ML20065M648
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| ML20065M648 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/18/1982 |
| From: | Cassel D, Cassell D DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20065M655 | List: |
| References | |
| NUDOCS 8210210346 | |
| Download: ML20065M648 (1) | |
Similar Documents at Byron | |
|---|---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999
[Table view]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 Category:PLEADINGS MONTHYEARML20102A2981985-01-0707 January 1985
[Table view]Petition Requesting Aslab Grant Intervenor Appeal & Order Further Hearings on Safety of Plant ML20100K0411984-11-22022 November 1984 Submits Concerns Re Safety of Local Residents in Event of Accident & Excessively High Cost of Projected Operation of Facility ML20098G8681984-10-0202 October 1984 Answer to Intervenor Motion to Reopen Record Re Bechtel Independent Design Review.Motion Should Be Denied 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 ML20095F0701984-08-19019 August 1984 Motion to Exclude Portions of Prefiled Testimony of CC Stokes,Filed on 840816.Related Correspondence ML20094S6131984-08-16016 August 1984 Memorandum Opposing Intervenor 840813 Motion for Leave to File Testimony of Wh Bleuel.Bleuel Qualifications Not of Expert Caliber to Assist Aslb.Related Correspondence ML20094P6741984-08-13013 August 1984 Motion for Leave to File Testimony of Wh Bleuel on Contention 1 Re Reinsp Program.Related Correspondence ML20092P2441984-07-0202 July 1984 Motion for Extension of Time to Petition ASLB Re Emergency Planning Contention.Notice of Appearance & Certificate of Svc Encl ML20084J8721984-05-0404 May 1984 Response to Applicants Supplemental Memorandum Re Financial Qualification Issues.Util Attempt to Reargue Opening Brief Should Be Rejected.Certificate of Svc Encl ML20087E0531984-03-12012 March 1984 Response Opposing Applicant Alternative Motion to Reopen Record & Vacate ASLB Denial of Ol.Motion Would Be Considered Acceptable Under Single Issue of Reinspection Program. Certificate of Svc Encl ML20080L0421984-02-13013 February 1984 Motion for Alternative to Reopen Record to Receive Further Evidence.Evidence Described in Encl LO George Affidavit ML20080E8191984-02-0606 February 1984 Motion for Increase in Page Limitation to File Brief Up to 120 Pages.Certificate of Svc Encl ML20080C5441984-02-0303 February 1984 Motion to Limit Consideration of post-record Submissions in Applicant .Certificate of Svc Encl ML20079N5571984-01-25025 January 1984 Motion for Expedition of Util Appeal of 840113 Initial Decision LBP-84-2 Re Inadequate QA Program.Aslab Should Adopt Intervenor Proposed Schedule Which Allows for Full & Fair Briefing on Expedited Basis.W/Certificate of Svc ML20079N3821984-01-24024 January 1984 Motion for Expedited Consideration of Appeal of ASLB Denial of Ol.Facility in Final Stages of Const & Will Be Ready for Fuel Load by 840315.Briefing Schedule Delineated ML20083G0531984-01-0606 January 1984 Addendum to Petition for Emergency Relief Per 10CFR2.206 Re Integrated Leak Rate Testing.All Documentation Re Integrated Leak Rate Tests Must Be Made Public ML20083J6161984-01-0606 January 1984 Response Opposing Intervenor Motion to Reopen Record & for Order Imposing Commitments Re Qa/Qc Issues.Issues Do Not Warrant Reopening Record ML20083D9501983-12-22022 December 1983 Motion to Reopen Record & for Order Imposing Commitments on Util Re Qa/Qc Issues ML20083C2741983-11-29029 November 1983 Petition for Emergency Relief Concerning Unsafe Conditions Re Integrated Leak Rate Testing for Us Nuclear Power Reactor Containments.Severe Errors,Defects & Loopholes Exist in Current Methodology ML20082M6711983-11-29029 November 1983 Petition for Emergency Relief Concerning Unsafe Conditions Re