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Category:INTERVENTION PETITIONS
MONTHYEARML20116M7641989-01-30030 January 1989 Petition for Immediate Action to Protect Public Health & Safety from Undue Risks Posed by Lack of Quality Assurance Compliance at Wolf Creek Generating Station,Burlington,Ks ML20092A4531984-06-15015 June 1984 Answer Opposing Kansans for Sensible Energy 840222 Motion to Have Status as Intervenor & Financial Qualifications Contention Reinstated.Certificate of Svc Encl ML20087B3481984-03-0606 March 1984 Petition of Nuclear Awareness Network for Leave to Intervene & Request for Hearing.Certificate of Svc & Affidavits Encl ML20081C4521984-03-0606 March 1984 Response to Applicant 840203 & Staff 840208 Responses to Nuclear Awareness Network 840119 Petition to Intervene & Request for Hearing.Requests for late-filed Intervenor Status Should Be Granted.Certificate of Svc Encl ML20080R7851984-02-22022 February 1984 Motion to Have Status as Intervenor & Financial Qualifications Contention Reinstated.Certificate of Svc Encl ML20080B5871984-02-0303 February 1984 Responds to Nuclear Awareness Network,Inc 840119 Petition for Leave to Intervene & Request for Hearing.Petition Untimely,Unjustified & Should Be Denied in Entirety ML20079H8251984-01-19019 January 1984 Petition of Nuclear Awareness Network,Inc for Leave to Intervene & Request for Hearing.Certificate of Svc Encl ML20083F5541983-12-27027 December 1983 Amended Answer to Intervenor 831207 Motion to Add Contention & Witnesses.Opposition to Request to Call Addl Witnesses Withdrawn.Certificate of Svc Encl ML20082R4531983-12-0808 December 1983 Request to Add Contention & Witnesses.Certificate of Svc Encl ML20074A2031983-05-0505 May 1983 Attachment A,Alternative Evacuation Plan Contention,To Response in Opposition to Intervenors W Christy & Me Salava 830330 Objections to ASLB 830318 Prehearing Conference Order.Related Correspondence ML20073P4831983-04-20020 April 1983 Response to Applicant 830415 Response Re Intervenor Objection to 830310 Prehearing Conference Order.Objection to Be Withdrawn,Provided Contentions Can Be Amended After Stipulation Based on New Info.Certificate of Svc Encl ML20073B6791983-04-0606 April 1983 Proposed Stipulation of Contention Re Inadequacy of Coffey County & State of Ks Emergency Preparedness Plan.Details Intervenor Objections ML20126H4331981-03-31031 March 1981 Contentions Supporting Request to Intervene in Facility Licensing Proceeding.No Plant Should Be Licensed Until Workable Evacuation Plan Has Been Developed.County Has No Serviceable Plan or Funds for Needed Manpower & Equipment ML19341D7241981-03-30030 March 1981 Amended Petition to Intervene in Proceeding.Certificate of Svc Encl ML20003E7361981-03-21021 March 1981 Contention Supporting 810113 Petition to Intervene in Facility OL Proceeding.Facility Should Not Be Licensed W/O Workable Evacuation Plan ML19345E8601981-02-0303 February 1981 Answer Opposing Kansans for Sensible Energy Petition for Leave to Intervene.Standing Requirements Not Met by Petitioner Conservation Interests or Residence.Requests Special Prehearing Conference.Certificate of Svc Encl ML19341A4831981-01-19019 January 1981 Petition for Leave to Intervene ML19341A6051981-01-16016 January 1981 Petition for Leave to Intervene in Proceeding.Certificate of Svc Encl ML20062L1921981-01-13013 January 1981 Petition to Intervene in Proceeding.Certificate of Svc Encl ML20049A3801981-01-0606 January 1981 Petition to Intervene in Proceeding.Certificate of Svc Encl ML20002E0501980-12-16016 December 1980 Petition for Leave to Intervene in Proceeding.Affidavit & Certificate of Svc Encl 1989-01-30
