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| | number = ML18082A502 | | | number = ML18082A502 |
| | issue date = 04/18/1980 | | | issue date = 04/18/1980 |
| | title = Response in Opposition to NRC Testimony of Wf Pasedag Re Aslb Question 5.Spent Fuel Pool Old Fuel Would Be Involved in Enlargement Case & Would Consequently Increase Radiological Effects.Certificate of Svc Encl | | | title = Response in Opposition to NRC Testimony of Wf Pasedag Re ASLB Question 5.Spent Fuel Pool Old Fuel Would Be Involved in Enlargement Case & Would Consequently Increase Radiological Effects.Certificate of Svc Encl |
| | author name = Valore C | | | author name = Valore C |
| | author affiliation = LOWER ALLOWAYS CREEK, NJ, VALORE, C. | | | author affiliation = LOWER ALLOWAYS CREEK, NJ, VALORE, C. |
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| =Text= | | =Text= |
| {{#Wiki_filter:(' . e UNITED STATES OF AME.A NUCLEAR REGULATORY COMMISSION Before the In the Matter of PUBLIC SERVICE ELECTRIC & GAS COMPANY (Salem Nuclear Generating Station, Unit No. 1) DOCKETED USN RC . APR d 21980 II Board Office Seer-eta" / | | {{#Wiki_filter:e UNITED STATES OF NUCLEAR REGULATORY COMMISSION AME.A |
| &_Sei':'i:' | | (' . |
| No. 50-272 Propos7d. | | Before the Board DOCKETED USN RC In the Matter of |
| Issuance c:>f Amendment | | . APR d21980 II PUBLIC SERVICE ELECTRIC Office ~f t~e Seer-eta" / |
| *to Facility Operating License ..;* | | & GAS COMPANY Llockt:t~1g &_Sei':'i:' /-D~cket No. 50-272 i;r~/*.* Propos7d. Issuance c:>f Amendment (Salem Nuclear Generating ~if;._\\...-'. *to Facility Operating License Station, Unit No. 1) ..;* |
| * No. DPR-70 INTERVENOR TOWNSHIP OF LOWER ALLOWAYS CREEK'S OBJECTIONS DIRECT TESTIMONY OF WALTER F. PASEDAG FILED BY THE NRC STAFF The Intervenor, Township of Lower Alloways (TOLAC) considers paragraph 2 of page 5 of the response of the NRC Staff responsive to the Board's question. | | * No. DPR-70 INTERVENOR TOWNSHIP OF LOWER ALLOWAYS CREEK'S OBJECTIONS |
| The Intervenor TOLAC objects to the conclusion reached by the NRC Staff based on the testimony filed in response to the Board's 5th question. | | ~T-0 DIRECT TESTIMONY OF WALTER F. PASEDAG FILED BY THE NRC STAFF The Intervenor, Township of Lower Alloways C~eek (TOLAC) considers paragraph 2 of page 5 of the response of the NRC Staff responsive to the Board's question. The Intervenor TOLAC objects to the conclusion reached by the NRC Staff based on the testimony filed in response to the Board's 5th question. Specifically, the Intervenor, contends that old fuel would be involved in the case of enlargement and the _consequences of the accident would not be limited to fresh fuel. |
| Specifically, the Intervenor, contends that old fuel would be involved in the case of enlargement and the _consequences of the accident would not be limited to fresh fuel. The Intervenor, TOLAC, agrees with the NRC Staff that involvement of new fuel in a gross loss of water accident could involve large radiological consequences. | | The Intervenor, TOLAC, agrees with the NRC Staff that involvement of new fuel in a gross loss of water accident could involve large radiological consequences. The Intervenor, TOLAC, objects to the response in that an analysis of these consequences was not set forth in the response. Tpe Intervenor, TOLAC, preceives this was not done because the consequences would occur with either the present or the expanded pool, however, the Intervenor contends |
| The Intervenor, TOLAC, objects to the response in that an analysis of these consequences was not set forth in the response. | | |
| Tpe Intervenor, TOLAC, preceives this was not done because the consequences would occur with either the present or the expanded pool, however, the Intervenor contends t .. *** " 1 the old fuel in the spent fuel pool would be involved and increase the radiological consequences. | | t . *** " |
