|
---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] Category:PLEADINGS
MONTHYEARML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20236W0931998-07-30030 July 1998 Reply to Staff & Naesco Objections to Joinder of Necnp & to Naesco Objection to Standing.* Advises That Jointer Issue Involves Only Question of How Pleadings May Be Captioned. W/Certificate of Svc ML20236U4221998-07-27027 July 1998 North Atlantic Energy Svc Corp Supplemental Answer Standing Issues.* Request for Hearing & Petition to Intervene,As Applied to Sapl & New England Coalition on Nuclear Pollution,Should Be Denied.W/Certificate of Svc ML20236T5201998-07-27027 July 1998 NRC Staff Response to 980709 Submittal by Seacoast Anti- Pollution League & New England Coalition on Nuclear Pollution (Necnp).* Board Should Deny Intervention by Necnp. Staff Does Not Contest Sapl Standing.W/Certificate of Svc ML20236J1111998-07-0202 July 1998 North Atlantic Energy Svc Corp Answer to Supplemental Petition for Hearing.* Util Will Respond to Any Further Petitions on Schedule Directed by Licensing Board Memorandum & Order of 980618.W/Certificate of Svc ML20249B9151998-06-24024 June 1998 NRC Staff Answer to Seacoast Anti-Pollution League (Sapl) 980605 Request for Hearing & to New England Coalition on Nuclear Pollution 980618 Request for Intervention.* Board Should Not Grant Sapl 980605 Request.W/Certificate of Svc ML20249B7631998-06-18018 June 1998 Supplemental & Amended Petition for Institution of Proceeding & for Intervention Pursuant to 10CFR2.714 on Behalf of Seacoast Anti-Pollution League & New England Coalition on Nuclear Power.* ML20249A9501998-06-12012 June 1998 Supplemental Petition of Great Bay Power Corp for Determination of Reasonable Assurance of Decommissioning Funding ML20199K3861998-01-29029 January 1998 Petition for Determination That Great Bay Power Corp'S Acceleration of Decommissioning Trust Fund Payments Would Provide Reasonable Asurance of Decommissioning Funding Or,In Alternative,Would Merit Permanent Exemption ML20217P7781997-12-18018 December 1997 Petition to Suspend Operating License Until Root Cause Analysis of Leaks in Piping in Train B of RHR Sys Conducted, Per 10CFR2.206 ML20140B9601997-06-0404 June 1997 Suppl to Great Bay Power Corp Petition for Partial Reconsideration of Exemption Order to Submit Requested Cost Data & to Request,In Alternate,Further Exemption ML20135A1051997-02-21021 February 1997 Petition of Great Bay Power Corp for Partial Reconsideration of Exemption Order.* Seeks Reconsideration of Staff'S Preliminary Finding That Great Bay Is Not Electric Utility as Defined by NRC in 10CFR50.2 ML20094N4021992-03-27027 March 1992 App to Appeal of Ofc of Consumer Advocate (Nuclear Decommissioning Finance Committee) Appeal by Petition Per Rsa 541 & Rule 10 ML20076D1281991-07-17017 July 1991 Licensee Motion to Dismiss Appeal.* Appeal Should Be Dismissed Based on Listed Reasons.W/Certificate of Svc ML20073E1301991-04-22022 April 1991 Opposition of Ma Atty General & New England Coalition on Nuclear Pollution to Licensee Motion for Summary Disposition.* Board Should Reopen Record,Permit Discovery & Hold Hearing on Beach Sheltering Issues ML20070V3311991-03-29029 March 1991 Licensee Motion for Summary Disposition of Record Clarification Directive in ALAB-939.* Licensee Request That Motion Be Moved on Grounds That Issues Herein Identified Became Moot & Thus Resolved.W/Certificate of Svc ML20070V4061991-03-25025 March 1991 Massachusetts Atty General Response to Appeal Board 910311 Order.