|
---|
Category:INTERVENTION PETITIONS
MONTHYEARML20237B6611987-12-0303 December 1987 Clarification of NRC Staff Response to Proposed Contentions of Susquehanna Valley Alliance & TMI Alert,Inc & Response to Amended Proposed Contentions.* Position Noted in 871116 Response Reiterated.W/Certificate of Svc ML20235A8611987-11-20020 November 1987 Amends to Suppl to Petition for Leave to Intervene for Susquehanna Valley Alliance (Sva) & TMI Alert (Tmia).* Contentions Listed ML20236R8041987-11-16016 November 1987 NRC Staff Response to Proposed Contentions of Susquehanna Valley Alliance & TMI Alert.* Contentions 2 & 6 Should Be Admitted as Issues in Proceeding.Contentions 1,3,4,5,7 & 8 Should Be Rejected.W/Certificate of Svc ML20236P8481987-11-12012 November 1987 Licensee Response to Suppl to Petition for Leave to Intervene by Susquehanna Valley Alliance & TMI Alert.* Petition for Hearing Should Be Denied.Supporting Documentation & Certificate of Svc Encl ML20235W1501987-10-0505 October 1987 TMI Alert Inc (Tmia) Authorization for F Skolnick,Member of Tmia,To Act as Intervenor Representing Organization.* Served on 871009 ML20236C0771987-10-0101 October 1987 Response to Licensee & NRC Response to Petition to Intervene.* Skolnick Appointed as Representative as Well as Member of TMI Alert & Fulfills Requirements of 10CFR2.713(b).Certificate of Svc Encl ML20235H6451987-09-25025 September 1987 NRC Staff Response to Petitions to Intervene Filed by Susquehanna Valley Alliance & TMI Alert,Inc & Petition by Commonwealth of PA to Participate as Interested State.* Notice of Appearance & Certificate of Svc Encl ML20234D2981987-09-15015 September 1987 Licensee Response to Commonwealth of PA Petition to Participate as Interested State.* Util Has No Objection to Granting Commonwealth of PA 870903 Petition If Request for Hearing Granted.Certificate of Svc Encl ML20234D3301987-09-15015 September 1987 Licensee Response to Petitions to Intervene.* Licensee Suggests That ASLB Issue Order Scheduling Special Prehearing Conference for 871015 & Directing Petitioners to File Proposes Contentions by 870930.W/Certificate of Svc ML20206R6411986-06-30030 June 1986 Petition of Commonwealth of PA for Leave to Participate as Interested State.Notice of Appearance & Certificate of Svc Encl ML20199E2301986-03-20020 March 1986 Response to TMI Alert Suppl to 851223 Petition for Leave to Intervene.Proposed Contentions 1,4 & 5 Raise Matters within Scope of Proceeding & Should Be Admitted.Proposed Contentions 2 & 3 Inadmissible.Certificate of Svc Encl ML20199E1951986-03-20020 March 1986 Response to TMI Alert,Inc 860310 Suppl to Petition to Intervene Re Proposed Amend to License DPR-50 Re Criteria for Steam Generator Tube Repair.Contentions Fail 10CFR2.714(b) Requirements.Certificate of Svc Encl ML20138A9161986-03-13013 March 1986 Petition of Aamodts,Representing Committee on Health Aspects & Mgt of Nuclear Power for Leave to Intervene & Request for Hearing ML20138B2221986-03-10010 March 1986 Demand for Full Adjudicatory Hearing on Licensee 860204 Request for Amend to License DPR-50,identified as Tech Spec Change 153,to Relax Tube Plugging Criteria.Served on 860318 ML20138A2631986-03-10010 March 1986 Demand for Adjudicatory Hearing Re Gpu 860204 Tech Spec Change Request 153,revising Tube Plugging Criteria for Steam Generators ML20205K5101986-02-25025 February 1986 Response to Mm Aamodt 860208 Petition for Leave to Intervene & Request for Hearing Re Alleged Falsification of Leak Rate Data.Certificate of Svc Encl ML20141E5711986-02-24024 February 1986 Amend to Petition of TMI Alert,Inc for Leave to Intervene & Request for Hearing to Include Encl Affidavit of Kk Pickering,Per ASLB 860212 Order ML20151T4341986-02-0404 February 1986 Petition of Jm