| Respectfully submitted, ,, .-C6L *. -V LORE, uSpecial Counse for the Township of Lower Alloways Creek * | | 1 the old fuel in the spent fuel pool would be involved and increase the radiological consequences. |
| .. -UNITED STATES OF AMERICA NUCLEAR REGULATORY Ca1MISSION Before the Atomic Safety and Licensing Board ., In the Matter of ) Docket No. 50-272 l'UI3LIC SERVICE ELECTRIC & GAS COMP ANY (Salem Nuclear Generating Station, Unit No. 1) Proposed Issuance of Amendment to Facility Operating License No. DPR-70 ) CERTIFICATE OF HAILING I hereby certify that copies of Intervenor's Township of Lower Alloway Creek Objection to s and Staff's testimony and Motion to Strike Licensee's testimony were mailed on April 18, 1980 by Federal Express from Northfield, N.J. to the attached mai lipg list. ---. c_ ____
| | Respectfully submitted, |
| __ _ CARL J:::VALORE
| | ,-----~--~n~ |
| /,, .... * / --,__.,-* April 18, 1980 | | ~ |
| ***'I. Gary L. Milhollin, Esq. Chainnan, Atanic Safety & Licensing Board 1815 Jefferson* | | C 6 L *. -V LORE, uSpecial Nuc~ear Counse for the Township of Lower Alloways Creek |
| Street M:idison, Wisconsin 53711 Glen O. Bright Member, Atanic Safety & Licensing Board U. S. Nuclear Regulatory C'.amlission Washington, D. C. 20555 Dr. Janes C. Lamb, III Member, Atanic Safety & Licensing Board Panel 313 Wocrlhaven Road Chapel Hill, N. C. 27514 Chairrran, Atanic Safety arrl Licensing Appeal Board-Panel U. S. Nuclear Regulatory Carmission Washington, D. C. 20555 Chairrran, Atanic Safety & Licensing Board Panel U. S. Nuclear Regulatory Comnission Washington, D. C. 20555 Jan:; ce E. _Hoo!e, Esq. Office of the Executive Legal Director U. S. Nuclear Regulatory C.orrrnission Washington, D. C. 20555 Mark L. First, Esquire. Deputy Attorney General Department of Law & Public Safety Environmental Protection Section 36 West State Street Trenton, N. J. 08625 Mark J. Wetterhahn, Esquire for Troy B. Conner, Jr., Esq. 1747 Pennsylvania Avenue, N. W. Suite 1050 Washington, D. C. 20006 Richard Fryling, Jr., Esquire Assistant General Solicitor Public.Service Electric & Gas C.anpany 80 Park Place Newark, N. J. 07101 Keith Ansdorff, Esquire Assistant Deputy Public Advocate Department of the Public Advocate Divisicin of Public Interest Advocacy | | * UNITED STATES OF AMERICA NUCLEAR REGULATORY Ca1MISSION Before the Atomic Safety and Licensing Board In the Matter of l'UI3LIC SERVICE ELECTRIC ) Docket No. 50-272 |
| * P. O. Box 141 Trenton, New Jersey 08601 Sandra T. Ayres , Esquire Department of the Public Advocate 520 E:ast State Street Trenton, N. J. 08625 Mr. Alfred C. Coleman, Jr. Mrs. Eleanor G. Coleman 35 "K" Drive i Pennsville, N. J. 08070 Office of the Secretary Docketing and Service Section U. S. Nuclear Regulatory Comnission
| | & GAS COMP ANY Proposed Issuance of Amendment to Facility Operating License (Salem Nuclear Generating No. DPR-70 Station, Unit No. 1) ) |
| ' Washington, D. C. 20555 June D. MacArtor, Esquire Deputy Attorney General Tatnall Building, P. O. Box 1401 Dover,* Delaware 19901 Mr. Frederick J. Shon Atanic Safety arrl Licensing*Boa.rd U. S. Nuclear Regulatory
| | CERTIFICATE OF HAILING I hereby certify that copies of Intervenor's Township of Lower Alloway Creek Objection to Licens~ee' s and Staff's testimony and Motion to Strike Licensee's testimony were mailed on April 18, 1980 by Federal Express from Northfield, N.J. |
| <:annission. | | to the attached mai lipg list. --- |
| Washington, D. C. 20555 Mary O. Herrlerson, Clerk Township of Lower Alloways Creek Municipal Building Hancock's Bridge, N. J. 08038}} | | . c_ ____-"-:'~ -~? ?- : !'-: - - -Z':~ /:b~:~:=---....0-"<..._~-*6;_;!( |
| | CARL J:::VALORE/,, .... * |
| | / -- |
| | April 18, 1980 |
| | |
| | ***'I. |
| | Gary L. Milhollin, Esq. Richard Fryling, Jr., Esquire Chainnan, Atanic Safety Assistant General Solicitor |
