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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
[Table view] Category:PLEADINGS
MONTHYEARML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235N1621989-02-20020 February 1989 Application for Stay of Effectiveness of Final Initial Decision LBP-89-07 Dtd 890202.* Licensee Would Not Be Harmed by Granting of Stay ML20205D8451988-10-24024 October 1988 Licensee Motion to Strike Portions of Proposed Testimony of Kz Morgan.* Proposed Testimony Should Be Ruled to Be Not Admissible as Evidence in Upcoming Hearing.Supporting Info & Certificate of Svc Encl.W/Copyrighted Matl ML20205D6801988-10-20020 October 1988 Valley Alliance/Tmi Alert Notification to Parties That Kz Morgan Apps to Testimony Should Be Accepted as Exhibits.* Apps Listed.Svc List Encl.Related Correspondence ML20155G9981988-10-0404 October 1988 Valley Alliance/Tmi Alert Motion for Reconsideration of Part of Judge Order (880927) Re Limited Appearance Statements by Public.* Certificate of Svc Encl ML20155G9921988-10-0404 October 1988 Valley Alliance/Tmi Alert Motion to Submit Witness Testimony as Evidence W/O cross-exam at Hearing in Lancaster.* Requests That Cw Huver Testimony Be Accepted as Evidence ML20151S0261988-07-28028 July 1988 Valley Alliance/Tmi Alert Response to Licensee Notification of Typo in Bid Procurement Document.* Explanation for Change in Document Inadequate.W/Svc List ML20196G7801988-06-23023 June 1988 Motion of NRC Staff for Leave to File Response Out of Time.* Encl NRC Response in Support of Licensee Motion for Summary Disposition Delayed Due to Equipment Problems ML20196G9051988-06-23023 June 1988 NRC Staff Response in Support of Licensee Motion for Summary Disposition.* Motion Should Be Granted on Basis That No Genuine Issue Before ASLB or to Be Litigated.Supporting Documentation & Certificate of Svc Encl ML20196B5091988-06-20020 June 1988 Valley Alliance/Tmi Alert Response to Licensee Motion or Summary Disposition on Contentions 1-4,5d,6 & 8.* Affidavits of Kz Morgan,R Piccioni,L Kosarek & C Huver & Supporting Documentation Encl ML20154E2301988-05-16016 May 1988 Licensee Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard (Contentions 1,2,3 & 8).* ML20154E2081988-05-16016 May 1988 Licensee Motion for Summary Disposition on Alternatives (Contentions 1,2,3 & 8).* Motion Should Be Granted Based on Licensee Meeting Burden of Showing That Alternatives Not Superior to Licensee Proposal ML20154E3491988-05-16016 May 1988 Licensee Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard (Contention 5d).* ML20154E2851988-05-16016 May 1988 Licensee Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard (Contentions 4b in Part & 6 on Chemicals).* ML20154E3251988-05-16016 May 1988 Licensee Motion for Summary Disposition of Contention 5d.* Motion Should Be Granted in Licensee Favor ML20154E2681988-05-16016 May 1988 Licensee Motion for Summary Disposition of Contentions 4b in Part & 6 (Chemicals).* Licensee Entitled to Decision in Favor on Contentions & Motion Should Be Granted ML20154E1631988-05-0909 May 1988 Licensee Statement of Matl Facts as to Which No Genuine Issue to Be Heard (Contentions 4b in part,4c & 4d).* Lists Matl Facts for Which No Genuine Issue Exists ML20154E1281988-05-0909 May 1988 Licensee Motion for Summary Disposition of Contentions 4b (in part),4c & 4d.* Requests That Motion for Summary Disposition Be Granted on Basis That No Genuine Issue of Matl Fact Exists to Be Heard Re Contentions ML20154E1761988-05-0909 May 1988 Licensee Memorandum of Law in Support of Motions for Summary Disposition.* Requests Ample Notice Should Board Decide to Deny Summary in Part or in Whole ML20151E9491988-04-0707 April 1988 Licensee Answer to Intervenor Motion for Order on Production of Info on Disposal Sys Installation & Testing.* Intervenor 880330 Motion Should Be Denied Due to Insufficient Legal Basis.W/Certificate of Svc ML20150F9821988-04-0101 April 1988 Licensee Answer to Intervenors Motion to Compel Discovery.* Motion Should Be Denied on Basis That Licensee Responded Fully to Discovery Request.Certificate of Svc Encl ML20148P3931988-03-30030 March 1988 Valley Alliance & TMI Alert Motion to Request That Presiding Judge Order Gpu Nuclear to Provide Addl Info & Clarify Intentions to Install Test & Conduct Experiments W/Evaporator Prior to Hearings.* ML20196D2801988-02-12012 February 1988 NRC Staff Response to Motion by TMI Alert/Susquehanna Valley Alliance for Extension of Discovery.* Motion Should Be Denied.Certificate of Svc Encl ML20196D3541988-02-10010 February 1988 Licensee Response Opposing Susquehanna Valley Alliance/Tmi Alert Intervenor Motion for Extension of Time for Discovery.* Joint Intervenors Failed to Show Good Cause for Extension of Time for Discovery.Certificate of Svc Encl ML20148D4661988-01-19019 January 1988 Licensee Objection to Special Prehearing Conference Order.* Board Requested to Clarify 880105 Order Consistent W/ Discussed Description of Board Jurisdiction & Scope of Proceeding.W/Certificate of Svc ML20236N9081987-11-0505 November 1987 Joint Motion for Approval of Settlement Agreement & for Termination of Proceeding.* Termination of Proceeding Should Be Granted ML20235F3651987-09-23023 September 1987 Util Response Opposing NRC Staff Motion to Rescind Protective Order.* Response Opposing Protective Order Guarding Confidentiality of Document Re Methodology of Bechtel Internal Audit Group ML20235B3911987-09-18018 September 1987 NRC Staff Motion for Extension of Time.* Staff Requests Short Extension of Time Until 870925 to File Responses to Pending Petitions.Certificate of Svc Encl ML20235F4401987-09-18018 September 1987 Util Supplemental Response to NRC Staff First Request for Admissions.