|
---|
Category:INTERVENTION PETITIONS
MONTHYEARML20082E4541983-11-21021 November 1983 Partial Response to NRC 831118 Response to Public Advocate of Nj Contentions.Aslb Should Admit Unconditionally Contentions I & V & Admit Conditionally Contentions II-IV & VI-X ML20082D8011983-11-21021 November 1983 Corrected Page 26 of 831118 Brief Opposing State of Nj Public Advocate Contention ML20082D4841983-11-18018 November 1983 Answer Opposing State of Nj 831107 Proposed Contentions Re Environ Conditions.Contentions Lack Specificity & Pertain to Matters Beyond Scope of Hearing.Certificate of Svc Encl ML20081K7671983-11-0707 November 1983 Memorandum of Law in Support of Intervenor Contentions, Listed in Encl App I.Certificate of Svc Encl ML20078C8881983-09-24024 September 1983 Answer Opposing Dept of Public Advocate of State of Nj Motion to Hold Hearing & for Admission to OL Proceeding Per 42USC2239.Advocate Fails to Demonstrate Possession of Requisite Statutory Authority.Certificate of Svc Encl ML20077Q3311983-09-0909 September 1983 Motion to Hold Hearings & to Admit State of Nj Dept of Public Advocate as Party.Health & Safety of Citizens of Nj & Property of Citizens Are Nj Interests ML20077M2641983-09-0909 September 1983 Petition of Public Advocate of State of Nj for Leave to Intervene & Request for Hearing 1983-09-09
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20082E4541983-11-21021 November 1983 Partial Response to NRC 831118 Response to Public Advocate of Nj Contentions.Aslb Should Admit Unconditionally Contentions I & V & Admit Conditionally Contentions II-IV & VI-X ML20082D8011983-11-21021 November 1983 Corrected Page 26 of 831118 Brief Opposing State of Nj Public Advocate Contention ML20082D4841983-11-18018 November 1983 Answer Opposing State of Nj 831107 Proposed Contentions Re Environ Conditions.Contentions Lack Specificity & Pertain to Matters Beyond Scope of Hearing.Certificate of Svc Encl ML20081K7671983-11-0707 November 1983 Memorandum of Law in Support of Intervenor Contentions, Listed in Encl App I.Certificate of Svc Encl ML20078C8881983-09-24024 September 1983 Answer Opposing Dept of Public Advocate of State of Nj Motion to Hold Hearing & for Admission to OL Proceeding Per 42USC2239.Advocate Fails to Demonstrate Possession of Requisite Statutory Authority.Certificate of Svc Encl ML20077Q3311983-09-0909 September 1983 Motion to Hold Hearings & to Admit State of Nj Dept of Public Advocate as Party.Health & Safety of Citizens of Nj & Property of Citizens Are Nj Interests ML20077M2641983-09-0909 September 1983 Petition of Public Advocate of State of Nj for Leave to Intervene & Request for Hearing 1983-09-09
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation ML18106A8811998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG ML18106A8731998-09-15015 September 1998 Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998 Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991 LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis ML18102B4361997-07-0707 July 1997 Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst ML20132A8961996-12-0606 December 1996 Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry ML20084H9251995-06-0202 June 1995 Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs ML20080G8321995-02-0606 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary ML20077L8631995-01-0303 January 1995 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities ML20056G4121993-08-31031 August 1993 Comment Supporting Proposed Rule 10CFR2 Re Review of 2.206 Process 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 ML20095B2411992-04-10010 April 1992 Comment on Draft NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us ML20072T2421991-04-11011 April 1991 Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams ML20246H8141989-07-0505 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20195H0331988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing ML20153F9681988-08-17017 August 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons ML20154G1421988-04-20020 April 1988 Comment Opposing Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization Program.Nrc Should Establish Program Mutually Agreed Upon Between Union & Util,Per Hope Creek & Salem Programs ML20154G4601988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility ML18093A6331988-02-0101 February 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods ML20207H6521986-07-21021 July 1986 Transcript of Commission 860721 Discussion/Possible Vote on Full Power OL for Facility in Washington,Dc.Pp 1-76. Supporting Documentation Encl ML20203D9661986-07-21021 July 1986 Corrected Page 5 to 860721 Transcript Re Facility ML20107A5261985-02-19019 February 1985 Joint Motion for Leave to Withdraw as Party to Proceeding & Dismissal of Admitted Contentions.Draft Order Approving Both Requests,Settlement Agreement & Certificate of Svc Encl ML20114A6911985-01-23023 January 1985 Response Opposing Intervenor,Public Advocate of State of Ny Notice of Deposition & Motion for Protective Order. Certificate of Svc Encl.Related Correspondence ML20113H7211985-01-22022 January 1985 Response Opposing Applicant Motion for Sanctions Re Discovery.Certificate of Svc Encl.Related Correspondence ML20114B7361985-01-21021 January 1985 Applicant Response to Intervenor Third Set of Interrogatories & Request for Production of Documents Re Pipe Cracks.Related Correspondence ML20113H7321985-01-21021 