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Category:AFFIDAVITS
MONTHYEARML20079R8351983-06-0707 June 1983 Affidavit of Gb Varnado Re ASLB Consultant Pj Amico Recommendation to Provide Expert Testimony on Risk Significance of Sabotage.Nrc Studies & PRA Do Not Estimate Risk of Sabotage.Prof Qualifications Encl ML20076J0441983-05-31031 May 1983 Affidavit of RA Rosen on Commission Question 6.3.ESRG Model Underestimated Average 1982 Saltwater PWR Capacity by 9.5%. Value of Model Should Be Assessed Based on Ability to Track Experience Over Period of Time ML20074A7401983-05-10010 May 1983 Affidavit of I Levi Clarifying 830211 Testimony Re Suggested Method of Making Sensible Probability Judgments Described in Section 5 ML20073R3511983-04-26026 April 1983 Affidavit of KT Erickson & Aj Solnit Re Radiological Emergency Response Plan ML20069L2361983-04-19019 April 1983 Affidavit of Ms Della Rocca in Support of Motion for Admission Into Evidence of EPZ Tour Documents,Exhibits CE-11,CE-11A & CE-11B.One Oversize Map Encl.Aperture Card Available in Pdr.Certificate of Svc Encl ML20069F4911983-03-17017 March 1983 Affidavit of CM Pratt Supporting Licensee Motion to Impose Sanctions on D Corren & R Rosen of Greater Ny Council on Energy & Energy Sys Research Group,Inc for Failure to Respond to Interrogatories.Document Request Encl ML20053D0941982-05-27027 May 1982 Affidavit of Jm Blum Supporting Ucs 820527 Motion for Order Compelling Util to Produce RR Dynes,S Lecker,Pl Rosenblatt, MD Rocca & B Podwal for Depositions.Certificate of Svc Encl ML20039G0391981-12-31031 December 1981 Affidavit of a Latman,Westchester Peoples Action Coalition Atty,Authorizing Organization to Represent Interests in Proceeding ML20039E1491981-12-17017 December 1981 Affidavit of D Valinsky That Nypirg Survey Was Not Designed to Elicit Objective Responses Re Attitudes or Knowledge of Emergency Evacuation Plans But Was Designed to Intimidate & Frighten.Prof Qualifications Encl ML20039A7461981-12-0808 December 1981 Affidavit of OL Rosenberg Authorizing Ny City Audubon Soc to Represent Interests ML20039G7411981-12-0707 December 1981 Affidavit Supporting NRC Motion to Dismiss Ucs & Ny Pirg Petitions for Review of NRC Decision Re Status of Offsite Radiological Emergency Response Plan.Emergency Planning Evaluation Process Incomplete.Related Correspondence ML20033C9671981-12-0101 December 1981 Affidavit Supporting PASNY Motion to Exclude Fear as Issue in Proceeding.Listed Documents Contain No Useful Info & Are Designed to Generate Fear Reaction.Certificate of Svc Encl ML19350F1691981-06-19019 June 1981 Affidavit That Licensees Could Not Meet CLI-80-21 820630 Deadline Due to Lack of Appropriate Regulatory Guidance to Allow Utils to Proceed W/Qualification,Replacement or Reanalysis of Equipment.W/Certificate of Svc ML19246B1491979-06-15015 June 1979 Avers Familiarity W/Contents of l976 Year Class Rept for Multiplant Impact Study of Hudson River Estuary, May 1979. Contents of Rept Are True ML19225A2801979-06-0606 June 1979 Affidavit Stating Familiarity W/Contents of June 1979 Document on Efficiency of Epibenthic Sled for Collecting Perch in 1978.Rept Prepared by Tx Instruments,Inc for Util 1983-06-07
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARJPN-99-029, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirement for Nuclear Power Reactors1999-09-20020 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirement for Nuclear Power Reactors ML20212E4181999-09-15015 September 1999 Petition Per 10CFR2.206 Requesting OL for Unit 2 Be Modified or Suspended to Prevent Restart Until Reasonable Assurance That Licensee in Substantial Compliance with Terms of OL & Has Proper Consideration for Public Health & Safety JPN-99-022, Comment Supporting Proposed Rule 10CFR50 Re Requirements for Industry Codes & Stds1999-06-22022 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Requirements for Industry Codes & Stds ML20202J6321999-01-20020 January 1999 Transcript of 990120 Meeting in Peekskill,Ny Re Decommissioning.Pp 1-132.With Related Documentation