Kidwell,1978-1979 Employee of Met Ed,For Leave to Intervene Re Alleged Falsification of Leak Rate Data at Facility.Certificate of Svc Encl ML20137P1761986-01-31031 January 1986 Response Opposing Mi Lewis 860113 Petition for Leave to Intervene & Suggested ASLB Questions.Lewis Has No Interest That May Be Affected by Inquiry.Notices of Appearance & Certificate of Svc Encl ML20137P1721986-01-31031 January 1986 Petition of Numerous 1978-79 Employees of Met Ed for Leave to Intervene.Served on 860203 ML20140F1601986-01-30030 January 1986 Response to Contentions Submitted by Util & TMI-Alert as Suppls to Petitions to Intervene.Contentions Should Be Admitted as Consistent W/Regulatory Pleading Requirements & Notice of Hearing.Certificate of Svc Encl ML20137P1511986-01-30030 January 1986 Petition of Jg Herbein for Leave to Intervene in Matter of Inquiry Into Facility Leak Rate Data Falsification.Served on 860203 ML20137P1261986-01-29029 January 1986 Petition of GP Miller for Leave to Intervene in Proceeding. Miller Can Present Testimony to Contribute to Development of Adequate Record on Issues.Notice of Appearance & Certificate of Svc Encl.Served on 860203 ML20137P1341986-01-29029 January 1986 Petition of Jg Herbein for Leave to Intervene in Inquiry Re Leak Rate Data Falsification.Petitioner Has Interest Which May Be Affected by Proceeding.Notice of Appearance Encl ML20151Y7351986-01-27027 January 1986 Petition of Mm Aamodt for Leave to Intervene & Request for Hearing.Served on 860212 ML20137N0841986-01-24024 January 1986 Answer of C Husted to Suppl to TMI Alert,Inc,Request for Leave to Intervene in Hearing Granted C Husted,Per 851206 Memorandum & Order.Contentions Should Be Recast & Issues Stated as Listed.Certificate of Svc Encl ML20137N2121986-01-24024 January 1986 Response of C Husted Supporting Util Suppl to Petition to Intervene.Util Contention That NRC Should Not Disqualify Husted as NRC-licensed Operator Admissible.Certificate of Svc Encl ML20140C6131986-01-23023 January 1986 Petition of Gpu Nuclear Corp for Leave to Intervene in Leak Rate Data Falsification Inquiry.Certificate of Svc Encl. Served on 860127 ML20137A8371986-01-10010 January 1986 Petition of Licensee for Leave to Intervene & Request for Supplemental Hearing.Permission to Litigate Listed Contention Re Conduct & Attitude of C Husted Requested. Certificate of Svc Encl ML20137A7621986-01-0909 January 1986 Petition of Mi Lewis for Leave to Intervene & Request for Hearing.Served on 860113 ML20210A3571985-11-12012 November 1985 Response to Util 851021 Petition for Leave to Intervene.Nrc Does Not Oppose Petition,Subj to Util Satisfying Requirements of 10CFR2.714(b) ML20210A3751985-11-12012 November 1985 Responds to TMI Alert (Tmia) 851020 Petition for Leave to Intervene.Nrc Does Not Oppose Petition,Subj to Tmia Satisfying Requirements of 10CFR2.714(b).Notice of Appearance for GE Johnson & Certificate of Svc Encl ML20138P7881985-11-0404 November 1985 Petition of D Davenport to Join in Petition of Mi Lewis for New or Expanded Contention Re Hartman Leak Rate Allegations ML20138N6561985-11-0101 November 1985 Answer Supporting Gpu Petition for Leave to Intervene in Proceeding.Certificate of Svc Encl ML20138N5701985-11-0101 November 1985 Answer Supporting TMI Alert (Tmia) Request for Leave to Intervene in Hearing.Answer Does Not Foreclose Any Position to Be Taken in Future W/Tmia in Proceeding.Certificate of Svc Encl ML20138E3491985-10-21021 October 1985 Petition of DB Bauser for Leave to Intervene.Certificate of Svc Encl ML20138E3591985-10-20020 October 1985 Petition of L Bradford for Leave to Intervene & Request for Hearing Re C Husted Integrity & Suitability to Serve as Licensed Operator Instructor or Training Supervisor. Certificate of Svc