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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20151L5181997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately) Re SL Nevin Deliberately Falsifying Records of RECW Sample Documentation on 960207 ML20151L3671997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately).Orders That SA Blacklock Prohibited from Engaging in Activities Licensed by NRC for 5 Yrs from Date of Order ML20203H6891997-06-0202 June 1997 Transcript of 970602 Enforcement Conference in King of Prussia,Pa ML20083N3971995-04-26026 April 1995 Comment Supporting Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20081B3811995-03-0101 March 1995 Comment Supporting Proposed Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20045D8121993-06-14014 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54 Re FSAR Update Submittals. ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20062C6561990-10-22022 October 1990 Affidavit Requesting Withholding of Summary Rept on Evaluation of Recirculation Nozzle to Safe End Weld Indication & Proposed Disposition to Permit Unit 1 Cycle 4 Operation, from Public Disclosure,Per 10CFR2.790 ML20246J4521989-08-30030 August 1989 Memorandum & Order (Terminating Proceeding).* Terminates Proceeding Per Settlement Agreement Between Limerick Ecology Action,Inc & Licensee.W/Certificate of Svc.Served on 890831 ML20246F1011989-08-25025 August 1989 Joint Motion for Termination of Proceedings.* Board Moved to Accept Encl Settlement Agreement,Dismiss Limerick Ecology Action,Inc (Lea) Contention W/Prejudice,Dismiss Lea as Party to Proceeding & Terminate Proceeding ML20246F0121989-08-25025 August 1989 Memorandum & Order CLI-89-17.* Staff Authorizes Issuance of Full Power License to Licensee to Operate Unit 2 After Requisite Safety Findings Under 10CFR50.57 Completed. W/Certificate of Svc ML20246F1471989-08-25025 August 1989 Settlement Agreement.* Certificate of Svc Encl ML20246E3431989-08-22022 August 1989 Opposition of Intervenor Limerick Ecology Action,Inc to Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing.* Requests That Schedule Be Replaced W/More Reasonable Schedule,As Proposed.W/Certificate of Svc ML20246C0271989-08-18018 August 1989 Notice of Appointment of Adjudicatory Employee.* Informs That D Nash Appointed as Commission Adjudicatory Employee to Advise Commission on Issues in Proceeding.W/Certificate of Svc.Served on 890818 ML20246B7721989-08-17017 August 1989 Correction of Memorandum & Order of 890815.* Advises That Refs to 49CFR2.730(c) on Page 1 & 49CFR2.710 & 49CFR2.711 on Page 2 Should Be Corrected to Read as 10CFR2.730(c),2.710 & 2.711,respectively.W/Certificate of Svc.Served on 890818 ML20246D7411989-08-17017 August 1989 Transcript of 890817 Meeting in Rockville,Md Re Discussion of Full Power OL for Facility.Pp 1-58.Supporting Documentation Encl ML20246B7571989-08-16016 August 1989 Order Responding to Limerick Ecology Action Motion for Reconsideration.* Denies Motion to Reconsider,Stay,Suspend or Revoke 890707 Order on Basis That Order Appropriate.W/ Certificate of Svc.Served on 890816.Re-served on 890818 ML20246B7751989-08-16016 August 1989 Memorandum & Order.* Denies Rl Anthony 890623 Request for Hearing for Intervention in Remand Proceeding & for Stay of Low Power Authorization.W/Certificate of Svc.Served on 890816 ML20246B7931989-08-15015 August 1989 Memorandum & Order (Request for Expedited Answer).* Denies Licensee 890811 Request for Expedited Answer from NRC & Limerick Ecology Action on Basis That Request Lacks Good Cause.W/Certificate of Svc.Served on 890816 ML20245H8491989-08-14014 August 1989 Notice of Change of Address.* Advises of Council Change of Address for Svc of Documents ML20245H8061989-08-14014 August 1989 Supplemental Response of Intervenor Limerick Ecology Action, Inc to Memorandum & Order of Commission & to Memorandum & Order of 890807.* Requests Further Extension of Time in Which to Reply.Certificate of Svc Encl ML20245H5991989-08-11011 August 1989 Memorandum & Order (Terminating Proceeding).