ML20198L2731998-12-21021 December 1998 Comment Supporting NEI Re Proposed Rules 10CFR50, 52 & 72 Re Changes,Tests & Experiments ML20198E9721998-12-21021 December 1998 Order Prohibiting Involvement in NRC-Licensed Activities. Orders That Wh Clark Prohibited for 1 Yr from Engaging in NRC-Licensed Activities JPN-98-052, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects JPN-98-050, Comment on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Encourages NRC Staff to Withdraw Proposed Change & to Work with Nuclear Power Industry & Other Stakeholders to Accomplish Goal1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Encourages NRC Staff to Withdraw Proposed Change & to Work with Nuclear Power Industry & Other Stakeholders to Accomplish Goal ML20155F4561998-08-26026 August 1998 Demand for Info Re False Info Allegedly Provided by Wh Clark to Two NRC Licensees.Nrc Considering Whether Individual Should Be Prohibited from Working in NRC-licensed Activities for Period of 5 Yrs IA-98-261, Partially Deleted Transcript of 980520 Enforcement Conference in King of Prussia,Pa Re J Stipek.Pp 1-461998-05-20020 May 1998 Partially Deleted Transcript of 980520 Enforcement Conference in King of Prussia,Pa Re J Stipek.Pp 1-46 ML20238F5271998-05-20020 May 1998 Partially Deleted Transcript of 980520 Enforcement Conference in King of Prussia,Pa Re J Stipek.Pp 1-46 ML20238F5241998-05-0606 May 1998 Transcript of 980506 Enforcement Conference Held in King of Prussia,Pa Re Con Edison,Indian Point.Pp 1-75 JPN-97-037, Comment on Final Direct Rule Changes to Paragraph (H) of 10CFR50.55a Codes & Standards. Effective Date of New Rule Should Be Delayed Until Listed Concerns Can Be Resolved & Appropriate Changes Incorporated1997-12-0101 December 1997 Comment on Final Direct Rule Changes to Paragraph (H) of 10CFR50.55a Codes & Standards. Effective Date of New Rule Should Be Delayed Until Listed Concerns Can Be Resolved & Appropriate Changes Incorporated ML20149D2521997-07-11011 July 1997 Exemption from Requirements of 10CFR50,App R,Section III.G.2.c to Extent That Requires Installation of Automatic Suppression Sys in Certain Fire Areas.Exemption Approved for Listed Fire Areas.Exemption for Fire Zone FH-FZ-5 Denied ML20148M6471997-06-19019 June 1997 Comment Opposing Porposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems ML20133N0511997-01-0505 January 1997 Comment Opposing Proposed Rule 10CFR50, Draft Policy Statement on Resturcturing & Economic Deregulation of Electric Util Industry ML20149M4621996-12-0909 December 1996 Comment Opposing Proposed Rule 10CFR50 Re Draft Policy Statement on Restructuring & Economic Deregulation of Electric Utility Industry ML20077G3481994-12-0808 December 1994 Comment on Proposed Rule 10CFR2,51 & 54 Re Nuclear Power License Renewal ML20070P0561994-04-19019 April 1994 Comment Supporting Proposed Rule 10CFR50 Re NRC Draft Policy Statement on Use of Decommissioning Trust Funds Before Decommissioning Plan Approval ML20029C5771994-03-11011 March 1994 Comment on Proposed Rule 10CFR20 Re Draft Rule on Decommissioning.Informs That 15 Mrem/Yr Unreasonably Low Fraction of Icrp,Ncrp & Regulatory Public Dose Limit of 100 Mrem/Yr ML20059C3031993-12-28028 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Definition of Commercial Grade Item ML20045H8751993-07-19019 July 1993 Comment on Proposed Rule 10CFR55 Re Exam Procedures for Operator Licensing.Supports Rule ML20045F2451993-06-28028 June 1993 Comment on Proposal Re Radiological Criteria for Decommissioning NRC-licensed Facilities.Opposes Proposed Criteria JPN-93-045, Comment on Proposal Re Radiological Criteria for Decommissioning NRC-licensed Facilities.Opposes Proposed Criteria1993-06-28028 June 1993 Comment on Proposal Re Radiological Criteria for Decommissioning NRC-licensed Facilities.Opposes Proposed Criteria ML20044F5681993-05-20020 May 1993 Comment on Draft Commercial Grade Dedication Insp Procedure 38703,entitled Commercial Grade Procurement Insp. Endorses NUMARC Comments JPN-02-034, Comment Supporting Proposed Rule 10CFR50.54 Re Receipt of Byproduct & Special Nuclear Matl1992-07-0606 July 1992 Comment Supporting Proposed Rule 10CFR50.54 Re Receipt of Byproduct & Special Nuclear Matl JPN-91-021, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants1991-05-13013 May 1991 Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants JPN-91-005, Comment Re SECY-90-347, Regulatory Impact Survey Rept. Util Concurs W/Numarc Comments.Analysis of Info from NUREG-1395 Insufficient to Complete Evaluation.Root Cause Analysis of Seven Themes Listed in SECY-90-347 Recommended1991-01-28028 January 1991 Comment Re SECY-90-347, Regulatory Impact Survey Rept. Util Concurs W/Numarc Comments.Analysis of Info from NUREG-1395 Insufficient to Complete Evaluation.Root Cause Analysis of Seven Themes Listed in SECY-90-347 Recommended ML20066G4411991-01-23023 January 1991 Comments on Proposed Rule 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Substantive Typo in 901015 Filing on Behalf of Licensee Noted ML20058G6341990-10-30030 October 1990 Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty Program JPN-90-068, Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS1990-10-22022 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS JPN-90-067, Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC1990-10-15015 October 1990 Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC ML20065H7541990-10-15015 October 1990 Comment Re Proposed Rules 10CFR2,50 & 54 on Nuclear Power Plant License Renewal.Commission Assessment of Four Alternatives Should Be Expanded to Include Not Only Safety Considerations But Other Atomic Energy Act Objectives JPN-90-052, Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR1990-07-0909 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR JPN-90-050, Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Proposed Rule Will Place More Stringent Restrictions on Licensed Operators & Unnecessary1990-07-0202 July 1990 Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Proposed Rule Will Place More Stringent Restrictions on Licensed Operators & Unnecessary ML20033G4331990-03-27027 March 1990 Order Impositing Civil Monetary Penalty in Amount of $50,000 for Safeguards/Security Violations Noted During 890605-07 Insp ML20012C6491990-03-0909 March 1990 Comment on Proposed Rule 10CFR50, Fracture Toughness Requirements for Protection Against PTS Events. Any Utilization of NRC Proposed Application of Reg Guide 1.99, Rev 2,would Be Inappropriate W/O re-evaluation by NRC ML20006D3341990-02-0606 February 1990 Transcript of ACRS Subcommittee on Systematic Assessment of Experience 900206 Meeting in Bethesda,Md Re Proposed Power Level Increase for Plant.Pp 1-147.Supporting Info Encl ML20005F6521989-12-13013 December 1989 Comment on Proposed Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Util Concurs w/industry-wide Position Presented by NUMARC & Offers Addl Comments ML20246P6061989-07-0707 July 1989 Comment Opposing Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Significant & Independent Industry Efforts Already Underway to Address Issue ML20245K1941989-06-16016 June 1989 Comment on Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites JPN-89-008, Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants1989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20235V9011989-02-24024 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Supports NUMARC Position.Proposed Rule Will Hinder Important Initiatives to Improve Maint JPN-88-063, Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments1988-11-18018 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments ML20205L8521988-10-21021 October 1988 Comment Opposing Proposed Rule 10CFR20 Re Cleaning or Disposing of Nuclear Waste.Incineration of Radwaste Oil Should Not Be Allowed JPN-88-015, Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Rule Includes Requirement Contrary to Mgt Notification Practices.Rule Should Clarify Length of Time Applicable Once Inspector Arrives on Site1988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Rule Includes Requirement Contrary to Mgt Notification Practices.Rule