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20116M7641989-01-30030 January 1989 Petition for Immediate Action to Protect Public Health & Safety from Undue Risks Posed by Lack of Quality Assurance Compliance at Wolf Creek Generating Station,Burlington,Ks ML20092A4531984-06-15015 June 1984 Answer Opposing Kansans for Sensible Energy 840222 Motion to Have Status as Intervenor & Financial Qualifications Contention Reinstated.Certificate of Svc Encl ML20087B3481984-03-0606 March 1984 Petition of Nuclear Awareness Network for Leave to Intervene & Request for Hearing.Certificate of Svc & Affidavits Encl ML20081C4521984-03-0606 March 1984 Response to Applicant 840203 & Staff 840208 Responses to Nuclear Awareness Network 840119 Petition to Intervene & Request for Hearing.Requests for late-filed Intervenor Status Should Be Granted.Certificate of Svc Encl ML20080R7851984-02-22022 February 1984 Motion to Have Status as Intervenor & Financial Qualifications Contention Reinstated.Certificate of Svc Encl ML20080B5871984-02-0303 February 1984 Responds to Nuclear Awareness Network,Inc 840119 Petition for Leave to Intervene & Request for Hearing.Petition Untimely,Unjustified & Should Be Denied in Entirety ML20079H8251984-01-19019 January 1984 Petition of Nuclear Awareness Network,Inc for Leave to Intervene & Request for Hearing.Certificate of Svc Encl ML20083F5541983-12-27027 December 1983 Amended Answer to Intervenor 831207 Motion to Add Contention & Witnesses.Opposition to Request to Call Addl Witnesses Withdrawn.Certificate of Svc Encl ML20082R4531983-12-0808 December 1983 Request to Add Contention & Witnesses.Certificate of Svc Encl ML20074A2031983-05-0505 May 1983 Attachment A,Alternative Evacuation Plan Contention,To Response in Opposition to Intervenors W Christy & Me Salava 830330 Objections to ASLB 830318 Prehearing Conference Order.Related Correspondence ML20073P4831983-04-20020 April 1983 Response to Applicant 830415 Response Re Intervenor Objection to 830310 Prehearing Conference Order.Objection to Be Withdrawn,Provided Contentions Can Be Amended After Stipulation Based on New Info.Certificate of Svc Encl ML20073B6791983-04-0606 April 1983 Proposed Stipulation of Contention Re Inadequacy of Coffey County & State of Ks Emergency Preparedness Plan.Details Intervenor Objections ML20126H4331981-03-31031 March 1981 Contentions Supporting Request to Intervene in Facility Licensing Proceeding.No Plant Should Be Licensed Until Workable Evacuation Plan Has Been Developed.County Has No Serviceable Plan or Funds for Needed Manpower & Equipment ML19341D7241981-03-30030 March 1981 Amended Petition to Intervene in Proceeding.Certificate of Svc Encl ML20003E7361981-03-21021 March 1981 Contention Supporting 810113 Petition to Intervene in Facility OL Proceeding.Facility Should Not Be Licensed W/O Workable Evacuation Plan ML19345E8601981-02-0303 February 1981 Answer Opposing Kansans for Sensible Energy Petition for Leave to Intervene.Standing Requirements Not Met by Petitioner Conservation Interests or Residence.Requests Special Prehearing Conference.Certificate of Svc Encl ML19341A4831981-01-19019 January 1981 Petition for Leave to Intervene ML19341A6051981-01-16016 January 1981 Petition for Leave to Intervene in Proceeding.Certificate of Svc Encl ML20062L1921981-01-13013 January 1981 Petition to Intervene in Proceeding.Certificate of Svc Encl ML20049A3801981-01-0606 January 1981 Petition to Intervene in Proceeding.Certificate of Svc Encl ML20002E0501980-12-16016 December 1980 Petition for Leave to Intervene in Proceeding.Affidavit & Certificate of Svc Encl 1989-01-30
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196K7991999-07-0606 July 1999 Comments of Nuclear Energy Institute,Inc on Treatment of Existing Antitrust Conditions in License Transfer Cases.* Recommends Establishing Basic Guidelines for Evaluating Disposition of Antitrust Conditions.With Certificate of Svc ML20196H1511999-06-30030 June 1999 Response of Wml Associates to Commission Memorandum & Order CLI-99-19.* Strongly Urge Commission to Reconsider Decision in CLI-99-19 & Seek Congressional Input,Per Commission Review Responsibilities.With Certificate of Svc ML20195J4341999-06-18018 June 1999 Memorandum & Order.