Integrated Leak Rate Testing of Us Nuclear Power Reactor Containments.Severe Errors,Defects & Loopholes Exist in Current Methodology ML20083C2771983-11-29029 November 1983 Petition for Emergency Relief Re Primary Containment Leak Rate at Facilities.Unsafe Condition Exists Re Ability of Primary Containment to Fulfill Design Function ML20081G7381983-11-0202 November 1983 Response Opposing Intervenor 831018 Motion for Discovery on 840215 Fuel Load Date.Discovery Irrelevant to Proceeding Issues & Based on Faulty & Unsupported Premise.Certificate of Svc Encl ML20081C1381983-10-27027 October 1983 Withdrawal of Previous Response to Own Counsel Motion to Strike Proposed Findings of Fact & Conclusions of Law.Motion to Strike Never Filed But Mailed to Svc List to Intimidate Intervenor Into Paying Disputed Fee.Related Correspondence ML20085K9361983-10-18018 October 1983 Motion for Limited Discovery Against NRC & Util Re 840215 Projected Fuel Load Date.Date Critical to Proceeding at Present Stage ML20078H1981983-10-13013 October 1983 Motion to Strike Rockford League of Women Voters Proposed Findings of Fact & Conclusions of Law & for Leave to Withdraw as Rockford Counsel.Rockford Told Counsel of Dissatisfaction W/Findings.Related Correspondence ML20078H1861983-10-13013 October 1983 Response to DC Thomas Motion to Strike Proposed Findings of Fact & Conclusions of Law & to Withdraw as Rockford League of Women Voters Counsel.Rockford Objects to Motion to Strike But Not to Withdrawal.Related Correspondence ML20024D1701983-07-28028 July 1983 Motion for Extension of Time Until 830701 in Which to File Remaining Proposed Findings of Fact & Conclusions of Law. Certificate of Svc Encl ML20024D1661983-07-28028 July 1983 Motion to Strike Intervenor 830701 Revised Findings of Fact & Opinion on Contention 22 Re Steam Generator Tube Integrity.Substantive Changes Made.If Motion Denied,Util Requests 10 Days to Respond ML20077B6711983-07-22022 July 1983 Response Opposing NRC Application for Stay of ASLB 830701 Memorandum & Order,Memorializing 830629 & 30 Conference Call Rulings.Nrc Showing of Irreparable Harm Insufficient. Certificate of Svc Encl ML20077C9861983-07-22022 July 1983 Response Opposing Govt Accountability Project Motion for Leave to File Amicus Curiae Brief Re NRC 830708 Certification Motion.Project Interest ill-founded & Arguments Immaterial.Certificate of Svc Encl ML20077C9241983-07-21021 July 1983 Response Opposing NRC 830711 Application for Stay of Effectiveness of 830621 & 0701 Orders Re Withholding Evidence.Requisite Showing to Support Stay Not Established. Certificate of Svc Encl ML20077D2031983-07-21021 July 1983 Response Supporting Intervenor Motion to Suppl Qa/Qc Record on Preoperational Testing,Per 830721 Telcon.Qa/Qc Concerns Arise Out of Entire Scope of Region III Insps & Cannot Be Separated from Preoperational Testing ML20076N1711983-07-19019 July 1983 Response Supporting NRC 830708 Motion for Directed Certification of Issue of Disclosure of Detailed Info Re Allegations Subj to Ongoing Insps & Investigations.Notices of Appearance & Certificate of Svc Encl ML20077A5441983-07-19019 July 1983 Motion for Leave to File Amicus Curiae Brief Re NRC Refusal to Provide Info Re Allegations Which Are Subj of Ongoing Investigations.Govt Accountability Project Has Substantial Experience W/Region III ML20077A5501983-07-19019 July 1983 Amicus Curiae Brief Re NRC Refusal to Provide Info Re Allegations Which Are Subj of Ongoing Investigations.Nrc Has No Valid Legal Excuse to Withhold Evidence in Dispute.Nrc Violated Legal Duty to Disclose Info.W/Certificate of Svc ML20076L3221983-07-13013 July 1983 Opposition to Intervenor Motion to Suppl Qa/Qc Record Re Preoperational Testing.Motion Deals W/Matters Tangential & Immaterial to QA Issues.Certificate of Svc