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Category:INTERVENTION PETITIONS
MONTHYEARML20084K8771984-05-11011 May 1984 Intervenor B Stamiris Second Supplemental Proposed Findings of Fact & Conclusions of Law Re QA & Mgt Attitude Issues. Determination of Whether 791206 Order of Mod Should Be Sustained Is Only Outstanding Issue to Be Decided ML20087G7921984-03-15015 March 1984 Addendum to Stamiris Contention on Transamerica Delaval,Inc Diesel Generators Addressing Late Filing Factors of 10CFR2.714 ML20081C5091984-03-0404 March 1984 Contention on Transamerica Delaval Diesel Generators Re Model Dsrv 12.Model Cannot Be Relied Upon to Perform Requisite Safety Function ML20081F8711983-10-28028 October 1983 Motion to Reopen & Suppl Record on Sinclair Contention 14,to Submit DA Sommers,Jp Bradley & CR Nefe Affidavits.Affidavits Provide Results of Postulated Evergreen Fog Sweep or Planted Barrier Analysis ML20081C9361983-10-26026 October 1983 Motion to Stay ASLB 830831 & 1006 Orders Denying Deponent Motion for Reconsideration of Motion to Quash Subpoenas Pending Aslab Decision on Deponent 831021 Appeal.Certificate of Svc Encl.Related Correspondence ML20023A8241982-10-15015 October 1982 Reply to NRC & Applicant Responses to M Sinclair Revised Contentions 6,34,37,43,56 & 57.Contention 6,bases (A),(B) & (d)(4),Contention 43 & Contention 56,Basis 3,withdrawn. Certificate of Svc Encl ML20065M7161982-10-15015 October 1982 Response to Util 820923 & NRC 820928 Response to B Stamiris New Contention Based on Fes.Gross Misrepresentation of Overall Costs & Benefits to Public Represented by Cost/ Benefit Analysis Demands Redress ML20063N7541982-10-0404 October 1982 Responses to Applicant & NRC 820903 & NRC 820910 Responses to M Sinclair Revised Contentions.Limiting Contention 31 to Litigation of Util Compliance W/Existing Requirements.Contention 32 Amended ML20065J7501982-09-30030 September 1982 Response Opposing M Sinclair Resubmitted Contention 56 on Station Blackout.Contention Lacks Requisite Basis & Specificity to Stand Alone.Certificate of Svc Encl ML20065H6691982-09-30030 September 1982 Response to M Sinclair 820920 Revised Contentions,Set Ii. Objects to Contentions 34(a),37 & 43 & Portions of Contentions 6 & 57.Util Nonconformance Rept & Certificate of Svc Encl ML20027B7571982-09-28028 September 1982 Response to B Stamiris 820824 Contention Based on New Info in Fes,Challenging Cost/Benefit Analysis.Nrc Objects to Some Basis of Contention.Addendum Objectionable Since Contention Must Be Based on New Info.Certificate of Svc Encl ML20065H7201982-09-28028 September 1982 Responses Opposing B Stamiris 820913 Addendum to 820824 Cost Benefit Contention.Good Cause for Late Filing Not Demonstrated.Certificate of Svc Encl ML20065H6881982-09-28028 September 1982 Response to M Sinclair Resubmitted Contention on Table S-3. Contention Should Be Deferred Until Commission Issues Policy Statement.Certificates of Svc Encl ML20069F9451982-09-23023 September 1982 Response Opposing B Stamiris 820824 New Contention Challenging cost-benefit Analysis of Fes.Production Cost Estimates Unrepresentative,Inconsistent & Untimely & Provide Inadequate Basis for Contention.Certificate of Svc Encl ML20065C1221982-09-22022 September 1982 Revised Contentions (II) Based on Remainder of Discovery from NRC Per ASLB 820525 Order.Related Correspondence ML20065C1181982-09-20020 September 1982 Resubmission of Contention 56 on Station Blackout.Related Correspondence ML20027B2471982-09-13013 September 1982 Addendum to 820824 Cost/Benefit Contention on Dewatering Costs ML20027B2421982-09-0909 September 1982 Resubmitted Contention 1 Based on Encl Us Court of Appeals, DC Circuit,820816 Opinion That NRC Original,Interim & Final Table S-3 Rule Resulted from Inadequate Consideration of Environ Impacts ML20063E5381982-08-24024 August 1982 New Contention Based on Fes Re Cost Production & Cost Saving Analysis of Fes.Statement of Good Cause for Filing New Contention Encl ML20062L5491982-08-16016 August 1982 Page 36a of Util Further Answer to B Stamiris Petition to Intervene in OL Proceeding,Amended Contentions & Statement of Good Cause for Late Intervention,Inadvertently Omitted from Original Filing ML20062M9581982-08-13013 August 1982 Restated Contentions 6,8 & 16 Re QA Program.Certificate of Svc Encl ML20062M8741982-08-12012 August 1982 Restated Contentions,Superseding Contentions Filed on 820718,23 & 0803 ML20062M9801982-08-12012 August 1982 Revised Contentions Based on Discovery Per ASLB 820525 Order ML20091N0601982-08-11011 August 1982 Annotated OL Contentions of Intervenor Stamiris ML20062F7401982-08-0606 August 1982 New Contention 16 Adding Info That Should Be Covered as Part of Zack Co Nonconformance Rept Re Unverified Welder Qualifications for Fabrication Weld ML20062D5291982-08-0303 August 1982 New Contention 15 Re Documentation on Welds ML20058J7251982-08-0202 August 1982 Response Opposing MP Sinclair 820723 New Contention 14 & Request for Addl Time to Respond to New Contention 13 Until Prehearing Conference on 820812.Contention Has No Basis. Certificate of Svc & Related