January 1985 Second Supplemental Response to Preliminary & First Sets of Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20113H9441985-01-18018 January 1985 Notice of H Sonn 850130 Deposition in Trenton,Nj.Concurrent Depositions of Listed Applicant Employees Requested.Related Correspondence ML20113H9671985-01-18018 January 1985 Fourth Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20113H8091985-01-17017 January 1985 Response to Applicant 850114 Objections to Intervenor 850104 Third Set of Interrogatories & Request for Production of Documents & Motion for Protective Order.Certificate of Svc Encl.Related Correspondence ML20112J2841985-01-15015 January 1985 Second Set of Interrogatories Requesting Production of Documents Re Listed Definitions & Instructions to Public Advocate.Certificate of Svc Encl.Related Correspondence ML20112G4171985-01-14014 January 1985 Applicant Objections to Intervenor 850107 Third Set of Interrogatories & Request for Production of Documents to Applicants & Motion for Protective Order.Certificate of Svc Encl.Related Correspondence ML20112G3921985-01-14014 January 1985 Motion That ASLB Impose Sanction of Dismissal of Contentions Due to Intervenor Failure to Respond to ASLB 841121 Order to Show Cause Why OL Proceeding Should Not Be Dismissed. Related Correspondence ML20112D8631985-01-10010 January 1985 Response Opposing Intervenor 850107 Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20112C0001985-01-0707 January 1985 Joint Motion for Issuance of Protective Order Re Personnel Info.Draft Protective Order,Unexecuted Affidavit & Certificate of Svc Encl.Related Correspondence ML20112C9651985-01-0707 January 1985 Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor 841213 Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101Q6111985-01-0404 January 1985 Third Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101Q7911985-01-0404 January 1985 Intervenors Supplemental Response to Applicants Preliminary & First Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101P9441984-12-31031 December 1984 Response to Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101L1861984-12-28028 December 1984 Motion to Correct 841224 Record.Applicants Never Agreed to Discovery & Trial Preparation Schedule.Certificate of Svc Encl ML20101M5731984-12-28028 December 1984 Response to Applicant Objections to Intervenor 841213 Second Set of Interrogatories & Request for Production.Document Request & Motion for Protective Order Should Be Denied. W/Certificate of Svc.Related Correspondence ML20101E7821984-12-21021 December 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20101E8381984-12-21021 December 1984 Objections to State of Nj Second Set of Interrogatories & Request for Production of Documents & Motion for Protective Order.Disclosure Will Constitute Unwarranted Invasion of Privacy.Related Correspondence ML20101E8511984-12-20020 December 1984 Affidavit of RM Nelson Re Info Requested by State of Nj 841213 Second Set of Interrogatories & Request for Production of Documents.Personnel Files Maintained in Confidence.Related Correspondence ML20101A1651984-12-13013 December 1984 Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20108E1161984-12-10010 December 1984 Response to ASLB 841121 Order Directing Public Advocate to Show Cause Re Dismissal of Contentions.State of Nj Safety & Environ Concerns Essential.Prehearing & Hearing Schedule Rerequested.Certificate of Svc Encl ML20099E7201984-11-23023 November 1984 Notice of Appearance in Proceeding 1998-09-15
[Table view] |
Text
m,- - - - . _ , , , . , , _
M h- --mess, ,
~
(FES S5.2) as well as accidental releases (FES 57), it is incum-bent upon the Public Advocate to demonstrate significantly new information which would affect thc earlier analyses before this issue may be litigated. It is not sufficient for an intervenor simply to criticize an EROL as insufficient in detail.52/
Even assuming th-t this issue could properly be raised at the operating license stage, the bases cited by the Public Advocate, for example, the 1972 BEIR Report of the National Academy of Sciences, only serve to demonstrate that these well understood impacts are generic and raise no issue unique to Hope Creek.L"3/ Further, the AEC concluded in the Hope Creek FES:
The AEC staff has estimated the probable radionuclide releases from the Hope Creek Station based upon experience with comparable operating reactors and an evaluation of the radwaste system.54/
Evaluating radiological impact to man based upon average annual dose to the population, the AEC concluded:
Using conservative assumptions, the total man-rem from all effluent 52/ Moreover, the regulations themselves provide that the EROL need not repeat matters previously covered at the construc-tion permit stage. 10 C.F.R. S51.21.
5,3/ " Routine releases" constitute a generic problem and, as such, may not properly be considered in this proceeding, unless the intervenor can present "the best available evidence on health effects where this would seem important to the decision." See Public Service Company of Oklahoma (Black Fox Station, Units 1 and 2), CLI-80-31, 12 NRC 264, 277 (1980). Absent some showing of " specific environmental impact," compliance with Appendix I should govern. See Boston Edison Company (Pilgrim Nuclear Power Station, Unit 2), LBP-81-3, 13 NRC 103, 209-10 (1981).
54_/ FES S5.2.2.1.
8311230056 831121 PDR ADOCK 05000354 G PDR
_ _ _ _ . . . ,