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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20151L3671997-08-0505 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 ML20151L5181997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately) Re SL Nevin Deliberately Falsifying Records of RECW Sample Documentation on 960207 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 ML20246F1471989-08-25025 August 1989 Settlement Agreement.* Certificate of Svc Encl 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 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 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 ML20245H8491989-08-14014 August 1989 Notice of Change of Address.* Advises of Council Change of Address for Svc of Documents 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 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 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 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 ML20248D5391989-08-0202 August 1989 Affidavit of MT Masnik.* Advises That Author Prepared Response to Question 3 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 ML20248D5671989-08-0202 August 1989 Affidavit of SE Feld.* Advises That Author Prepared Response to Question 5.W/Certificate of Svc ML20248D4971989-08-0202 August 1989 Joint Affidavit of Gy Suh & CS Hinson.* Advises That Authors Prepared Responses to Questions 1 & 4 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 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 ML20248D5311989-08-0202 August 1989 Affidavit of Rj Barrett.* Advises That Author Prepared Response to Question 2 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:OTHER LEGAL DOCUMENT
MONTHYEARML20246F1471989-08-25025 August 1989 Settlement Agreement.* Certificate of Svc Encl 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 ML20245H8491989-08-14014 August 1989 Notice of Change of Address.* Advises of Council Change of Address for Svc of Documents 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 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 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 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 ML20246N7701989-07-0303 July 1989 Notice of Appointment of Adjudicatory Employees.* Advises That Jh Conran & Rl Pedersen Have Been Appointed as Commission Adjudicatory Employees to Advise Commission on Issues Re Proceeding.W/Certificate of Svc.Served on 890705 ML20246P0871989-06-30030 June 1989 Rept of Parties.* Parties Agree That Further Exam of Large Hydrogen Recombiner Unnecessary Since Units Already Equipped W/Recombiners & Larger Recombiners Would Be Be Cost Beneficial.W/Supporting Documentation & Certificate of Svc ML20246P0791989-06-30030 June 1989 First Rept of Parties on Implementation of Stipulation for Settlement & Dismissal of Graterford Inmates Contention.* Standardized Lesson Plan for Providing Training to Dept of Corrections Personnel Approved.W/Certificate of Svc ML20245J6611989-06-22022 June 1989 Corrected Certificate of Svc.* Certifies Svc of Applicant 890621 Reply Memorandum in Support of Motion for Clarification Or,Alternatively,For Exemption,On 890622 ML20245A7531989-06-13013 June 1989 Notice of Substitution of Appearance.* Advises That Commonwealth of PA & Agencies Will Be Represented by Author Hereafter.W/Certificate of Svc ML20244D4861989-06-12012 June 1989 Notice of Change of Address.* States New Address for Svc of Documents.W/Certificate of Svc ML20246P0491989-05-16016 May 1989 Notice of Prehearing Conference.* Prehearing Conference Will Be Held on 890606 in Philadelphia,Pa to Consider Contention Re Design Alternatives for Mitigation of Severe Accidents at Plant.W/Certificate of Svc.Served on 890517 ML20246H2381989-05-0909 May 1989 Establishment of Board.* Board Will Consist of Mb Margulies, Chairman & J Harbour & Fj Shon,Members.W/Certificate of Svc. Served on 890512 ML20244D6211989-04-18018 April 1989 Notice of Prehearing Conference.* Prehearing Conference Will Be Held on 890512 Re Contention Questioning Radiological Emergency Response Plan Compliance w/10CFR50.47(b)(15). Certificate of Svc Encl.Served on 890419 ML20244C8761989-04-14014 April 1989 Establishment of Aslb.