Documentation Encl ML20071K7901982-07-28028 July 1982 Further Answer Opposing B Stamiris Petition to Intervene as Supplemented by 820709 Amended Contentions.Petitioner Fails to Meet Requirements for Late Intervention ML20071K7831982-07-28028 July 1982 Response Opposing M Sinclair 820618 New Contentions. Contentions Untimely.Good Cause for Late Filing Not Shown. Contentions Lack Basis & Specificity &/Or Raise Issues Being Resolved in Another Forum ML20058D5591982-07-23023 July 1982 Addl New Contentions Based on Significant New Info ML20058B1501982-07-21021 July 1982 Response to M Sinclair 820618 Late Filed Contentions & Basis for Late Contentions.Contention 1 Should Be Deferred Pending Commission Guidance.Contentions 2-10 Opposed.Contentions 11 & 12 Unopposed.Certificate of Svc Encl ML20054N0101982-07-0909 July 1982 Statement of Good Cause for Late Intervention.Issues Raised Have Occurred Since Inception of 1978 OL Proceeding ML20054N0241982-07-0909 July 1982 Amended OL Contentions ML20054K4861982-07-0101 July 1982 Response to ASLB 820625 Order,Specifying Reasons for Late Filing of New Contentions ML20054H7571982-06-18018 June 1982 Contentions for OL Hearing ML20054H5941982-06-18018 June 1982 New Contentions for OL Hearing.Proof of Svc Encl ML20054C6621982-04-19019 April 1982 Answer Opposing B Stamiris 820330 Petition to Intervene in OL Hearing.Good Cause for Lateness Not Shown.Certificate of Svc Encl ML19332B1141980-09-0909 September 1980 Suppl to Sk Warren Petition to Intervene & Amended Suppl to B Stamiris Petition to Intervene.Alleges Inadequacy of Permanent Dewatering Procedures & CPC Financial Pressures Adversely Affecting Resolution of Soil Settlement Issues ML19331D8821980-08-30030 August 1980 Response to Sk Warren 800814 Suppl & B Stamiris Amend to Petitions to Intervene.Opposes Warren Contentions 2 & Stamiris Contentions 1,2,3 & 5.Urges Rephrasing of Stamiris Contention 4 Re Qa.Certificate of Svc Encl ML19331E0721980-08-27027 August 1980 Contention Alleging That Class 9 Accident Will Cause Massive Flow of Radioactive Matls Into Saginaw Bay River Which Provides Drinking Water to Area.Urges Full Disclosure Per NEPA ML19331D3131980-08-25025 August 1980 Amended Petition to Intervene Alleging That Inability of Soil to Support Plant Structure W/O Compaction Procedures Violates Requirements.Claims That FSAR Statements Are False & Evasive ML19344A5251980-08-18018 August 1980 Amended Petition to Intervene Alleging Inability of Soil Conditions to Support Plant Structures.Alleges Falsification,Evasiveness & Reluctance in FSAR Statements Re Fill Soils & Seismic Characteristics ML19344A7581980-08-14014 August 1980 Suppl to Petition to Intervene Alleging Poor Quality of Fill Soil Composition & Inadequacy of Dewatering & Preloading Procedures ML19330B6421980-07-31031 July 1980 Response Stating No Opposition to Wh Marshall Present Intervention Re Interest & Standing.Reserves Right of Future Objection Depending on Substance of Contention.Certificate of Svc Encl ML19329G1211980-07-0808 July 1980 Response Stating No Present Opposition to Sk Warren,Sd Reist,Gc Wilson & Ma Race Petitions to Intervene Re License Mod.Reserves Right for Future Objection & Urges Representation by Single Spokesman.Certificate of Svc Encl ML19320B0121980-07-0101 July 1980 Response Stating No Present Opposition to Wa Thibodeau,Tr Miller,Pa Race,B Stamiris & C Gilbert Petitions to Intervene.Reserves Right to Oppose Participation in Future Development & Urges Consolidation.Certificate of Svc Encl ML19318D2041980-06-26026 June 1980 Petition to Intervene Re Order for CP Mod,Alleging That Unresolved Soil Settlement Issue Will Create Adverse Safety Problems & Will Result in Inefficient Exercise of Atomic Energy Use.Certificate of Svc Encl ML19318D0651980-06-25025 June 1980 Petition to Intervene in CP Mod Proceeding,Alleging That Unresolved Soil Settlement Problems Will Create Adverse Safety Problems.Certificate of Svc Encl ML19318D1871980-06-25025 June 1980 Petition to Intervene in CP Mod Proceeding,Alleging That Unresolved Soil Settlement Problems Will Adversely Affect Safety & Will Create Inefficient Exercise of Atomic Energy Use.Questions Integrity of Const.Certificate of Svc Encl ML19318D2031980-06-24024 June 1980 Petition to Intervene Re Order for CP Mod,Alleging That Mod Will Result in Unsafe & Inefficient Exercise of Atomic Energy Use & Will Create Adverse Environ Effects. Certificate of Svc Encl 1984-05-11