| | & Licensing Board Public.Service Electric & |
| | 1815 Jefferson* Street Gas C.anpany M:idison, Wisconsin 53711 80 Park Place Newark, N. J. 07101 Glen O. Bright Member, Atanic Safety Keith Ansdorff, Esquire |
| | & Licensing Board Assistant Deputy Public Advocate U. S. Nuclear Regulatory C'.amlission Department of the Public Advocate Washington, D. C. 20555 Divisicin of Public Interest Advocacy |
| | * P. O. Box 141 Dr. Janes C. Lamb, III Trenton, New Jersey 08601 Member, Atanic Safety & |
| | Licensing Board Panel Sandra T. Ayres , Esquire 313 Wocrlhaven Road Department of the Public Advocate Chapel Hill, N. C. 27514 520 E:ast State Street Trenton, N. J. 08625 Chairrran, Atanic Safety arrl Licensing Appeal Board-Panel Mr. Alfred C. Coleman, Jr. |
| | U. S. Nuclear Regulatory Carmission Mrs. Eleanor G. Coleman Washington, D. C. 20555 35 "K" Drive i Pennsville, N. J. 08070 Chairrran, Atanic Safety & |
| | Licensing Board Panel Office of the Secretary U. S. Nuclear Regulatory Comnission Docketing and Service Section Washington, D. C. 20555 U. S. Nuclear Regulatory Comnission |
| | ' Washington, D. C. 20555 Jan:; ce E. _Hoo!e, Esq. |
| | Office of the Executive Legal Director June D. MacArtor, Esquire U. S. Nuclear Regulatory C.orrrnission Deputy Attorney General Washington, D. C. 20555 Tatnall Building, P. O. Box 1401 Dover,* Delaware 19901 Mark L. First, Esquire. |
| | Deputy Attorney General Mr. Frederick J. Shon Department of Law & Public Safety Atanic Safety arrl Licensing*Boa.rd Environmental Protection Section U. S. Nuclear Regulatory <:annission. |
| | 36 West State Street Washington, D. C. 20555 Trenton, N. J. 08625 Mary O. Herrlerson, Clerk Mark J. Wetterhahn, Esquire Township of Lower Alloways Creek for Troy B. Conner, Jr., Esq. Municipal Building 1747 Pennsylvania Avenue, N. W. Hancock's Bridge, N. J. 08038 Suite 1050 Washington, D. C. 20006}} |
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1998-09-15
[Table view]
Category:PLEADINGS
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Petition to Amend 790802 Motion for Issuance of Show Cause Order & Stay of Licensing Procedure.Adds Addendum 7A & Contentions 8-10.Certificate of Svc Encl
ML19209C3871979-08-31031 August 1979
Motion,Submitted by Intervenors Coleman,That NRC Amend Request for Order to Show Cause & Stay Licensing.Seek Addl Contentions Re Cost/Benefit Analysis,Seismic Analysis & Class 9 Accidents
ML18081A4141979-08-31031 August 1979
Seeks Denial of Intervenors Coleman 790802 Motion for Reconsideration of Contention 13 Re Release of Radioactive Matl.No Justification for Late Filing.Criteria for Compliance W/Operation Objectives Defined in 10CFR50,App I
ML18079B1161979-08-29029 August 1979
Request by Intervenors Coleman That ASLB Accept Addl Argument on ASLB Question 4 Re Consideration of Class 9 Accidents.Nrc Admits That TMI Accident Was Class 9. Certificate of Svc Encl
ML18079B1151979-08-27027 August 1979
Response to ASLB Question 4 Re Class 9 Accidents.Tmi 790328 Accident Was Class 9,constituting Successive Failures of Operator Procedures & Equipment.Testimony in Present Proceedings Requires Wide Latitude.Certificate of Svc Encl
ML18079B0881979-08-21021 August 1979
Response to ASLB Question 4,submitted on Behalf of Intervenors Coleman.Alleges TMI Accident Was Class 9 Accident.Accident Posed Significant Risk to Health & Safety of Population & Environ.Certificate of Svc Encl
ML18079B0611979-08-20020 August 1979
Responds to Question 4 of ASLB 790710 Order.Forwards C Kepford Rept on TMI Accident.Prof Qualifications & Certificate of Svc Encl
ML18081A4111979-08-10010 August 1979
Requests That ASLB Order Extension Until 790831 for Response to Intervenors Coleman Request to Reopen Consideration of Contentions 2 & 6
ML18079B0461979-08-0303 August 1979
Forwards Re Webb 790723 Rept, TMI Accident:Was It Class 9 Accident, in Response to ASLB 790710 Question 4