* License Should Be Vacated Until There Is Evidence of Adequate Protective Measure for Special Needs Population. W/Certificate of Svc ML20076N0831991-03-21021 March 1991 Massachusetts Atty General Response to Appeal Board 910308 Order.* Opposes Licensing Board Issuance of Full Power OL Based on Reliance of Adequacy of Plan.W/Certificate of Svc ML20076N1861991-03-19019 March 1991 Intervenors Reply to NRC Staff & Licensee Responses to 910222 Appeal Board Order.* NRC & Licensee Should File Appropriate Motions & Supply Requisite Evidentiary Basis That Will Allow Board to Make Decision.W/Certificate of Svc ML20070M5151991-03-18018 March 1991 Licensee Response to Appeal Board 910308 Order.* Listed Issues Currently Being Appealed Should Be Dismissed as Moot. W/Certificate of Svc ML20076N0671991-03-15015 March 1991 Licensee Response to Appeal Board 910311 Order.* Controversy Re Special Needs Survey Resolved.Next Survey Will Be Designed by Person Selected by State of Ma & Licensee Will Pay Costs.W/Certificate of Svc ML20070M3781991-03-11011 March 1991 Licensee Response to 910222 Appeal Board Order.* Response Opposing Suspending or Otherwise Affecting OL for Plant Re Offsite Emergency Plan That Has Been Twice Exercised W/No Weakness Identified.W/Certificate of Svc & Svc List ML20070M2101991-03-11011 March 1991 Reply to Appeal Board 910222 Order.* Response Opposes ALAB-918 Issues Re Onsite Exercise Contention.W/Certificate of Svc ML20029B6061991-02-28028 February 1991 Response of Ma Atty General to Appeal Board 910222 Order.* Questionable Whether Eight Issues Resolved.To Dismiss Issues Would Be Wrong on Procedural Grounds & Moot on Substantive Grounds.W/Certificate of Svc ML20070E7741991-02-25025 February 1991 Opposition to Licensee Motion to Dismiss Appeal of LPB-89-38.* Believes Board Should Not Dismiss Intervenors Appeal Because There Was No Hearing on Rejected Contentions. Board Should Deny Licensee Motion.W/Certificate of Svc ML20066H0831991-02-12012 February 1991 Licensee Motion to Dismiss Appeal of LBP-89-38.* Appeal Should Be Dismissed Either as Moot or on Grounds That as Matter of Law,Board Correct in Denying Hearing W/Respect to Contentions at Issue.W/Certificate of Svc ML20066H0021991-02-0808 February 1991 Licensee Response to Appeal Board Order of 910204.* W/Certificate of Svc ML20067C5081991-02-0101 February 1991 Ma Atty General Response to Appeal Board Dtd 910122.* Identifies Two Issues That Potentially May Be Resolved. State Will Continue to Investigate Facts Re post-hearing Events That May Effect Pending Issues.W/Certificate of Svc ML20029A0451991-01-28028 January 1991 Licensee Suggestion for Certified Question.* Draft Certified Question for Appeal Board Encl.* W/Certificate of Svc ML20029A0431991-01-28028 January 1991 Licensee Response to 910124 Memorandum & Order.* Common Ref Document Derived from Copying Respective Portions of Emergency Response Plan & Associated Documents Provided.W/ Certificate of Svc ML20070U4811991-01-24024 January 1991 Motion Requesting Limited Oral Argument Before Commission of City of Holyoke Gas & Electric Dept New Hampshire Electric Cooperative Mact Towns ML20029A0091991-01-24024 January 1991 Response to Appeal Board 910111 Order.* Atty General Will Continue Ad Intervenor in Facility Licensing Proceeding. Changes to Emergency Planning for Facility Forthcoming. W/Certificate of Svc ML20029A0121991-01-24024 January 1991 Motion for Substitution of Party.* Atty General s Harshbarger Moves That Secretary of NRC Enter Order Substituting Him in Place Jm Shannon as Intervenor to Proceeding.W/Certificate of Svc 1999-08-03
[Table view] |
Text
, , _ _ _ _ _
\.