* Dismisses Graterford Inmates Contention Re Adequacy of Training for Drivers Responsible for Evacuating Graterford & Terminates Proceeding.Certificate of Svc Encl.Served on 890814 ML20245H7341989-08-10010 August 1989 Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing & Request for Expedited Answer to This Motion.* Divergence in Positions of Respective Parties Emphasizes Need to Conclude Proceeding.W/Certificate of Svc ML20245F7511989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to NRC Staff Response to Commission Questions.* Commission Should Rely on Licensee Cost Analysis in Response to Question 5 & Rc Williams Affidavit.W/Certificate of Svc ML20245F7161989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Environ Benefits for Operating Unit 2 Outweigh Small Risk of Severe Accident ML20245F7341989-08-0909 August 1989 NRC Staff Response to Commission Memorandum & Order of 890807.* Advises That NRC Will Provide Comments on Limerick Ecology Action 890814 Filing Prior to Commission Meeting Scheduled for 890817.W/Certificate of Svc ML20245F7291989-08-0808 August 1989 Affidavit.* Discusses Costs Incurred While Plant Inoperable. Allowance for Funds Used During Const,Security,Maint & Operational Costs Considered Proper for Calculating Costs for Delay ML20248D9241989-08-0707 August 1989 Memorandum & Order.* Extends Limerick Ecology Action Response Deadline to 890814 to Respond to Five Questions Re Severe Accident Mitigation Design Alternatives.W/Certificate of Svc.Served on 890807 ML20248D7871989-08-0303 August 1989 Correction for NRC Staff Response to Commission Questions.* Forwards Corrected Page 5 to NRC Response to Questions Filed on 890802,deleting Phrase by Nearly Factor 2.5 in Next to Last Line.W/Certificate of Svc ML20248D7111989-08-0202 August 1989 Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Commission Order Fails to Provide Intervenor Adequate Time for Response & Should Therefore Be Revoked.W/Certificate of Svc ML20248D5391989-08-0202 August 1989 Affidavit of MT Masnik.* Advises That Author Prepared Response to Question 3 ML20248D5671989-08-0202 August 1989 Affidavit of SE Feld.* Advises That Author Prepared Response to Question 5.W/Certificate of Svc ML20248D6451989-08-0202 August 1989 Affidavit.* Advises That Author Read Responses to Request for Comments by NRC & Knows Contents.W/Certificate of Svc ML20248D4721989-08-0202 August 1989 NRC Staff Response to Commission Questions.* Provides Info for Use in Commission Effectiveness Review of Plant Full Power Operation,Per Commission 890726 Memorandum & Order. Supporting Affidavits Encl ML20248D4971989-08-0202 August 1989 Joint Affidavit of Gy Suh & CS Hinson.* Advises That Authors Prepared Responses to Questions 1 & 4 ML20248D5311989-08-0202 August 1989 Affidavit of Rj Barrett.* Advises That Author Prepared Response to Question 2 ML20248D5981989-08-0202 August 1989 Response by Licensee Philadelphia Electric Co to Commission Request for Comments by Memorandum & Order Dtd 890726.* Licensee Requests Commission Issue Full Power OL for Unit 2 Conditioned Upon Outcome of Pending Litigation ML20245J1321989-07-27027 July 1989 Transcript of 890727 Meeting in Rockville,Md Re Facility Severe Accident Mitigation Issues.Pp 1-130.Supporting Info Encl ML20247N3261989-07-26026 July 1989 Transcript of 890726 Affirmation/Discussion & Vote in Rockville,Md on SECY-89-220 Re Order Requesting Info from Parties for Immediate Effectiveness Review of Full Power Authorization for Limerick Unit 2.Pp 1-4 ML20248D7331989-07-24024 July 1989 Second Rept of Parties & Request for Dismissal of Graterford Inmates Contention & Termination of Proceeding.* Requests Board to Enter Order to Terminate Proceeding Based on Parties Agreeing to Dismissal of Remaining Contention ML20247Q4621989-07-23023 July 1989 Response of Intervenor Rl Anthony to Answer of Philadelphia Electric Co (PECO) to Request for Hearing on PECO Application for Low Power Operation of Unit 2 & Stay of Any Operation in Keeping W/Us Circuit Court Remand Of....* ML20247B7261989-07-20020 July 1989 Notice of Appointment of Adjudicatory Employee.* Advises That H Vandermole Appointed to Advise Commission on Issues in Proceeding Re Severe Accident Mitigation Design Alternatives.W/Certificate of Svc.Served on 890720 ML20247B3821989-07-18018 July 1989 Memorandum & Order.* Orders That Severe Accident Mitigation Alternatives,Per Nepa,To Be Considered Include Containment Heat Removal,Core Residue Capture & Venting.Certificate of Encl.Served on 890719 ML20247B7641989-07-13013 July 1989 Motion of Intervenor,Limerick Ecology Action Inc,To Reconsider/Stay/Suspend/Revoke Order Authorizing Issuance of Low Power OL for Limerick 2.* Consideration of Accident Mitigation Alternatives Imperative.Certificate of Svc Encl 1997-08-05
