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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212G0521999-09-22022 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors ML20211A1671999-07-30030 July 1999 Comments Supporting Comment Transmitted by NEI , Transmittal of Industry Comments on Draft Reg Guide DG-1074, Steam Generator Tube Integrity ML20207D5301999-05-20020 May 1999 Comment Supporting Generic Environmental Impact Statement for License Renewal of Nuclear Plants,Calvert Cliffs Nuclear Power Plant (NUREG-1437,suppl 1) ML20207A4431999-05-19019 May 1999 Comment Supporting NUREG-1437,suppl 1,generic Environmental Impact Statement for Licensing Renewal of Nuclear Plants. Licensee Agrees with Approach Taken by NRC to Evaluate Environ Impacts of Extending Util Operating Licenses ML20207A4471999-05-19019 May 1999 Comment Supporting NUREG-1437,Suppl 1, Generic Environ Impact Statement for License Renewal of Nuclear Plants, Calvert Cliffs Nuclear Power Plant. State of MD Concurs with Staff Conclusion ML20207A9301999-05-18018 May 1999 Comment on NUREG-1437,suppl 1 Re Bge Application for License Renewal for Calvert Cliffs.Results of DOE Transportation Risk Assessments Appear to Be Consistent with NRC Conclusion in NUREG-1437 ML20207A4521999-05-0808 May 1999 Comment Supporting NRC Draft Environ Impact Statement for Bg&E Calvert Cliffs NPP License Renewal Application ML20206M0621999-05-0404 May 1999 Comment Opposing NUREG-1437, Generic Environmental Statement for License Renewal of Npps, Supplement 1, Calvert Cliffs NPP ML20206S9001999-04-27027 April 1999 Comment on Proposed Rule 10CFR51 Re Draft NUREG-1437,vol 1, Addendum 1, Generic EIS of License Renewal of Power Plant ML20206N2341999-04-27027 April 1999 Comment Supporting Draft NUREG-1437,Vol 1,Addendum 1, Generic Environ Impact Statement for License Renewal of Nuclear Plants;Main Rept,Section 6.3-Transportation;Table 9.1-Summary of Findings on NEPA Issues for Renewal of Npps ML20205Q4051999-04-12012 April 1999 Comment Opposing Renewal of Calverts Cliffs NPP License. Urges NRC Not to Renew Calvert Cliffs License & Shut Plant Down as Soon as Possible ML20205P9871999-04-12012 April 1999 Comment Opposing Draft Environmental Impact Statement (NUREG-1447,Suppl 1) for Calvert Cliffs License Renewal Application ML20205Q4001999-04-10010 April 1999 Comment Opposing Renewal of License for Calvert Cliffs Npp. Requests That Plant Be Shut Down ML20205Q3961999-04-0909 April 1999 Comment Opposing License Extension of Bge for Calvert Cliffs NPP to Operate Another Twenty Years ML20207A6521999-04-0606 April 1999 Transcript of 990406 Public Meeting in Solomons,Maryland Re Draft Environ Impact Statement for Calvert Cliffs NPP to Support Review of License Renewal Application (7:00 P.M. Session).Pp 1-83.Supporting Documentation Encl ML20207A6391999-04-0606 April 1999 Transcript of 990406 Public Meeting in Solomons,Maryland Re Draft Environ Impact Statement for Calvert Cliffs NPP to Support Review of License Renewal Application.Pp 1-164. Supporting Documentation Encl ML20205B2101999-03-18018 March 1999 Comment on Potential Impacts of Patuxent River Complex Flight Operations on Calvert Cliffs Nuclear Power Plant ML20207M4101999-03-0808 March 1999 Comments on Draft Suppl to Geis.Both GEIS & Suppl Using Obsolescent Views on Alternatives.Shelf Technology for Widley Used Fuel Cells Mfg by United Technologies Can Replace Grid Supplied Energy for Bldgs ML20207M4841999-03-0202 March 1999 Comments on NPP Draft Suppl to Generic Environ Impact statement,NUREG-1437,suppl 1 ML20207M3741999-02-25025 February 1999 Comment on NPP Draft Suppl 1 to Generic Environ Impact Statement.Informs That Ref to Abbe,1992 on Page 4-31 Should Read Population Structure of Eastern Oyster... Not Pollution Structure.. CLI-98-25, Erratum.* Advises That Citation to CLI-98-12 on Page 7 of CLI-98-25 (Issued on 981223),immediately Following First Indented Quotation,Should Read 48 NRC 18, Not 48 NRC 11998-12-30030 December 1998 Erratum.