ML20086M981
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| ML20086M981 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/10/1984 |
| From: | Kerekes W ABB IMPELL CORP. (FORMERLY IMPELL CORP.) |
| To: | |
| Shared Package | |
| ML20086M832 | List: |
| References | |
| ISSUANCES-OL-3, NUDOCS 8402170168 | |
| Download: ML20086M981 (2) | |
Similar Documents at Shoreham | |
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Category:AFFIDAVITS
MONTHYEARML20059B1291993-09-14014 September 1993
[Table view]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 ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20073B7461991-04-17017 April 1991 Affidavit of EM Franz Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073B7211991-04-17017 April 1991 Affidavit of Jl Bateman Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073B7941991-04-17017 April 1991 Affidavit of Jr Stehn Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing Intervention as of Right.W/Certificate of Svc ML20073B7821991-04-17017 April 1991 Affidavit of J Scrandis Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073B7161991-04-17017 April 1991 Affidavit of Organizational Interest by Mm Todorovich, Executive Director of Scientists & Engineers for Secure Energy,Inc (Sese) Re Intervenors Status for Sese ML20073B7611991-04-17017 April 1991 Affidavit of SV Musolino Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right ML20073A6101991-04-0505 April 1991 Affidavit of Jl Bateman Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A4631991-04-0505 April 1991 Affidavit of Ag Prodell Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention.W/Certificate of Svc ML20073A6161991-04-0505 April 1991 Affidavit of AP Hull Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention.W/Certificate of Svc ML20073A5831991-04-0505 April 1991 Affidavit of E Franz Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A5571991-04-0505 April 1991 Affidavit of Jr Stehn Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A6041991-04-0505 April 1991 Affidavit of SV Musolino Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A5511991-04-0505 April 1991 Affidavit of J Scrandis Re Determination of Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention ML20073A5301991-04-0505 April 1991 Affidavit of Organizational Interest by Mm Todorovich, Executive Director of Scientists & Engineers for Secure Energy,Inc.* ML20067C5361991-02-0303 February 1991 Affidavit of Franz,E M.* Affidavit Re Mod to Facility License ML20067C6721991-02-0303 February 1991 Affidavit of Eena-Mai Franz.* Believes Confirmatory Order Constitutes Another Step in Decommissioning Process to Violate Rights Under NEPA & Represents Threat to Health & Safety ML20067D0671991-02-0202 February 1991 Affidavit of Jr Stehn.* Affidavit Re Mod of Plant License. W/Certificate of Svc ML20067C4911991-02-0101 February 1991 Affidavit of Organizational Interest by Mm Todorovich, Executive Director of Scientists & Engineers for Secure Energy,Inc.* Affidavit of Mm Todorovich Re Organizational Interest in Modifying License to Plant ML20067C5881991-02-0101 February 1991 Affidavit of J Scrandis.* Affidavit Re Mod of Plant License ML20067C6101991-02-0101 February 1991 Affidavit of Jr Stehn.* Affidavit Re Mod of Facility License.W/ Certificate of Svc ML20067C8651991-02-0101 February 1991 Affidavit of Ag Prodell.* Opposes Confirmatory Order Issued on 900329,prohibiting Licensee from Placing Fuel Into Reactor Vessel W/O Prior NRC Approval ML20067C4991991-02-0101 February 1991 Affidavit of Jl Bateman.* Affidavit Re Mod of Plant License ML20067C5741991-01-31031 January 1991 Affidavit of SV Musolino.* Affidavit Re Mod of Plant License ML20067C5631991-01-31031 January 1991 Affidavit of AP Hull.* Affidavit Re Mod of Plant License ML20091C6711990-03-30030 March 1990 Affidavit of WE Steiger.* Provides Info in Support of Util Request to Amend Facility Physical Security Plan. W/Certificate of Svc ML20247B8831989-09-0707 September 1989 Affidavit of WE Steiger in Support of Util Request for Exemption from Onsite Property Damage Insurance,Per 10CFR50.54(w) ML20206M9851988-11-22022 November 1988 Affidavit of LC Lanpher.* Affidavit Re Govts 881123 Motion to Stay 881121 Licensing Board Memorandum & Order Authorizing NRC to Make Necessary Findings on 25% Power Issues & to Issue 25% Power License to Util ML20206M9921988-11-22022 November 1988 Affidavit of Gc Minor in Support of Motion for Stay.* Supports Govts Motion to Stay ASLB 881121 Order Authorizing Issuance of 25% Power OL for Plant ML20206N0001988-11-0303 November 1988 Affidavit of Ej Gleason,Director of Planning,State of Ny Energy Ofc.* Provides Data on Whether Supply of Electric Power to Long Island Would Be Adversely Impacted If Plant Did Not Operate.W/Related Info & Certificate of Svc ML20205R5351988-11-0303 November 1988 Affidavit of CA Daverio in Support of Lilco Response to 1988 Exercise Contentions.* ML20205N5231988-10-31031 October 1988 Affidavit of Kj Letsche in Support of Motion to Disqualify Judges Gleason & Kline.