Encl ML20133H1291985-10-0909 October 1985 Answer to Mi Lewis 850919 Petition for New or Expanded Contention Re Hartman Leak Rate Allegations.Petition Should Be Denied in Entirety ML20133E8771985-10-0404 October 1985 Response to Mi Lewis 850919 Petition for New Leak Rate Contention.Board Has No Jurisdiction to Consider Petitioner Contention ML20135H9541985-09-18018 September 1985 Petition of Mi Lewis for Leave to Intervene & Request for Hearing ML20090C4901984-07-0909 July 1984 Motion for Leave to Participate as Interested State Pursuant to 10CFR2.715(c).Notice of Appearance & Certificate of Svc Encl ML20086G5271984-01-0909 January 1984 Motion to Dismiss TMI Alert,Inc (Tmia) Contentions 1.a,1.b, 1.c & 2.b.1 Re post-repair & Plant Performance Testing & Use of Sulfur Compounds in Sys.Tmia Failed to Provide Bases for Contentions ML20082F5731983-11-23023 November 1983 Motion for Leave to Participate in Oral Presentations at Commission 831205 Meeting Re Mgt Competence & Integrity. Certificate of Svc Encl ML20078N8631983-10-31031 October 1983 Response Opposing Joint Petitioners 831017 Restatement of Contentions.Licensee Agrees to Substitution of Revised Proposed Contention 1 for Original Proposed Contentions 1, 2 & 3.Certificate of Svc Encl ML20081A5071983-10-22022 October 1983 Restatement of Proposed Contentions 1,2 & 3 Re Physical & Chemical Processes Employed to Return Tubes to Design Basis. Certificate of Svc Encl ML20078F8681983-10-0606 October 1983 Response Opposing TMI Alert 830921 Suppl to Petition to Intervene.Contentions Satisfy None of Specificity Requirements.Certificate of Svc Encl ML20078F9071983-10-0606 October 1983 Response to Proposed Contentions Re Steam Generator Repair. Joint Petitioners Fail to Identify Concerns Which Warrant Consideration.Certificate of Svc Encl ML20078A3541983-09-21021 September 1983 Suppl to 830808 Petition to Intervene,Listing Contentions. Certificate of Svc Encl ML20078B8011983-09-21021 September 1983 Contentions of J Lee,N Aamodt & B Molholt Re Steam Generator Degradation & Repair.Svc List Encl ML20085D8481983-07-26026 July 1983 Response to NRC Intervention Requirements for Adjudicatory Hearing on Steam Generator Repair Amend.Petitioner Has Standing Due to Close Proximity of Residence to Plant. Certificate of Svc Encl 1987-09-25
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20237B6611987-12-0303 December 1987 Clarification of NRC Staff Response to Proposed Contentions of Susquehanna Valley Alliance & TMI Alert,Inc & Response to Amended Proposed Contentions.* Position Noted in 871116 Response Reiterated.W/Certificate of Svc ML20235A8611987-11-20020 November 1987 Amends to Suppl to Petition for Leave to Intervene for Susquehanna Valley Alliance (Sva) & TMI Alert (Tmia).* Contentions Listed ML20236R8041987-11-16016 November 1987 NRC Staff Response to Proposed Contentions of Susquehanna Valley Alliance & TMI Alert.* Contentions 2 & 6 Should Be Admitted as Issues in Proceeding.Contentions 1,3,4,5,7 & 8 Should Be Rejected.W/Certificate of Svc ML20236P8481987-11-12012 November 1987 Licensee Response to Suppl to Petition for Leave to Intervene by Susquehanna Valley Alliance & TMI Alert.* Petition for Hearing Should Be Denied.Supporting Documentation & Certificate of Svc Encl ML20235W1501987-10-0505 October 1987 TMI Alert Inc (Tmia) Authorization for F Skolnick,Member of Tmia,To Act as Intervenor Representing Organization.* Served on 871009 ML20236C0771987-10-0101 October 1987 Response to Licensee & NRC Response to Petition to Intervene.* Skolnick Appointed as Representative as Well as Member of TMI Alert & Fulfills Requirements of 10CFR2.713(b).Certificate of Svc Encl ML20235H6451987-09-25025 September 1987 NRC Staff Response to Petitions to Intervene Filed by Susquehanna Valley Alliance & TMI Alert,Inc & Petition by Commonwealth of PA to Participate as Interested State.