I l
FILED: June 27, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '
DOCKETED BEFORE THE ATOMIC SAFETY AND LICENSb M BOARD l
In the matter of: '86 JA. -2 All 52 PUBLIC SERVICE COMPANY OF- 6sf ?? C' '
50-443 OL NEW HAMPSHIRE, et al Docketff[# h i:
50-444 OL (Seabrook Station, Units I a,nd 2) On-site Emergency Planning and Safety Issues SEACOAST ANTI-POLLUTION LEAGUE'S RESPONSE AND OBJ ECT ION TO APPLICANTS ' MOTION FOR INCORPORATION OF CERTAIN MATERIALS IN RECORD; FOR CLOSING OF RECORD; AND FOR ISSUANCE OF OPERATING LICENSE FOR OPERATION NOT IN ESCESS OF 5% OF RATED POWER NOW COMES the Seacoas t Ant i-Pollut ion League and obj ects to the Applicants' motion of June 17, 1986 insofar as it would allow the closing of the record and issuance of an operating license for operation up to 5% of Seabrook Unit l's rated capacity. SAPL does not object to having Section 13.3 of SSER Supp. No. 4 and the Staf f's environmental quali ficat ion review, submi t ted under date of June 11, 1986 as Section 3.11 of SSER Supp. No. 5, admitted into the record of this proceeding, provided that the parties to this proceeding are allowed a hearing with respect to the issues allegedly resolved by these materials. To deny a hearing would be to arbitrarily impair
{
l tne rights of SAPL and other parties.
The particular issues which SAPL does not believe are adequately resolved are as follows:
f[Ogg $ p G
TSO3 ,
O
- 1. Contention NH-10 SAPL does not believe that the status of the Detailed Control Room Design Review nor the Safety Parameter Display Sys tem are adequate. SAPL set forth with particularity its arguments against the State of New Hampshire's Mot ion to Wi thdraw Content ion NH -10 in an obj ect ion filed on June 1"9,1986.1 SAPL incorporates its obj ect ion by reference herein (appended as " Attachment A") and reserves its right to cross examine on the issues detailed in that objection.
SAPL would par t icularly emphas ize the two ins tances in which a prior Applicant commitment to complete design review prior to fuel load is now reduced to a commitment by applicants to complete the task at the first refueling.
- 2. NECNP 1.B.2 and SSER Supplement No. 5, Section 3.11 SAPL is concerned that the NRC staff is taking a position of allowing the Applicants to put off installment of environmentally qualified instrumentation for monitoring accumulator pressure (or level) and instrumentation for monitoring containment sump water temperature until after the first refueling outage. The chances of an accident at Seabrook are as great, if not greater, during the initial stages of operation as at any other period between ref uelings.
In SAPL's view, the description of the justification for allowing this postponement in Sect ion 3.11 of SSER Supp. No. 5 is insuf ficient.
SAPL reserves its right to cross examine on t ri i s issue.
- 1. Inadvertently, Seacoast Anti-Pollution League's Objection to Motion to Withdraw Contention NH -10 was filed with the wrong ASLB Chairman and SAPL neglected to put the words "On-site Emergency Planning and Safety Issues" underneath the docket numbers pursuant to the Board order of Oct. 7, 1985. SAPL apologizes for any inconvenience this may have caused the Board and partles.
SAPL is also interested in probing the analysis of equipment performance and shutdown capability following a postulated main steamline break with accompanying release of superheated steam.
Further, SAPL would like to probe the equipment capability and saf e l
} shutdown performance resulting from high energy line breaks (HELB) in compartments outside containment, par ticularly in the main s team and feedwater pipe chase areas.
SAPL also is interested in examining in regard to the maint enance/ surveillance programs for identification and prevention of age-related degradation of mechanical and electrical equipment.