[Table view] Category:PLEADINGS
MONTHYEARML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20246F1011989-08-25025 August 1989 Joint Motion for Termination of Proceedings.* Board Moved to Accept Encl Settlement Agreement,Dismiss Limerick Ecology Action,Inc (Lea) Contention W/Prejudice,Dismiss Lea as Party to Proceeding & Terminate Proceeding ML20246E3431989-08-22022 August 1989 Opposition of Intervenor Limerick Ecology Action,Inc to Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing.* Requests That Schedule Be Replaced W/More Reasonable Schedule,As Proposed.W/Certificate of Svc ML20245H8061989-08-14014 August 1989 Supplemental Response of Intervenor Limerick Ecology Action, Inc to Memorandum & Order of Commission & to Memorandum & Order of 890807.* Requests Further Extension of Time in Which to Reply.Certificate of Svc Encl ML20245H7341989-08-10010 August 1989 Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing & Request for Expedited Answer to This Motion.* Divergence in Positions of Respective Parties Emphasizes Need to Conclude Proceeding.W/Certificate of Svc ML20245F7511989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to NRC Staff Response to Commission Questions.* Commission Should Rely on Licensee Cost Analysis in Response to Question 5 & Rc Williams Affidavit.W/Certificate of Svc ML20245F7161989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Environ Benefits for Operating Unit 2 Outweigh Small Risk of Severe Accident ML20248D5981989-08-0202 August 1989 Response by Licensee Philadelphia Electric Co to Commission Request for Comments by Memorandum & Order Dtd 890726.* Licensee Requests Commission Issue Full Power OL for Unit 2 Conditioned Upon Outcome of Pending Litigation ML20248D7111989-08-0202 August 1989 Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Commission Order Fails to Provide Intervenor Adequate Time for Response & Should Therefore Be Revoked.W/Certificate of Svc ML20247Q4621989-07-23023 July 1989 Response of Intervenor Rl Anthony to Answer of Philadelphia Electric Co (PECO) to Request for Hearing on PECO Application for Low Power Operation of Unit 2 & Stay of Any Operation in Keeping W/Us Circuit Court Remand Of....* ML20247B7641989-07-13013 July 1989 Motion of Intervenor,Limerick Ecology Action Inc,To Reconsider/Stay/Suspend/Revoke Order Authorizing Issuance of Low Power OL for Limerick 2.* Consideration of Accident Mitigation Alternatives Imperative.Certificate of Svc Encl ML20246P4951989-07-0303 July 1989 Licensee Memorandum Re Proposed Design Mitigation Alternatives for Which Agreement Among Parties Could Not Be Reached.* Only Specific Alternatives Being Considered by Licensee & Should Be Given Attention.W/Certificate of Svc ML20246P3321989-07-0303 July 1989 NRC Staff Memorandum Supporting Staff Position Re Alternatives to Be Litigated.* Board Should Reject Limerick Ecology Action Suggested Items for Litigation Considered Outside of Scope of Remand.W/Certificate of Svc ML20246N9971989-06-30030 June 1989 Memorandum of Limerick Ecology Action,Inc,Per Prehearing Conference Order of ASLB of 890609.* Proposed Alternatives for Severe Accident Mitigation within Scope of Proceeding on Remand.Certificate of Svc Encl ML20245D2691989-06-21021 June 1989 Applicant Reply Memorandum in Support of Motion for Clarification Or,Alternatively,For Exemption.* Commission Should Determine That NRC Fully Authorized to Issue OL for Facility & Be Directed,Per 10CFR51.6.W/Certificate of Svc ML20245A5981989-06-15015 June 1989 Opposition of Limerick Ecology Action,Inc to Applicant Motion for Clarification of Commission Delegation of Authority & for Issuance of Ol,Or Alternatively,For Exemption from Procedural....