* Notice of Appearance & Certificate of Svc Encl ML20234D2981987-09-15015 September 1987 Licensee Response to Commonwealth of PA Petition to Participate as Interested State.* Util Has No Objection to Granting Commonwealth of PA 870903 Petition If Request for Hearing Granted.Certificate of Svc Encl ML20234D3301987-09-15015 September 1987 Licensee Response to Petitions to Intervene.* Licensee Suggests That ASLB Issue Order Scheduling Special Prehearing Conference for 871015 & Directing Petitioners to File Proposes Contentions by 870930.W/Certificate of Svc ML20206R6411986-06-30030 June 1986 Petition of Commonwealth of PA for Leave to Participate as Interested State.Notice of Appearance & Certificate of Svc Encl ML20199E2301986-03-20020 March 1986 Response to TMI Alert Suppl to 851223 Petition for Leave to Intervene.Proposed Contentions 1,4 & 5 Raise Matters within Scope of Proceeding & Should Be Admitted.Proposed Contentions 2 & 3 Inadmissible.Certificate of Svc Encl ML20199E1951986-03-20020 March 1986 Response to TMI Alert,Inc 860310 Suppl to Petition to Intervene Re Proposed Amend to License DPR-50 Re Criteria for Steam Generator Tube Repair.Contentions Fail 10CFR2.714(b) Requirements.Certificate of Svc Encl ML20138A9161986-03-13013 March 1986 Petition of Aamodts,Representing Committee on Health Aspects & Mgt of Nuclear Power for Leave to Intervene & Request for Hearing ML20138B2221986-03-10010 March 1986 Demand for Full Adjudicatory Hearing on Licensee 860204 Request for Amend to License DPR-50,identified as Tech Spec Change 153,to Relax Tube Plugging Criteria.Served on 860318 ML20138A2631986-03-10010 March 1986 Demand for Adjudicatory Hearing Re Gpu 860204 Tech Spec Change Request 153,revising Tube Plugging Criteria for Steam Generators ML20205K5101986-02-25025 February 1986 Response to Mm Aamodt 860208 Petition for Leave to Intervene & Request for Hearing Re Alleged Falsification of Leak Rate Data.Certificate of Svc Encl ML20141E5711986-02-24024 February 1986 Amend to Petition of TMI Alert,Inc for Leave to Intervene & Request for Hearing to Include Encl Affidavit of Kk Pickering,Per ASLB 860212 Order ML20151T4341986-02-0404 February 1986 Petition of Jm Kidwell,1978-1979 Employee of Met Ed,For Leave to Intervene Re Alleged Falsification of Leak Rate Data at Facility.Certificate of Svc Encl ML20137P1761986-01-31031 January 1986 Response Opposing Mi Lewis 860113 Petition for Leave to Intervene & Suggested ASLB Questions.Lewis Has No Interest That May Be Affected by Inquiry.Notices of Appearance & Certificate of Svc Encl ML20137P1721986-01-31031 January 1986 Petition of Numerous 1978-79 Employees of Met Ed for Leave to Intervene.Served on 860203 ML20140F1601986-01-30030 January 1986 Response to Contentions Submitted by Util & TMI-Alert as Suppls to Petitions to Intervene.Contentions Should Be Admitted as Consistent W/Regulatory Pleading Requirements & Notice of Hearing.Certificate of Svc Encl ML20137P1511986-01-30030 January 1986 Petition of Jg Herbein for Leave to Intervene in Matter of Inquiry Into Facility Leak Rate Data Falsification.Served on 860203 ML20137P1261986-01-29029 January 1986 Petition of GP Miller for Leave to Intervene in Proceeding. Miller Can Present Testimony to Contribute to Development of Adequate Record on Issues.Notice of Appearance & Certificate of Svc Encl.Served on 860203 ML20137P1341986-01-29029 January 1986 Petition of Jg Herbein for Leave to Intervene in Inquiry Re Leak Rate Data Falsification.Petitioner Has Interest Which May Be Affected by Proceeding.Notice of Appearance Encl ML20151Y7351986-01-27027 January 1986 Petition of Mm Aamodt for Leave to