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Category:INTERVENTION PETITIONS
MONTHYEARML20106D3131992-10-0505 October 1992 Suppl to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SM Hasan.* Board Should Admit Petitioner Contention 1 for Listed Reasons.W/Certificate of Svc ML20099J8751992-08-14014 August 1992 TU Electric Answer to Petition for Intervention & Request for Hearings by Dows.* Petition to Intervene Should Not Be Accepted for Filing Because Petition Contains Untrue & Scandalous Allegations.Certificate of Svc & Other Info Encl ML20099H1071992-08-0606 August 1992 TU Electric Answer to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SMA Hasan.* Petition Should Be Denied Re Macktal & Hasan Since Neither Showed Standing to Intervene.W/Notices & Certificate of Svc ML20114A9331992-07-28028 July 1992 Petition of SL Dow Dba Disposable Workers of Comanche Peak Ses & RM Dow for Intervention & Request for Hearings.* Licensee Seeks to Extend Expiration Date of CP for Period of Addl 3 Yrs.W/Certificate of Svc ML20099H0921992-07-27027 July 1992 Petition to Intervene & Request for Hearing of Bi Orr, Di Orr,Jj Macktal & SMA Hasan.* Requests That Hearing Be Convened to Determine Whether Good Cause Exists for Extension of CP Completion Date.Certificate of Svc Encl ML19325D6381989-10-20020 October 1989 Request to Continue Proceedings & Petition to Intervene by Citizens for Fair Util Regulation & Greater Fort Worth Group of Lone Star Chapter of Sierra Club.* Petitioners Have Requisite Interest to Establish Standing ML20154G7591988-09-12012 September 1988 Citizen for Fair Util Regulation (Cfur) First Suppl to 880811 Request for Hearing & Petition for Leave to Intervene.* Cfur 880811 Request for Hearing & Petition for Leave to Intervene Should Be Granted.W/Certificate of Svc ML20153D1361988-08-26026 August 1988 Applicant Answer to Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* Request Should Be Denied Based on Inability to Develop Allegations. Certificate of Svc Encl ML20207E5261988-08-11011 August 1988 Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* ML20150E2131988-07-13013 July 1988 Citizens Audit Motion for Stay & Motion for Sua Sponte Relief.* Requests Time to Review Concerns of J Doe & for Relief for Listed Items in Order to Act as Intervenor in Proceeding.W/Certificate of Svc ML20150E2071988-07-11011 July 1988 Second Group of Individual Residents Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released.W/Certificate of Svc ML20150E3301988-07-11011 July 1988 Greater Fort Worth Sierra Club Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That Relief for Listed Items Be Granted Sua Sponte to Address Complex safety-related Issues.W/Certificate of Svc ML20150D5141988-07-0808 July 1988 Citizens for Fair Util Regulation Motion to Intervene & for Sua Sponte Relief.* Petitioner Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released & That 880713 Hearing Be Continued for 60 Days ML20150D5371988-07-0808 July 1988 Individual Residents Motion to Intervene & for Sua Sponte Relief.* Listed Petitioners Request Relief That All Settlement Agreements Re Joint Stipulation Be Publicly Released & 880713 Hearing Be Extended.W/Certificate of Svc ML20211H3921986-10-31031 October 1986 Consolidated Intervenors Motion to Dismiss Pending Appeal as Moot &/Or for Lack of Jurisdiction & to Immediately Dissolve Order Staying Discovery.Certificate of Svc Encl ML20210N2811986-09-30030 September 1986 Consolidated Intervenors Amended Contentions 1 & 2 Re Reinsp Efforts & Const Delay.Certificate of Svc Encl ML20203G4731986-04-18018 April 1986 Answer Opposing M Gregory & Case 860407 Petition for Leave to Intervene Re NRC 860210 Order Extending Completion Date for CPPR-126 to 880801.Contentions Fail to Satisfy 10CFR2.714(b) Criteria.W/Certificate of Svc ML20203D5681986-04-17017 April 1986 Permittees Answer to Petitions to Intervene of Case & M Gregory.Certificate of Svc Encl ML20202G4751986-04-0707 April 1986 Petition of Case for Leave to Intervene & Request for Hearing.Certificate of Svc & Jl Howard Affidavit Encl ML20199K7401986-04-0707 April 1986 Petition of