* Util Objects to Request as Vague in Not Specifying Time Frame or Defining Proprietary, Pecuniary.... W/Certificate of Svc.Related Correspondence ML20238E6001987-09-0404 September 1987 NRC Staff Motion to Rescind Protective Order.* Protective Order Should Be Rescinded & Presiding Officer Should Take Further Action as Deemed Appropriate.W/ Certificate of Svc ML20238E6391987-09-0303 September 1987 Commonwealth of PA Statement in Support of Request for Hearing & Petition to Participate as Interested State.* Susquehanna Valley Alliance 870728 Request for Hearing, Notice of Appearance & Certificate of Svc Encl ML20237J9931987-08-12012 August 1987 Joint Gpu & NRC Staff Motion for Protective Order.* Order Will Resolve Discovery Dispute ML20237K0431987-08-11011 August 1987 Gpu Response Opposing Parks Motion to Quash Subpoena Duces Tecum.* Exhibits & Certificate of Svc Encl ML20236P1871987-08-0505 August 1987 Formal Response of Rd Parks to Subpoena Duces Tecum of Gpu &/Or,In Alternative,Motion to Quash/Modify Subpoena Due to Privileged Info.* Documents Are Communications Protected by Atty/Client Privilege.Certificate of Svc Encl ML20236E7101987-07-28028 July 1987 Joint General Public Utils Nuclear Corp & NRC Staff Motion for Protective Order.* Adoption & Signature of Encl Proposed Order Requested ML20216J7871987-06-29029 June 1987 Opposition of Gpu Nuclear Corp to Aamodt Motion for Reconsideration.* Motion Asserts Board Did Not Consider Important Evidence on Leakage at TMI-2.W/Certificate of Svc ML20216D2311987-06-23023 June 1987 Response of Jg Herbein to Aamodt Request for Review & Motion for Reconsideration.* Opportunity for Comment Should Come After NRC Has Made Recommendations to Commission.Certificate of Svc Encl ML20215J8981987-06-19019 June 1987 Response of Numerous Employees to Aamodt Request to File Comments on Recommended Decision.* Numerous Employees Do Not Agree W/Aamodt That Recommended Decision Is Greatly in Error.Certificate of Svc Encl ML20215K2121987-06-17017 June 1987 (Motion for reconsideration,870610).* Corrections to Pages 3 & 4 Listed ML20215J7551987-06-15015 June 1987 Gpu Response to Motion to Quash Subpoena.* Dept of Labor 870601 Motion to Quash Subpoena Served on D Feinberg Should Be Denied.W/Certificate of Svc 1992-12-30
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May 9, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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GPU NUCLEAR CORPORATION ) Docket No. 50-320-OLA
) (Disposal of Accident-(Three Mile Island Nuclear ) Generated Water)
Station, Unit 2) )
LICENSEE'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (CONTENTIONS 4b-IN PART, 4c AND 4d)
Pursuant to 10 C.F.R. S 2.749(a), Licensee states, in sup-port of its Motion for Summary Disposition of Contentions 4b in part, 4c and 4d, that there is no genuine issue to be heard with !
respect to the following material facts:
- 1. The AGW disposal system proposed includes a dual closed-cycle evaporator system and an electric-powered vaporizer designed to raise the evaporator distillate temperature and to release the resultant steam to the atmosphere via a flash tank and exhaust stack.
- 2. The main evaporator is a vapor recompression type unit with the designed flexibility to be configured as a spraying film or climbing film evaporator, eBP O
fan BSfoEBR
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- 3. Prior to processing in the disposal system, the AGW l
will be and/or will have been pretreated by other systems to whatever extent is necessary to be at or below the levels of ra-dionuclide concentrations identified as influent criteria for the evaporator disposal system.
- 4. The carry-over fraction for this disposal system is ex-pected to be 0.1% or less (a decontamination factor of at least 1,000), based upon routine performance experience with typical and similar evaporator systems.
- 5. Conductivity monitors will be provided at the main evaporator feed, the evaporator effluent (distillate) and the va-porizer influent.
- 6. Five sample point stations will be provided for the ex-traction of process fluids for radiochemical analysis.
- 7. The vaporizer section of the system, which releases the vaporized distillate into the atmosphere, will be monitored and controlled by a gamma radiation detector, with pre-determined set points based on insuring the THI-2 Technical Specification in-stantaneous release limit will not be exceeded.
- 8. Measurement of Cs-137 by the ir-line radiation detector provides a bounding determination of compliance with Technical Specification limits. Therefore, it is not necessary to measure tritium and strontium at the release.
- 9. Tritium and the beta-emitting isotopes will be deter-mined by sampling and radioanalytical methods.
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- 10. The in-line radiation detector will sound an audible alarm and terminate atmospheric release if its setpoint is reached.
- 11.- The instrumentation and safety systems, along with the process control plan, will-assure that radiological. releases do i not exceed those estimated by the NRC Staff in PEIS Supp. No. 2. ;
- 12. The disposal system is designed to operate at an evaporator feed rate of 5 gallons per minute; and by design that feed rate cannot be exceeded.
Respectfully submitted,
.SHAW, PITTMAN, POTTS & TROWBRIDGE ,
w .
Thomas A. Baxter, P.C.
Counsel for-Licensee 2300 N Street, N.W.
Washington, D.C. 20037 (202) 663-8000 Dated: May 9, 1988 p
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