Should Clarify Length of Time Applicable Once Inspector Arrives on Site JPN-88-002, Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods.Concerns Re Schedule as License Amend Expressed1988-01-25025 January 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods.Concerns Re Schedule as License Amend Expressed JPN-87-062, Comment on Proposed Rules 10CFR4,11,25,30,31,32,34,35,40,50, 60,61,70,71,73,74,75,95 & 110 Re Retention Period for Records.Proposed Changes Ineffective in Reducing Record Vol & Rule Remains Inconsistent & Complex1987-12-31031 December 1987 Comment on Proposed Rules 10CFR4,11,25,30,31,32,34,35,40,50, 60,61,70,71,73,74,75,95 & 110 Re Retention Period for Records.Proposed Changes Ineffective in Reducing Record Vol & Rule Remains Inconsistent & Complex JPN-87-053, Comment Supporting Proposed Rule 10CFR50 Re Revising Backfitting Process for Power Reactors.Minor Alterations Urged Re Conditions Under Which Backfit Needed to Assure Adequate Protection1987-10-15015 October 1987 Comment Supporting Proposed Rule 10CFR50 Re Revising Backfitting Process for Power Reactors.Minor Alterations Urged Re Conditions Under Which Backfit Needed to Assure Adequate Protection JPN-87-051, Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl1987-09-28028 September 1987 Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl 1999-09-20
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOAR F Before Administrative Judges:
Jamesi.'*G1eason, Chairman P
Dr. Oscar H. Paris Frederick J. Shon In the Matter of x
^
x Docket Nos.
CONSOLIDATED EDISON COMPANY OF x
NEW YORK (Indian Point Unit 2')
x 50-247-SP x
50-286-SP
~ POWER AUTHORITY OF THE STATE OF x
~~~
"-~~ "
' Tdy T ~1983
~
~
NEW YORK (IMid Point Unit 3) x x
x AFFIDAVIT OF ISAAC LEVI I,
Isaac Levi, being duly sworn, state as follows:
1.
In my testimony in this proceeding on February 11, 1983 (Tr. 7823-7828), in answer to questions by Judge Frederick J. Shon, I explained the suggested method of making sensible probability judgements described in Section Five cf my written testimony, and indicated the significance of my illustrative examples.
Upon review of my answer, I believe that it should be clarified.
2.
The method of determining worst permissible priors employed in my testimony was based on a simplifying assumption stated on page 37 of my written testimony.
This simplifying assumption--that the event, all of whose points are assigned
~densityg, ~shoti1d imve total probability.5 - implies th'at
~
~
~
p x = o((1-x) =
.5.
By removing this simplifying assumption so that /x could be greater than
.5, one may obtain mean values-for worst permissible priors indefinitely close to the upper end of the assessed range of values of A.
w 8305160028 830510 PDR ADOCK 05000247 0
PDR 9
l' 2
3.
Thus, the small variation in mean values of X d
in my examples, which were pointed out by Judge Shon, depen /s._
on a simplifying assumption which is heavily biassed in favor of IPPSS.
The decision as to what value to assign tojG x 4.
is, like the value of k, a reflection of the caution of the investigator, that is, how much indeterminacy he seeks to put in his prior judgement.
As stated in my testimony, when-ever there is a dispute-on this point, one should be more rather than less cautious.
It should be noted that the assessed range used in 5.
the example I took from the Reactor Safety Study as reported in IPPSS is only one order of magnitude.
Hence, it is to be expected that the difference in both mean and median estimates will be less than an order of magnitude when relying on these assessed intervals.
Other examples could turn out quite We can only find out by doing the calculations different.
in IPPSS along the lines I have suggested.
Finally, on line 24 of page 7826 of the transcript, 6.
" medians" should read 'Ineans,"and vice versa at the end of the sentence.
,.-f
_/
Isaac Levi Subscribed and sworn to before me
~
this /d th day of May, 1983 NOTARY PUBLIC P; chi..'C M. HARTZMAN h0TARY e4,041". 3TME OF NEW YORK Nc.
1-4.Th39 Commisvan Empirt. Manh 30.g1 8' Qualified in tv<w ' fork Cou a
_