M Gregory for Leave to Intervene Re Improper Const & Invalid Util Justification for Delay.Affidavit of M Gregory & Certificate of Svc Encl.Served on 860409 ML20151U6791986-02-0505 February 1986 Response to Ha Stiner Request to Intervene late.Late-filed Petition Should Be Denied.W/Certificate of Svc ML20137Q0151985-12-0202 December 1985 Answer Supporting Applicant 851105 Petition for Directed Certification of ASLB 851031 Order for Review.Order Adversely Affects Basic Structure of OL Proceeding. Certificate of Svc Encl ML20081G7771983-11-0303 November 1983 Answer Opposing Citizens Assoc for Sound Energy (Case) 831024 Motions to Add New Contention & for Discovery Re Hot Functional Test Results.Case Should Have Begun to Pursue Subj Matter by 830513 ML20080S3261983-10-13013 October 1983 Motion to Add Proposed Contention 26 Re Hot Functional Test, Motion for Discovery & Offer of Proof.Certificate of Svc Encl ML20024A5251983-06-12012 June 1983 Answer Opposing State of Tx 830609 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Proposed Contention Lacks Requisite Specificity & Bases for late-filed Contentions.Certificate of Svc Encl ML20024A0311983-06-0909 June 1983 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Somervell County & Hood County Commitment,Expertise & Resources Inadequate to Adopt & Implement Emergency Plans.Certificate of Svc Encl ML20063H0351982-08-26026 August 1982 Motion to Add New Contention 26 Re Apparent Applicant Violation of 10CFR50,App A,Criterion 1,requiring Possession of Design Criteria for Pipe Support Sys & Components at Site.Certificate of Svc Encl ML19340D3001980-11-25025 November 1980 Supplemental Response,Submitted to Ferc,On DOJ 800917 Petition to Intervene.Doj Position Is Irrelevant to Approval of Supplemental Offer of Settlement & Should Be Denied W/O Prejudice.Supporting Info & Certificate of Svc Encl ML19338E9471980-09-17017 September 1980 Petition for Leave to Intervene ML19338C4101980-08-13013 August 1980 Response in Support of Tx Border Cooperatives Petition to Intervene.Nexus Requirement for Util Operations Affected by Dc Interconnection Satisfied.Untimeliness Is Measured by Necessity to Preserve Rights.Certificate of Svc Encl ML19331C5331980-08-13013 August 1980 Answer in Support of Tx Border Cooperatives 800731 Petition to Intervene.Good Cause Shown for Late Filing.No Other Means Exist to Protect Interests.Intervention Would Assist in Development of Sound Record.Certificate of Svc Encl ML19330C5831980-08-0707 August 1980 Response in Opposition to Tx Border Cooperative Petition to Intervene.Good Cause Not Shown.Cooperative Interests Can Be Protected in Pending FERC Hearing.Petitioners Failed to Show Participation Would Assist in Development of Record ML19330B5911980-07-31031 July 1980 Petition for Untimely Intervention.Petitioners Had Reason to Believe That Interests Would Be Adequately Protected by Other Utils,But Significant Developments Created Concerns Re Dc Interconnections.Certificate of Svc Encl ML19331D9051980-07-31031 July 1980 Response to Applicants,Central & South West Corp & City of Austin,Tx Objections to Tx Border Cooperative Petition to Intervene.Asserts Interests Under LBP-74-13.Urges Full Party Participation.W/Certificate of Svc ML19323B5551980-04-10010 April 1980 Statement of Position in Opposition to Tx Association of Community Organizations for Reform Now Proposed Contentions. Intervenor Failed to Submit Allegations Warranting Admission in Proceeding.Certificate of Svc Encl ML19309H6591980-04-10010 April 1980 Statement of Position in Opposition to Citizens Association for Sound Energy Proposed Contentions.Intervenor Failed to Submit Allegations Warranting Admission in Proceeding. Proposed Contentions & Certificate of Svc Encl ML19344D5751980-03-25025 March 1980 Response in Opposition to Public Utils Board of City of Brownsville,Tx 800317 Comments Requesting Admittance as Party in Consolidated Proceeding.Statement of Interest Untimely & Vague.Certificate of Svc Encl 1992-08-06