The June 16, 1986 IE Information Notice No. 86-49 on the subj ect of Age / Environment Induced Electrical Cable Failures reinforces SAPL's belief that this is a very important safety issue. This notice describes an incident in November of 1985 in which San Onofre Unit i experienced a loss of offsite power; the most likely cause was determined to be temperature-induced accelerated aging and degradation of electrical insulation.
Additionally, SAPL has an interest in deficiencies found in the Environmental Qualification A'u d i t . SAPL has an interest in deficiencies found in the Environmental Qualification Audit. SAPL would like to examine on the issue of how representative the files selected for audit were, how the correction of deficiencies is to be verified before fuel load and what the j us t i f ica t ion was for not auditing addit ional files given the f act that deficiencies were found in the audited files.
- 3. SSER Supplement No. 4, Section 13.3 The notice of proposed rulemaking on the issuance of operating licenses authorizing only fuel loading and low power opernt ion up to 5% of rated power (46 Federal Register 61132) stated as follows:
) While the proposed rule would eliminate the need to have any NRC or FEMA review, firidings , or determinat ions on the adequacy of offsite agencies' emergency planning and preparedness, the NRC review of the licensees' onsite response will necessarily include aspects of some offsite elements:2 Communications; not i f icat ion; ass is tance agreement s wi th local law enf orcement ,
fire protection and medical organizations; and the like.
SAPL does not agree with the interpretation in SSER Supp. No.
}
4 that the let ters of agreement gef erring to the concept of operat ions developed between the Applica nts and the States of Massachuset ts and New Hampshire are not required before operation up to 5% of rated power. If communications, notification and local law enforcement are to be in place, it seems only reasonable that the concept of operations with New Hampshire and Massachusetts be in place. The plant is s ituated near the border between the two s tates (wi thin two miles) and any evacuation of plant employees could affect traffic enforcement in both states. ,
SAPL would like to examine on the issue of how the operational capability of the public alerting system is to be confirmed and on the issue of how the public information materials are to be distributed pr ior to f uel load. SAPL is also concerned with the decontaminat ion capability for onsite personnel, particularly given SAPL's understanding that t he Emer gency Opera t ions Facili t y (EOF) only has one shower.
- 2. The footnote refers to NUREG-0654/ FEMA REP-1, Rev. 1 and states that NRC will review only those elements under planning criteria essential for assessing licensee preparedness.
Further, SAPL is concerened with the finding in SAPL Report No.
50-443/86-99 at 25 that there are a lack of sufficient numbers of qualified individuals to fill key emergency response positions on a 24-hour basis during an emergency and that there is a lack of on-shift dose assessment capability. SAPL believes both of these situations ought to be corrected prior to any level of operation.
Finally, SAPL is very much concerned with onsite and offsite emergeney medical services. As far as offsite issues go, SAPL continues to find the Commission's action on the GUARD remand arbitrary and capricious. A year has gone by since the Commissio issued its Statement of Policy following the Court's vacation and remand of the Commission's interpretation of 10 CFR 950.47(b)(12).
The time is past ripe for moving this issue out of limbo and taking some rational action on it. Particularly in light of the Chernobyl 4 accident, the Commission's generic findings that accidents that would expose the public to dangerous levels of radiation are of low probability and that the adverse reactions to overexposure would be slow in developing require a critical reappraisal.
SAPL does not believe that letters of agreement with Exeter Hospital and Brigham and Women's Hospital are sufficient to assure that onsite personnel will receive adequate medical care. Exeter Hospital is within the EPZ and hence should not be relied upon.
Other Contentions 13 As this Board will be aware, a very large number of contentions raised by the parties were deposed of by summary disposition, and therefore without evidentiary hearings.
One of the issues so disposed of was SAPL's Supplemental Contention III, admitted by the Board Order of September 13,.1982.
This contention raised the issue of whether or not the Seabrook FES met t he requi remen t s o f t he Na t ional Envi ronmen tal Pol icy Act in the Commission's Interim Policy Statement of June 13, 1980, 45 Fed. Reg.
40101, when it did not disclose the consequences of a single major accident, and f ailed to quantify the bounds of uncertainty regarding an accident.