* W/Certificate of Svc ML20245A5811989-06-15015 June 1989 Opposition of Commonwealth of PA to Motion of Philadelphia Electric Co for Clarification of Commission Delegation of Authority & for Issuance of OL & Opposition to Motion for Exemption.* W/Certificate of Svc ML20248B7471989-06-0505 June 1989 Applicant Motion for Clarification of Commission Delegation of Authority & for Issuance of Ol,Or,Alternatively,For Exemption from Procedural Requirement That License for Limerick Unit 2 Cannot Issue Until Contention Remanded....* ML20151T6901988-04-25025 April 1988 Response of Intervenor Rl Anthony to PECO 880331 Response & NRC Staff 880404.* Denial of Applicant Motion for Summary Disposition & Application for License Amend Urged ML20150F8721988-03-31031 March 1988 Licensee Response to Order of 880317 Requesting Clarifying Info.* Clarifying Info Needed to Decide Parties Submissions on Licensee Motion for Summary Disposition ML20149K9821988-02-18018 February 1988 Response of NRC Staff in Support of Licensee Motion for Summary Disposition.* NRC Agrees W/Licensee Motion Because No Genuine Issue of Matl Fact Exists to Be Litigated. Consolidated Contention & Proceeding Should Be Dismissed ML20196D6751988-02-0909 February 1988 Response in Opposition to Licensee Request for Summary of Disposition of Air & Water Pollution Patrol Opposition to Licensee Application for Amend to License NPF-39 & Exemption to App J of 871218. * ML20235A8101988-01-0606 January 1988 Licensee Opposition to Intervenor Rl Anthony Request for Extension of Time for Discovery.* Intervenor Request Should Be Denied as Intervenor Had Adequate Opportunity to Review Responses & Pursue Addl Discovery.W/Certificate of Svc ML20235A8041988-01-0505 January 1988 Air & Water Pollution Patrol (Romano) Reaction to Licensee time-defaulted Response for Production of Documents as Ordered by NRC Administrative judges,871120.* Requests That Util Be Reprimanded for Defaulting on 871120 Order ML20238D1601987-12-20020 December 1987 Intervenor Rl Anthony Request for Extension of Time for Discovery.* Extension Requested Due to Listed Obstacles Which Have Prevented Study of Matl Provided & Matl Missing ML20236T1781987-11-23023 November 1987 Licensee Memorandum in Support of Motion for Summary Disposition,Preliminary Statement.* Proposed Amend Does Not Downgrade Reporting Requirements for Iodine Spikes. Consolidated Contention & Proceeding Should Be Dismissed ML20236T1611987-11-23023 November 1987 Licensee Motion for Summary Disposition.* Forwards Util Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard,Memorandum in Support of Motion for Summary Disposition & J Doering & Js Wiley Affidavits ML20236P8241987-11-12012 November 1987 Air & Water Pollution Patrol (Awpp) (Romano) Objection to Licensee Objection to Intervenor Awpp Request for Opportunity to File for Discovery & Motion for Protective Order.* Failure to Monitor Proceeding Inadvertent ML20236P8971987-11-10010 November 1987 Intervenor Rl Anthony Objection to Philadelphia Electric Co Objection to Anthony Discovery & Request for Protective Order Dtd 871030.* Only Essential Matl for Appeal of Granting License Amend Requested ML20236N8971987-11-0909 November 1987 Response of NRC Staff to Rl Anthony Discovery Requests & Licensee Objections Thereto.* ASLB Should Deny Request,But Protective Order Not Opposed.Certificate of Svc Encl.Related Correspondence ML20236N8351987-11-0909 November 1987 Response of NRC Staff to Air & Water Pollution Patrol Motion of 871027 Concerning Summary Disposition & Discovery & Licensees Objections Thereto.* Motion Should Be Denied. Certificate of Svc Encl ML20236L7471987-11-0202 November 1987 Licensee Objection to Intervenor Air & Water Pollution Patrol Request for Opportunity to File for Discovery & Motion for Protective Order.* Certificate of Svc Encl ML20236H3911987-10-30030 October 1987 Licensee Objection to Intervenor Anthony Request for Discovery & Motion for Protective Order.* Certificate of Svc Encl ML20236H4091987-10-27027 October 1987 Memorandum & Order (Memorializing Special Prehearing Conference;Ruling on Contentions).* Motion for Board to Summarily Dispose Util Request Instant Amend & for Exercise to Discovery ML20236H3401987-10-25025 October 1987 Intervenor Rl Anthony Response to 871009 Memorandum & Order.