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20106D3131992-10-0505 October 1992 Suppl to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SM Hasan.* Board Should Admit Petitioner Contention 1 for Listed Reasons.W/Certificate of Svc ML20099J8751992-08-14014 August 1992 TU Electric Answer to Petition for Intervention & Request for Hearings by Dows.* Petition to Intervene Should Not Be Accepted for Filing Because Petition Contains Untrue & Scandalous Allegations.Certificate of Svc & Other Info Encl ML20099H1071992-08-0606 August 1992 TU Electric Answer to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SMA Hasan.* Petition Should Be Denied Re Macktal & Hasan Since Neither Showed Standing to Intervene.W/Notices & Certificate of Svc ML20114A9331992-07-28028 July 1992 Petition of SL Dow Dba Disposable Workers of Comanche Peak Ses & RM Dow for Intervention & Request for Hearings.* Licensee Seeks to Extend Expiration Date of CP for Period of Addl 3 Yrs.W/Certificate of Svc ML20099H0921992-07-27027 July 1992 Petition to Intervene & Request for Hearing of Bi Orr, Di Orr,Jj Macktal & SMA Hasan.* Requests That Hearing Be Convened to Determine Whether Good Cause Exists for Extension of CP Completion Date.Certificate of Svc Encl ML19325D6381989-10-20020 October 1989 Request to Continue Proceedings & Petition to Intervene by Citizens for Fair Util Regulation & Greater Fort Worth Group of Lone Star Chapter of Sierra Club.* Petitioners Have Requisite Interest to Establish Standing ML20154G7591988-09-12012 September 1988 Citizen for Fair Util Regulation (Cfur) First Suppl to 880811 Request for Hearing & Petition for Leave to Intervene.* Cfur 880811 Request for Hearing & Petition for Leave to Intervene Should Be Granted.W/Certificate of Svc ML20153D1361988-08-26026 August 1988 Applicant Answer to Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* Request Should Be Denied Based on Inability to Develop Allegations. Certificate of Svc Encl ML20207E5261988-08-11011 August 1988 Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* ML20150E2131988-07-13013 July 1988 Citizens Audit Motion for Stay & Motion for Sua Sponte Relief.* Requests Time to Review Concerns of J Doe & for Relief for Listed Items in Order to Act as Intervenor in Proceeding.W/Certificate of Svc ML20150E2071988-07-11011 July 1988 Second Group of Individual Residents Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released.W/Certificate of Svc ML20150E3301988-07-11011 July 1988 Greater Fort Worth Sierra Club Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That Relief for Listed Items Be Granted Sua Sponte to Address Complex safety-related Issues.W/Certificate of Svc ML20150D5141988-07-0808 July 1988 Citizens for Fair Util Regulation Motion to Intervene & for Sua Sponte Relief.* Petitioner Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released & That 880713 Hearing Be Continued for 60 Days ML20150D5371988-07-0808 July 1988 Individual Residents Motion to Intervene & for Sua Sponte Relief.* Listed Petitioners Request Relief That All Settlement Agreements Re Joint Stipulation Be Publicly Released & 880713 Hearing Be Extended.W/Certificate of Svc ML20211H3921986-10-31031 October 1986 Consolidated Intervenors Motion to Dismiss Pending Appeal as Moot &/Or for Lack of Jurisdiction & to Immediately Dissolve Order Staying Discovery.Certificate of Svc Encl ML20210N2811986-09-30030 September 1986 Consolidated Intervenors Amended Contentions 1 & 2 Re Reinsp Efforts & Const Delay.Certificate of Svc Encl ML20203G4731986-04-18018 April 1986 Answer Opposing M Gregory & Case 860407 Petition for Leave to Intervene Re NRC 860210 Order Extending Completion Date for CPPR-126 to 880801.Contentions Fail to Satisfy 10CFR2.714(b) Criteria.W/Certificate of Svc ML20203D5681986-04-17017 April 1986 Permittees Answer to Petitions to Intervene of Case & M Gregory.Certificate of Svc Encl ML20202G4751986-04-0707 April 1986 Petition of Case for Leave to Intervene & Request for Hearing.Certificate of Svc & Jl Howard Affidavit Encl ML20199K7401986-04-0707 April 1986 Petition of M Gregory for Leave to Intervene Re Improper Const & Invalid Util Justification for Delay.Affidavit of M Gregory & Certificate of Svc Encl.Served on 860409 