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Category:INTERVENTION PETITIONS
MONTHYEARML20107K6961984-11-0707 November 1984 Motion to Reopen Record & Admit Three Contentions for Litigation Re Applicant QA Breakdown & Lack of Character & Competence to Operate Plant.Svc List Encl ML20082J1021983-11-28028 November 1983 Response Opposing Joint Intervenors 831108 Motion to Reopen Contention 8/9 Re Synergism Issue.Aslab No Longer Has Jurisdiction Over Subj Issue.Motion Fails to Meet Legal Stds for Motion to Reopen.Certificate of Svc Encl ML20078Q8361983-11-0707 November 1983 Motion to Reopen Contention 8/9 Re Synergism.Commission Rept on Cause of Disease & Possibility That Conditions Exist at Facility Requested.Certificate of Svc Encl ML20085D7211983-07-22022 July 1983 Memorandum Supporting Motion to Reopen Contention 22 Re Cracks in Plant Foundation.Plant Is Sui Generis.Safety Implications Re Plant Built W/O Pilings on Cracked Slab Unknown.Certificate of Svc Encl ML20085D7021983-07-22022 July 1983 Motion to Reopen Contention 22 in Light of Newly Discovered Evidence ML20070H1601982-12-15015 December 1982 Contentions of State of La.Certificate of Svc Encl ML20066E9691982-11-12012 November 1982 Answer Opposing Joint Intervenors 820612 Motion to Reconsider & Reopen & State of La 820721 Petition to Intervene.New Contentions Must Be Rejected Per Commission 821108 Statement of Policy.W/Certificate of Svc ML20058J5181982-08-10010 August 1982 Response Supporting State of La 820721 Petition to Participate as Interested State,But Opposing Admission as Intervenor Except in Table S-3/high Level Waste Issue. Certificate of Svc Encl ML20062F7421982-08-0909 August 1982 Response Opposing State of La 820721 Petition to Intervene. No Good Cause Shown for Untimely Attempt to Raise Emergency Feedwater Sys Waste Disposal Issues.Certificate of Svc Encl ML20058D6631982-07-21021 July 1982 Petition to Participate as Interested State in OL Proceedings & to Reopen Proceedings to Precipitate Commission Rulings Consistent W/Recent Court of Appeals Decision.Notices of Appearance & Certificate of Svc Encl ML20054B6771982-04-15015 April 1982 Petition to Participate as Interested State.Specific Aspects of Subj Matter Listed.Certificate of Svc Encl 1984-11-07
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20107K6961984-11-0707 November 1984 Motion to Reopen Record & Admit Three Contentions for Litigation Re Applicant QA Breakdown & Lack of Character & Competence to Operate Plant.Svc List Encl ML20082J1021983-11-28028 November 1983 Response Opposing Joint Intervenors 831108 Motion to Reopen Contention 8/9 Re Synergism Issue.Aslab No Longer Has Jurisdiction Over Subj Issue.Motion Fails to Meet Legal Stds for Motion to Reopen.Certificate of Svc Encl ML20078Q8361983-11-0707 November 1983 Motion to Reopen Contention 8/9 Re Synergism.Commission Rept on Cause of Disease & Possibility That Conditions Exist at Facility Requested.Certificate of Svc Encl ML20085D7211983-07-22022 July 1983 Memorandum Supporting Motion to Reopen Contention 22 Re Cracks in Plant Foundation.Plant Is Sui Generis.Safety Implications Re Plant Built W/O Pilings on Cracked Slab Unknown.Certificate of Svc Encl ML20085D7021983-07-22022 July 1983 Motion to Reopen Contention 22 in Light of Newly Discovered Evidence ML20070H1601982-12-15015 December 1982 Contentions of State of La.Certificate of Svc Encl ML20066E9691982-11-12012 November 1982 Answer Opposing Joint Intervenors 820612 Motion to Reconsider & Reopen & State of La 820721 Petition to Intervene.New Contentions Must Be Rejected Per Commission 821108 Statement of Policy.W/Certificate of Svc ML20058J5181982-08-10010 August 1982 Response Supporting State of La 820721 Petition to Participate as Interested State,But Opposing Admission as Intervenor Except in Table S-3/high Level Waste Issue. Certificate of Svc Encl ML20062F7421982-08-0909 August 1982 Response Opposing State of La 820721 Petition to Intervene. No Good Cause Shown for Untimely Attempt to Raise Emergency Feedwater Sys Waste Disposal Issues.Certificate of Svc Encl ML20058D6631982-07-21021 July 1982 Petition to Participate as Interested State in OL Proceedings & to Reopen Proceedings to Precipitate Commission Rulings Consistent W/Recent Court of Appeals Decision.Notices of Appearance & Certificate of Svc Encl ML20054B6771982-04-15015 April 1982 Petition to Participate as Interested State.Specific Aspects of Subj Matter Listed.Certificate of Svc Encl 1984-11-07