Intervene & Request for Hearing.Served on 860212 ML20137N0841986-01-24024 January 1986 Answer of C Husted to Suppl to TMI Alert,Inc,Request for Leave to Intervene in Hearing Granted C Husted,Per 851206 Memorandum & Order.Contentions Should Be Recast & Issues Stated as Listed.Certificate of Svc Encl ML20137N2121986-01-24024 January 1986 Response of C Husted Supporting Util Suppl to Petition to Intervene.Util Contention That NRC Should Not Disqualify Husted as NRC-licensed Operator Admissible.Certificate of Svc Encl ML20140C6131986-01-23023 January 1986 Petition of Gpu Nuclear Corp for Leave to Intervene in Leak Rate Data Falsification Inquiry.Certificate of Svc Encl. Served on 860127 ML20137A8371986-01-10010 January 1986 Petition of Licensee for Leave to Intervene & Request for Supplemental Hearing.Permission to Litigate Listed Contention Re Conduct & Attitude of C Husted Requested. Certificate of Svc Encl ML20137A7621986-01-0909 January 1986 Petition of Mi Lewis for Leave to Intervene & Request for Hearing.Served on 860113 ML20210A3571985-11-12012 November 1985 Response to Util 851021 Petition for Leave to Intervene.Nrc Does Not Oppose Petition,Subj to Util Satisfying Requirements of 10CFR2.714(b) ML20210A3751985-11-12012 November 1985 Responds to TMI Alert (Tmia) 851020 Petition for Leave to Intervene.Nrc Does Not Oppose Petition,Subj to Tmia Satisfying Requirements of 10CFR2.714(b).Notice of Appearance for GE Johnson & Certificate of Svc Encl ML20138P7881985-11-0404 November 1985 Petition of D Davenport to Join in Petition of Mi Lewis for New or Expanded Contention Re Hartman Leak Rate Allegations ML20138N6561985-11-0101 November 1985 Answer Supporting Gpu Petition for Leave to Intervene in Proceeding.Certificate of Svc Encl ML20138N5701985-11-0101 November 1985 Answer Supporting TMI Alert (Tmia) Request for Leave to Intervene in Hearing.Answer Does Not Foreclose Any Position to Be Taken in Future W/Tmia in Proceeding.Certificate of Svc Encl ML20138E3491985-10-21021 October 1985 Petition of DB Bauser for Leave to Intervene.Certificate of Svc Encl ML20138E3591985-10-20020 October 1985 Petition of L Bradford for Leave to Intervene & Request for Hearing Re C Husted Integrity & Suitability to Serve as Licensed Operator Instructor or Training Supervisor. Certificate of Svc Encl ML20133H1291985-10-0909 October 1985 Answer to Mi Lewis 850919 Petition for New or Expanded Contention Re Hartman Leak Rate Allegations.Petition Should Be Denied in Entirety ML20133E8771985-10-0404 October 1985 Response to Mi Lewis 850919 Petition for New Leak Rate Contention.Board Has No Jurisdiction to Consider Petitioner Contention ML20135H9541985-09-18018 September 1985 Petition of Mi Lewis for Leave to Intervene & Request for Hearing ML20090C4901984-07-0909 July 1984 Motion for Leave to Participate as Interested State Pursuant to 10CFR2.715(c).Notice of Appearance & Certificate of Svc Encl ML20086G5271984-01-0909 January 1984 Motion to Dismiss TMI Alert,Inc (Tmia) Contentions 1.a,1.b, 1.c & 2.b.1 Re post-repair & Plant Performance Testing & Use of Sulfur Compounds in Sys.Tmia Failed to Provide Bases for Contentions ML20082F5731983-11-23023 November 1983 Motion for Leave to Participate in Oral Presentations at Commission 831205 Meeting Re Mgt Competence & Integrity. Certificate of Svc Encl ML20078N8631983-10-31031 October 1983 Response Opposing Joint Petitioners 831017 Restatement of Contentions.Licensee Agrees to Substitution of Revised Proposed Contention 1 for Original Proposed Contentions 1, 2 & 3.Certificate of Svc Encl ML20081A5071983-10-22022 October 1983 Restatement of Proposed Contentions 1,2 & 3 Re Physical & Chemical Processes Employed to Return Tubes to Design Basis. Certificate of Svc Encl ML20078F8681983-10-0606 