* Concludes That AEA Does Not Require Antitrust Reviews of post-operating License Transfer Applications & Dismisses Kepco Petition to Intervene on Antitrust Grounds.With Certificate of Svc.Served on 990618 ML20206H3351999-04-30030 April 1999 Exemption from Certain Requirements of 10CFR50.60, Acceptance Criteria for Fracture Prevention Measures for Lightwater Nuclear Power Reactors for Normal Operation. Exemption Related to Application ML20205K9381999-04-0505 April 1999 Amicus Curiae Brief Wml Associates.* Commission Should Not Eliminate Antitrust Review of License Transfers,For Listed Reasons.With Certificate of Svc ML20205C8081999-03-31031 March 1999 Affidavit of D Penn.* Affidavit of D Penn in Support of NRC Antitrust License Conditions & Significant Impacts Conditions Have in Shaping Competitive Electric Markets ML20205C7681999-03-31031 March 1999 Amicus Filing National Association of State Utility Consumer Advocates.* Brief Submitted in Accordance with Memo & Order of 990302 & in Support of Argument 1 in Initial & Reply Briefs of Kepco & Nreca.With Certificate of Svc ML20205G0511999-03-31031 March 1999 Amicus Brief of Nuclear Energy Institute on Issue of Antitrust Reviews in License Transfer Cases.* Industry Supports Agency Actions & Urges Commission to Implement Recommended Changes.With Certificate of Svc ML20205C8701999-03-31031 March 1999 Motion to Submit Comments & Comments of Amici Curiae of American Antitrust Institute.* for Listed Reasons, Interpreting Act as If No Transfer Took Place Would Turn Statutory Purpose on Its Head.With Certificate of Svc ML20205C7791999-03-31031 March 1999 Joint Brief of American Public Power Association & Florida Municipal Power Agency.* Brief Addresses Question on Whether Commission May & Should Eliminate All Antitrust Reviews in Connection with License Transfers.With Certificate of Svc ML20204H5211999-03-23023 March 1999 Reply to Brief of Applicants in Response to Joint Brief of Kansas Electric Power Cooperative & National Rural Electric Cooperative Association.* Petition Should Be Dismissed.With Certificate of Svc ML20205A8561999-03-23023 March 1999 Reply Brief of Kansas Electric Power Cooperative Inc.* Facts of Case Warrant Changes Occurred.Commission Should Perform Changes Review in Case & Based on Results Should Perform Antitrust Review on Competition.With Certificate of Svc ML20207M8241999-03-16016 March 1999 Joint Brief of Kansas Electric Power Cooperative,Inc & Amicus Curiae Natl Rural Electric Cooperative Assoc.* Commission Should Perform Significant Changes Review Mandated by Statute & Regulations.With Certificate of Svc ML20204E5131999-03-16016 March 1999 Initial Brief of Applicants in Response to NRC Memorandum & Order Re Antitrust Review of License Transfers.* Commission Should Deny Licensee Petition,For Listed Reasons.With Certificate of Svc ML20207G3041999-03-0303 March 1999 Computer Access & Operating Agreement Between NRC & WCNOC, for Purpose of Providing NRC with Access to Certain WCNOC Computer Data Bases ML20154K2231998-10-0707 October 1998 Comment Opposing Integrated Review of Assessment Process for Commercial Nuclear Power Plants.Wolf Creek Endorses Comments Submitted by NEI in from Re Beedle to Dl Meyer ML20217F5411998-03-26026 March 1998 Comment Re Draft RG DG-5008, Reporting of Safeguards Events ML20202C1411998-01-29029 January 1998 Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Nuclear Power Plants ML20141D5191997-06-24024 June 1997 Exemption from Requirements of 10CFR70.24, Criticality Accident Requirements, for Plant,Granted ML20148N0641997-06-19019 June 1997 Comment on Proposed Suppl to NRC Bulletin 96-001, Control Rod Insertion Problems ML20136H6441997-03-14014 March 1997 Comment Opposing Proposed NRC GL 97-XX Loss of Reactor Coolant Inventory & Associated Potential for Loss of Emergency Mitigation Functions While in Shutdown Condition ML20086M8151995-07-13013 July 1995 Comment Supporting Proposed Generic Ltr Re Process for Changes to Security