The Board dismissed this contention on May 11, 1983, and the Appeal Board refused to accept the appeal, on the ground that SAPL remained a party since it was a co-sponsor of Contention NH - 10.
SAPL sets this forth in order to make clear it intends to preserve as an issue on appeal the denial of this contention on the f ailure to adequately disclose the consequences of a severe accident.
SAPL renews its claim that this issue was a matter that required an evidentiary hearing, since there were factual issues in dispute in l
regard to this contention.
Conclusion In conclusion, SAPL would ref er to this Board's Order of November 4, 1985, which provided that "After a prehearing conference, and after discovery, if any, a supplemental hearing will be ordered to tale evidence on the above identified matters... .
For the reasons set forth, prior to the closing of the record on this matter, SAPL believes that the hearing anticipated by this Board in its November 4th Order should now be scheduled, and that it should be entitled to participate on the matters set f orth herein.
Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By its attorney, BACKUS , MEYER & SOLOT10N
., u.-
',7 [. -
. Robert A. Backus P.O. Box 516 116 Lowell Street Manchester, N.H. 03105 Tel: (603) 668-7272 DATE: June 27, 1986 I hereby certify that a copy of the within Seacoast Anti-Pollution League's Response and Obj ection has been sent this date, first class, postage prepaid, to all counsel per attached, service list.
A ,
kff/M.
Robert 4. Backus F
ATTACHMENT A Filed: June 19,1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ;
In the Matter of:
PUBLIC SERVICE COMPANY OF DOCKET NOS. 50-444 OL NEW HAMPSHIRE, ET AL 50-443 OL (Seabrook Station, Units 1 and 2)
SEACOAST ANTI-POLLUTION LE A GUE'S O BJECTION TO MOTION TO WITH D R AW CONTENTION NH-10 The Seacoast Anti-Pollution League hereby objects to the withdrawal of Contention NH-10 on the grounds that such withdrawal is premature. Contention NH-10, amended by the State of New Hampshire and Gregory H. Smith, Attorney General j of the State of New Hampshire on May 24, 1982, reads as follows:
The Seabrook Station Control Room Design does not comply with General Design Criteria 19 through 22 in 10 CFR Part 50, Appendix A, and NUREG-0737, Items I.D. I and I.D. 2.
In the State of'New Hampshire's statement of basis for Contention NH-10, the State declared that: ,.,
It is especially critical at Seabrook that accident monitoring and control room design be the optimum because of the difficulties inherent in carrying out protective actions for the population in the immediate ' vicinity of the plant.1 By Board Order of Sept. 14, 1982, the Board admitted SdP'L Supplement 6 in which SAPL joined in and adopted as its own the contentions an bises of the State of New Hampshire and Attorney General Gregory Smith, Nos. 4 through 10, and 12 through 1 See Amendment and Supplement to the Petition for Leave to Intervene akd; Request for Hearing of the State of New Hampshire and Gregory H. Smith, Attorney General of the State of New Hampshire, April 5,1982, at 27. ,
- C;wtAYk { UJ.'f3
- P . .
- 16. The Board stated that it would permit SAPL to participate as a Joint Intervenor with New Hampshire. Contention NH-10, therefore, cannot be withdrawn without SAPL's assent. SAPL does not lend its assent to this action for the reasons set forth herein.
The Seacoast Anti-Pollution League does not believe that the results of the Detailed Control Room Design Review (DCRDR) nor the design of the Safety Parameter Display System (SPDS) are adequate at this time. Particularly in view of the Chernobyl 4 reactor accident, SAPL holds that additional variables need to be displayed on the SPDS. Further, SAPL does not believe it acceptable to allow the so-called lower priority Human Engineering Discrepancies (HEDs) resolutions to remain uncorrected until the first refueling outage. Additionally, SAPL asserts that the change to the Video Alarm System (VAS) color coding scheme, to make it more consistent with other control room CRT's should be accomplished prior to fuel load and low power testing. SAPL also holds that a preliminary evaluation of the control room environment (including such variables as humidity, acoustic noise, auditory signals, airflow and temperature) ought to be accomplished prior to fuel load. SAPL is aware of no evidence that such a preliminary review has been accomplished except on some auditory signals.