* Author Has No Further Requests for Info in Addition to Items Recorded in .Util Should Provide Listed Records ML20236R7731987-08-26026 August 1987 Suppl to Petitioner Response of 870702 to Board Notice of Hearing & Order of 870729.* Petitioner Lists Contentions Opposing Granting of License Amend to Tech Specs for Plant Re Matter of Radioactive Iodine Spikes ML20237G9731987-08-21021 August 1987 Air & Water Pollution Patrol Suppl to Opposition to Radioactive Iodine Amend for License NPF-39.* Concerns Expressed Re Unusual Sensitivity of Thyroid to Iodine. Licensee Does Not Merit Amend,Based on Util Past Conduct ML20235M1751987-07-13013 July 1987 Staff Reply to Licensee Answers to Petitioner Requests for Hearing & Motions to Intervene (Licensee Second Argument).* Air & Water Pollution Patrol & R Anthony Failed to Meet Stds for Intervention in Amend Proceedings.Aslb Denies Petition ML20235G5851987-07-0505 July 1987 Awpp (Romano) Answers Licensee Argument II as Per Order of 870522 Re Representational Standing.* Urges Licensee to Show Cause Why Cable Pulling Necessitates Greater Air Leakage from Reactor Openings ML20235J0491987-07-0202 July 1987 Response by Intervenor Rl Anthony to Board Order of 870622.* Licensee Opposed to License Amend & Request Hearing to Form Basis for Board to Deny Request.Reduction of Control Over Iodine Spikes & Levels Is Threat to Health of Public ML20215J7661987-06-16016 June 1987 NRC Staff Response to Licensee Answer in Opposition to Request for Hearing & Leave to Intervene by Air & Water Pollution Patrol.* Board Should Reject Licensee First Argument & Anthony Request for Hearing.W/Certificate of Svc ML20216D3641987-06-16016 June 1987 NRC Staff Response to Licensee Answer in Opposition to Request for Hearing & Leave to Intervene by Air & Water Pollution Patrol.* ASLB Should Reject Licensee First Argument & Anthony Request for Hearing.W/Certificate of Svc ML20215D9491987-06-0808 June 1987 Intervenor Rl Anthony Response to ASLB Order of 870522.* Licensee Position Mistaken Both in Relation to Correctness of Petition to Intervene & as to Intent of Citizen Participation Specified in NEPA & Aea.Served on 870616 ML20214W5531987-06-0202 June 1987 Response Opposing Util Request for Legal Loopholes to Prevent Groups w/long-term Commitment to Insure Licensee Does Better Job Abiding Rules Re Public Safety ML20214G6271987-05-19019 May 1987 Commonwealth of PA Opposition to Graterford Inmates Petition for Review of ALAB-863.* Graterford Inmates Failed to Prove That Aslab Decision Erroneous W/Respect to Important Question of Fact,Policy or Law.W/Certificate of Svc ML20214A9491987-05-18018 May 1987 NRC Staff Answer in Opposition to Petition for Review of Inmates of State Correctional Inst at Graterford.* Inmates Failed to Establish That Issues Raised Re ALAB-863 Warrant Review.Commission Should Deny Review.W/Certificate of Svc ML20210C1011987-05-0404 May 1987 Petition for Review.* Review of Aslab 870417 Decision ALAB-836 Requested to Determine If Reasonable Assurances Given That Sufficient Manpower Will Be Mobilized in Event of Evacuation.Certificate of Svc Encl ML20212K5141987-01-23023 January 1987 Response of NRC Staff in Opposition to Graterford Inmates Appeal of Licensing Board Suppl to Fourth Partial Initial Decision.* Certificate of Svc Encl ML20207P9441987-01-12012 January 1987 Commonwealth of PA Brief in Opposition to Appeal by Graterford Inmates of Suppl to Fourth Partial Initial Decision:Preliminary Statement.* W/Certificate of Svc 1993-10-22
[Table view] |
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_ _ . ,
00CMETED USNRC UNITED STATES OF AMERICA 3 mi11 #0:25 NUCLEAR REGULATORY COMMISSION BeforetheAtomicSafetyand-LicensinghEdd;k%[
w ;.3 In the Matter of )
)
Philadelphia Electric Company ) Docket Nos. 50-362
- ) 50-353 (Limerick Generating Staticn, )
Units 1 and 2) )
APPLICANT'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD WITH REGARD TO CONTENTIONS V-3a AND V-3b
- 1. The Atlantic Richfield Company (" ARCO") refined petroleum products pipeline passes within about 1,600 feet of the Unit 2 reacttr enclosure, which is the nearest. it approaches safety-related structures (Affidavit of John D.