ML20151U6791986-02-0505 February 1986 Response to Ha Stiner Request to Intervene late.Late-filed Petition Should Be Denied.W/Certificate of Svc ML20137Q0151985-12-0202 December 1985 Answer Supporting Applicant 851105 Petition for Directed Certification of ASLB 851031 Order for Review.Order Adversely Affects Basic Structure of OL Proceeding. Certificate of Svc Encl ML20081G7771983-11-0303 November 1983 Answer Opposing Citizens Assoc for Sound Energy (Case) 831024 Motions to Add New Contention & for Discovery Re Hot Functional Test Results.Case Should Have Begun to Pursue Subj Matter by 830513 ML20080S3261983-10-13013 October 1983 Motion to Add Proposed Contention 26 Re Hot Functional Test, Motion for Discovery & Offer of Proof.Certificate of Svc Encl ML20024A5251983-06-12012 June 1983 Answer Opposing State of Tx 830609 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Proposed Contention Lacks Requisite Specificity & Bases for late-filed Contentions.Certificate of Svc Encl ML20024A0311983-06-0909 June 1983 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Somervell County & Hood County Commitment,Expertise & Resources Inadequate to Adopt & Implement Emergency Plans.Certificate of Svc Encl ML20063H0351982-08-26026 August 1982 Motion to Add New Contention 26 Re Apparent Applicant Violation of 10CFR50,App A,Criterion 1,requiring Possession of Design Criteria for Pipe Support Sys & Components at Site.Certificate of Svc Encl ML19340D3001980-11-25025 November 1980 Supplemental Response,Submitted to Ferc,On DOJ 800917 Petition to Intervene.Doj Position Is Irrelevant to Approval of Supplemental Offer of Settlement & Should Be Denied W/O Prejudice.Supporting Info & Certificate of Svc Encl ML19338E9471980-09-17017 September 1980 Petition for Leave to Intervene ML19338C4101980-08-13013 August 1980 Response in Support of Tx Border Cooperatives Petition to Intervene.Nexus Requirement for Util Operations Affected by Dc Interconnection Satisfied.Untimeliness Is Measured by Necessity to Preserve Rights.Certificate of Svc Encl ML19331C5331980-08-13013 August 1980 Answer in Support of Tx Border Cooperatives 800731 Petition to Intervene.Good Cause Shown for Late Filing.No Other Means Exist to Protect Interests.Intervention Would Assist in Development of Sound Record.Certificate of Svc Encl ML19330C5831980-08-0707 August 1980 Response in Opposition to Tx Border Cooperative Petition to Intervene.Good Cause Not Shown.Cooperative Interests Can Be Protected in Pending FERC Hearing.Petitioners Failed to Show Participation Would Assist in Development of Record ML19330B5911980-07-31031 July 1980 Petition for Untimely Intervention.Petitioners Had Reason to Believe That Interests Would Be Adequately Protected by Other Utils,But Significant Developments Created Concerns Re Dc Interconnections.Certificate of Svc Encl ML19331D9051980-07-31031 July 1980 Response to Applicants,Central & South West Corp & City of Austin,Tx Objections to Tx Border Cooperative Petition to Intervene.Asserts Interests Under LBP-74-13.Urges Full Party Participation.W/Certificate of Svc ML19323B5551980-04-10010 April 1980 Statement of Position in Opposition to Tx Association of Community Organizations for Reform Now Proposed Contentions. Intervenor Failed to Submit Allegations Warranting Admission in Proceeding.Certificate of Svc Encl ML19309H6591980-04-10010 April 1980 Statement of Position in Opposition to Citizens Association for Sound Energy Proposed Contentions.Intervenor Failed to Submit Allegations Warranting Admission in Proceeding. Proposed Contentions & Certificate of Svc Encl ML19344D5751980-03-25025 March 1980 Response in Opposition to Public Utils Board of City of Brownsville,Tx 800317 Comments Requesting Admittance as Party in Consolidated Proceeding.Statement of Interest Untimely & Vague.Certificate of Svc Encl 1992-08-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
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, ., - n ,e 8/26/82 ,h UNITED STATES OF AMERICA 0ggya b NUCLEAR REGULATORY COMMISSION 4 11 BEFORE THE ATOMIC SAFETY AND LICENSING B0gD A93 30 P2:27 jj In the Matter of SgCRgAl{'( .
