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| | number = ML19225B245 | | | number = ML19225B245 |
| | issue date = 06/26/1979 | | | issue date = 06/26/1979 |
| | title = Brief by Intervenor Colemans in Support of Request That Aslb Compel Util to Suppl Answers to Interrogatories 1,3 & 6.ASLB Has Responsibility to Determine Significance of Facts Re Issues in Controversy | | | title = Brief by Intervenor Colemans in Support of Request That ASLB Compel Util to Suppl Answers to Interrogatories 1,3 & 6.ASLB Has Responsibility to Determine Significance of Facts Re Issues in Controversy |
| | author name = Onsdorff K | | | author name = Onsdorff K |
| | author affiliation = NEW JERSEY, STATE OF | | | author affiliation = NEW JERSEY, STATE OF |
Brief by Intervenor Colemans in Support of Request That ASLB Compel Util to Suppl Answers to Interrogatories 1,3 & 6.ASLB Has Responsibility to Determine Significance of Facts Re Issues in ControversyML19225B245 |
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Salem |
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06/26/1979 |
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Onsdorff K NEW JERSEY, STATE OF |
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ML19225B243 |
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NUDOCS 7907240350 |
Download: ML19225B245 (5) |
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Similar Documents at Salem |
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Category:BRIEFS
MONTHYEARML18085A8401981-02-17017 February 1981 Brief Supporting ASLB 801027 Decision Authorizing OL Amend to Permit Storage of 1,170 Spent Fuel Elements in Facility Spent Fuel Pool.All Exceptions Should Be Denied.Aslb Has Adequately Weighed Evidence.Certificate of Svc Encl ML18082A1661980-03-24024 March 1980 Supplemental Brief Re Motion for Directed Certification & for Stay.Commission 800321 Memorandum & Order Re Black Fox Leaves No Doubt That Aslab Proposed Consideration of Question 5 Is Contrary to Directive of Commission ML18081B2181980-03-0303 March 1980 Motion in Form of Brief for Directed Certification of Class 9 Question & for Stay of Proceeding.Aslab Intercession Is Warranted Per Stds Set in Marble Hill & Skagit Proceedings. Urges Consideration of All Aspects.Certificate of Svc Encl ML19225B2451979-06-26026 June 1979 Brief by Intervenor Colemans in Support of Request That ASLB Compel Util to Suppl Answers to Interrogatories 1,3 & 6.ASLB Has Responsibility to Determine Significance of Facts Re Issues in Controversy ML19241B8311979-06-25025 June 1979 Brief in Support of Motion for Reconsideration of Contention 7 Submitted by Intervenors Colemans.Aslb Order Would Comply W/Mandate in Mn Vs NRC Re Storage of Radwaste Beyond Term of Ol.Certificate of Svc Encl ML18079A7881979-06-22022 June 1979 Brief Submitted by Intervenor Colemans in Response to Util Opposition to ASLB Consideration of Class 9 Accident & Certification of Issue.Aslb Is Required to Review Class 9 Accidents.Certification Is Not Appropriate ML19225A2271979-06-14014 June 1979 Request for Denial of NRC 790601 Objection to ASLB Consideration of Class 9 Accidents Submitted by Intervenors States of Nj & DE & Colemans.Class 9 Accidents Are Legitimate Safety Concern,Germane to Admitted Contentions 1981-02-17
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation ML18106A8811998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG ML18106A8731998-09-15015 September 1998 Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998 Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991 LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis ML18102B4361997-07-0707 July 1997 Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst ML20132A8961996-12-0606 December 1996 Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry ML20084H9251995-06-0202 June 1995 Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs ML20134K5021995-02-24024 February 1995 Transcript of 950224 Enforcement Conference in King of Prussia,Pa Re C Vondra.Pp 1-136 ML20134K4511995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re Plant.Pp 1-93 ML20134K4791995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re V Polizzi.Pp 1-115 ML20134K4971995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re L Reiter.Pp 1-64 ML20080G8321995-02-0606 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary ML20077L8631995-01-0303 January 1995 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities ML20132B2281994-08-0202 August 1994 Transcript of 940802 Enforcement Conference in Salem,Nj W/Salem Senior Nuclear Shift Supervisor Involved in 940407 Event ML20067C1591994-02-17017 February 1994 Comments on NUREG/CR-5884 Re Analyses of Decommissioning for Ref PWR Power Station ML18100A5591993-08-26026 August 1993 Comment Opposing Proposed Rule Re Whistleblower Protection 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 ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20072T2421991-04-11011 April 1991 Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20195H0331988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing ML20153F9681988-08-17017 August 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged ML20154G1421988-04-20020 April 1988 Comment Opposing Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization Program.Nrc Should Establish Program Mutually Agreed Upon Between Union & Util,Per Hope Creek & Salem Programs