Additional Parameter Displays needed on SPDS SAPL does not believe that the. Applicants' justifications for non-inclusion of three safety parameter displays and the deferral of inclusion of two others until the first refueling outage, as described at P. 9 of SBN-987, should be at all acceptable to this Board. The three parameters the Applicants do not intend to include are RHR flow, Containment Isolation and Containment Hydrogen Concentration.
Residual Heat Removal Flow is a key indicator of the efficacy of heat removal when steam generators are not available. Applicants argue that RHR flow is not a
" stand alone" parameter, and they assert that the core cooling status tree on the SPDS is best used for determining that the heat removal function is being performed. SAPL holds that it would greatly enhance safety to have both parameters displayed. This would be consistent with the NRC's avowed defense in depth philosophy.
Containment isolation is important for a rapid assessment of the conditions prevailing in the containment and can provide additional assurance of containment integrity. Aoplicants argue that since there are status light indicators for every containment isolation valve on the main control board, it is not necessary to add containment isolation to the SPDS. Applicants assert that the status light indicators are visible from the SPDS console. In an emergency situation, there could be many people walking around in the control room who could obstruct the line of vision to the main control board. This potential problem should be eliminated prior to operation at any level by installation of the appropriate parameter display on the SPDS console.
Containment hydrogen concentration is a key parameter required to monitor combustible gas control. Aaplicants aver that this parameter display is unnecessary because it is indicated on the main control board, is not likely to cause any need for action within the first few hours of any accident, that an operators emergency support group would be in place at any time hydrogen concentration would be a threat, and that it is a parameter reviewed in the emergency procedures set. SAPL urges that this line of argument be found non-persuasive. Particularly in view of the questions that are yet unanswered with regard to the role of hydrogen in the breach of the Chernobyl 4 containment, the monitoring of combustible gases is very important. It is possible that, even in light water moderated reactors; combustible gases could accumulate much more quickly than anticipated via processes not yet fully understood.
The Applicants seek a deferral of the incorporation of parameter displays for Steam Generator Radiation and Stack Monitor until the first refueling outage. This should be wholly unacceptable. These parameters are very important and without them the SPDS will be incapable of displaying information allowing the assessment of radiation in the secondary steam system when the steam generators and/or their steamlines are isolated. Applicants point to the fact that there is a radiation monitoring console in the Control Room. Applicants do not detail whether or not the information on the
radiation monitoring console is readable from the vantage point of the SPDS console.
In SAPL's view, there is no justification for postponement of installation of these
- parameter displays. All 5 of the above-mentioned parameter displays ogt to be installed prior to fuel load and station operators should be thoroughly trained in their use prior to any operation of the plant.
4 HEDS Resolutions including the V,KS Color Coding Scheme f In SBN-839, the Applicants on July 17, 1985 committed to review the control
- room furnishings for HEDs "at least 120 days PTLF" (prior to loading fuel). However, i
SER Supplement 4, transmitted to the Board and parties by the staff on June 4,1986, 1
! indicates as follows:
$ Subsequent to completion of installation of furnishings in the control room a review will be conducted by PSNH and any HEDs found will be resolved prior to startup from the first refueling outage.
In SBN-839, the Applicants said that operator protective equipment and emergency t
equipment storage would be reviewed at least 120 days PTLF and any HEDs submitted for NRC review. Yet, SER Supplement 4 says:
Once the equipment has been purchased and installed, the storage facilities i will be re-evaluated by PSNH. Any HEDs found will be resolved prior to start up from the first refueling outage.
SER Supplement 4 goes on to state that final evaluation of the control room i
j environment will be completed and reported to NRC for confirmatory review after a year of commercial operation has been achieved. Hoivever, there appears to SAPL to
, be no good reason why a preliminary evaluation and identification of HEDs cannot be unciertaken prior to fuel loading.