Walsh at 14).
I 2. The pipeline is approximately 1,675 feet from the
! Unit 2 diesel generator building at its closest point of I
approach (Walsh Attidavit at 14). ,
- 3. The pipeline runs generally north-south in the vicinity of the plant; pumpages are in a northward direction (Walsh Affidavit at 14).
- 4. Routing of the pipeline and its relationship to the Limerick Station is as shown on FSAR Figure 2.2-4 (Walsh Atridavit at 14; Affidavit of Vincent S. Boyer Regarding Contentions V-3a and V-3b at 112-3).
- 5. Tnis pipeline is buried a minimum of three feet below grade (Walsh Affidavit at 14) .
8310120368 831007
-PDR ADOCK 05000352 G PDR
2-4
- 6. The pipeline is a dedicated carrier for refined ARCO petroleum products such as gasoline and diesel and home heating oil (Walsh Affidavit at 1 4).
- 7. Propane is not and never has been carried by this pipeline, and could not be carried by the pipeline without major modifications (Walsh Afridavit at 14).
- 8. Philadelphia Electric Company has obtained an agreement from ARCO that it will not trancport propane through this. pipeline (Walsh Affidavit at 14; Boyer Affidavit at 14).
- 9. The pumping stations for this pipeline are equipped with pressure sensors to detect a sudden rise or fall in pressure which could indicate a leak or break in the lines (Walsh Af fidavit at 15) .
- 10. The pumps would automatically be shut off in this event (Walsh Af fidavit at SS) ,
- 11. Following a pipelina rupture, operators monitoring the pipeline and pump stations would also note a speedup of the pumps and could terminate pumping (Walsh Attidavit at 15).
- 12. Even small pipeline leaks would be detected through routine inventory procedures in a relatively short time (Walsh Affidavit at 15) .
- 13. Analyzing the potential effects upon the Limerick Station from a rupture of this pipeline, it is conservative to assume a gasoline release since gasolina is the most
volatile substance carried and has the highest energy content (Walsh Affidavit at.15).
- 14 . Possum Hollow Run is the lowest point between the adjacent high points ot the terrain in the vicinity of the Limerick Station (Walsh Affidavit at 16) .
- 15. Rupture of the pipeline at this location would have ,
the greatest effect on the Station (Walsh Attidavit at $6) .
- 16. Ruptures of the pipeline at other locations in the vicinity would either release less gasoline, because of the relative elevation, or the gasoline would drain into other, less proximate drainage systems (Walsh Affidavit at 16) .
- 17. Such rupturcs would have less effect (Walsh Affidavit at 16).
- 18. The entire calculated gasoline content of the pipeline between those two adjacent high points of land (1,400 feet north and 600 feet south) is 4,962 gallons (Walsh Affidavit at 17).
- 19. Assuming that 4,962 gallons of gasoline flowed into the streambed, it would be distributed over the bed between the pipeline and the first downstream bridge in a pool 610 meters by 1 meter wide by approximately 3 centimeters deep (Walsh Af fidavit at 17) .
- 20. The pooling capacity of the creek bed is very small (Walsh Affidavit at 17).
Even if more than the entire calculated gasoline J
21.
content of the pipeline between the two high points were
- . . _ _ _ _ . . _ _ . _ . _ _ _ _ _ _ _ _ . . _ _ . . _ . _ . . . _ _ . ~ _ _ . - . .