Plans W/O Prior NRC Approval ML20077E8671994-12-0808 December 1994 Comment Supporting Proposed Rule 10CFR2,51 & 54 Re Regulations Governing NPP License Renewal Process ML20077E1861994-12-0202 December 1994 Comment Supporting Proposed GL on Reconsideration of NPP Security Requirements for Internal Threat.Endorses Comments Submitted to NRC by NUMARC on 941202 ML20076L1471994-10-24024 October 1994 Comments on Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Endorses Response Submitted by Nuclear Energy Institute ML20045D7351993-06-0303 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule ML20094L4441992-03-20020 March 1992 Application Under Exigent Circumstances to Extend Effective Period of NRC Approval of Transfer & Amend to OL NPF-42 in Connection W/Merger of Ksge W/Kansas Power & Light Co ML20091A2281992-03-18018 March 1992 Comment Endorsing Comments Provided by NUMARC Re Proposed Rule 10CFR51 Re Requirements for Environ Review of Applications to Renew OLs for Nuclear Power Plants ML20095B7741992-03-17017 March 1992 Application Under Exigent Circumstances to Extend Effective Period of NRC Approval of Transfer of & Amend to License NPF-42 in Connection W/Merger of Ksge W/Kansas Power & Light Co ML20073P7301991-05-16016 May 1991 Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery ML20073F9331991-04-25025 April 1991 Testimony Re Application of Kansas Power & Light Co & Kca Corp for Approval of Acquisition of All Classes of Capital Stock of Kansas Gas & Electric Co,To Merge W/Kansas Gas & Electric Co,To Issue Stock & Incur Debt Obligations ML20029A7471991-02-0606 February 1991 Testimony of Kpl Gas Svc & Ks G&E Re Co Merger ML20245J8761989-06-26026 June 1989 Director'S Decision 89-04,denying Sierra Club of Kansas 2.206 Petition to Revoke Ol,Based on Safety Concerns W/Qa Program & Mgt Failure to Safeguard Integrity of QA Program ML20116M7641989-01-30030 January 1989 Petition for Immediate Action to Protect Public Health & Safety from Undue Risks Posed by Lack of Quality Assurance Compliance at Wolf Creek Generating Station,Burlington,Ks ML20155G0961988-09-30030 September 1988 Exemption from Schedular Requirements of Property Insurance Rule 10CFR50.54(w)(5)(i),effective 881004 ML20151K0201988-07-28028 July 1988 Order Imposing Civil Monetary Penalty in Amount of $100,000 Re Mgt Oversight of safety-related Activities to Preclude Procedural Control Weaknesses ML20236Q2501987-11-12012 November 1987 Petition Per 10CFR2.206 Requesting Investigation of Plant Security Problems Resulting from Easy Access to Cooling Lake Which May Be Exploited by Terrorists.Supporting Info & Certificate of Mailing Encl ML20150C2791987-06-0303 June 1987 Sanitized Version of Investigative Interview of Rl Scott Conducted by Hb Griffin on 870603 Re Util Investigation ML20150C3011987-05-13013 May 1987 Sanitized Version of Investigative Interview of GL Koester on 870513 Re Investigation of Util ML20150C2931987-05-12012 May 1987 Sanitized Version of Interview of C Snyder by Hb Griffin on 870512 in Burlington,Ks Re Investigation of Util ML20150C2401986-08-21021 August 1986 Sanitized Version of 860821 Testimony of OL Thero in Lebo,Ks Re Investigation of Util ML20150C2581986-06-27027 June 1986 Sanitized Version of Investigative Interview of C Hill Taken by DD Driskill on 860627 Re Plant Quality First Program ML20125E0641985-06-0404 June 1985 Unexecuted Amend 3 to Indemnity Agreement B-99,changing Item3 Re License Number ML20138P8761985-06-0303 June 1985 Transcript of Closed Commission 850603 Meeting in Washington,Dc for Discussion of Pending Investigations. Pp 1-48.Portions Deleted ML20138B6151985-06-0303 June 1985 Transcript of Closed Commission 850603 Meeting in Washington,Dc Re Pending Investigations.Pp 1-38.Portions Deleted ML20126E3881985-06-0303 June 1985 Transcript of Commission 850603 Meeting in Washington,Dc Re Discussion/Possible Vote on Full Power OL for Facility. Pp 1-46 ML20128P2971985-05-28028 May 1985 Affidavit of