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20084K8771984-05-11011 May 1984 Intervenor B Stamiris Second Supplemental Proposed Findings of Fact & Conclusions of Law Re QA & Mgt Attitude Issues. Determination of Whether 791206 Order of Mod Should Be Sustained Is Only Outstanding Issue to Be Decided ML20087G7921984-03-15015 March 1984 Addendum to Stamiris Contention on Transamerica Delaval,Inc Diesel Generators Addressing Late Filing Factors of 10CFR2.714 ML20081C5091984-03-0404 March 1984 Contention on Transamerica Delaval Diesel Generators Re Model Dsrv 12.Model Cannot Be Relied Upon to Perform Requisite Safety Function ML20081F8711983-10-28028 October 1983 Motion to Reopen & Suppl Record on Sinclair Contention 14,to Submit DA Sommers,Jp Bradley & CR Nefe Affidavits.Affidavits Provide Results of Postulated Evergreen Fog Sweep or Planted Barrier Analysis ML20081C9361983-10-26026 October 1983 Motion to Stay ASLB 830831 & 1006 Orders Denying Deponent Motion for Reconsideration of Motion to Quash Subpoenas Pending Aslab Decision on Deponent 831021 Appeal.Certificate of Svc Encl.Related Correspondence ML20023A8241982-10-15015 October 1982 Reply to NRC & Applicant Responses to M Sinclair Revised Contentions 6,34,37,43,56 & 57.Contention 6,bases (A),(B) & (d)(4),Contention 43 & Contention 56,Basis 3,withdrawn. Certificate of Svc Encl ML20065M7161982-10-15015 October 1982 Response to Util 820923 & NRC 820928 Response to B Stamiris New Contention Based on Fes.Gross Misrepresentation of Overall Costs & Benefits to Public Represented by Cost/ Benefit Analysis Demands Redress ML20063N7541982-10-0404 October 1982 Responses to Applicant & NRC 820903 & NRC 820910 Responses to M Sinclair Revised Contentions.Limiting Contention 31 to Litigation of Util Compliance W/Existing Requirements.Contention 32 Amended ML20065J7501982-09-30030 September 1982 Response Opposing M Sinclair Resubmitted Contention 56 on Station Blackout.Contention Lacks Requisite Basis & Specificity to Stand Alone.Certificate of Svc Encl ML20065H6691982-09-30030 September 1982 Response to M Sinclair 820920 Revised Contentions,Set Ii. Objects to Contentions 34(a),37 & 43 & Portions of Contentions 6 & 57.Util Nonconformance Rept & Certificate of Svc Encl ML20027B7571982-09-28028 September 1982 Response to B Stamiris 820824 Contention Based on New Info in Fes,Challenging Cost/Benefit Analysis.Nrc Objects to Some Basis of Contention.Addendum Objectionable Since Contention Must Be Based on New Info.Certificate of Svc Encl ML20065H7201982-09-28028 September 1982 Responses Opposing B Stamiris 820913 Addendum to 820824 Cost Benefit Contention.Good Cause for Late Filing Not Demonstrated.Certificate of Svc Encl ML20065H6881982-09-28028 September 1982 Response to M Sinclair Resubmitted Contention on Table S-3. Contention Should Be Deferred Until Commission Issues Policy Statement.Certificates of Svc Encl ML20069F9451982-09-23023 September 1982 Response Opposing B Stamiris 820824 New Contention Challenging cost-benefit Analysis of Fes.Production Cost Estimates Unrepresentative,Inconsistent & Untimely & Provide Inadequate Basis for Contention.Certificate of Svc Encl ML20065C1221982-09-22022 September 1982 Revised Contentions (II) Based on Remainder of Discovery from NRC Per ASLB 820525 Order.Related Correspondence ML20065C1181982-09-20020 September 1982 Resubmission of Contention 56 on Station Blackout.Related Correspondence ML20027B2471982-09-13013 September 1982 Addendum to 820824 Cost/Benefit Contention on Dewatering Costs ML20027B2421982-09-0909 September 1982 Resubmitted Contention 1 Based on Encl Us Court of Appeals, DC Circuit,820816 Opinion That NRC Original,Interim & Final Table S-3 Rule Resulted from Inadequate Consideration of Environ Impacts ML20063E5381982-08-24024 August 1982 New Contention Based on Fes Re Cost Production & Cost Saving Analysis of Fes.Statement of Good Cause for Filing New Contention Encl ML20062L5491982-08-16016 August 1982 Page 36a of Util Further Answer to B Stamiris Petition to Intervene in OL Proceeding,Amended Contentions & Statement of Good Cause for Late Intervention,Inadvertently Omitted from Original Filing ML20062M9581982-08-13013 August 1982 Restated Contentions 6,8 & 16 Re QA Program.Certificate of Svc Encl ML20062M8741982-08-12012 August 1982 Restated Contentions,Superseding Contentions Filed on 820718,23 & 0803 ML20062M9801982-08-12012 August 1982 Revised Contentions Based on Discovery Per ASLB 820525 Order ML20091N0601982-08-11011 August 1982 Annotated OL Contentions of Intervenor Stamiris ML20062F7401982-08-0606 August 1982 New Contention 16 Adding Info That Should Be Covered as Part of Zack Co Nonconformance Rept Re Unverified Welder Qualifications for Fabrication Weld ML20062D5291982-08-0303 August 1982 New Contention 15 Re Documentation on Welds ML20058J7251982-08-0202 August 1982 Response Opposing MP Sinclair 820723 New Contention 14 & Request for Addl Time to Respond to New Contention 13 Until Prehearing Conference on 820812.Contention Has No Basis. Certificate of Svc & Related Documentation Encl ML20071K7901982-07-28028 July 1982 Further Answer Opposing B Stamiris Petition to Intervene as Supplemented by 820709 Amended Contentions.Petitioner Fails to Meet Requirements for Late Intervention ML20071K7831982-07-28028 July 1982 Response Opposing M Sinclair 820618 New Contentions. Contentions Untimely.Good Cause for Late Filing Not Shown. Contentions Lack Basis & Specificity &/Or Raise Issues Being Resolved in Another Forum ML20058D5591982-07-23023 July 1982 Addl New Contentions Based on Significant New Info ML20058B1501982-07-21021 July 1982 Response to M Sinclair 820618 Late Filed Contentions & Basis for Late Contentions.Contention 1 Should Be Deferred Pending Commission Guidance.Contentions 