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements 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 ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072B8521994-08-0505 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission ML20065P4121994-04-25025 April 1994 Comment on Proposed Rule 10CFR50 Rule Re Code & Stds Re Subsections IWE & Iwl.Expresses Deep Concern About Ramifications of Implementing Proposed Rule ML20058G6211993-12-0606 December 1993 Comment on Draft NUREG/BR-0058, Regulatory Analysis Guidelines,Rev 2. Concurs W/Numarc & Nubarg Comments ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 ML20058B6891993-05-0707 May 1993 Affidavit of RP Barkhurst to File W/Nrc Encl TS Change Request NPF-38-135 ML20058E0251990-10-12012 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20055E9871990-06-29029 June 1990 Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity ML19353B2241989-12-0101 December 1989 Comments on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. Util Endorses NUMARC Comments W3P89-0196, Comment Opposing Proposed Rule 10CFR50 Re Maint Programs at Nuclear Plants.Proposed Rule Would Require Establishment of Maint Programs Based on Reg Guides That Have Not Been Developed,Proposed or Approved1989-02-28028 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint Programs at Nuclear Plants.Proposed Rule Would Require Establishment of Maint Programs Based on Reg Guides That Have Not Been Developed,Proposed or Approved ML20235V4571989-02-27027 February 1989 Comment Supporting Proposed Chapter 1 Re Policy Statement on Exemption from Regulatory Control.Agrees W/Recommendations & Limits Proposed by Health Physics Society in L Taylor Ltr to Commission ML20205P9691988-10-26026 October 1988 Comment Supporting Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear License Renewal. Supports Contents of NUREG-1317 & Endorses NUMARC Comments on Rulemaking & Position Paper by NUMARC Nuplex Working Group W3P88-1366, Comment Supporting Proposed Rule 10CFR50 Conserning Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants or Utilization Facilities1988-07-13013 July 1988 Comment Supporting Proposed Rule 10CFR50 Conserning Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants or Utilization Facilities ML20135F0931987-04-0909 April 1987 Testimony of Bb Hayes Before Senate Government Governmental Affairs Committee on 870326 Re Discovery of Sensitive NRC Document in Files of Senior Official of Louisiana Power & Light Co ML20212N5781986-08-27027 August 1986 Order Imposing Civil Monetary Penalty in Amount of $50,000 Based on Violations Noted in Insp Conducted on 860101-31. Violation Noted:Plant Entered Mode 3 While Relying on Action Requirements of Tech Spec 3.6.2.1 ML20202G3811986-04-10010 April 1986 Order Imposing Civil Penalties in Amount of $130,000,based on Safety Insps of Licensee Activities Under CPPR-103 Conducted from June 1983 - Sept 1985.Supporting Documentation Encl ML20210B9141986-02-0505 February 1986 Notice of Publication of Encl 841219 Order.Served on 860206 ML20198H4461986-01-30030 January 1986 Memorandum & Order CLI-86-01 Denying Remaining Portion of Joint Intervenors 841108 Fifth & Final Motion to Reopen Record Re Character & Competence of Util Per 850711 Decision ALAB-812.Dissenting View of Palladino Encl.Served on 860130 ML20137J3531986-01-17017 January 1986 Order Extending Time Until 860214 for Commission to Act to Review ALAB-812.Served on 860117 ML20138P5301985-12-20020 December 1985 Order Extending Time Until 860117 for Commission to Review ALAB-812.Served on 851220 ML20137U4821985-12-0505 December 1985 Order Extending Time Until 851220 for Commission to Act to Review ALAB-812.Served on 851205 ML20138S0051985-11-15015 November 1985 Order Extending Time Until 851206 for Commission to Review ALAB-812.Served on 851115 ML20138H2451985-10-24024 October 1985 Order Extending Time Until 851115 for Commission to Act to Review ALAB-812.Served on 851024 ML20133F2711985-10-0404 October 1985 Order Extending Time Until 851025 for Commission to Act to Review ALAB-812 .Served on 851007 ML20134L5981985-08-28028 August 1985 Notice of Appearance of R Guild & Withdrawal of Appearance by L Bernabei & G Shohet for Joint Intervenors.Certificate of Svc Encl ML20137J2801985-08-26026 August 1985 Answer in Opposition to Joint Intervenors 850809 Petition