Similar Documents at Byron |
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Category:INTERVENTION PETITIONS
MONTHYEARML20092H9591984-06-0707 June 1984
Forwards Proposed Financial Qualification Contention.Const Cannot Be Completed in Manner Resulting in Safe Plant. Evacuation Plan Will Be Terrible Financial Burden.Served on 840625
ML20024A1201983-02-21021 February 1983
Amend & Consolidation of Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 & Rockford League of Women Voters Contentions 19 & 108
ML20024A1181983-02-21021 February 1983
Motion to Amend & Consolidate Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 W/Rockford League of Women Voters Contentions 19 & 108
ML20062B0591982-07-30030 July 1982
Need for Power & Alternative Energy Source Contention
ML20062B0471982-07-30030 July 1982
Financial Qualifications Contention
ML20054C6741982-04-15015 April 1982
Revised Contentions 10-12.Certificate of Svc Encl
ML19310A1801980-05-0909 May 1980
Supplemented Statement of Contentions Alleging Lack of Technical Qualifications to Operate Station.Dose Impacts of Projected Routine Releases of Radioactive Matls Should Be re-evaluated.Certificate of Svc Encl
ML19323C6711980-04-18018 April 1980
Response to Rockford League of Women Voters Revised Contentions.Urges Admission of Contentions 50,85,104,112(d) & 119(a)(b),consolidation of Contentions 2,5,88,90 & 116 & Rejection of Remaining Contentions.W/Certificate of Svc
ML20028B9861980-03-10010 March 1980
Revised Contentions.Ols Should Be Denied
1984-06-07
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Category:RESPONSES & CONTENTIONS
MONTHYEARML20092H9591984-06-0707 June 1984
Forwards Proposed Financial Qualification Contention.Const Cannot Be Completed in Manner Resulting in Safe Plant. Evacuation Plan Will Be Terrible Financial Burden.Served on 840625
ML20024A1201983-02-21021 February 1983
Amend & Consolidation of Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 & Rockford League of Women Voters Contentions 19 & 108
ML20024A1181983-02-21021 February 1983
Motion to Amend & Consolidate Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 W/Rockford League of Women Voters Contentions 19 & 108
ML20062B0591982-07-30030 July 1982
Need for Power & Alternative Energy Source Contention
ML20062B0471982-07-30030 July 1982
Financial Qualifications Contention
ML20054C6741982-04-15015 April 1982
Revised Contentions 10-12.Certificate of Svc Encl
ML19310A1801980-05-0909 May 1980
Supplemented Statement of Contentions Alleging Lack of Technical Qualifications to Operate Station.Dose Impacts of Projected Routine Releases of Radioactive Matls Should Be re-evaluated.Certificate of Svc Encl
ML19323C6711980-04-18018 April 1980
Response to Rockford League of Women Voters Revised Contentions.Urges Admission of Contentions 50,85,104,112(d) & 119(a)(b),consolidation of Contentions 2,5,88,90 & 116 & Rejection of Remaining Contentions.W/Certificate of Svc
ML20028B9861980-03-10010 March 1980
Revised Contentions.Ols Should Be Denied
1984-06-07
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999
Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl
ML20236H9381998-06-30030 June 1998
Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl
ML20198P3001997-11-0404 November 1997
Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs
ML20149M2951996-11-29029 November 1996
Exemption from Requirements of 10CFR50.60 Re Safety Margins Recommended in ASME Boiler & Pressure Vessel Code Case N-514
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
ML20059C2351993-12-17017 December 1993
Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication
ML20044A8111990-06-27027 June 1990
Comment Opposing Closure of Lpdr of Rockford Public Library
ML20245J0191989-04-14014 April 1989
Comment Re Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants
ML20214X1871987-06-11011 June 1987
Order Imposing Civil Monetary Penalty in Amount of $25,000 Based on Four Severity Level III Violations Noted During 860721-0808 Insp
ML20205Q1711987-04-0202 April 1987
Order Imposing Civil Monetary Penalty in Amount of $25,000. App Re Evaluations & Conclusions Encl
IR 05000812/20100311987-02-26026 February 1987
Order Imposing Civil Monetary Penalty in Amount of $100,000 Based on Violations Noted During Insps on 850812-1031
ML20210T7321987-02-11011 February 1987
Unexecuted Amend 6 to Indemnity Agreement B-97 Substituting Item 3 of Attachment to Indemnity Agreement in Entirety W/ Listed License Numbers,Effective 870130
ML20209J3251987-01-30030 January 1987
Transcript of 870130 Commission Discussion/Possible Vote on Full Power OL for Facility.Pp 1-72.Supporting Viewgraphs Encl