2-10 Opposed.Contentions 11 & 12 Unopposed.Certificate of Svc Encl ML20054N0101982-07-0909 July 1982 Statement of Good Cause for Late Intervention.Issues Raised Have Occurred Since Inception of 1978 OL Proceeding ML20054N0241982-07-0909 July 1982 Amended OL Contentions ML20054K4861982-07-0101 July 1982 Response to ASLB 820625 Order,Specifying Reasons for Late Filing of New Contentions ML20054H7571982-06-18018 June 1982 Contentions for OL Hearing ML20054H5941982-06-18018 June 1982 New Contentions for OL Hearing.Proof of Svc Encl ML20054C6621982-04-19019 April 1982 Answer Opposing B Stamiris 820330 Petition to Intervene in OL Hearing.Good Cause for Lateness Not Shown.Certificate of Svc Encl ML19332B1141980-09-0909 September 1980 Suppl to Sk Warren Petition to Intervene & Amended Suppl to B Stamiris Petition to Intervene.Alleges Inadequacy of Permanent Dewatering Procedures & CPC Financial Pressures Adversely Affecting Resolution of Soil Settlement Issues ML19331D8821980-08-30030 August 1980 Response to Sk Warren 800814 Suppl & B Stamiris Amend to Petitions to Intervene.Opposes Warren Contentions 2 & Stamiris Contentions 1,2,3 & 5.Urges Rephrasing of Stamiris Contention 4 Re Qa.Certificate of Svc Encl ML19331E0721980-08-27027 August 1980 Contention Alleging That Class 9 Accident Will Cause Massive Flow of Radioactive Matls Into Saginaw Bay River Which Provides Drinking Water to Area.Urges Full Disclosure Per NEPA ML19331D3131980-08-25025 August 1980 Amended Petition to Intervene Alleging That Inability of Soil to Support Plant Structure W/O Compaction Procedures Violates Requirements.Claims That FSAR Statements Are False & Evasive ML19344A5251980-08-18018 August 1980 Amended Petition to Intervene Alleging Inability of Soil Conditions to Support Plant Structures.Alleges Falsification,Evasiveness & Reluctance in FSAR Statements Re Fill Soils & Seismic Characteristics ML19344A7581980-08-14014 August 1980 Suppl to Petition to Intervene Alleging Poor Quality of Fill Soil Composition & Inadequacy of Dewatering & Preloading Procedures ML19330B6421980-07-31031 July 1980 Response Stating No Opposition to Wh Marshall Present Intervention Re Interest & Standing.Reserves Right of Future Objection Depending on Substance of Contention.Certificate of Svc Encl ML19329G1211980-07-0808 July 1980 Response Stating No Present Opposition to Sk Warren,Sd Reist,Gc Wilson & Ma Race Petitions to Intervene Re License Mod.Reserves Right for Future Objection & Urges Representation by Single Spokesman.Certificate of Svc Encl ML19320B0121980-07-0101 July 1980 Response Stating No Present Opposition to Wa Thibodeau,Tr Miller,Pa Race,B Stamiris & C Gilbert Petitions to Intervene.Reserves Right to Oppose Participation in Future Development & Urges Consolidation.Certificate of Svc Encl ML19318D2041980-06-26026 June 1980 Petition to Intervene Re Order for CP Mod,Alleging That Unresolved Soil Settlement Issue Will Create Adverse Safety Problems & Will Result in Inefficient Exercise of Atomic Energy Use.Certificate of Svc Encl ML19318D0651980-06-25025 June 1980 Petition to Intervene in CP Mod Proceeding,Alleging That Unresolved Soil Settlement Problems Will Create Adverse Safety Problems.Certificate of Svc Encl ML19318D1871980-06-25025 June 1980 Petition to Intervene in CP Mod Proceeding,Alleging That Unresolved Soil Settlement Problems Will Adversely Affect Safety & Will Create Inefficient Exercise of Atomic Energy Use.Questions Integrity of Const.Certificate of Svc Encl ML19318D2031980-06-24024 June 1980 Petition to Intervene Re Order for CP Mod,Alleging That Mod Will Result in Unsafe & Inefficient Exercise of Atomic Energy Use & Will Create Adverse Environ Effects. Certificate of Svc Encl 1984-05-11
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20070E4671991-02-26026 February 1991 Comment Opposing Petition for Rulemaking PRM-73-9 Re Upgrading Design Basis Threat for Radiological Sabotage of Nuclear Reactors.Recommends That NRC Deny Petition to Increase Design Basis Threat for Security ML20207C1331986-12-18018 December 1986 Order Terminating CPPR-81 & CPPR-82,per Util 860711 Motion to Withdraw Applications for OLs ML20215E7301986-12-17017 December 1986 Memorandum & Order Authorizing Withdrawal of OL Application & Dismissing OL Proceeding,Per Applicant 860711 Motion. Served on 861218 ML20215B2071986-12-11011 December 1986 Responds to Questions Posed in ASLBP 861203 Memorandum & Order Re Conversion to gas-fired Facility.Imposition of Conditions on Withdrawal of OL Application Unnecessary. Certificate of Svc & Svc List Encl ML20211L6391986-12-11011 December 1986 Affidavit of Gb Staley Re Preparation of Answers to Board 861203 Questions on Termination of OL Proceeding. Certificate of Svc Encl ML20211L6181986-12-11011 December 1986 Response to Board 861203 Questions Re Util Request to Terminate OL Proceeding ML20214Q4431986-12-0303 December 1986 Memorandum & Order Granting Motion to Expedite Completion of Withdrawal Proceedings & Posing Questions to Parties.Served on 861204 ML20214G7941986-11-24024 November 1986 Motion to Expedite Completion of Withdrawal