APPLICATION OF TEXAS UTILITIES I I
Docket tYos. M 445 GENERATING COMPANY, ET AL. FOR and 50-446 AN OPERATING LICENSE FOR I + e COMANCHE PEAY, STEAM ELECTRIC I STATION UNITS #1 AND #2 I (CPSES) -
l CASE'S MOTION TO ADD NEW CONTENTION 26 ,
t.
. Pursuant to 10 CFR 2.730, CASE (Citizens Association for Sound Energy), ;
Intervenor herein, hereby files this, its Motion to Add New Contention 26. $
The contention which CASE moves the Board to accept for litigation in these proceedings may already be within the scope of CASE's Contention 5, at least in part. However, because of the far-reaching implications of this contention, we want to. be certain that a full and complete record can be obtained regarding it and therefore believe the instant motion to be necessary.
PROPOSED CONTENTION Con tention 26. Applicants do not possess copies of the design criteria for "
pipe support systems and components used at CPSES. Therefore, the require- . ,!
ments of 10 CFR Part 50, Appendices A and B, cannot be met.
I BASES FOR PROPOSED CONTENTION .f BACKGROUND. On August 9,1982, CASE filed its Twelfth Set of Interrogatories 1
'to Applicants and Requests to Produce. Included in those Requests to Produce l were certain documents pertaining to ITT Grinnell and NPSI pipe supports at - i l Comanche Peak, as .well as other documents. On Friday, August 20, 1982, CASE initiated a conference telephone call between the Board and all parties to )
request the Board's assistance regarding several matters, including Applicants' 8209010289 820926 PDR ADOCK 05000445 G PDR bD3 .
i I
. g
', , (,
. B 2- S e
objection to certain documents and testimony regarding ITT Grinnell and NPSI E pipe supports at Comanche Peak; Applicants had asked that several documents t
brought by Mr. Jack Doyle and introduced as a part of Mr. Doyle's deposition, ,
as well as Mr. Doyle's testimony during the deposition, be stricken from tie record of the deposition insofar as it concerned fTT Grinnell and NPSI design >
cri teria. Applicants' purported reason for this was that ITT Grinnell and NPSI pipe support design criteria are proprietary infonnation. ,
On August 24, 1982, CASE received Applicants' Responses to CASE's Twelfth !I t:;
and Thirteenth Sets of Interrogatories and Requests to Produce. In those y C
Responses', Applicants stated regarding CASE's requests regarding ITT Grinnell, L HPSI, Hilti bolts, and Richmond Inserts, as set forth in CASE's Twelfth Set: l,.
Question: "9. Provide for inspection and copying the NPSI Design Criteria [6 for pipe supports (the official one issued in May,1981)." I Response: " Applicants do not possess a copy of this document. CASE should b a
submit a request directly to NPSI at the following address: ~
NPS Industries, Inc. f-One Harmon P1aza e Secaucus, N.J. 07094" Ques tion: "10. Provide for inspection and copying all documents (in the E broad sense of the word, including but not limited to: internal ,
- memoranda, papers, letters, handwritten notes, etc.) which wem ,
used to define the method used to detennine the tensile force -
6-in the Richmond Inserts." ,
Response: "The only information in Applicants' possession regarding :.
this topic is contained in the PSE Design Manual. See Response to Question 15. Any further information CASE seeks on this topic !(t must be requested directly from NPSI or ITT Grinnel." j (NOTE: Applicants agreed to provide for inspection and copying the entire '
i volume of the curmnt PSE design criteria for pipe supports at CPSES, as
! mquested in CASE's Question 15, and CASE now has a copy of it.)
Question: "12. Provide for inspection and copying the current Grinnell l
Design Criteria for pipe supports at CPSES."
l Response: " Applicants do not possess a copy of this document. CASE should I submit a request directly to ITT Grinnel at the following address:
____b
f
-3 . , -
(Question 12; continued):
ITT Grinnel Corporation j 260 W. Exchange St.