* Board Will Be Comprised of Mb Margulies,Chairman & J Harbour & Jr Kline,Members.W/ Certificate of Svc.Served on 890418 ML20195D0321988-06-16016 June 1988 Notice of Assignment of Listed ASLAP Members to Serve as ASLBP for OL Amend Proceeding.Served on 880616 ML20197E2531988-05-12012 May 1988 Air & Water Pollution Patrol Notice of Appeal to Memorandum & Order (Granting Licensee Motion for Summary Disposition Re ASLBP 87-550-03-LA).* Appeals ASLB 880505 Decision Re Iodine Spiking Amend ML20236P7711987-11-12012 November 1987 Memorandum (Memorializing Two Conference Calls).* Served on 871116 ML20236H2901987-10-28028 October 1987 Notice of Reconstitution of Board.* Judge Ga Ferguson Appointed in Place of Judge PA Morris.As Reconstituted,Board Comprised of Listed Judges.Served on 871029 ML20236N9431987-07-28028 July 1987 Notice of Hearing on Issuance of Amend to Facility Ol.* Page 4 Corrected to Reflect Signature of ASLB Chairman Alone ML20236E6611987-07-28028 July 1987 Notice of Hearing on Issuance of Amend to Facility Ol.* Date That Hearing Ultimately Held Dependent Upon Whether One or More Contentions Suitable for Hearing Develop in Prehearing Procedures.Served on 870729 ML20215J5451987-06-11011 June 1987 Notice of Appearance.* RM Weisman Enters Appearance Re Plant.Certificate of Svc Encl ML20215K9111987-05-0707 May 1987 Establishment of Aslb.* Sj Wolfe,Chairman & Rf Cole & PA Morris,Members.Served on 870508 ML20207D0931986-12-23023 December 1986 Notice of Appeal of ASLB 861114 Decision Ruling on Del-Aware Unlimited,Inc Motion to Reopen Proceedings for Further Consideration of Environ Impacts of Proposed,But Not Yet Incurred.Certificate of Svc Encl ML20214H0121986-11-25025 November 1986 Notice of Appeal by Graterford Inmates Re ASLB 861110 Decision.W/Certificate of Svc ML20215L8851986-10-24024 October 1986 Notice of Aslab Reconstitution.Cn Kohl,Chairman & Gj Edles & Ha Wilber,Members.Served on 861028 ML20214R4521986-09-18018 September 1986 Notice of Appeal from ASLB 860905 Suppl to Third Partial Initial Decision Served on 860909 ML20214N5081986-09-11011 September 1986 Notice That J Asher Will Be Witness at 860922 Hearing on Remanded Issue Re Manpower Mobilization at State Correctional Institution at Graterford,Pa.W/Certificate of Svc ML20214L5091986-09-0808 September 1986 Notice of Appeal from Aslab 860828 Order ALAB-845. Certificate of Svc Encl ML20202G1961986-07-10010 July 1986 Comments & Request for Evidentiary Hearing on Util Proposal for Resolution of Remanded School Bus Driver Issue for Oj Roberts & Spring-Ford Area School Districts.Withdrawal of Appearance Encl ML20206D8901986-06-17017 June 1986 Responds to Aslab 860603 Order Requesting Response to Certain Questions Re ASLB Fourth Partial Initial Decision & 850612 Order.Certificate of Svc Encl ML20206D6521986-06-16016 June 1986 Response to Aslab 860603 Order Re State of Record on Emergency Planning for Graterford.No Procedural Irregularity Occurred for Reasons Discussed.Certificate of Svc Encl ML20138B0141986-03-18018 March 1986 Certifies Svc of ASLB 860314 Notice of Prehearing Conference & Memorandum & Order,Consolidating Proceedings & Setting Schedule for Identification of Issues,On 860314.Served on 860319 ML20141N8181986-03-14014 March 1986 Notice of 860327 Prehearing Conference in Philadelphia,Pa Re Util 851218 Application for Amend to License NPF-39,allowing Extension of Time to Perform Valve Tests.Served on 860317 ML20141N7761986-03-13013 March 1986 Notice of ASLB Constitution.Iw Smith,Chairman & Rf Cole & Ga Linenberger,Members.Served on 860314 ML20137U7501986-02-12012 February 1986 Notice of ASLB Constitution.Iw Smith,Chairman & Rf Cole & Ga Linenberger,Members.Served on 860214 ML20137K9791985-12-0202 December 1985 Response Objecting to Licensee Proposal for Resolution of Remanded Issue Re Licensee Medical Arrangements for Contaminated Injured Onsite Personnel.Adjudicatory Hearing Requested.W/Certificate of Svc ML20136E1401985-11-18018 November 1985 Proposal for Resolution of Remanded Issue from Second Partial Initial Decision ALAB-819 Re Medical Arrangements for Contaminated/Injured Onsite Personnel.One Oversize Map & Certificates of Svc Encl ML20134A7871985-11-0606 November 1985 Notice of 841204 Oral Arguments in Bethesda,Md on Appeals of Graterford Inmates & Air & Water Pollution Patrol from ASLB 850722 Fourth Partial Initial Decision LBP-85-25 