Encl ML20085A2791983-06-29029 June 1983 Motion to Suppl Closed Qa/Qc Record W/Info on Preoperational Testing.Exhibits Show Evidence of Severe Deficiencies in Preoperational Testing Program.Certificate of Svc Encl ML20072J7341983-06-29029 June 1983 Motion for Extension Until 830701 to File Remaining Proposed Findings of Fact & Conclusions of Law for Parties ML20072G5101983-06-23023 June 1983 Motion for Extension Until 830715 to Reply to Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ & Rockford League of Women Voters Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20072E5561983-06-21021 June 1983 Motion for Leave to File out-of-time Reply to Proposed Findings of Fact & Conclusions of Law on Waterhammer.Addl Time Needed Due to Demands Imposed by Preparation of Other Documents ML20076J1021983-06-14014 June 1983 Motion for Extension Until 830628 to File Proposed Findings of Fact & Conclusions of Law Re Contentions 22 & 9(c) ML20072A0621983-06-0707 June 1983 Supplementary Memorandum Opposing Intervenor Motion to Reopen Record.Neither Triable Issue Nor Significant Safety Issue Exists Re Hughes Allegations.Certificate of Svc Encl ML20072A6131983-06-0707 June 1983 Brief Supporting Motion to Admit J Hughes Testimony. Intervenors Have Raised Serious & Significant Safety Issues Re Quality of Work at Plant.Hughes Testimony Should Be Considered in Ruling on Contention 1A.W/Certificate of Svc ML20071N1731983-06-0303 June 1983 Complaint Filed in Circuit Court of Seventeenth Judicial Circuit,Winnebago County,Il Requesting Imposition of Punitive Damages for Wrongful Diversion of Waste Water Onto Plaintiff Property ML20023C7081983-05-12012 May 1983 Motion to Receive Into Evidence Stipulation & Portions of Prefiled Testimony.Stipulation Covers Admissibility of Affidavits & Exhibits Bearing on Emergency Planning Matters. W/Unexecuted Stipulation ML20079P9081983-05-0909 May 1983 Response in Opposition to Rockford League of Women Voters & Dekalb Area Alliance for Responsible Energy/Safe Alternatives for Future Energy Motion to Allow Testimony of J Hughes on Qa/Qc.Certificate of Svc Encl ML20069M4611983-04-27027 April 1983 Motion to Permit J Hughes Testimony Re Qa/Qc at Facility & to Shorten Time for Responses by Util & Nrc.Matters of Testing Documentation & Welding Constitute Significant Safety Issues ML20072F6611983-03-21021 March 1983 Motion for Leave to Respond to Intervenor 830317 Reply to Licensee Response to ASLB 820914 Order,By 830405.Licensee Entitled to Respond to Specific Issues Raised by Intervenors.Certificate of Svc Encl ML20069M2191982-11-18018 November 1982 Motion to Direct NRC to Commence Special Insp Immediately of Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Allegations of Unsafe Qa/Qc Practices at Plant 1985-01-07 |
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r ,
.- o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKET @
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Dockets Nos. 50-454 3 0F SE
) 50-455 '"I$NSd (Byron Station, Units 1 and 2) )
DAARE/ SAFE MOTION FOR LEAVE TO FILE ATTACHED REPLY DAARE/ SAFE, by its undersigned counsel, moves for leave to file the attached reply which addresses new matters raised for the first time by Commonwealth Edison and the NRC Staff in their responses to DAARE/ SAFE's motion. Fairness suggests that DAARE/ SAFE, too, be afforded an opportunity to address these new matters.
DATED: October 18, 1982 Respectfully submitted, Douglass W. Cassel, Jr.
Jane M. Whicher by: O/ h Dougla"ss W. Cassel, Jr.
Attorneys for DAARE/ SAFE on matters relating to Quality Assurance / Quality Control Douglass W. Cassel, Jr.
Jane M. Whicher 109 North
Dearborn,
- 1300 Chicago, IL 60602 (312) 641-5570 9210210346 821018
{DRADOCK 05000454 PDR
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