ML20154G4601988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility ML18093A6331988-02-0101 February 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods ML20151B3641987-02-24024 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning ML20079N4271984-01-25025 January 1984 Response to State of DE 840120 Motion to Withdraw Petition for Leave to Intervene.Licensee Concurs in Motion.Dismissal of Proceeding Requested.Certificate of Svc Encl ML20079K9311984-01-20020 January 1984 Motion to Withdraw Petition for Leave to Intervene & Request for Hearing Re Extension of Time for Type a Test.Certificate of Svc Encl ML20078P6771983-11-0404 November 1983 Answer to State of DE Atty General 831021 Petition for Leave to Intervene & Request for Hearing on License Amend Re Inservice Integrated Leak Tests.Notices of Appearance & Certificate of Svc Encl ML20078M1551983-10-21021 October 1983 Petition for Leave to Intervene & Request for Hearing on Proposed Issuance of Amend to License DPR-70 Re Inservice Integrated Leak Tests.Affidavit of Mailing Encl ML18087A8331983-04-12012 April 1983 Petition for Order to Show Cause Why Util Should Not Be Restrained from Restarting Facility Until Qualifications for Operation Demonstrated at Public Hearing ML18087A8341983-04-11011 April 1983 Affidavit of DG Bridenbaugh Re Delay of Facility Restart. Full Review of safety-related Equipment Must Be Completed & Appropriate Changes Implemented.Prof Qualifications Encl ML20213E3601983-03-0808 March 1983 Testimony Before Subcommittee on Energy & Environ Re Plant Licensing Concerns ML18086A9691981-10-14014 October 1981 Affidavit Confirming Validity of Util 811009 Response to IE Insp Repts 50-272/81-15 & 50-311/81-14 ML20005B6831981-08-20020 August 1981 Petition for Review of Aslab 810717 Order,Permitting OL Amend,Allowing Installation of New Storage Racks & Increasing Pool Capacity.Notice of Appearance & Affidavit of Svc Encl.Related Correspondence ML20010C1481981-08-14014 August 1981 Response in Opposition to Lower Alloways Creek Township 810803 Petition for Review of ALAB-650.Petitioner Has Raised No Issue Which Warrants Commission Consideration.Certificate of Svc Encl ML20009H2221981-08-0303 August 1981 Petition Supporting Review of Aslab Decision.Case Involves Matter That Could Significantly Affect Environ,Public Health & Safety & Involves,Important Procedural Issues & Public Policy Questions.Certificate of Svc Encl ML18086A5181981-05-15015 May 1981 Answer Opposing AC Coleman 810504 Request for Stay of Initial decision,LBP-80-27,pending Appeal.Request Untimely & Fails to Meet Requirements for Issuance of Stay. Certificate of Svc Encl ML18085A8401981-02-17017 February 1981 Brief Supporting ASLB 801027 Decision Authorizing OL Amend to Permit Storage of 1,170 Spent Fuel Elements in Facility Spent Fuel Pool.All Exceptions Should Be Denied.Aslb Has Adequately Weighed Evidence.Certificate of Svc Encl ML18085A5231981-01-13013 January 1981 Findings of Fact & Conclusions of Law in Support of 801111 Exceptions to ASLB 801027 Initial Decision Re Applicant Proposed Expansion of Fuel Storage.Certificate of Svc Encl ML18085A4091980-12-0808 December 1980 Response to Intervenors Eg & a Coleman Motion for Extension Until 810131 to File Brief in Support of Exceptions.Opposes Motion But Would Not Object to 2-wk Extension.Certificate of Svc Encl ML18085A4081980-12-0404 December 1980 Appeal from ASLB Initial Decision Granting Util Right to Increase Spent Fuel Pool Storage Capacity.Nepa Requires Detailed Analysis of Safety & Health Problems Posed by Reracking.Certificate of Svc Encl ML19340D3431980-11-30030 November 1980 Request for Extension to 810131 to File Brief in Support of Exceptions to ASLB 801027 Initial Decision Re Spent Fuel Pool Proceeding.Certification of Svc Encl ML18085A2791980-11-20020 November 1980 Notice of Withdrawal of Appearance as Counsel for Intervenors Coleman.Intervenors Coleman to Remain Parties to Proceeding.Certificate of Svc Encl ML18085A2501980-11-11011 November 1980 Appeal from ASLB 801027 Initial Decision.Alleges Erroneous Finding of Facts Re Contentions 2 & 6,evaluation of Eia, Acceptance of Pasedag Testimony & Rejection of Benjamin Testimony.Counsel Withdrawal & Certificate of Svc Encl ML18085A2161980-11-0404 November 1980 Exceptions & Appeal from ASLB 801027 Initial Decision. Exclusion of as Benjamin of Sandia Labs Testimony Is Arbitrary Due to Relevant Evidence Re Oxidation That Could Propagate to Older Fuel.Certificate of Svc Encl ML20062J4921980-10-21021 October 1980 Addl Testimony Presented Before ASLB to Correct & Clarify 800710 Testimony Re Loss of Water from Spent Fuel Storage Pool ML18082A7101980-07-11011 July 1980 Reply Findings of Fact & Conclusions of Law in Form of Partial Initial Decision Substituting for Licensee 800613 Findings,In Response to ASLB 800509 Order & ASLB 800626 Question 5 on away-from-reactor Issues.W/Certificate of Svc 1998-09-15
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STATEMENT IN SUPPORT CF MCTION By letter dated June 6, 1979, Intervenors, Coleman, requested that the licensee supplement its answers to certain interrogatories dealing with safety and refueling cycle at the Salem One Nuclear Generating Station. (Copy of letter attached hereto as Exhibit A). "'his request for supplementation was precipitated by media repor*s of unanticipated damage to fuel assembly support straps being discovered during the recent refueling cutage at the Salem plant.