October 1983 Response Opposing TMI Alert 830921 Suppl to Petition to Intervene.Contentions Satisfy None of Specificity Requirements.Certificate of Svc Encl ML20078F9071983-10-0606 October 1983 Response to Proposed Contentions Re Steam Generator Repair. Joint Petitioners Fail to Identify Concerns Which Warrant Consideration.Certificate of Svc Encl ML20078A3541983-09-21021 September 1983 Suppl to 830808 Petition to Intervene,Listing Contentions. Certificate of Svc Encl ML20078B8011983-09-21021 September 1983 Contentions of J Lee,N Aamodt & B Molholt Re Steam Generator Degradation & Repair.Svc List Encl ML20085D8481983-07-26026 July 1983 Response to NRC Intervention Requirements for Adjudicatory Hearing on Steam Generator Repair Amend.Petitioner Has Standing Due to Close Proximity of Residence to Plant. Certificate of Svc Encl 1987-09-25
[Table view] 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] |
Text
._
fCf.[ l ?, Yl ?f 1
.. f , &
0,\
/
e
'0A? y.
i j
g[ FJ * $74 > (
UNITED STATES OF AMERJCA .,
Ld. c .,....,. 2/
. NUCLEAR REGULATORY COMMISSION \r., . . . ....
i -TR; f, 'N' N_ #'
SU l 6 y.,
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
)
(Three Mile Island Nuclear Station, )
Unit No.1) )
PETITON FOR INTERVENTION CF _THREE MILE ISLAND v.'.ERT, INCORPORATED Petitioner, Three Mile Island Alert, Incorporated (hereinafter referred to as TMIA), seeks intervention as a party in this proceeding, and respectfully represents that:
TMIA is a non-profit corporation, with cffices at 315 Peffer Street, Harris-burg, Pennsylvania,17102. The members of TMIA reside in Dauphin, Cumberland, and Iort counties, of the Commonwealth of Pennsylvania. Three M!Ie Island Nucicar Generating Station and its TMI Unit No.1, in particular, is located within twenty miles of the homes of every member of TMIA.
On March 28, 1979, an accident of unprecedented proportions occurred at the TMI nudear facility. As a result of that accident, large amounts of radiation were released into the local environment and the very real fear of a core melt down existed for at least four days. Many members d TMIA were forced to flee their 1
homes, and others experienced a period of mental anxiety and distress of an extra-1i ordinary magnitude, which continues to this day.
' 5 9,0 THIS DOCUMENT CONTAINS I
PO11190#O 4,- POOR QUAUTY PAGES -
lh
l Because of this experience, ntIA is concerned about the environmental, health, and economic consequences of reopening TMI Unit No.1. TMIA believea and asserts that the reopening of TMI Unit No. I will increase the detrimental health effects already suffered by its members and by the general population. It is further asserted that the economy of the area within twenty miles of the plant will be adversely affected by the reopening of TMI Unit No.1. Finally, it is asserted that the licensee, Metropolitan Edison Company (hereinafter Met-Ed), is incapable of safely operating TMI Unit No. I and that the past history of continual regulatory violations by Met-Ed should bar it from operating TMI Unit No.1.
Accordingly, Petitioner sets forth its contentions as follows:
- 1. TM1A contends that the reopening of Unit No. I will adversely affect the mental and physical health of its members and of the general population within twenty miles of the plant. It is contended that these people have been exposed to higher than normal levels of radiation because of the accident at TMI Unit No. 2 and that the low-level releases that will occur if Unit No.1 is reopened, when combined with the high-level releases already experienced, will cause increased rates of cancer, birth defects, spontaneous abortions, and other adverse health consequences to the general population living within twenty miles of the plant.