- Providence, R.I. 02901" J Question: "16. Pmvide for inspection 6nd copying a copy of the Hilti '
allowables and the procedures for the analysis."
Response: "To the extent this information is within Applicants' possession, it is set forth in the PSE Design Manual. See Response to Question 15. If CASE seeks any further information on this topic it should contact dimctly NPSI or ITT Grinnel."-
Question: "17. Provide for inspection and copying a copy of FUB II and the instructions of how to use the FUB II information (i.e.,
the entire procedure for using all of the information off of .
FUB II) to detennine the capacity of the Hilti bolt."
Response: " Applicants do not possess this infonnation. CASE should mquest the information directly from ITT Grinnel." .
i 10 CFR 2.741(d) states regarding the production of documents: ,
"The response shall state, with respect to each item or category. that ;
inspection and related activities will be permitted as requested, unless the request is objected to, in which case the reasons for objection shall be stated. If objection is made to part of an item or category, the part shall be speci fied."
It should be noted that, despite their verbal statements in the August 20 telephone conference call, Applicants did not object to supplying the requested infonnation in their written responses to CASE's requests for documents; they .
merely stated that they did not possess the information sought. There was no indication whatsoever in their written responses that the infonnation sought i was of a proprietary nature.
Since the responses to our requests for doc m nts were under oath, one would I
assume that the information contained in R" re nanses was true and correct.
However, it should be noted that at least ,ome u- tne information sought by CASE in its requests for documents is (or was) available on site, according
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to the sworn depositions of sone of the witnesses CASE has recently deposed.
This was indica'ted in the deposition, for example, of Mr. Jack Doyle, who
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1 brought with him (and CASE introduced as an Exhibit to his deposition) some of the supposedly proprietary information to which Applicants objected. Since there is nothing in Mr. Doyle's deposition testimony to indicate that he went .;
i to Secaucus, N.J. or Providence, R.I. (where NPSI and ITT Grinnel are located) to_ obtain this information, it would appear logidal to assume that he did indeed obtain those doctznents from the CPSES site. This, in turn, raises grave questions about the accuracy of the infonnation supplied in response to CASE's requests for documents.
If the information requested h available on site, CASE should have been provided the documents requested for inspection and copying, in accordance
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with the Board's directions in the conference call as CASE understood them.
t If the information requested is not available on site, as indicated in Applicants' '
. sworn answers to CASE's requests to produce, this is sufficient basis in and of f i
itself to support CASE's proposed new Contention 26, as demonstrated in the following.
I R_Er0LATIONS AND REQUIREMENTS SUPPORTING CASE'S MOTION:
10 CFR Part 50, Appendix B -- Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, states, in part:
"This appendix establishes quality assurance requirements for the design, -
- construction, and operation of those structures, systems, and components. p The pertinent requirements of this appendix apply to all acti'vities affect- ,
ing the safety-related functions of those structures, systems, and compo- i-nents; these activities include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying. a, "As used in this appendix,. ' quality assurance' comprises all those planned and systematic actions necessary to provide adequate confidc.1ce that a structure, system, or component will perform satisfactorily in service.
Quality assurance includes quality control, which comprises those quality assurance actions related to the physical characteristics of a material, structure, component, or system which provide a means to control the ,
quality of the material, s tructure, component, or system to predetermined requirements . .-
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"I. Organization (
"The applicantl shall be responsible for the establishment and execution h of the quality assurance program. The applicant may delegate to others, 3
, such as contractors, agents, or consultants, the work of establishing !
and executing the quality assurance program, or any part thereof, but r shall retain responsibility therefor. The authority and duties of persons l and organizations perfonning activities affecting the safety-related functions c of structures, systems, and components shall*be clearly established and t l delineated in wri ting. . . i Quality Assurance Program "II.
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"... Activities affecting quality shall be accomplished under suitably con- j tmlled conditions. Controlled conditions include... assurance that all i, prerequisites for 'he given activity have been satisfied. The program i shall take into account the need for special controls, processes, test 3
. equipment, tools, and skills to attain the mquired quality, and the need 'i for verification of quality by inspection and test. The program shall j prwide for indoci.rinat. ion and training of personnel perfonning activities ;
affecting quality as necessary to assure that suitable proficiency is achieved e, and maintained...