4 released, the additional gasoline would drain downstream away from the plant (Walsh Af fidavit at 17) .
- 22. Accordingly, larger releases than postulated would not significantly change the predicted impact on the Station (Walsh Affidavit at 17).
- 23. Assuming pf.poline failure, air would enter the lines at the point of rupture and travel through the upper portions of the pipe above the surface of the draining fluid until it reached the adjacent high points, where it would accumulate and prevent further drainage by gravity flow-(Walsh Affidavit at 18).
- 24. No siphoning effect would occur from beyond the high points because a siphon requires the presence of atmospheric pressure at both ends (Walsh Af fidavit at 18) .
- 25. Gasoline from the ruptured pipeline would distribute in the Possum Hollow Run creek bed and evaporate, forming a gradient of gasoline vapor at decreasing concentrations above the stream and confined horizontally within the valley walls (Walsh Af fidavit at 19) .
- 26. The greatest concentration of gasoline vapor will exist if winds are calm such that the only mixing which occurs is due to the vapor pressure of the evaporating gasoline forcing vapor upward (Walsh Affidavit at 19).
- 27. If winds were not calm, even assuming wind in the direction of the Station, greater dilution of the gasoline vapor would exist, resulting in lesser concentrations of
l vapor within flammable limits near the Station (Walsh Affidavit at 19).
- 28. Using accepted values, the explosive limits of gasoline vapor is 1.3 to 6.0 percent by volume in air (Walsh Affidavit at 110).
- 29. Assuming detonation of the gasoline vapor approximately 800 feet from the Unit 2 reactor enclosure, a wide spot in the valley where direct exposure to safety related structure exists, and using Regulatory Guide 1.91 f
methodology, the resulting peak reflected overpressure is 1.9 pounds per square inch . (" psi") (Walsh Affidavit at 110).
- 30. This calculation does not credit intervening terrain at the location of the explosion centroid (Walsh Affidavit at 110).
- 31. If the closest approach of Possum Hollow Run (approximately 550 feet) were selected as the explosion I
l' centroid location, the calculated peak overpressure would be 1
I approximately 3 psi and would have no effect on Limerick safety'related structures (Walsh Af fidavit at 110) .
- 32. No credit was taken for the shielding effects of the Possum Hollow Run valley walls in this calculation (Walsh Affidavit at 110) .
- 33. The design reflected average overpressure of the l
affected safety related structures at Limerick is 12 psi l
. (Walsh Af fidavit at 110) .
- 34. An alternative assumption is that the 5,000 gallons of spilled gasoline deflagrates in a 15-minute period, which t- - - _ - , _ _ ._. _ . _ . . _ _ , - . _ _ _ _ _ _ _ _ - _ . . . _ . _ - _ . . _ . _ , . . - . . . _ . _ . _ , . . . _ ~ - - . , , _ . - - _
conservatively maximizes the heat generation rate (Walsh Affidavit at 111).
- 35. .The heat from such a deflagration would produce a radiant heat load of 85 Btu per square foot per hour at the Unit 2 reactor enclosure (Walsh Af fidavit at 111) .
- 36. A radiant heat load of 85 Btu per square foot per hour would not have any effect on the reactor enclosure other than a slight warming of the concrete surface, even for an extended period of deflagration (Walsh Affidavit at ill).
- 37. By comparison, a flat surface in the sun at mid-day would receive solar radiation at approximately 50 to 60 Btu per square foot per hour (Walsh Affidavit at ill) .
- 38. Neither the peak overpressure of 1.9 psi by detonation nor the radiant heat at 85 Btu per square foot per hour by deflagration of spilled gasoline vapors would aftect safety related structures (Walsh Affidavit at 112) .
- 39. Columbia Gas Transmission Company pipelines Nos.
1278 and 1010 carry only natural gas and pass within 3,500 feet of the Unit 2 reactor building at the closest approach (Walsh Attidavit at 113).
- 40. Both pipelines share the same right-of-way and run south-southwest to north-northeast-(Walsh Affidavit at 113).
- 41. The routing of these gas pipelines and their relationship to the facility are as depicted on FSAR Figure
- 2.2-4 (Walsh Af fidavit at 113; Boyer Af fidavit at 112-3) .