* Certificate of Svc Encl ML20205D6451988-10-14014 October 1988 Affidavit of Am Madsen in Support of Lilco Request for Stay of ALAB-902.* Certificate of Svc Encl ML20151N5851988-07-23023 July 1988 Affidavit of Dp Dreikorn on Lilco Compliance W/Fema Guidance Memorandum MS-1.* Certificate of Svc Encl ML20151G6051988-07-18018 July 1988 Affidavit of Ja Weistmantle.* Discusses Assertion That Lilco Obtained Complete Copy of Suffolk County Emergency Operations Plan Outside of Formal Discovery Processes ML20196B3571988-06-23023 June 1988 Affidavit of Jn Christman.* Schedule of Dispositions & Certificate of Svc Encl ML20151T4791988-04-21021 April 1988 Affidavit of Gc Minor & Sc Sholly Re Validity of Analyses & Conclusions Ref in Youngling Affidavit.W/Certificate of Svc ML20149H7411988-02-11011 February 1988 Affidavit of Rt Hogan Re Disposition of Hosp Evacuation Issue,Per Rev 9 to Util Offsite Emergency Plan.W/Certificate of Svc ML20196D7771988-02-10010 February 1988 Affidavits in Support of Govts Opposition to Lilco Summary Disposition Motions on Contentions 1-2 & 4-10.* Supporting Affidavits Include Mm Cuomo,Pg Halpin,Rc Roberts,Je Papile, Kj Letsche & Rj Zahnleuter ML20196H1111988-02-0909 February 1988 Affidavit of Pg Halpin Re Matters Alleged by Util in Lilco Motions for Summary Disposition of Contentions 1-2 & 4-10 Dtd 871218.Summaries & Quotations of Util Assertions, Resolution 111-1983 & Pf Cohalan Statement Encl ML20196H0841988-02-0808 February 1988 Affidavit of Mm Cuomo Re Util Radiological Emergency Response Plan.Reaffirms Statements Made in 870506 Affidavit & 860630 Statement.Statement Encl ML20149D8311988-02-0404 February 1988 Affidavit of DM Crocker Re Suffolk County First Set of Requests for Admissions Dtd 880125.* Certificate of Svc Encl.Related Correspondence ML20149F1281988-01-25025 January 1988 Affidavit of T Urbanik Re Lilco Motion for Summary Disposition of Contentions 1,2 & 9.* Certificate of Svc Encl ML20148D4041988-01-19019 January 1988 Affidavit of Fg Palomino.* Util Had Matl Role in Activities Before Federal Govt by Endeavoring to Persuade Govt to Intercede in Proceeding During 1984 & 1985.Certificate of Svc Encl ML20148D3541988-01-19019 January 1988 Affidavit of Fr Jones.* Lists Conduct Supporting Fact That Util Has Not Made Good Faith to Secure & Retain Participation of Suffolk County ML20148D2281988-01-19019 January 1988 Affidavit of Gj Blass.* Util Refusal to Pay Property Taxes During 1984 & First Half of 1985 Constituted Severe Injury to County.Related Info Encl ML20148D1541988-01-19019 January 1988 Affidavit of LC Lanpher.* Submits Related Info to Support Contention That Lilco Has Not Made Isolated Good Faith Effort to Secure & Retain Participation of Suffolk County ML20147D7301988-01-15015 January 1988 Affidavit of Ms Miller Re Proposed Offsite Emergency Plan. Certificate of Svc Encl ML20148D3101988-01-11011 January 1988 Affidavit of T Urbanik.* Assumptions,Speeds & Methodology Used in Hosp Evaluation Time Estimates in Rev 9 to Util Plan Correct.Estimates Suitable for Inclusion for Use in Making Protective Action Recommendations.W/Certificate of Svc 1993-09-14 Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS MONTHYEARML20093G4541995-10-18018 October 1995
[Table view]Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors 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 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down 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 ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc 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 ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans 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 ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* 1995-10-18 |
Text
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LILCC, February 13, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
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) (Emergency Planning (Shoreham Nuclear Power Station, ) Proceeding)
Unit 1) )
AFFIDAVIT OF WILLIAM h. KEREKE3 IN SUPPORT OF LILCO'S MOTION FOR
SUMMARY
DISPOSITION OF PHASE II EMERGENCY PLANNING CONTENTION 46 (CONTINUED AVAILABILITY OF DOE-RAP RESOURCES 1 William A. Kerekes, duly sworn, deposes and says as fol-lows:
My name is William A. Kerekes. I am employed by Impell Corporation as Section Manager, Power Services Division. The following statements are true:
- 1. Attachmenc 2 to this affidavit describes the capa-bilities of Impell Corporation to provide technical assistance during an emergency at Shoreham, including employees to fill L
the LERO position of Radiation Health Coordinator.
- 2. Impell Corporation, drawing upon its staff, is pre-l pared to provide a cohtinuous, sustained response to a ra-l diological emergency over a period of several days, or even longer if circumstances require, as indicat ed in Attachment 2 at.page 1. l 8402170168 840213 PDR ADOCK 05000322
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((' ~ k William A. Kerekes V
subscribed and sworn to before me this / 0 day of se 4.t
, 1984.
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