility.
- 11. Applicant has failed to properly evaluate radiation emissions which will be created by spent fuel storage by underestimating the amounts of spent fuel which will be processed, handled, and stored based upon underestimation of the quantity of such products which will be stored on site at the facility.
- 13. Applicant has failed to appropriately evaluate the health, cafety, and environmental risks which result from storage at the Waterford 3 site for an extended and as yet undetermined length of time, of spent nuclear fuel materials because of the lack of an acceptable and technologically feasible and reasonable means for permanent and interim storage of high-level radioactive wastes and spent fuel materials; which thus renders Applicant's interim storage as de facto permanent storage.
- 14. Applicant has failed to properly evaluate the present inability to dispose of spent fuel assemblies, which will ultimately result in the necessity of increased expansion of spent fuel storage facilities at the Waterford 3 site.
Joint Intervenors upon further suggesting to the Board that in view of the monumental significance of the nuclear waste problem
[see NRDC v. USNRC and USA; Baltimore Gas and Electric et al--id.
page 1 (Edw rds, J. concurring) "This case (involving nuclear waste disposal) may prove to be one of the most important cases to be decided by the United Sta.tes courts this century'! ], Joint Intervenors move that the ASLB open evidentiary hearings on the following new contentions:
- 30. The Staff's Final Environmental Impact Statement for Waterford Steam Elecrric Station Unit 3 fails to satisfy the National Environ-
mental Protection Act and in particular section~ 102 (2) (C) of NEPA' and the requirements of 10 CFR 51 and other NRC regulations concerning the uncertainties and the environmental, health, and safety effects of the burial of high-level and transuranic wastes from Waterford 3.
- 31. The uncertainties in the cost / benefit analysis for WSES 3 in view of-the failure of the Staff and/or the Applicant to consider the integrity of permanent repositories of the high level and transuranic wastes, or whether or when such a repository will be developed for high level and transuranic wastes, are so large that the costs outweigh the benefits and the licensing of Waterford 3 is not in the public interest.
- 32. Applicant and/or Staff have failed to adefuatedly consider the uncer'tainties concerning the integrity of the permanent repository, if such a repository is ever built, for the high-level and transuranic wastes from Waterford 3.
- 33. Applicant and/or Staff has inadequately assessed the uncertainties over whether and when such a repository, or equivalent system of disposal, will be developed for the high-level and transuranic wastes from Waterford 3.
- 34. Applicant and/or Staff has failed to adequately assess the the health, socioeconomic and cumulative effects of the proposed plan for the disposal of high-level and transuranic wastes from Waterford 3.
- 35. Applicant and/or Staff has failed to adequately assess the health, socioeconomic and cumulative effects of the entire back end of the fuel cycle for Waterford 3.
- 36. Applicant and/or Staff has failed to adequately assess the' cumulative and/or synergistic effects of the back end of the fuel ,
cycle, including the disposal of high-level and transuranic wastes from Waterford 3.
Joint Intervenors aver that this petition is necessary to protect the health, safety, property and liberty of Joint Intervenors and that other means are not available to protect the interest of pet-itioner.
Joint Intervenors have participated in 3 years of the Intervention process and have succeeded in aiding this Board in developing a record for consideration and brought the testimony and publications of eminent scientists to the attention of the Board.
Joint Intervenors' participation will broaden the issues since neither Applicant nor Staf f has raised questions concerning numerous and huge uncertainties in the disposal of high-level and transuranic wastes.
Joint Intervenors motion is not advanced for dilatory purposes.
j Joint Intervenors' participation as a party in the hearings on all aforementioned contentions is necessary to conplete the record and
+
resolve issues which must be dealt with as a pre-condition to this Board making its recommendation and the NRC making its decision whether i to grant an operating license.
In the alternative only that the NRC finds that any of the aforementioned contentions is untimely, petitioners move that l the record be reopened and hearings held on such contentions pursuant to 10 CFR 2.714 (a) (i-v) and 10 CFR 2.714 (d) and all other pertinent regulations and laws of the United States for the aforementioned reasons and:
1 (a) The recentness of the NRDC v. USNRC and USA, et al. decision declaring NRC regulation on high-level and transuranic waste
! disposalinvalid and illegal.
l (b) the magnitude of the waste problem. [see NRDC v. USNRC et al.
(Edwards, J. concurring)].
(c) the magnitude of the risk to the public from high-level and transuranic wastes from Waterford 3 [see NRDC v. NRC et al. (Edwards, J. concurring)].
l (d) to restore public confidence in the integrity and fairness of I
the Nuclear Regulatory Commission's Licensing Process and to allay public concern that the NRC hearing process is not concerned with the health and safety of the people of Louisiana.
l Respectfully-y submitted,
'3( ,,( I Y l
. < ^ , ;,
' Garyj l. Groesch ~ /
l Acting Counsel for Joint Intervenors e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382
)
(Waterford Steam Electric )
Station, Unit 3) )
SERVICE LIST Sheldon J. Wolfe, Esquire Lyman L. Jones, Jr., Esquire Administrative Judge Post Office Box 9216 Chairman, Atomic Safety and Metairie, LA 70055 Licensing Board U.S. Nuclear Regulatory Luke B. Fontana, Esquire Commission 824 Esplanade Avenue Washington, D.C. 20555 New Orleans, LA 70116 Dr. Harry Foreman Atomic Safety and Licensing Administrative Judge Board Panel Director, Center for U.S. Nuclear Regulatory Population Studies Commission Box 395, Mayo Washington, D.C. 20555 University of Minnesota
. Minneapolis, MN 55455 Atomic Safety and Licensing Appeal Board Panel Dr. Walter H. Jordan U.S. Nuclear Regulatory Administrative Judge Commission 881 West Outer Drive Washington, D.C. 20555 Oak Ridge, TN 37830 Docketing & Service Section (3)
Sherwin E. Turk, Esquire (4) Office of the Secretary Office of the Executive U.S. Nuclear Regulatcry Legal Director Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555
.[-!{f'~'
U K !; P '~
June 14, 1982
'82 R17 tn :06 UNITED STATES OF AMERICA :'
~
NUCLEAR REGULATORY COMMISSION :
HEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
LOUISIANA POWER $ LIGHT ) Docket No. 50-382
! (Waterford. Steam Electric Station, )
Unit 3) )
i CERTIFICATE OF SERVICE I hereby certify that copies of the following document, JOINT INTERVENORS MOTION TO RECONSIDER ATOMIC SAFETY AND LICENSING BOARD ORDER OF SEPTEMBER 13, 1979 and RULING OF MAY 12, 1982, TO REOPIM OPERATING LICENSE HEARINGS AND/OR HOLD NEW OPERATING LICENSE HEAR--
l INGS, were served by deposit in the United States mail, first class, postage prepaid, this 15th day of June , to parties identified on the attached service list.
f p v' =
l
/:k ' 1, . - ,
Gary /L.'Groesch
~
i Dated: June 15, 1982 a