* Advises That Citation to CLI-98-12 on Page 7 of CLI-98-25 (Issued on 981223),immediately Following First Indented Quotation,Should Read 48 NRC 18, Not 48 NRC 1 ML20198E1721998-12-23023 December 1998 Memorandum & Order.* for Reasons Set Forth,As Well as Reasons Set Forth in LBP-98-26,National Whistleblower Ctr Appeal Denied & LBP-98-26 Affirmed.With Certificate of Svc. Served on 981223 ML20198J6951998-12-21021 December 1998 Comment Endorsing NEI Comments to Proposed Rule 10CFR50.59, Changes,Tests & Experiments. Offers Addl Comments on Areas That Continue to Remain Vague Even with Proposed Rule Language & NEI Comments ML20155H5371998-11-0505 November 1998 NRC Staff Brief in Opposition to Appeal of National Whistleblower Center.* for Reasons Set Forth,Licensing Board Decision in LBP-98-26 Should Be Affirmed. with Certificate of Svc ML20155F4751998-11-0505 November 1998 Baltimore Gas & Electric Co Brief in Opposition to Appeal of Natl Whistleblower Ctr.* Licensing Board 981016 Memorandum & Order Should Be Affirmed.Natl Whistleblower Refused to Comply with Deadline.With Certificate of Svc ML20155C8691998-10-26026 October 1998 Notice of Appeal.* Petitioner Natl Whistleblower Ctr Hereby Files Notice of Appeal to Commission for Review of ASLB 981016 Order Denying Petitioner Petition for Leave to Intervene & Request for Hearing.Supporting Brief Encl ML20155C8941998-10-26026 October 1998 Petitioner Brief in Support of Appeal of Order Denying Intervention Petition & Dismissing Proceeding.* Commission Must Vacate Decision of Board & Remand Case for Proceeding Re Disposition of Contentions.With Certificate of Svc ML20154P6361998-10-21021 October 1998 Petitioner National Whistleblower Center Request for Extension of Page Limitation.* National Whistleblower Requests Leave to File Brief of Approx 25 Pages in Length. with Certificate of Svc ML20154M8211998-10-16016 October 1998 Petitioner Second Revised Notice of Filing (Concerning Rais).* Center Should Not Be Required to Submit Final List of Contentions or Final Suppl/Amended Petition Until 100 Days After Bg&E Responses.With Certificate of Svc ML20154K8431998-10-16016 October 1998 Memorandum & Order (Denying Intervention Petition/Hearing Request & Dismissing Proceeding).* Intervention Petition Hearing Request of Petitioner Denied & Proceeding Terminated.With Certificate of Svc.Served on 981016 ML20154K8721998-10-13013 October 1998 Petitioner Notice of Filing.* Natl Whistleblower Ctr Files First Supplemental Set of Contentions in Matter of Bg&E.With Certificate of Svc ML20154H0801998-10-0909 October 1998 Bg&E Answer to Petitioner Notice of Filing.* National Whistleblower Ctr Notice of Filing Is Legally & Factually Infirm & Petition Should Be Dismissed.With Certificate of Svc ML20154H1371998-10-0909 October 1998 Bg&E Answer to Petitioner Motion Requesting to Be Informed of Communication Between NRC Staff & Applicant.* Natl Whistleblower Ctr Petition Should Be Dismissed for Failure to File Contentions.With Certificate of Svc ML20154H2371998-10-0909 October 1998 NRC Staff Response to Status Rept & Petitioners Motion to Be Informed of Communication Between NRC Staff & Applicant.* Petitioner Request for Hearing Should Be Denied & Proceeding Should Be Terminated.With Certificate of Svc ML20154H2321998-10-0909 October 1998 Bg&E Answer to Petitioner Motion to Vacate & Reschedule pre- Hearing Conference.* Natl Whistleblower Ctr Motion Should Be Denied & Intervention Petition Should Be Dismissed,For Listed Reasons.With Certificate of Svc ML20154H2091998-10-0909 October 1998 NRC Staff Answer in Opposition to Petitioners Motion to Vacate & re-schedule pre-hearing Conference.Motion Should Be Denied Due to Petitioner Failure to Establish Extreme Circumstances to Delay Proceeding.With Certificate of Svc ML20154F1751998-10-0808 October 1998 Order (Schedule for Responses to Petitioner Notice of Filing).* If Bg&E & NRC Wish to Address Matters in 981007 Notice,Action Should Be Taken as Part of Responsive Filings Due on 981009.With Certificate of Svc.Served on 981008 ML20154H0921998-10-0707 October 1998 Petitioner Notice of Filing.