for Commission Review of Aslab 850711 Decision ALAB-812, Which Denied Joint Intervenors 841108 Motion to Reopen Record.Kw Cook 850821 Affidavit Encl ML20137J2941985-08-21021 August 1985 Affidavit of Kw Cook Re Recent Equipment Failures Discussed in Joint Intervenors 850809 Petition for Review.Certificate of Svc Encl ML20136J1961985-08-19019 August 1985 Answer Requesting That Commission Deny Joint Intervenors 850809 Petition for Review of ALAB-812 Denying Motion to Reopen QA & Character Competence Issues.Certificate of Svc Encl ML20133L8901985-08-0909 August 1985 Petition for Review of ALAB-812,denying Joint Intervenor Motion to Reopen Record of OL Hearing to Litigate Util Lack of Character & Inability to Assure Safe Operation in Light of Const QA Breakdown.Certificate of Svc Encl ML20133L0421985-08-0808 August 1985 Order Extending Time Until 850920 for Commission to Act to Review ALAB-812.Served on 850808 ML20128Q1861985-07-23023 July 1985 Request for Extension of Time Until 850809 to File Appeal to 850711 ALAB-812 Denying Joint Intervenors Motion to Reopen Record.Certificate of Svc Encl ML20209F1921985-07-11011 July 1985 Decision ALAB-812 Denying Joint Intervenors 841108 Motion to Reopen Record on Const QA & Mgt Character & Competence, Except Insofar as Issues Re Matters Under Investigation by Ofc of Investigation Are Raised.Served on 850711 ML20116P1931985-05-0606 May 1985 Response to NRC & Util Responses to Aslab 850322 Memorandum & Order ALAB-801.Motion to Reopen Record of Licensing Proceedings for Litigation of Util Competence Should Be Granted.Supporting Documentation & Svc List Encl ML20116H3341985-04-30030 April 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20100K3221985-04-10010 April 1985 Supplementary Comments Attesting to Validity of Statements of Fact in Sser 9 & Clarifying & Explaining Current Position on Resolution of Allegation A-48.Util Can Safely Operate & Manage Facility.Certificate of Svc Encl ML20111C7021985-03-14014 March 1985 Affidavit of RP Barkhurst Re Power Ascension Testing Program to Be Performed at Levels Above 5% of Rated Power.Facility & Operating Staff in Excellent State of Readiness to Proceed W/Power Ascension ML20112A9381985-03-14014 March 1985 Affidavit of RP Barkhurst Re Power Ascension Testing Program Performed at Levels Above 5% Rated Power & Delay in Issuance of Full Power Operating Authority.Related Correspondence ML20111B6541985-03-12012 March 1985 Motion for Leave to File Reply to Applicant Answer to Joint Intervenors Motion for Leave to File Supplemental Memorandum & Applicant Response to Supplemental Memorandum.Svc List Encl ML20102C1351985-02-28028 February 1985 Response Opposing Joint Intervenors 850225 Motion for Leave to File Supplemental Memorandum & Response to Suppl.Suppl Untimely Filed.Allegations Unsupported.Certificate of Svc Encl ML20107M7321985-02-25025 February 1985 Motion for Leave to File Supplemental Memorandum in Support of Motions to Reopen.Request Based on Recent Public Repts Re Instability & Lack of Independence of Mgt of Applicant & Lack of Respect for NRC ML20195F5871985-02-25025 February 1985 Affidavit of Rk Kerr Re 841120 Meeting W/Cain,Dd Driskill, R Barkhurst,Admiral Williams & Rs Leddick to Discuss Licensee 1983 Drug Investigation 05-001-83(966) & 841206 Meeting Between Licensee & NRC in Arlington,Tx ML20107M7461985-02-25025 February 1985 Supplemental Memorandum in Support of Joint Intervenors Motion to Reopen.Determination by Aslab That Joint Intervenors Met Burden to Reopen Record for Litigation of Contention That Util Mgt Lacks Competence Requested ML20101T3701985-02-0101 February 1985 Answer Opposing Joint Intervenors 850125 Motion for Leave to File Reply to Applicant 841130 & Staff 841221 Answers.Motion Should Be Denied & Reply Brief Rejected.Certificate of Svc Encl ML20101U3411985-01-25025 January 1985 Joint Intervenors Motion for Leave to File Reply to Applicant & NRC 841221 Responses to Joint Intervenors 841108 Motion to Reopen Three QA & Mgt Integrity Contentions for Litigation ML20101U3511985-01-25025 January 1985 Joint Intervenors Reply to Applicant & NRC 841221 Responses to Joint Intervenors 841108 Motion to Reopen Three QA & Mgt Integrity Contentions for Litigation.Certificate of Svc Encl 1996-08-07
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00CKETED USNRC
'83 NOV 10 P3:21 UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING APPEAL BO b jfcf Administrative Judges:
Christine N. Kohl, Chairman Dr. W. Reed Johnson Howard A. Wilber In the Matter of LOUISIANA POWER & LIGHT COMPANY Docket No. 50-382 OL (Waterford Steam Electric Station, Unit 3)
MOTION TO REOPEN CONTENTION November 7, 1983 Now before this honorable Appeal Board, through undersigned counsel, comes Gary Groesch, Chairman of Waterford 3 Joint intervenors, who with respect moves to reopen Contention 8/9 with respect to Synergism, for reasons which appear in a l UPI press release carried in the New Orleans daily newspaper, The Times-Picayune /The States-Item on October 31, 1983. This
- article is reproduced on the following page and is the only i
showing Intervenor is able to make at this time. Thus, while reserving the right to ask later for a public hearing, Intervenor respectfully requests for the present time that the staff of this honorable Commission do a study and make a report to Intervenor covering 1) whether the nuclear plant caused the l
disease and 2) whether similar conditions exist at Waterford 3.
Respectfully submitted, ADO O!hoch82 -
PDR ,
Carole H. Burstein Co-Counsel for Joint Intervenors D
e Researchr- pnks to / Jtf p X-plant, diseases IANDON (UPI) - Alarming levels of leukemia said calves with hairless deformed limbs or without and cancer have been found in children who live tongues and ears have been born over the last three near a nuclear power plant in northwestern England, years.
[
hv.4 to research for a British television docu- Professor Edward Radford, a leading epidemiolo-j mestary. gist at the University of Pittsburgh, told Yordire Yorkshire Television said research shows that television "the worst has happened fat Windscalei children in the village nearest the Windscale plant and the contamination is potentially much more have 10 times as much leukemia as the national serious than anyone would have realized 20 years average and a significantly higher incidence of can. ago."
cer. Radford, formerly chairman of the committee set The documentary will be shown Tuesday, up by the U.S. National Academy of Sciences to Copies of reports commissioned for the program research the effects of radiation, said the cancer allege that deadly plutonium dust has been found in risk in one village is one that "I would consider homes 40 miles from the plant. unacceptable if I were liting there."
The reports say animals are grazing in fields that The television team studied five coastal villages are contaminated with 100 times the normal level of near the plant and found 14 children with cancer radiation. compared with a national average of three for the l A farmer whose land borders the plant, in Cum- same number of population. They said the chance of l bria county some 250 miles northwest of London, that happening is one in 50.000.
l l
l l
1
CERTIFICATE OF SERVICE I hereby certify that service by First Class Mail has been made by me this day on the - parties named on the appended list, which is attached hereto and made a part hereof.
N 1983.
New Orleans, Louisiana, ,
( c f V Ly Carole H. Burstein Co-Counsel for Waterford 3 Intervenors 445 Walnut Street
- New Orleans, Louisiana 70118 Telephone : 866-6363
UNITED STATES OF AMERICA .
NUCLEAR REGULATORY COMMISSION' Before the Atomic Safety and Licensina Appeal Board In the Matter of Docket No. 50-382 OL LOUISIANA POWER & LIGHT COMPANY (Waterford Steam Electric '
Station Unit 3)
SERVICE LIST Administrative Judge Administrative Judge Christine N. Kohl, Chairman Sheldon J. Wolfe, Chairman Atomic Safety & Licensing Atomic Safety & Licensing Board Appeal Board U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Commi . Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Docketing & Service Section (3)
Office of the Secretary W. Reed Johnson U.S. Nuclear Regulatory Comm.
Atanic Safety & Licensing Washington, D.C. 20555
~
Appeal Board U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555 Administrative Judge Bruce Churchill, Esquire Shaw, Pittman, Potts & Trowbridge Howard A. Wilber 1800 M Street, N.W.
Atomic Safety & Licensing Washington, D.C. 20036 Appeal Board U.S. Nuclear Regulatory Comum.
Washington, D.C. 20555 .
Sherwin E. . Turk, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Comum.
Washington, D.C. 20555 Atomic Safety & Licensing Appeal Board Panel U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555.
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