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- 42. Pipeline No. 1278 is 14 inches in diameter, operates at a maximum pumping pressure of 1,000 psig, is 34 years old and is buried at a minimum of 3 feet below grade (Walsh Af fidavit at 113) .
- 43. Pipeline No. 1010 is 20 inches in diameter, operates at a maximum pumping pressure of 1,200 psig, is 17 years old and is buried at a minimum of 3 feet below grade (Walsh Affidavit at 113).
- 44. In calculating potential effects or pipeline rupture, the conservative assumption is a double-ended rupture (complete separation of the pipe at the point of rupture) and vertical orientation of the two pipe ends due to pressure and whip (Walsh Affidavit at 114) .
- 45. This assumption takes no credit for burial of the pipelines, which would mitigate the whip effect (Walsh Affidavit at 114).
- 46. If the pipe ends were not in a vertical orientation, the momentum of the two opposing streams of gas l
l would cause rapid mixing and dilution and would cause the l
gas emitted to be a ground level source, resulting in an explosion centroid further from the Limerick Station than f conservatively assumed (Walsh Af fidavit at 114) .
1 l 47. The amount of gas released during a pipeline i
l rupture is inconsequential since calculations or the effect of natural gas from the pipeline are of an explosion dependent upon the rate of release rather than the total l amount available for release (Walsh Affidavit at 115).
I
.,. --_.r -, , -. . . .
- 48. In analyzing the postulated failure or this pipeline, it is conservative to assume that the escaping gas rises in a column to about 500 feet above plant grade, where the momentum energy decays, and that the gas then travels horizontally, directly toward the Unit 2 reactor enclosure (Walsh Affidavit-at 116).
- 49. The mitigating effect of the height above plant grade was not used in the calculation of overpressure (Walsh Aftidavit at 116).
- 50. It is conservative to assume that the natural gas begins to disperse downward toward the Limerick Station trom directly above the rupture point, at a low dispersion rate using Pasquill "F" stability with one meter per second wind speed (approximately the 95th percentile meteorology) (Walsh Affidavit at 117).
- 51. These conservative assumptions allow the natural gas plume to travel nearest the plant prior to reaching detonable concentrations (Walsh Affidavit at 117).
- 52. The explosive limits of natural gas are between 6.0 and 14.0 percent by volumo in air (Walsh Affidavit at 117) .
- 53. Detonation of natural gas released from the postulated pipeline failure results in a peak overpressure at the Unit 2 reactor enclosure of 10 psi, which is less than the design overpressure for critical safety related structures (Walsh Affidavit at 118).
- 54. If the wind were blowing in any direction other l
than directly towards the plant, the effects of a gas l
l l
l
. n.
explosion on the facility would be less (Walsh Affidavit at 118).
- 55. If the wind speed were higher, greater dilution would occur and the zone of explosive limits would be closer to the point of release and further from the Station (Walsh Affidavit at 118).
- 56. The calculations are also conservative because natural gas clouds seldom detonate in the open air (Walsh Affidavit at 118).
- 57. If the natural gas cloud were to deflagrate rather than detonate, the flame front would probably move back and have a negligible effect on the plant (Walsh Affidavit at 119).
- 58. It is conservative to assume that the cloud continues to burn at the original point of ignition (Walsh Affidavit at 119). The radiant heat load at the Unit 2 reactor enclosure resulting from the postulated detonation l would be 70 Btu per square foot per hour (Walsh Affidavit at 119).
- 59. This radiant heat load level would only cause slight warming of the outer layer of concrete, and would not cause noticeable or lasting ettects, even for an extended period of deflagration (Walsh Affidavit at 119).
- 60. Diesel fuel storage tanks and associated piping are buried and would not be affected by either the detonation or deflagration of the natural gas postulated in these analyses (Walsh Affidavit at 120; Boyer Affidavit at 12).
- 61. Whether-detonation or deflagration of natural gas released from either of the two Columbia Gas Transmission Company pipelines were postulated to occur, no adverse effects on safety related structures or equipment at the Limerick Generating Station would result (Walsh Affidavit at 121).
Respectfully submitted, CONNER & WETTERHAHN, P.C.
Mark J. Wetterhahn, P.C.
Counsel for the Applicant October 7, 1983 l
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