ML20213G4381986-10-24024 October 1986
Unexecuted Amend 5 to Indemnity Agreement B-97,substituting Item 3 of Attachment to Agreement in Entirety W/Listed License Numbers,Effective on 861106
ML20211B0841986-08-0505 August 1986
Transcript of 860805 Meeting Between Region Iii,Computer Interference Elimination & Util in Redmond,Wa Re Plant as-built Drawing Review.Pp 1-200
IR 05000506/20070221986-05-0202 May 1986
Order Imposing Civil Monetary Penalty in Amount of $25,000 for Violations Noted During Insp on 850506-0722.Violations Noted:Failure to Establish Radiological Safety Procedures & to Adequately Train Personnel
ML20138C7301985-12-0909 December 1985
Order Imposing Civil Penalty in Amount of $25,000 Per 850606 Notice of Violation & Proposed Imposition of Civil Penalty.Licensee May Request Hearing within 30 Days of Date of Order
ML20205E8741985-10-28028 October 1985
Exemption from GDC 4 of 10CFR50,App a Requirement to Install Protective Devices Associated W/Postulated Pipe Breaks Primary Coolant Sys.Topical Rept Evaluation Encl
ML20102A2981985-01-0707 January 1985
Petition Requesting Aslab Grant Intervenor Appeal & Order Further Hearings on Safety of Plant
ML20099L2581984-11-27027 November 1984
Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl
ML20099G5381984-11-23023 November 1984
Supplemental Appeal Brief in Response to Intervenor 841106 Supplemental Brief on Appeal & in Support of ASLB 841016 Supplemental Initial Decision Authorizing Issuance of Ol. Certificate of Svc Encl
ML20100K0411984-11-22022 November 1984
Submits Concerns Re Safety of Local Residents in Event of Accident & Excessively High Cost of Projected Operation of Facility
ML20107H7841984-11-0606 November 1984
Supplemental Brief on Appeal of ASLB 841016 Supplemental Initial Decision Granting Authority for Issuance of Ol. Decision Should Be Reversed.Certificate of Svc Encl
ML20140E4081984-10-31031 October 1984
Executed Amend 1 to Indemnity Agreement B-97,deleting Items 2A & 3 in Entirety
ML20098G8841984-10-0202 October 1984
Joint Statement of RW Manz & W Faires Re Findings 3-11 Through 3-17 of NRC 830930 Integrated Design Insp Rept. Certificate of Svc Encl
ML20098G8681984-10-0202 October 1984
Answer to Intervenor Motion to Reopen Record Re Bechtel Independent Design Review.Motion Should Be Denied
ML20098G8901984-10-0202 October 1984
Joint Statement of Kj Green & RW Hooks Re Integrated Design Insp
ML20098G8911984-10-0202 October 1984
Joint Statement of Cw Dick & EM Hughes Re Independent Design Insp
ML20098G8821984-10-0101 October 1984
Affidavit of Kj Green Re Integrated Design Insp Concerning Mechanical Engineering Work
ML20098G8741984-10-0101 October 1984
Affidavit of Br Shelton Re Integrated Design Insp
ML20098G8881984-09-29029 September 1984
Affidavit of RW Hooks Re Integrated Design Insp Concerning Structural Design
ML20098G8831984-09-28028 September 1984
Affidavit of W Faires Re Findings 3-15 & 3-16 of NRC 830930 Integrated Design Insp Rept
ML20098G8811984-09-28028 September 1984
Affidavit of Cw Dick Re Independent Design Review
ML20098G8791984-09-28028 September 1984
Affidavit of RP Tuetken Re Readiness for Fuel Loading
ML20098G8781984-09-28028 September 1984
Affidavit of RW Manz Concerning Findings 3-11 Through 3-14 & 3-17 of NRC 830930 Integrated Design Insp Re Westinghouse
ML20098G8871984-09-28028 September 1984
Affidavit of EM Hughes Re Idvp
ML20098G8851984-09-27027 September 1984
Affidavit of Rl Heumann Re Costs of Delay in Startup & Operation of Unit 1
ML20098E2371984-09-24024 September 1984
Reply to Intervenor 840918 Proposed Supplemental Initial Decision.Certificate of Svc Encl
ML20097E7221984-09-13013 September 1984
Agreed Motion for Time Extension Until 841101 to File Petition for Hearing Re Emergency Planning Commitment W
ML20097C5311984-09-12012 September 1984
Motion to Reopen Record to Include Plant Design as Issue. Supporting Documentation & Certificate of Svc Encl
ML20097B7791984-09-10010 September 1984
Proposed Supplemental Initial Decision Re Reinsp Program. Certificate of Svc Encl
ML20096A6391984-08-30030 August 1984
Rebuttal Testimony of RW Hooks Re Validity of Info in Attachment 7 to Stokes Testimony Concerning Design Assumption for Plant.Stokes Info Inapplicable to Plant. Related Correspondence
ML20096A6191984-08-30030 August 1984
Rebuttal Testimony of B Erler Re Stokes Allegations Concerning Evaluations of Discrepancies in Calculated Actual Stress Performed by Sargent & Lundy.Related Correspondence
ML20096A6261984-08-30030 August 1984
Summary of Rebuttal Testimony & Testimony of ML Somsag, Eb Branch,D Demoss,Mr Frankel,Bf Maurer & Jk Buchanan Re Plant QC Inspector Reinsp Program & C Stokes Allegations Re Welds.Related Correspondence