of Licensee OL Application & Terminate Pending OL & CP Mod Proceedings. Certificate of Svc Encl ML20214T7361986-09-26026 September 1986 Memorandum & Order Dismissing OM Proceeding as Moot & Deferring Action on Applicant Motion for Authorization to Withdraw OL Application Pending NRC Preparation of Environ Assessment.Served on 860929 ML20212M7661986-08-25025 August 1986 Response to Util 860711 Motion for Authorization to Withdraw OL Application & for Dismissal of OL & Order of Mod Proceedings.Board Should Hold Motion in Abeyance Pending NRC Review of Stabilization Plan.Certificate of Svc Encl ML20206M8171986-08-15015 August 1986 Response to ASLB 860716 Order Requesting Responses Re Termination of OM Proceeding.Termination of OL Proceeding & Withdrawal of OL Application Requested.Om Proceeding Should Be Considered Moot.Certificate of Svc Encl ML20212B0311986-08-0101 August 1986 Memorandum & Order Withdrawing Retention of Jurisdiction Over Radon Issue Presented in Facility CP Proceeding & Vacating ASLB Partial Initial Decision on Remedial Soils in Consolidated CP Mod & OL Proceeding.Served on 860801 ML20212B0521986-07-31031 July 1986 Order Extending Time Until 860815 for Util & Other Parties to Respond to Questions Posed by 860716 ASLB Order.Time Extended Until 860825 for NRC Response to ASLB Questions & Util Motion.Served on 860801 ML20203F8791986-07-28028 July 1986 Response Supporting Util 860711 Motion for Termination of Appeal Board Jurisdiction Over Proceeding.Certificate of Svc Encl ML20207H6871986-07-22022 July 1986 Motion for Extension Until 860815 to File Responses to Four Questions Re Util Motion to Dismiss OL & OM Proceedings. Certificate of Svc Encl ML20207E2851986-07-16016 July 1986 Order Presenting Questions in Response to Util 860711 Motion to Dismiss OL Proceeding & to Terminate Order of Mod Proceeding.Served on 860717 ML20202G1621986-07-11011 July 1986 Notice of Change of Address for Washington Ofc of Isham, Lincoln & Beale,Attys for Util.Certificate of Svc Encl ML20202G0121986-07-11011 July 1986 Motion for Authorization to Withdraw OL Application & Dismissal of OL & Order of Mod Proceedings ML20202G1201986-07-11011 July 1986 Motion for Termination of Aslab Jurisdiction to Facilitate Termination of Cps,Withdrawal of OL Application & Dismissal of Consolidated OM-OL Proceeding ML20202G0491986-07-10010 July 1986 Affidavit of JW Cook Re Conversion of Plant Into combined- cycle,gas-fired Power Plant.Plant Never Operable as Nuclear facility.Nuclear-related Equipment Will Be Sold ML20202G0281986-07-0808 July 1986 Affidavit of Ta Mcnish Re True & Correct Extracts of 860408 & 0618 Minutes of Meetings.Resolutions Recited Therein in Full Force & Effect ML20198J3861986-05-27027 May 1986 Notice of ASLB Reconstitution.C Bechoefer,Chairman & J Harbour & Ga Linenberger,Members.Served on 860529 ML20198J4651986-05-27027 May 1986 Notice of ASLB Reconstitution.C Bechhoefer,Chairman & J Harbour & Ga Linenberger,Members.Served on 860529 ML20137E0041985-11-21021 November 1985 Notice of Appearance in Proceeding ML20137D9651985-11-21021 November 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20133F6421985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20134N3771985-08-30030 August 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl DD-84-17, Order Affirming 840724 Directors Decision DD-84-17 Denying Bp Garde 10CFR2.206 Petition for Action Against Util Re Plant Const.Const Abandoned on 840910.No Further Enforcement Action Required.Served on 8506241985-06-24024 June 1985 Order Affirming 840724 Directors Decision DD-84-17 Denying Bp Garde 10CFR2.206 Petition for Action Against Util Re Plant Const.Const Abandoned on 840910.No Further Enforcement Action Required.Served on 850624 ML20127N7591985-06-20020 June 1985 Transcript of Commission 850620 Affirmation/Discussion & Vote in Washington,Dc Concerning Denial of 2.206 Petition for Midland plant,SECY-85-60 Concerning Pressurized Thermal Shock Rule & Shoreham Order.Pp 1-4 ML20133D9481985-05-13013 May 1985 Response to Aslab 850423 Order.Aslab Should Cancel OL Application & CPs Because Compliance W/Nrc Basic Requirements Not Met ML20116G5181985-04-29029 April 1985 Response to Memorandum of City & County of Midland,Mi Re ASLB 850405 & 0313 Orders on CP Mod Proceedings.Bechtel Should Not Be Granted Admission to Proceedings ML20115J5551985-04-19019 April 1985 City & County of Midland,State of Mi Response to Aslab 850313 Order to File Memoranda Re Whether Aslab Should Vacate ASLB Decision Re Certain Mods to CP Due to Mootness. Proof of Svc Encl ML20115J4751985-04-19019 April 1985 Memorandum in Response to Aslab 850405 Order Re Dismissal of OL Application.Application Neither Abandoned Nor Delayed in Dilutory Manner.Certificate of Svc Encl ML20115J5501985-04-19019 April 1985 Response Opposing Aslab 850405 Memorandum & Order Re Dismissal of OL Applications.Urges Board to Permit OL Applications to Continue in Suspension Until Applicant Affirmatively Resolves Disposition ML20116G5321985-04-19019 April 1985 Motion to Participate as Amicus Curiae in Resolution of Issue to Involuntary Dismissal