Kr Brown Re Gap 850515 Petition Filed Per 10CFR2.206 Concerning Util Quality First Program.Program Provides Mechanism for Personnel to Confidentially Rept on Concerns Re Quality at Facility ML20128P3111985-05-28028 May 1985 Affidavit of CA Snyder Re Development,Staffing,Mgt, Implementation & NRC Review of Quality First Program. Supporting Documentation Encl ML20090F5211984-07-17017 July 1984 Motion for Clarification of ASLB 840702 Initial Decision Re Offsite Emergency Planning,Including Info on Two Conditions, Evacuation of Hosp & Nursing Home Patients & Redmond Reservoir Notification.Certificate of Svc Encl ML20092J7771984-06-25025 June 1984 Proposed Corrections to Transcript of Evidentiary Hearings 1999-07-06
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! .1 UNITED STATES OF AMERICA
'83 gpg 11 l NUCLEAR REGULATORY COMMISSION A9:57 i
- oi.
- x Before the Atomic Safety and Licensing Board 2'd
In the Matter of )
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'! KANSAS GAS AND ELECTRIC COMPANY, et. al. ) Docket No. 50-482
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i (Wolf Creek Generating Station, )
Unit No.1) )
- PROPOSED STIPULATION OF CONTENTIONS i
As directed by the Board's Prehearing Conference Order, the intervenors.
Mary Ellen Salava and Wanda Christy, offer the following as a detailed explanation j of their contention about the inadequacy of the Coffey County and State of I
Kansas Emergency Preparedness Plans.
] The intervenors' contention which was admitted is as follows: " Local I
j govemments do not have a workable evacuation plan and the Wolf Creek facility i
j should not be licensed until there is a workable plan and until the government i
) bodies in the evacuation area are suf ficiently staffed, equipped, and funded 1
- to successfully carry out evacuation plans."
i i Paragraphs 1 - 21 below specify in detail the objections of the intervenors, f and should be adopted as the Stipulation of Contentions.
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- 1. (a.) ' The State and County Plans are deficient because all personnel who have been assigned responsibilities in the plans are not adequately trained and are not sufficiently familiar with the plans and their responsibilities.
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. PDR ADOCK 05000482 PDR r ,
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(b) In many instances, personnel who are to perform a function have not been selected.
(c.) Assigned functions have not been cprried out in many instances by the individual responsible for the function.
- 2. The details of the plans are not adequate. In most instances, the plans are deficient because they do not provide suf ficient detail about how, when, and with what equipment emergency personnel charged with a responsibility will handle it.
- 3. The plans make no provisions for paying the costs of carrying out j the plans. Such costs will be incurred for equipment, shelter facilities, emergency workers' salaries, use of equipment, housing of evacuees, medical costs, and training.
- 4. (a.) The plans are deficient because they do not adequately specify.
the number of people and the type and amount of equipment and facilities that will be required to meet a duty specified under the plan.
(b.) Frequently, the plans underestimate the number of people that will be required to perform a function.
(c.) In many instances, not enough people are available to perform l an assigned function.
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(d.) The plans do not specify how people who have duties under .
the plans will be recruited.
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l (e.) Frequently, the plans require people to perform two functions at the same time.
- 3. The plans are deficient because they do not adequately detail how to evacuate transients and do not provide how they will be sheltered if that response rather than evacuation is chosen.