* Natl Whistleblower Ctr Should Not Be Required to Submit List of Contentions or Supplemental/Amended Petition Until at Least 100 Days After Bg&E Provides Responses to Rai.With Certificate of Svc ML20154B0081998-10-0202 October 1998 Order (Schedule for Responses to Petitioner Filings).* Orders That Bg&E & NRC Staff Shall Have Up to & Including 981009 within Which to Respond to Natl Whistleblower Ctr Submissions.With Certificate of Svc.Served on 981002 ML20154B2041998-10-0101 October 1998 Natl Whistleblower Ctr Reply to NRC Staff & Bg&E Answer to Natl Whistleblower Ctr Petition to Intervene & Request for Hearing.* Request for Dismissal of Petition to Intervene Should Be Denied for Listed Reasons ML20154B8701998-10-0101 October 1998 Petitioner Motion Requesting to Be Informed of Communication Between NRC Staff & Applicant.* Requests That NRC & Applicant Be Required to Put Petitioner & Board on Svc List & Give Notice of Communications Re Bg&E License Renewal ML20154B2161998-10-0101 October 1998 Second Affidavit of M Claro.* Affirms That Info Re Matter of Bg&E True & Correct ML20154B9391998-10-0101 October 1998 Status Rept.* Informs That Natl Whistleblower Ctr Reserves Right to File Contentions within 15 Days of Prehearing Conference in Matter of Bg&E ML20154B8521998-10-0101 October 1998 Petitioner Motion to Vacate & re-schedule pre-hearing Conference.* Requests That Motion to Vacate Be Granted & pre-hearing Conference Be Postponed Until No Sooner than 115 Days After 980828 RAI Response ML20153G3651998-09-29029 September 1998 Order (Revised Prehearing Conference Schedule).* Orders That ASLB Will Hold Prehearing Conference in Proceeding Re Issue of Standing Based on Info in Natl Whistleblower Ctr 980807 Petition.With Certificate of Svc.Served on 980929 ML20153E8211998-09-22022 September 1998 Comment Supporting Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Agrees with Staff Assessment in Secy 98-061 ML20153B2241998-09-21021 September 1998 Memorandum & Order (Scheduling Matters & Electronic Hearing Database).* Natl Whistleblower Ctr Motion to Delay Prehearing Conference Denied,But Petition Suppl Extension Request Granted.With Certificate of Svc.Served on 980921 ML20153B2661998-09-18018 September 1998 Petitioner Motion to Vacate Prehearing Conference or in Alternative for Extension of Time.* Postponement of Prehearing Conference Until After Close of Discovery Requested.With Certificate of Svc ML20151X9781998-09-17017 September 1998 Memorandum & Order.* for Reasons Stated,Commission Grants National Whistleblower Center Petition for Review & Gives Addl Time Until 980930,to File Contentions in Proceeding. with Certificate of Svc.Served on 980917 ML20151Z5531998-09-16016 September 1998 Bg&E Answer to Petitioners Filing in Response to Prehearing Order.* Natl Whistleblower Ctr Failed to Demonstrate Standing of at Least One Admissible Contention.Petition Should Be Dismissed.With Certificate of Svc 1999-09-22
[Table view] Category:PETITION FOR RULEMAKING
MONTHYEARML20059H7091993-06-23023 June 1993 Petition for Rulemaking PRM-72-1 to Suggest Amends to Listed Rules Under 10CFR Based on Accompanying Arguments 1993-06-23
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~ - . _. j3 (58FR ','72 2%) 's 'n': i' ,
Maryland Safe Energy Coalition. :ma f
P.O. Box 33111 JUN 3 01993 ._ ;
Baltimore, MD 21218 410-243-2077
. 3 N'
- ; i-W ,7, June 23 r-1993 The Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief, Docketing and Service Branch:
Robert M. Bernero of the Office of Nuclear Material Safety and Safeguards pointed out in a February 24, 1993 acknowledgement of our Petition of December 21, 1992, Docket No. 72-8 (50-317/318):
"to the extent that you are seeking to petition for rulemaking l regarding generic issues related to dry cask storage, you should l refer to 10 CFR 2.802 for the Commission's requirements for a proper petition for rulemaking." :
Accordingly, we hereby petition the NRC for rulemaking regarding ,
generic issues of dry cask storage. Pursuant to 10 CFR
- 2. 802 (c) (1) and (3), we wish to suggest amendments to the following rules under 10 CFR based on accompanying arguments:
72.22 (e) (2) add: "Specify the planned life of the ISFSI."