"III. Design Control g it'
" Measures shall be established to assure that applicable regulatory require- g ments and the design basis, as defined in paragraph 50.2 and as specified ;r in the license application, for those structures, systems, and components b to which this appendix applies are cormctly translated into specifications, :< s drawings, procedures, and instructions. These measures shall include pro- 7 visions to assure that appropriate quality standards are specified and in- ,1 cluded in design documents and that deviations from such standards are con-trolled. Measures shall also be established for the selection and review
[t for suitability of application of materials, parts, equipment, and processes ),
that are essential to the safety-related functions of the structures, systems :;, ,
and components. . f
" Measures shall be established for the identification and control of design interfaces and for coordination among participating design organizations. O These measures shall include the establishment of procedures among parti- Tij cipating design organizations for the review, approval, release, distri- h bution, and revision of documents involving design interfaces.
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"The design control measures shall provide for verifying or checking the U
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...These criteria will also be used for guidance in evaluating the adequacy -
of quality assurance programs in use by holders of construction permits and 1 operating licenses."
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adequacy of design, such as by the performance of design mviews, by the -
use of alternate or simplified calculational methods, or by the perfomance of a suitable testing program. The verifying or checking process shall be performed by individuals or groups other than those who performed the original design, but who may be from the saae organization. Whem a test program is used to verify the adequacy of a specific design feature in lieu of other verifying or checking processes, it shall include suitable qualifica-tion testing of a prototype unit under the most adverse design conditions.
Design control measums shall be applied to' items such as the following:
reactor physics, stress, thermal, hydraulic, and accident analyses; compati-bility of materials; accessibility for inservice inspection, maintenance, and repair; and delineation of acceptance criteria for inspections and tests.
" Design changes, including field changes, shall be subject to design control .
measures commensurate with those applied to the original design and be [
approved by the organization that perfomed the original design unless the ;
applicant designates another responsible organization. >
"V. Instructions, Procedures, and Drawings n G
" Activities affecting quali ty shall be prescribed by documented instructions, E procedures, or drawings, of a type appropriate to the circumstances and i shall be accomplished in accordance with these instructions, pmcedures, l or drawings. Instructions, procedures, or drawings shall include appro- I priate quantitative or qualitative acceptance criteria for determining that d important activities have been satisfactorily accomplished.
"VI. Document Control [
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" Measures shall be established to control the issuance of documents, such i as instructions, pmcedums, and drawings, including changes thereto, which E prescribe all activities affecting quality. These measures shall assum -
that documents, including changes,, are reviewed for adequacy and approved for release by authorized personnel and am distributed to and used at the j location where the prescribed activity is performed _...
"XI. Test Control f "A test program shall be established to assure that all testing required g!
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to demonstrate that structures, systems, and components will perfonn satis- E l factorily in service is identified and performed in accordance with written E test procedures which incorporate the requirements and acceptance limits [!;
contained in applicable design documents...
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"XV. Nonconforming Materials, Parts, or Components .
" Measures shall be stablished to control materials, parts, or components 5 which do not confonn to requirements in order to prevent their inadvertent @
use or installation. .. -
"XVI. Cormctive Action .
" Measures shall be estbalished to assure that conditions adverse to quality, e such as failures, malfunctions, deficiencies, deviations, d.efective material and equipment, and non-conformances are promptly identified and corrected.
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In the case of significant conditions adverse to quality, the measures shall li
- g assure that the cause of the condition is determined and corrective action fs taken to preclude repeti tion. The identification of the significant i condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of [
management. }
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" XVII. Quality Assurance , Records :
" Sufficient records shall be maintained to furnish evidence of activities ! ;
af fecting quality. The records shall include at least the following: : i Operating logs and the results of reviews, inspections, tests, audits, ;
monitoring of work performance, and materials analyses. The records shall also include closely-related data such as qualifications of personnel, procedures, and equipment. .. Records shall be identifiable and mtrievable.
Consistent with applicable regulatory requirements, the applicant shall establish mquirements concerning record retnetion, such as duration, location, and assigned responsibility..."