of License Application,Per Aslab 850405 Memorandum & Order.Granted for Aslab on 850422. Served on 850429 ML20115J4351985-04-19019 April 1985 Motion for Leave to Participate as Amicus Curiae,Per Aslab 850313 & 0405 Memoranda & Orders Requesting Response to Questions Re Proceeding ML20115J5461985-04-19019 April 1985 Motion to Participate Amici Curiae in Resolution of Issue of Involuntary Dismissal of License Application as Identified in Aslab 850405 Memorandum & Order ML20115J5421985-04-19019 April 1985 City & County of Midland,State of Mi Motion for Leave to Participate as Amicus Curiae in Aslab Request for Responses to Questions Presented in 850313 & 0405 Memoranda Orders. Proof of Svc Encl ML20112J5281985-04-0101 April 1985 Memorandum in Response to Aslab 850313 Order LBP-85-2. Decision Should Not Be Vacated.Ol Should Be Dismissed.Based on Listed Changes,New OL Review Required ML20112J6301985-04-0101 April 1985 Memorandum Requesting Aslab Not Take Any Action to Vacate LBP-85-2 or Dismiss OL Applications,Per 850313 Order,Based on Current Intent to Hold CPs & Attempt to Sell Plant. Certificate of Svc Encl ML20112H0981985-03-27027 March 1985 Response to Aslab 840313 Order Re Whether ASLB Decision to Review Issues in Soils Hearing Appropriate Use of Public Resources.Concurs W/Decision to Remand OL W/Instructions to Dismiss OL Application for Failure to Pursue Soils Issue ML20106F6531985-02-0808 February 1985 Response Opposing Intervenor B Stamiris 841224 Motion for Evidentiary Hearings Re Litigation Between Applicant & Dow Chemical Co.Supporting Documentation & Certificate of Svc Encl ML20106D6631985-02-0808 February 1985 Response Opposing B Stamiris 841224 Pleading Requesting Evidentiary Hearing on Matter Raised in applicant-Dow Chemical Trial & Referral of Certain Matters to Ofc of Investigations.Certificate of Svc Encl ML20101S9111985-02-0101 February 1985 Motion for Extension of Time within Which to File Notice of Appeal of ASLB 850123 Partial Initial Decision.Certificate of Svc Encl ML20101S9421985-02-0101 February 1985 Motion for Extension Until 850306 to File Notice of Appeal of ASLB 850123 Partial Initial Decision.Granted by Aslab on 850201 ML20101F3191984-12-24024 December 1984 Request for Evidentiary Hearings on Matter Raised in CPC-Dow Trial & Referral of Certain Matters to Ofc of Investigations.Certificate of Svc Encl ML20107K8011984-11-0101 November 1984 Affidavit of Jd Selby Re Plans Concerning Facilities.Const Will Be Resumed Only If Proposed by Appropriate Governmental Agencies & Officials & If Funds from Some Other Source Become Available.Related Correspondence ML20106F5241984-10-24024 October 1984 Motion to Request ASLB to Cancel Const License & Application for OL ML20094G4411984-07-18018 July 1984 Testimony of Jg Keppler Re QA Problems at Facility & Corrective Actions Taken ML20094P3501984-07-18018 July 1984 Testimony of Rn Gardner Re Allegations Concerning Qualification of Personnel Employed by Camstock 1991-02-26
[Table view] |
Text
TED coimESM#
UNITED STATES OF AMERICA.
00LXETED USNRC NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Boqmp ggs22 40 39 In the Matter of:
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0FFICE OF SECRETARv
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DOCXET'flG & SERvic:~
Docket Nos. 50-329 BRANCH CONSUMERS POWER COMPANY
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50-330 (Midland Plant, Units 1 and 2) )
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Operating License REVISED CONTENTIONS (II) OF MARY SINCLAIR BASED ON REMAINDER OF DISCOVERY FROM NUCLEAR REGULATORY COMMISSION STAFF PURSUANT TO BOARD ORDER OF MAY 25, 1982.
On September 3, 1982, the Nuclear Regulatory Commission ( "N RC " )
Staff completed its responses to interrogatories submitted to it by Mary Sinclair on June 18, 1982.
The following are revised contentions based on that discovery and on new information that relates to the original contentions.
CONTENTION 6 Serious and repeated deficiences in the quality assurance quality control program for Midland demonstrate that construction-of the facility has consistently failed to meet applicable requirements, that the quality assurance / quality control program has failed to detect these violations and assure proper corrective measures, and that an unknown number of serious construction violations now remain in the facility in areas where they can neither be examined nor corrected.
Deficiencies in the quality assurance / quality control program at Midland include the following:
h.
Violations of regulat>ry procedures According to an internal NRC memorandum from R.B. Landsman, Soil
&m ggg Specialist, to W.D. Shafer, Chief, Midland section, dated August 24, 1982,
$8 the Applicant has violated the Board's Order of April 30, 1982, by no og going ahead with construction activities in direct violation of a require-
@g ment to obtain prior NRC staff approval, and it has engaged in deception no og that has repeatedly been a part of the pattornof the Applicant's actions
$4 throughout the construction of Midland.
om O
REVISED CONTENTIONS - 1 p 503
b.