In addition, fear generated by the accident at TMI Unit No. 2, caused mental 111-ness, in varying degrees, to many people within the area of the plant. It is con- ;
tended, therefore, that the reopening of Unit No. I will increase the anxiety and 1
2-i
fear of persons living within the area of the plant and wiu cause long-term emotional damage. It is contended that the potential for additional adverse health effects if Unit No.1 is reopened is of such sufficient magnitude as to make the reopening of Unit No. I an unreasonable and unacceptable risk to the public health and safoty of the general population living within twenty miles of the plant.
- 2. TMIA contends that the additional low-level radiological discharges from Unit No.1, in addition to those high-level discharges that have and will be dis-charged as a result of the TMI No. 2 accident, will have a significant hdverse affect on watcr quality in the Susquehanna River. Therefore, it is contended that no consideration be given to reopening Unit No.1 until TMI Unit No. 2 is completely decontaminated and the diects of this decontamination on the water quality near the plant has been thoroughly analyzed.
- 3. Because of the accident at TMI No. 2. it is contended that new businesses have been unwilling to relocate in areas near the plant, and both businesses and governmental agencies have curtailed or canceled planned meetings and conven-tions in the area. It is contended that additional adverse economic consequence;.
will befall the Central Pennsylvania area if Unit No. I is reopened and that no j analysis has been done that adequately and honestly accounts for these effects.
It is contended that the economic consequences of reopening Unit No.1 outweigh l the benefits that will be obtained by its reopening.
- 4. It is centended that if Unit No.1 is reopened there will be considerable civil disruption in the aree surrounding the plant. I.ocal and State authorities are l
l
l .
I l
not presently equipped to deal with the types of civil disruptions that may very well occur. It is contended that the additional costs which will have to be incurred by the State and by the local municipalities involved in order to deal with the civil disruptions have not been evaluated at all. Furthermore, it is contended that this disruption, added to a crippled No. 2 reactor that will be contaminated with highly radicactive material for years to come, is an unreasonable and unacceptable cost not outweighed by the benefits of reopening Unit No.1
- 5. It la contended that Met-Ed has negligently, and on occasion, willfully viclated NRC regulations concerning the safe operatiert of both Units 1 and 2, in that it has deferred necessary maintenance ar.d repairs in order to minimize reactor downtime, to the detriment of the integrity of the nuclear facility itself. Conse-quen'ly, it is contended that Met-Ed is incapable of safely operating TML No. I and that its operating license should be revoked permanently.
- 6. It is contended that Met-Ed does not have the ability nor the resources to adequately train its personnel to safely operate the Unit No. I plant. The recent events at Unit No. 2 have severely strained the financial base of Met-Ed, causing widespread layoffs of personnel employed by the company. Since recent analyses indicate that the type of B & W designed reactor in operation at Unit No. I requires a larger number of trained operating personnel than that which is required for other nuclear generating facilities, these cutbacks, and future cutbeks that may occur, demonstrate the continuing inability of Met-Ed to safely operate Unit No.1, l
- 7. It is contended that the licensee will be unable to deal with a serious accident if one should occur at Unit No.1, while decontamination continues at 1 l
Unit No. 2. The Unit No. 2 containment building an'd' vessel today house in excess of half a million gallons of highly contaminated wastewater, and another 250,000 gallons in auxiliary storage buildings on the island. There is still no plan that has been accepted by the NRC which will result in the safe decontamination of Unit No. 2. Presently, there is no approved timetable for the safe decontamination cf Unit No. 2. It is contended that the wastewater storage capability of Unit No.1, if an accident were to occur, would be insufficient, since a large portion of this cap'. city may ultimately be committed to the safe decontamination of Unit No. 2.
Furtlurmore, even if no accident should occur at Unit No.1, there is a possibility of an accident occurring at Unit No. 2 during decontamination which would result in Qo diversion of all Unit No. l's storage capacity te Unit No. 2, thereby leaving Unit No. I unable to cope with any type of accident that would produce abnormal amounts of radioactive wastewater. If an accident cf the magnitude cf that which occurred at Unit No. 2 were to occur at Unit No.1, wastewater storage facilities at Unit No. 2 would have to be borrowed, just as Unit No.1 facilities have been borrowed to deal with the accident p Unit No. 2. Since there is presently insuffi-cient storage capacity on the island to deal with a Unit No. 2 accident at Unit No.1, it is an unreasonable and unacceptable risk to the public health and safety to reopen Unit No. I until Unit No. 2 has been safely decontaminated.