ML20133F7641985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20133F3021985-10-0404 October 1985 Notice of Receipt of Encl 850927 Air & Water Pollution Patrol Motion to Reopen Record on New Commonwealth of PA, Div of Environ Resources Regulations Re Gross alpha,Ra-226 & Ra-228.Served on 851008 ML20134N3581985-08-30030 August 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20126M8291985-07-26026 July 1985 Notice of Appeal Re Fourth Partial Initial Decision (on Offsite Emergency Planning Contentions Re Graterford). Opposes Lack of Requirement for Training Drivers Who Would Evacuate Prisoners.Served on 850801 ML20127A0171985-07-26026 July 1985 Notice of Appeal by Air & Water Pollution Patrol Re Fourth Partial Initial Decision on Offsite Emergency Planning Contentions Concerning Graterford ML20126K9821985-07-25025 July 1985 Notice of Appeal of ASLB 850722 Fourth Partial Initial Decision ASLBP 81-465-07 Ol,Dismissing Graterford Inmates 850711 Appeal Involving 5 of 6 Denied Contentions Rejected by ASLB 850702 Order.Certificate of Svc Encl ML20128Q2211985-07-24024 July 1985 Memorandum CLI-85-13 Determining That Limerick Ecology Action Comments Do Not Warrant Staying Effectiveness of Partial Initial Decisions LBP-84-31 & LBP-85-14 Re Authorization to Issue Full Power License.Served on 850725 ML20129D1451985-07-11011 July 1985 Notice of Appeal Requesting That Aslab Review ASLB 850702 Order Re Graterford Inmates Exception to ASLB 850612 Order 81-465-07 OL Admitting Only Two of Eight Proposed Contentions.Certificate of Svc Encl 1989-08-09
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. 00CKETES
. USNRC UNITED' STATES OF AMERICA . 84 EC 10. P4:39 NUCLEAR REGULATORY COMMISSION CFFici 00CdETINGOF& SECRET SERvic y(y 3 RANCH i Before the Nuclear Regulatory Commission ,
In the Matter of )
)
Philadelphia Electric Company ) Docket Nos. 50-3520C
) 50-353 d (__
(Limerick Generating Station, )
Units 1 and 2) )
APPLICANT'S RESPONSE TO PETITION BY DEL-AWARE UNLIMITED, INC. TO FILE REPLY TO THE NRC STAFF'S ANSWER ON REVIEW OF ALAB-785 In an undated pleading entitled Petition for Leave to File Reply, served November 26, 1984, intervenor Del-Aware Unlimited, Inc. (" Del-Aware") petitioned for leave to file a reply to the Staff's October 25, 1984 answer opposing Del-Aware's October 10, 1984 Petition for Review of ALAB-7851/ before the Commission. On November 9, 1984, Del-Aware had previously filed what purported to be a reply to the NRC Staff's answer to Del-Aware's petition requesting review of ALAB-785. Del-Aware's instant pleading reiterates its previous request.2/ Del-Aware's petition is 1/ Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), ALAB-785, 20 NRC (1984).
2/ On November 23, 1984, Applicant Philadelphia Electric
- ' Company filed its Response to Unauthorized Reply by Del-Aware Unlimited, Inc. to the NRC Staff's Answer on Review of ALAB-785
(" Applicant's Response") .
AkIo h
(
unauthorized by the Nuclear Regulatory . Commission's regulations, is without merit substantively, and should be
-denied.
The Commission's regulations expressly state in 10 i C.F.R. S2.786 (b) (3) that "[n]o . .. . replies to answers will be entertained by the Commission." Del-Aware here once again seeks to reply to the Staff's opposition to its petition for Commission review, a situation which is covered by the intent of such regulation. For this reason, the petition by Del-Aware is unauthorized and shou;.d be denied.
Moreover, Del-Aware's reply is without merit substantively and should be denied. The Applicant's Response of November 23, 1984 to Del-Aware's previous unauthorized reply, which is incorporated by reference herein, demonstrates that the points sought to be raised are without merit and unrelated to the issues which the Commission is considering for review.3/ Essentially, the record of the proceeding is clear that even if the Limerick P. pray pond (i.e., the ultimate heat sink) were temporarily lost,-adequate makeup water can be provided solely from the Schuylkill River. In rejecring a Del-Aware motion to stay the low power license for Limerick, che Appeal Board 9 - 3_/ Applicant's Response at pages two through four.
v.
concluded, that water from the Point Pleasant diversion is "not needed at all for safe shutdown of the plant."U For the foregoing reasons, Del-Adare's petition should be denied.