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10 CFR Part 50, Appendix A, states in part: *k
" CRITERIA f f
"I. Overall Requirements ;
" Criterion 1 -- Quality standards and records... Appropriate records of the f
design, fabrication, erection, and testing of structures, systems, and com- F ponents important to safety _ shall be maintained by or under the control of the nuclear power uni t licensee throughout the life of the unit." fa
-- (Emphases added) g The idea that Applicants are building secret pipe supports at Comanche .
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Peak is completely contrary to the whole idea of having public hearings on 5 U
whether or not Applicants should be granted an operating license. This is i '
especially true in this particular instance, since there is already testimony in the record and additional deposition testimony soon to be provided (as soon f as the court reporter can complete typing it and the individual (s) who were deposed sign a notarized statement as to the truth and correctness of the deposition (s) and we can get the original deposition (s) to the Board) which will indicate that there are major design problems with the pipe supkorts and components in question which may jeopardize the health and safety of the public.
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Applicants' statement in answer to CASE's requests for documents clearly shows that Applicants are in violation of Criterion 1 of Appendix A,10 CFR, Part 50, as well as Criterion VI of Appendix B,10 CFR, Part 50, and other related Criteria. If it should develop (as CASE expects it will) that the statement by Applicants that they do not possess' copies of the documents sought is incorrect, there are other aspects of this matter which CASE believes the Board should also consider prior to granting an operating license for CPSES, and we anticipate filing appropriate motion (s) at that time.
Based on the information now in hand, we urge that the Board grant our instant motion. We further urge that the Board ascertain the true facts of this matter insofar as whether or not Applicants do in fact possess or have
' access to the design criteria for the pipe support systems and components used at CPSES and advise all parties inmediately so that proper motions can be filed prior to the September 13 hearings. CASE does not anticipate at this time that it will be necessary to seek additional time for discovery on this matter, and as far as we know at the present time we will be prepared to go fomard on this contention at the September 13 hearings if Applicants do not I
, possess or have access to the documents requested. Should tne facts indicate that Applicants do possess the documents requested or have access to them, we will proceed from there, with appropriate motions at that time.
Respectfully submitted, n is s ptrs.T Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446
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UNITED STATES OF AMERICA .'. USNRC NUCLEAR REGULATORY COMMISSION- !
BEFORE THE ATOMIC SAFETY AND LICENSING BOAR ED 30 P2:27
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la the Matter of I 3 TA g7 I BRANCH -
APPLICATION OF TEXAS UTILITIES I Docket Nos. 50-445 .,,.
GENERATING COMPANY, ET AL. FOR AN I and 50-446 ,
OPERATING LICENSE FOR COMANCHE I PEAK STEAM ELECTRIC STATION X e
UNITS #1 AND #2 (CPSES) X CERTIFICATE OF SERVICE ,
By my signature below, I hereby certify that true and correct copies of CASE's Motion to Add New Contention 26 ,
have been sent to the names listed below this 26th day of August , 1982, by:
Express Mail where indicated by
- and First Class Mail elsewhere. ,
- Administrative Judge Marshall E. Miller David J. Preister, Esq. ']
U. S. Nuclear Regulatory Commission Asnistant Attorney Geh ral # '!1 i
Atomic Safety and Licensing Board Panel Environmental Protection Division W:shington, D. C. 20555 P. O. Box 12548, Capitol Station - -
Austin, TX 78711 l
- Dr . Kenneth A.'McCollom, Dean Ms. Lucinda Minton -j
- Division of Engineering, Architecture , Panel Law Clerk ~ .4 and Technology Atomic Safety & Licensing Board Pa'nel N Oklahoma State University U. S. Nuclear Regulatory Comission **
a' Stillwater, Oklahoma 74074 Washington,.D. C. 20555
- Dr. Richard Cole, Member Atomic Safety and Licensing Atomic Safety and Licenr,ing Board Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555
- Nicholas S. Reynolds, Esq. Atomic Safety and Licensing ,
Debevoise & Liberman Appeal Panel 1200 - 17th St., N. W. U. S. Nuclear Regulatory Commission W:shington, D. C. 20o36 washington, D. C. 20555
- Marjorie Ulman Rothschild, Esq. Docketing and Service Section - N.
Office of Executive Legal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission W:shington, D. C. 20555 Washington, D. C. 20555
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/J4Fs.) Juanita Ellis, President ..,
tX.ASE (Citizens Association for Sound Energy) ,,
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