ML20096A6441984-08-28028 August 1984
Notice of Withdrawal of Appearance in Proceeding.Related Correspondence
ML20112D5271984-08-24024 August 1984
Applicant Exhibit A-R-4,consisting of Feb 1984 Rept on Bryon QC Inspector Reinsp Program
ML20112D5031984-08-24024 August 1984
Applicant Exhibit A-R-5,consisting of June 1984 Suppl to Rept on Bryon QC Inspector Reinsp Program
ML20112D7441984-08-23023 August 1984
Intervenor Exhibit I-R-1,consisting of Undated List of Teutken Safety Category Insp Types
ML20112D7511984-08-21021 August 1984
Staff Exhibit S-R-1,consisting of 840813 Instruction for Walkdown of Cable Tray Hanger Connection Welds
ML20112D4641984-08-21021 August 1984
Intervenor Exhibit I-R-11,consisting of Undated Chronological Date Listing of Util Responses to Interrogatory 12.VA Judson to Mi Miller Re Interrogatory 12 & Supplemental Responses Encl
1999-03-02
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Text
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, r' UNITED STATES OF AMERICA = gETE:
NUCLEAR REGULATORY COMMISSION 05tGC BEFORE THE ATOMIC SAFETY AND LICENSING B R g y3 In the Matter of ) 2 9J[5r
) M" COMMONUEALTH EDISON COMPANY ) Docket Nos. 50-454
) 50-455 (Byron Station, Units 1 and 2) )
DAARE/ SAFE FINANCIAL QUALIFICATIONS CONTENTION Commonwealth Edison is not financially qualified to complete construction of Byron in a manner which will result in a safe plant. As a basis for this contention, DAARE/ SAFE incorporates herein by reference, in their entirety, the Petition of Rockford League of Uomen Voters for Waiver of or Exception to Financial Qualifications Regulations, the Petition of DAARE/ SAFE for Waiver of or Exception to Financial Qualifications Regulations, and all exhibits thereto. DAARE/ SAFE specifically contends that:
- a. Commonwealth Edison ("CE") does not possess or have reasonable assurance of obtaining the funds necessary to complete coastruction of Byron, to cover related fuel cycle costs, or to cover operation costs for the period of the license, plus the costs of permanently shutting down the facility and maintaining it in a safe condition. (See League Financial Qualifications Petition at 4-6 and Exhibits A, B, C, D, E, F, and G, supplemented by DAARE/ SAFE Financial Qualifications Petition and exhibits thereto.)
8208040299 PDR 820730 ADOCK 05000454 6
PDR a
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- b. There is no reasonable assurance that the Illinois Commerce Commission will raise CE's rates high enough to enable CE to complete construction of a safe plant and to safely operate Byron. (See League Financial Qualifications Petition at 6-8 and Exhibits A, C, E, F; Exhibits A, B and C to League Need for Power Petition; supplemented by DAARE/ SAFE Financial Qualifications Petition and Exhibits thereto.)
- c. CE's cost projections for completion of construction, operation and decommissioning of Byron are understated and more reasonable proj ections are so high that CE does not possess or ,
have reasonable assurance of obtaining the necessary funds. (See League Financial Qualifications Petition at 6-10; Exhibits II, 1, J, K and L; supplemented by DAARE/ SAFE Financial Qualifications Petition and Exhibits thereto.)
- d. As a result of CE's lack of financial qualifications, completion and operation of Byron will jeopardize the public health and safety. (See League Financial Qualifications Petition at 10-12; Exhibits F, 11 and M thereto; supplemented by DAARE/
SAFE Financial Qualifications Petition and Exhibits thereto.)
The Sa fety Evaluation Report (SER) issued by the NRC staff in February , 1982, and supplemented in March, 1982, analyzes in part the financial qualifications of CE. The SER must be supplemented in at least two respects:
-- the estimated costs of the Byron plant are understated and should be revised in light of new information submitted by intervenors.
9 the conclusion that CE is financially qualified safely to operate and decommission Byrca is erroneous and must be changed. The SER must be supplemented to reflect that the Company is not financially qualified and that there is no reason-able assurance that it will be able to obtain sufficient funds to complete construction of a safe plant at Byron and to cover the costs of safe operation and decommissioning.
DATED: July 30, 1982 Respectfully submitted, Douglass W. Cassel, Jr.
Jane M. Whicher by: tr>/ b k Douglas $ W. Cassel, Jr. )>
Attorneys for DAARE/ SAFE with respect to issues of financial qualifications, need for power and alternative energy sources Douglass W. Cassel, Jr.
I Jane M. Whicher
, 109 North Dearborn Chicago, IL 60602 (312) 641-5570 i
_.