Respectfuly submitted, CONNER & WETTERHAHN, P.C.
~
Mark J. Wetterhahn Counsel for Philadelphia-Electric Company December 10, 1984 4/ Limerick, supra, ALAB-785 (slip op, at 8).
.~ . .. . _ - . - .. - .. . -. - . - .
.o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
Philadelphia Electric Company ) Docket Nos. 50-352
) 50-353 (Limerick Generating Station, )
Units 1 and 2) )
CERTIFICATE OF SERVIFE I hereby certify that . copies of " Applicant's Response to Petition by Del-Aware Unlimited, Inc. to File Reply to the NRC Staff's Answer on Review of ALAB-785," dated December 10, 1984 in the captioned matter have been served upon the following by deposit in the United States mail this 10th day of December, 1984:
Samuel J. Chilk, Secretary Lando W. Zech, Jr.,
Office of the Secretary Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Nunzio J. Palladino, Christine N. Kohl, Chairman Chairman Atomic Safety and Licensing "U.S. Nuclear Regulatory Appeal Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Thomas M. Roberts, Commissioner Dr. Reginald L. Gotchy U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Appeal Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission James K. Asselstine, Washington, D.C. 20555 Commissioner U.S. Nuclear Regulatory Gary J. Edles Commission Atomic Safety and Licensing
, Washington, D.C. 20555 Appeal Board U.S. Nuclear Regulatory Frederick M. Bernthal, commission Commissioner Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l.. . , , . . . . . . . .. .
i . .. _ _ - _ _ _ _ _ _ . - - - _ _
e Helen F.-Hoyt, Esq. Atomic Safety and Licensing Chairperson Appeal Panel Atomic Safety and U.S. Nuclear Regulatory Licensing Board U.S. Commission Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary Dr. Richard F. Cole U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Ann P. Hodgdon, Esq.
Washington, D.C. 20555 Counsel ~for NRC Staff Office of the Executive Dr. Jerry Harbour Legal Director Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission Washington, D.C.
U.S. Nuclear Regulatory 20555 Commission Washington, D.C. 20555 Angus Love, Esq.
Atomic Safety and Licensing 107 East Main Street Board Panel Norristown, PA 19401 U.S. Nuclear Regulatory Commission Robert J. Sugarman, Esq.
Washington, D.C. 20555 Sugarman, Denworth &
Hellegers Philadelphia Electric Company 16th Floor, Center Plaza ATTN: Edward G. Bauer, Jr. 101 North Broad Street Vice President & Philadelphia, PA 19107 General Counsel 2301 Market Street Director, Pennsylvania Philadelphia, PA 19101 Emergency Management Agency Basement, Transportation Mr. Frank R. Romano and Safety Building 61 Forest Avenue Harrisburg, PA 17120 Ambler, Pennsylvania 19002 Martha W. Bush, Esq.
Mr. Robert L. Anthony Kathryn S. Lewis, Esq.
Friends of the Earth of City of Philadelphia the Delaware Valley Municipal Services Bldg.
106 Vernon Lane, Box 186 15th and JFK Blvd.
Moylan, Pennsylvania 19065 Philadelphia, PA 19107
-\
Charles W. Elliott, Esq. Spence W. Perry, Esq.
325 N. 10th Street Associate General Counsel Easton, PA 18042 Federal Emergency Management Agency Phyllis Zitzer, Esq. 500 C Street, S.W., Rm. 840 Limerick Ecology Action Washington, DC 20472 P.O. Box 761 762 Queen Street Thomas Gerusky, Director Pottstown, PA 19464 Bureau of Radiation Protection Zori G. Ferkin, Esq. Department of Environmental Assiatant Counsel Resources Commonwealth of Pennsylvania 5th Floor, Fulton Bank Bldg.
' Governor's Energy Council Third and Locust Streets 1625 N. Front Street Harrisburg, PA 17120 Harrisburg, PA 17102 James Wiggins Jay M. Gutierrez, Esq. U.S. Senior Resident Inspector Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 631 Park Avenue P. O. Box 47 King of Prussia, PA 19406 Sanatoga, PA 19464 Timothy R.S. Campbell Mr. Ralph Hippert Director Pennsylvania Emergency Department of Emergency Management Agency Services B151 - Transportation 14 East Biddle Street Safety Building West Chester, PA 19380 Harrisburg, PA 17120 Mazy ~JJWetterhahn
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