Alteration of Wold Radiographs
- According to I & E Bulletin No. 82-01, Rev.
1, Supplemen'g]
(August 18, 1982), alterations have been discovered in at least d af7 sets of piping weld radiographs for piping supplied to Midland by ITT Grinell Industrial Piping, Inc., of Kernersville, North Carolina.
These radiographs were altered over a period of six years.
As a result of-the alteration's, the quality of the welds is unknown.
It is doubtful that all of the af fected welds c,an be identified and corrected since some may no longer be accessible for inspection.
This is a violation of Criteria I, II, VII, IX, X, XI, XV,.XVI, and XVII of Appendix B to 10 CFR Part 50.
NOt only has the Applicant permitted the installation of noncomplying materials, it has f ailed to assure that its supplier has an effective quality assurance program as well.
This extended failure in an area crucial to reactor safety raises serious questions about the existence of deficiencies in all vendor-supplied items.
c.
Defective Welds in Control Panel; According to I&E Information Notice No. 82-34 (August 30, 1982),
Midland Units 1 and 2 contain defective $ields in the main control panels that were not prevented or detected as required by the quality assurance program.
d.
Paulty welding, piping, and electrical installation The following demonstrate quality assurance / quality control failures in a broad range of areas.
They demonstrate, generally, that the Applicant was incapable of preventing or detecting construction failures through its quality assurance program.
To the extent that the Applicant l
discovered such failures, it was through highly unusual reinspections, j
which are not a normal part of the quality assurance program, and which cannot be relied upon to assure reactor cafety:-
f 1.
Non-Conformance Report of June 19, 1982 which is a f
part of the reinspection to which the Applicant has committed, stat n that 66 weld joints were non-conforming out of 146 reinspected.'
i 2.
Report on Safety Concern and Reportability Evaluation (June 21, 1982) discussed welding defects that were discovered d,urirg reinspection of a sample of installed vnndor cupplied structural beams.
The report states, "The location of all [defectivf7 beams is not i
REVISED CONTENTIONS - 2
~
known, but the sample included beams in the Auxillary building and both containments...The safety impact of weld failure is unknown due to the diverse functions and locations of approximately 2,400 beams."
3.
Quality Action Request (QARF 175) closed out August 24, 1982, indicates that an " increase of approximately 164% has been experienced in the area of (welding) deficiencies."
4.
Non-Conformance Report, closed out on August 26, 1982, states that contrary to ASME requirements, radiographs submitted by Craven Energy Systems displayed mottlings in the vertical weld seams of the borated water storage tanks, a safety related building.
5.
The NRC has identified (Inspection Reports 50-329/
82-07 and 50/330/82-07) defective installation of pipe supports and restraints (NRC response to Interrogatories, p.
- 4), 127 deficiencies, 28% due to defective welds were reported.
6.
According to Applicant's response to Inspection Report 82-07 (Aug. 13, 1982) in the Hanger Report (Aug.
9, 1982), results of the resinspection showed that out of 123 hangers inspected, only 55% were acceptable, 7.
According to Applicant's May 5, 1982, report of the exit meeting of April 23, 1982, the< reinspection conducted by Applicant of piping hangers that had previously been inspected and accepted by Bechtel QC revealed that 43.9% of the hangers inspected were identified as non-conforming.
(Attachment 15 to Aug. 13, 1982 Report) 8.
In their August 30, 1982, letter to the Applicant, Region III stated that while the Applicant's response identified corrective actions taken or planned to be taken regarding the 55 defective hangers identified in Applicant's reinspection, Region III has "no confidence that the remaining hangers have been installed in accordance with the original drawings and specifications."
9.
The Safety Concerns and Reportability Evaluation (June 17, 1982) states that the minimum wall thickness of Piping Class ELB utilizes materials of a different allowable stress (17,500 psi) than the specifications for fittings (15,000 psi) for this class of piping.
10.
Inspection Report 81-23, July 26, 1982, discussed, in addition to rodent damage to insulation, a multitude of discrepancies in the penetrations such as: " conductor insulation cracking at REVISED CONTENTIONS - 3
1 I
module-conductor interfaces; cracks in the module opoxy insulation; j
inadequate crimping by use of improper sized lugs, improper crimping, j
loose terminations, and use of the wrong crimp;' butt splices improperly crimped which could be easily pulled apart and were covered with questionable. insulation; and' loose coaxial cable connections. "
These has not been. prevented or properly detected by Applicant's quality assurance program.
v:
Contention 29
, Dropped Contention 34 The installation of pipe supports.and restraints has been deficient such that there can be no assurance that the public health and safety will be protected.
In particular, (a)
There has been an inadequate examination of the use of snubbers as component supports, and there has been inadequate 3
- consideration of actual and potential snubber malfunction.
(b)
Inspection Reports 50-329/82-07 and 50-330/82-07 identify extensive deficiencies in installation of pipe supports and restraints.
(NRC staff response to Interrogator 13.b, p. 4).
The Applicant's response to the Inspection Report wac-determined to be unacceptable.
(Le tter,
J.A. Mooney, to J.G.
Keppler, dated August 13, 1982, i
file 0.4.2, Serial 17572 and letter, R.F. Warnick to J.W. Cook, dated August 30, 1982).
As a result of these deficiencies, the findings required by 4
j 10 CFR 50.57 (a) (3) (1) and 50.57(a) (6) cannot be made.
Contention 37 The current design criteria for the postulation of pipe breaks and protection therefrom at Midland are inconsistent and have not been justified.
According to Supplement 1 to.the SER, dated July 13, 1982 (p. 6-2), the Staff is conducting a re-review of B&W's small break j
LOCA methods.