- 6. The plans ar.e deficient because they do not give officials making a decision about evactation or another emergency response sufficient guide-i lines about choosing cne response in preference to another. The plans should provide detailed guidelines about what emergency response is to be chosen in specified circumstances and at certain stages of an accident.
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- 7. The plans are insufficient because they do not provide adequate
! backup personnel for officials or workers who are not available to perform their duties. Also, they do not specify what will be done if people or equipment are not available.
- 8. The plans are deficient because they rely on the assumption that emergency workers and the general public will always act as directed and in a very rational manner. The plan should make adequate provision to deal i
with people (workers and the general public) who fail to respond or respond i
in ways other than assumed. The plans cannot assume that people will respond in a nuclear emergency as they will in any other disaster situation.
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- 9. The plans are deficient because they do not give adequate consideration l l
to the problems weather conditions, severe weather, and changes in weather 1
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i j will create. The plans do not provide enough flexibility to deal with weather j problems that will occur.
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- 10. The plans do not take into consideration,the full range of accident j scenarios that can occur. For example, sheltering might be selected as a response and then later evacuation would be appropriate. The plans do not i
f prepare emergency personnel to consider enough of the possibilities and problems that can occur and then provide them alternatives to meet these various possibilities.
The plans do not adequately consider the number of people who will have to
, be dealt with at various times.
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i 11. The plans are deficient because they do not contemplate that a very 4
l substantial number of radiologicalinjuries can occur. Hundreds or-even more i
j such injuries could occur. The plans do not provide for quick and adequate i
] evacuation and treatment for that number of injuries. Also, hospital facilities j for that number of people have not been arranged for, and the hospitals are l- not prepared to deal with that number of injuries, a
i i 12. (a.) The State and the County Plans make reference to the other I
! plan and indicate that certain functions will be coordinated or that the State j
i or the County will supplement the other. The details of such cooperation and i
, supplementation are not adequately specified. Therefore, confusion and lack l of action will result during an emergency response at the time of an accident.
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- (b.) In some instances, one part of the State or the County plan conflicts with another part about what will be done and who is responsible for a specified duty.
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< 13. Much of the equipment and facilities required.to implement the plans i l are not available or are inadequate. Also, little, if any, plans have been made i
- to obtain such equipment or facilities.
l 14. The amount of time required to complete an evacuation will be longer
! than is indicated in the plans. Because the estimated evacuation time is not correct, officials may choose an emergency response that will cause more injuries. Also, because the time estimate is too short, the number of injuries
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that can occur will be under estimated.
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- 15. The plans are deficient because adequate methods to educate the i
j public about how to respond to an emergency have not been developed. The details of such education should be specifically set forth in the plan. The draft
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emergency notices to be broadcast during an emergency are not adequate.
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- 16. In the event of an accident, the initial notice of the accident to the public cannot be made in the time rcquired by NUREG 0654, and some people will not receive the warning notice as required.
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- 17. The emergency plans are deficient because details about the extent i
of drills and exercises and their planning and conduct are not included in the plans. Coffey County and the State of Kansas have made little and inadequate '
preparation for such drills and exercises.
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- 18. The plans do not provide adequate assurance that they will be reviewed and revised in a timely manner. Also, there is no indication of how the public
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will be kept advised of changes in the plans so they can attempt to respond l 1
properly when an accident occurs. The plans do not adequately provide for the checking of equipment and maintenance on sirens, radiation monitoring equipment, and other equipment required to implement the plans.
- 19. The plans do not provide enough detail about training programs, and i few, if any, plans for these programs have been developed. The plans do not provide any adequate means to test if the emergency personnel and the general public adequately understand their duties and roles at the time of an accident.
- 20. The plans are deficient because there is inadequate provision for i
coordination of specified duties between units of government and within a governmental unit.
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- 21. The plans are deficient because in some instances, one plan contradicts 1
the provisions in another plan about who is responsible for a function or the plans lack sufficient details to make it clear which unit of government and its personnel will be responsible for a particular function.
i A %. h Tohn M. Simpson Attorney for Intervenors, Wanda Christy and Mary Ellen Salava 4350 Johnson Drive, Suite 120 Shawnee Mission, KS 66205
, (913) 384-9144 Dated: M S ,1983 1
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