- 8. It is contended that tha decision to reopen Unit No.1, in light of what has occurrod at Unit No. 2, is a significant federal action that will affect the
.~
environment. Accordingly, it is contended that an environmental impact statement must be prepared prior to any decision by the NRC to reopen Unit No.1
- 9. It is contended that Met-Ed does not have the financial capability to:
(1) comply with technical changes that may be demanded as a result of the accident at Unit No. 2, and (2) comply with regulations of the NRC requiring the expenditure of additional sums cf money either for mandated design changes or changes in the financial protection requirements of 10 CFR Part 140.
- 10. It is contended that the customers of Met-Ed are presently receiving uniziterrupted and adequate electric power and that the reopening of Unit No.1is
- unnecessary for the future electricity needs of Met-Ed's customers,
- 11. It is contended that even if power is needed to meet the future needs of Met-Ed customers that Unit No. I be converted to a coal-fired plant. It is con-tended that the environmental, health and safety costs d reopening Unit No. I as a nuclear facility outweigh the cost of converting the facility to a coal-fired plant.
- 12. In the Commission Order of July 2,1979, the NRC stated that it
' presently lacks the requisite reasonable assurance that the . . 11censee's Three Mile Island Unit No.1 facility . . . can be operated without endangering the health and safety of the public." It is contended, therefore, that the burden 1
of proving that the reopening of Unit No. I will not endanger the health and j safety of the public rests with Met-Ed. It is further contended, therefore, that l
, 1
. l l
the presumption that Met-Ed cannot operate Unit No I without endangering the health and safety of the public can only be overcome by presenting clear and convincing evidence to the contrary.
Pursuant to the NRC's Order of August 9,1979, intervenors have been adviced that contentions dealing with psychological distress and other conten-tions unrolated to radiation exposure will require briefing "as part of the conten-tion procecs set out in the Commission's regulations." The contentions herein that are not related to radiation exposure are broadly related to psychological dbtrern and econcmic consequences. It is submitted that both these contentions
- are mandated considerations under the National Environmental Policy Act. NEPA Saction 102 does not contain an exhaustive list of these environmental concerns thr.t are to be considered. Rather, tho aim cf NEPA is to go t 2 yond purely
" environmental" considerations, such as air and water pollution, and to consider the quality of life, including the mental and economic health of the community.
S e Trinity Episcopal School Corp. v. Romney, 387 F.Supp.1044 (D.C. N.Y.
197 0 : Town of Groton v. Laird, 353 F.Supp. 344 (D.C. Conn.1972); 7_ackson
{,ounty Mo. v. Jones, 571 F.2d 1004 (C.A. Mo.1978) . McDowell v. Schlesinger, 404 F.Supp. 221 (D.C. Mo.1975) .
It is for these reasons, that the NRC and the Atomic Safety and Licensing Board clearly have Jurisdiction to consider the contentions raised herein.
Respectfully submitted, l
1% d . ,, S 'ts\ ' D heA Mailino Address: Kathy McC ' chin,' Authorized R,epresentative 23 South 21st Street for T ree Mile Island Alett, Inc.
Itrrisburg, PA 17104
]O J.~. ~.. ~j
> _ a
~ .
1
. j e *
'\
%*M s" UNITED STATES OF AMERICA g _
NUCLEAR REGULATORY COMMISSION S
? E? ::: w.: l'.1978 > $
, %v fi In the Matter d ) 4 ?
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
)
(Three E!ila Island Nuclear Statk3n, )
Unit No.1) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Petition For Intervention Of Three Mlle
!aland Alert, Incorporated," in the above,:aptioned matter, have been served on the fcilowing by deposit in the United States mail, first-class, this 12th day of Septsaber,1979:
Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. George F. Trowbridge, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, DC 20036
.i , .
4- ;
U_t w.a Vn_,-
L2.y :.':C:n;tiin. Autherisoci Representative !
for Th@ Mile Island Alert, Inc. l I
D ecj D
e Ju WJ 3
kI-$
t =
.