In sum, it appears to SAPL that the rush to core load Seabrook is causing the NRC and Applicants to push aside tasks that ought to be completed before any operation for the plant is allowed, even in the face of Applicant's own prior commitment to complete them.
i i
The color-related HED in the Video Alarm System clearly ought to be corrected before any operation of the plant is allowed.
Plant operators should accustom themselves to the change in color-coding before the plant operates at any-level. It is imprudent to allow the plant to be low power tested while the color coding is still inconsistent with other CRT's. This will only serve to reinforce this anomalous situation in the minds of the operators and could lead them to make an error when the plant is put into full power operation with the color code modified.
In attachment 1 to SBN-948, in the discussion related to the need for a sensitive containment pressure indicator, applicants note that they have " committed to banding indicators by the end of the first refueling outage." Again, SAPL urges this Board to find that there is no acceptable justification for deferring improvements that will aid the plant operators in monitoring plant conditions.
SAPL would call to attention again the State of New Hampshire's statement of April 5,1982, that monitoring and control room design should be optimum because of the population in the immediate vicinity. The State of New Hampshire appears to be retreating from its prior commitment to protect public health and safety in its withdrawal of Contention NH-10. Although this is truly unfortunate, the NRC ought nonetheless insist on a high standard of safety. F6r the reasons set forth above, SAPL objects to and opposes the Motion to Withdraw Contention NH-10 on the grounds that such withdrawal is premature.
Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By its Attorney, BACKUS, MEYER & SOLOMON
/ .g>',
C '
7 S
Robert A: ~Backus Pt O. Box 516 116 Lowell Street Manchester, NH 03105 Tel: (603) 668-7272 DATE: June 19,1986 CERTIFICATE OF SERVICE AND SERVICE LIST Asst.Gn.Cnsl. Sheldon J. Wolfe, Chrm. Thomas Dignan, Esq.
Joseph Fed. Flynndgmt. Agcy.
Emerg. Admn. Judge Ropes & Gray 500 C.St. So. West Atomic Safety & Lic Brd. 225 Franklin St.
Washington, DC 20472 USNRC Boston, MA 02110 Washington, DC 20555 Office of Selectmen Dr. Jerry Harbour Docketing & Serv. Sec.
Town of Hampton Falls Admin. Judge Office of the Secretary Hampton Falls, NH 03844 Atomic Safety & Lic Brd. USNRC USNIlC Washington, DC 20555 Washington, DC 20555 Sherwin E. Turk, Esq. Jane Doughty Dr. Emmeth A. Luebke Of . e of Exec. Legl. Dr. Admin Judge SAPL Atomic Safety & Lic. Brd. 5 Market Street Wahsington, DC 205__ USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq. Paul McEachern, Esq. George Dana Bisbee, Esq.
Asst. Atty. General Matthew BInck, Esq. Attorney General's OFF.
State House, Sta. F6 25 Maplewood Ave. State of New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsr:nuth, NH 03801 Carol Sneider, Esq., Asst.AG Diane Curran, Esq. William S. Iord One Ashburton Place, Harmon, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430 Town Hall-Friend St.
Boston, MA 02108 Washingcon, DC 20009 Amesbury, MA 01913 Richard A. Ha::pe, Esq. Maynard Young, Chainmn Sandra Gauvutis New Hampshire Civil Delense Board of Selectmen Town of Kingston Agency 10 Central Road Box 1154 Harpe & McNicholas Rye, NH 03870 East Kensington, NH 03827 35 Pleasant St. ,
Concord, NH 03301 Edward Thomas Mr. Robert Harrison FEMA Pres, & Chief Exec. Officer 442 J.W. McCormack (pOCH) PSCO Boston, MA 02109 P.O. Box 330 Manchester, NH 03105 Roberta Pevear State Rep.-Town of Harpt Falls Drinlexater Road Hanpton Falls, NH 03844
_