- If the storage of spent fuel is temporary, it follows that the planned life has a definite duration. Licensees should be required to state the length of time that each storage canister and/or cask will be used. In the absence of a stated lifetime, it should not be assumed the storage is temporary. Any storage which might become either permanent or indefinite would require additional regulations.
l 72.22 (e) (3) change from "after the removal of spent fuel and/or I
high-level radioactive waste" to "if the spent fuel and/or the high-level radioactive waste is removed".
The NRC should not assume that removal of nuclear waste including spent fuel from a reactor site is the safest policy. The lack of a national waste repository, MRS or the hazards of transporting high-level nuclear waste may make a prolonged or indefinite on-site storage the only option or the safest policy.
72.42 add: "(d) No license will be issued before 90 days after the final SER is published".
I hIlh80930623 72-1 pyg
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Requiring a reasonable period between the final SER and the issuing of a license will allow potential petitioners time to intervene based on issues in the final SER.
- 72. 44 (c) (3 ) (ii) add "(v) dry storage casks must be monitored continuously for radioactivity at the exit cooling vents".
Since the exit vents are the most likely location of radioactive venting, it is logical that monitors would be required at such locations.
72.46(d) add: "The time prescribed for a notice of opportunity for a hearing or petition for leave to intervene will extend from the notice of proposed action through 90 days after the final SER ;
is published". i I
If a notice of opportunity for a hearing or intervention is !
limited to a short period after the license application, i interested parties may be prevented from obtaining a hearing i based on the second or final SER. Information in the latter safety reports may impact on the advisability of issuing a i license. The public should have the right and opportunity to I comment on the final SAR and SER before a license is issued. l 72.72(a) add after first sentence: "The records must include the history and condition of all spent fuel assemblies including a description of any defective fuel, such as fuel that is cracked, swollen, blistered, pinholed or offgassing."
Defective fuel can cause problems for safe storage, therefor the history and condition of all spent fuel should be documented. ;
i 72.104(a) in place of "real" put: " maximally exposed" after " individual" add: "or fetus" change "25 mrem" to "5 mrem" change "75 mrem" to "15 mrem" change "25 mrem" to "5 mrcm" The sentence will then read: " ... dose equivalent to any maximally exposed individual or fetus who is located beyond the controlled area must not exceed 5 mrem to the whole body, 15 mrem to the thyroid and 5 mrem to any other organ..."
The radiation limit should be based on a the dose to a maximally exposed individual at the perimeter of the controlled area. The possibility of a pregnant person working and/or living at the perimeter should be a safety assumption for setting radiation limits. ;
Recent studies have shown that women, children and fetus are especially sensitive to radiation damage. The National Academy
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F 3
of Science's Committee on the Biological Effects of Ionizing Radiation cited a report in 1990 by Dr. Alice Stewart establishing "a direct correlation of childhood cancers and leukemias with background levels of gamma radiation from natural and man-made sources in England, Wales and Scotland. The cumulative outdoor doses due to this source during fetal life varied between only 10 and 40 millirads, with an average of 22 millirads. This study indicates that the standards set for exposure of adults to low-level radiation are too high for the developing fetus.
Pursuant to 10 CFR 2.802 (c) (2) , our grounds and interest in the above changes in regulations are as follows:
As an environmental consumer organization, the Maryland Safe Energy Coalition is interested in the minimization and safe stor ge of nuclear waste including spa.nt fuel at nuclear power j .r s in general and Calvert Cliffs Nuclear Power Plant in
- particular.
Even though the NRC license to Baltimore Gas & Electric Company (BG&E) is site-specific rather than generic, many of the generic regulations are the same or similar to the specific regulations for the Calvert Cliffs ISFSI. We are petitioning for these changes in both the specific and generic rules. While our immediate interest is in Calvert Cliffs, these changes apply to all on-site dry cask storage facilities in general. The docket number of our site-specific petition, filed on December 21, 1992, is 72-8 (50-317/318).
We are representing the interests of more than a hundred petition signers (see enclosed petitions to the State of Maryland for an NRC hearing), most of whom reside in the vicinity of the Calvert Cliffs plant. We also support the efforts of similar organizations in several states where dry cask storage of spent fuel is an issue.
Since we are not experienced or trained in regulatory legal standards, please advise us if we have overlooked any procedural requirements for a rulemaking petition.
l 1
Sincerely yours, OW2Wto J
Richard Ochs Director, MSEC cc: Robert M. Bernero, Office of Nuclear Safety and Safeguards Maryland Public Service Commission John Glynn, Maryland Peoples Counsel
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