During a telephone conversatien with Mr. Wetterhahn, Counsel for public Service on June 25, 1979, I was informed that no further infor=ation would be forthccming in response to Intervenors request beyond the statement in his June 19, 1979 letter to the Board, found at page two, that:
"it does not appear at this time that these two problems will increase the number of spent fuel elements to be stored in the spent fuel pool nor will the present refueling outage be significantly lengthened."
June 19, 1979 letter; p.2.
Of course, the conclusion of counsel for licensee pertaining to the significance of the period of this first refueling cutage at Salem One is subject to differing interpretations by tha Scard and other disinterested parties. Moreover, the tendency for pieces of sharp metal to disengage from the fuel assembly support straps may constitute a significant hacard to the fuel pool environ =ent, including the boral shields used to prevent the stored fuel from beccming critical. While this risk may be m"'ml, it cannot and shc.uli nct be either ignored, overlocked or exanined by cnly one litigant during the pendency of an adjusicatory proceeding. Yet, this latter issue is not even addressed by Mr. Uetterhahn's missive of June 19, J79.
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It would apprear, therefore, that the parties to the within proceeding b3 fore the Nuclear Regulatory Cor:=tission are entitled to exa: tine the cbjective facts pertaining to the issues in controversy and suhmit appropriate evidence and argu:nents to 'the Atemic Safety and Licensing Board, which panel is charged with the exclusive responsibility for determining the significance of such =atters, and not counsel for one or another party to the proceeding.
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CONCLUSICN For all the foregoing reasons, it is respectfully sub=itted that licensee should be ordered to submit a report to the parties and the Board setting forth the details of the fuel asscrbly support strap defect problem at the Salem One Nuclear Generating Station.
Respectfully submitted,
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ICITH A. CNSCORFF /9/
ASSISTANT DEFUTY PUBLIC ACVCCATE KAO/l=e
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DIVISION OF PU BLIC INTEREST ADVOCACY CAn\s g 9g e 9 P.O DOX 141 TEL. 609-23 2- 16 93 STANLE Y C. V AN NE SS TRENTON. NEW JEMSEY C8423 PUSLIC ACVOCATE June 6, 1979 O k '* %v Mark J. Wetterhahn, Esq. '
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Dear Mr. Wetterhahn:
It has cc=e to our attention that during the recent refueling at Salem Cne certain dents anc cr.tcks in scme metal plates used to secure ,
the supports of the fuel assemblies were discovered.
As we discussed by telephone today, I believe that pursuant to 10 C.F.R. 2.740(e), Supplementatica of Respon;es, the licensee is cbligated to provide inter.enors with a detailed explanation of this recently discovered defect in the fuel support structure. Both Intenega-tories Cne and Three per ain to the refueling cycle at 'the Salem facilirf
- .nd Incerrogatorf Six addresses safery censiderations which, it wculd appear, have been affected by this unforeseen cccurrence.
We would appr=ciate receiving icur Supplemental answers to these-In crogatories by no later than June I5,1979.
Thank ycu for ycur cocperatien.
Very tntly y~ws
&O ' )C KEITH A. CNSCCP_:F 40CDlf r Assistant Depurf PublicV& j/ ,ca}'^
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Before the Atemic Safety and Licensinc Ecard x CJ In the Matter of : Docket No. 50-272 PUBLIC SER7 ICE ELECTRIC : Propcsed Issuance of Amendment
& GAS CO. to Facility Cperating License (Salem Nuclear Generating : No. DPR-70 Station, Unit #1)
CERTIFICA3 CF SERVICE I hereby certify that copies of Interrenors, Colemans Motion To Ccapel Licensee To Supplement Answers To Interrogatories in the above captioned matter has been seried upon the parties to this proceedings by deposit in the United States M 1 at the post office in Trenton, N.J. , with proper postage thereon, this 26th day of June, 1979. ,
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