The Staff has determined that integral system experimenta.
data are needed to confirm the predicted behavior of the B&W designed nuclear steam supply system.
The Staff has not yet obtained these data.
Accordingly, it is not possible to evaluate the safetyfof the Midland design.
Therefore, the findings required by 10 CFR 50.57 (a) (3) (i) and 50.57 (a) (6) cannot be made with respect to the Midland facility.
2 REVISED CONTENTIONS -4
Contention 43 It is not possible to assure the security of the Midland facility against sabotage or other terrorist acts without seriously infringing on the constitutionally protected civil liberties of plant workers and citizens of the surrounding community.
In such a conflict between constitutional rights and nuclear power, the Constitution must prevail.
Several NRC sponsored reports have been made on the type of security and safeguards that nuclear facilities need.
These include among others, the Rosenbaum Report, the Mitre Report, Barton Report and BDM Report.
These government studies stress the implementation of intelligence operations as the first and one of the most important lines of defense. (Rosenbaum Report)
The priorities are not to preserve basic constitutional rights but to preserve nuclear power as an energy source for our country and the world.
(Mitre Report to the U.S.
NRC, p. 1-26)
These and other studies are discussed in a report called
" Nuclear Power and Civil Liberties - - Can We Have Both," published by the Citizens' Energy Project (CEP) of Washington, D.C.,
in 1979.
That CEP report states that the Mitre Report says that any group which organizes large demonstrations is suspect.
Communities surrounding nuclear plants should be monitored as well. (p.52) The Mitro Report urged the NRC to distribute the intelligence data it gathered to the security officers as each nuclear facility.
The following statement quoting the Mitre Report is carried on page 53 of this study:
"We recommend that NRC maintain a close working relationship with the intelligence community and keep intelligence agencies aware of the information needed by NRC to meet its safeguard responsibilities."
A quote from the Barton Report in this study says: "In constitutional language, the most serious effects are on freddom of association and discussion (particularly on nuclear issues) and on privacy." (p.52)
A 1976 GAO Report found that utility employers were regularly used as " confidential informants" in FBI's investigation of groups and workers at nuclear facilities.
REVISED CONTENTIONS - 5
4 FBI data is recorded in the agency's National Crime Information
' Center (NCIC) computer. (p. 57)
The Georgia Power Co..and Alabama roi.cc CO. t..nc ma LL received Infamation from tha u.puter. (p. 5S) tg Georgia Power Co. opened secret offices in Atlanta to conducQ,,g)
" security" operations, intelligence, surveillance and harassment of citizen anti-nuclear activists and characterized them as a " bolshevik brain trust set up to wreck the electric business." (p. 78)
Now thatthis Administration is pressing for the construction of the Clinch River Breeder Reactor to produce plutonium, the warnings on dangers to civil liberties 'that are carried in the " Harvard Civil Rights--Civil Liberties Law Review," Vol. 10, 1975, p. 369-443 become most important.
The report points out that this plutonium is to be used as additional fuel for nuclear reactors (p. 370).
The author of this report, Russell Ayres, states,
" Plutonium provides the first rational. justification for widespread intelligence-gathering against the civilian population.
In the past, federal courts have taken a skeptical view of attempts to justify spying on national security grounds, but with the very real threat of ' nuclear terrorism (which production of plutonium will invite) in the picture, the justification is going to sound very convincing."
The security of this nuclear plant cannot be assured unless serious infringement of civil liberties of workers and the citizens of the community takes place.
Therefore, the findings required by 10 CFR 50.57 (a) (3) (i) and 10 CFR 50.57 ( A) (6) cannot be made.
Contention 44 -
Dropped Centention 51 -
Dropped Contention 57 -
There is no basis for a finding of reasonatle assurance that the electrical system at Midland will function adecuately because:
1.
It is vulnerable to damage by fire.
In late 1975, it was learned that Bechtel-- the architect-engineer f or the Midland proje ~t --
had tolerated cases where non-safeguard cables routed in safeguard raceways had been terminated and a new non-safeguard cable (same circuit) had been continued in a different safeguard channnl's raceway.
So far as appears, at that time Bechtel took no correctiv REVISED CONTENTIONS -
6
m a.
W.
---J a.--L action to prevent recurrence of that problem and was unable to gli r.ccit.'. ;c assurances that other cables did nc c inilarly viola; the single failure criterion.
Further, in September and October 15 8, a fire test of a full-scale vertical cabic tray array demonstrated that the configuration of fire protection features used in the t
test would not be acceptable for application in nuclear power plants.
The final test reports of several tests conducted for che NRC fire protection research program have not yet been issued.
(NRC Response to Interrogatory 36.a).
There is no assurance that the same cable problems, and the same inadequate' fire protection featuras, do not exist at Midland.
There can be no reasonable as.3urance that the electrical system at Midland will function adequately under accident or fire conditions.
2.
According to an affidavit by an anonymous electrician at the plant, there were serious quality control lapses in the electrical systems that he installed.
For example, where a cable design called for three, shielded pairs of 16-gauge wire, the cable shop would use 6-stranded 16-gauge wire with the shiciding around the entire bundle.
(Midland Daily News, July 28, 1982).
This could result in' a weaker signal than necessary through the wires, and it could contribute to the likelihood of shorting, which could disrupt service and pose a fire hazard.
i Respectfully submitted,
(
/
A.
Le p pg j
Lee Bishop 5
i j
llarmon & Weiss Law Firm i
1725 I St.,
N.W.
Washington, D.C.
(202) 833-9070 I
l 1
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i REVISED CONTENTIONS - 7
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