ML19208C3681979-08-0202 August 1979
Requests Issuance of Order to Show Cause & Stay of Licensing Per 10CFR2.202 & 2.206.NRC Has Failed to Act on Info Re PA-NJ-MD Grid,Cost/Benefit Analysis,Expansion of Spent Fuel Pool & Lessons Learned Re TMI
ML18079B0851979-08-0202 August 1979
Request by Intervenors Coleman That ASLB Reconsider Dismissal of Contention 13.Intervenor State of Nj Supports Motion.Util Is Obliged Per 10CFR50 to Explore Alternatives to Spent Fuel Pool Expansion
ML19225D1441979-08-0202 August 1979
Request That NRC Issue Order to Show Cause & Request to Stay Licensing.Requests Intervenor Status.Submits List of Contentions & Partial List of Resouce Documents.Certificate of Svc Encl
ML18079B0871979-08-0101 August 1979
Request by Intervenors Coleman That ASLB Reopen Record Re Contentions 2 & 6.Intervenor State of Nj Supports Motion. Experiences at Northern State Power Co Are Pertinent to Proceedings
ML18079A7621979-07-0909 July 1979
Response Submitted by Intervernor Township of Lower Alloways Creek to NRC Motion to Strike Portions of Re Webb & EA Gulbransen Testimony Re ASLB 790418 Order. Affidavit of EA Gulbransen & Certificate of Svc Encl
ML18079A8311979-07-0606 July 1979
Request Submitted by Util for Denial of Intervenors Coleman 790625 Request for Reconsideration of Dismissal of Coleman Contention 7.NRC Must Remand Matter to Aslb. Certificate of Svc Encl
ML18079A8291979-07-0606 July 1979
Request Submitted by Util for Denial of Intervenors Coleman 790626 Request That ASLB Compel Licensee to Suppl Responses to Interrogatories 1,3 & 6.Questions Have No Relation to Grid Strap Problem
1984-01-25
[Table view] |
Text
e UNITED STATES OF NUCLEAR REGULATORY COMMISSION AME.A
(' .
Before the Board DOCKETED USN RC In the Matter of
. APR d21980 II PUBLIC SERVICE ELECTRIC Office ~f t~e Seer-eta" /
& GAS COMPANY Llockt:t~1g &_Sei':'i:' /-D~cket No. 50-272 i;r~/*.* Propos7d. Issuance c:>f Amendment (Salem Nuclear Generating ~if;._\\...-'. *to Facility Operating License Station, Unit No. 1) ..;*
- No. DPR-70 INTERVENOR TOWNSHIP OF LOWER ALLOWAYS CREEK'S OBJECTIONS
~T-0 DIRECT TESTIMONY OF WALTER F. PASEDAG FILED BY THE NRC STAFF The Intervenor, Township of Lower Alloways C~eek (TOLAC) considers paragraph 2 of page 5 of the response of the NRC Staff responsive to the Board's question. The Intervenor TOLAC objects to the conclusion reached by the NRC Staff based on the testimony filed in response to the Board's 5th question. Specifically, the Intervenor, contends that old fuel would be involved in the case of enlargement and the _consequences of the accident would not be limited to fresh fuel.
The Intervenor, TOLAC, agrees with the NRC Staff that involvement of new fuel in a gross loss of water accident could involve large radiological consequences. The Intervenor, TOLAC, objects to the response in that an analysis of these consequences was not set forth in the response. Tpe Intervenor, TOLAC, preceives this was not done because the consequences would occur with either the present or the expanded pool, however, the Intervenor contends
t . *** "
1 the old fuel in the spent fuel pool would be involved and increase the radiological consequences.
Respectfully submitted,
,-----~--~n~
~
C 6 L *. -V LORE, uSpecial Nuc~ear Counse for the Township of Lower Alloways Creek
- UNITED STATES OF AMERICA NUCLEAR REGULATORY Ca1MISSION Before the Atomic Safety and Licensing Board In the Matter of l'UI3LIC SERVICE ELECTRIC ) Docket No. 50-272
& GAS COMP ANY Proposed Issuance of Amendment to Facility Operating License (Salem Nuclear Generating No. DPR-70 Station, Unit No. 1) )
CERTIFICATE OF HAILING I hereby certify that copies of Intervenor's Township of Lower Alloway Creek Objection to Licens~ee' s and Staff's testimony and Motion to Strike Licensee's testimony were mailed on April 18, 1980 by Federal Express from Northfield, N.J.
to the attached mai lipg list. ---
. c_ ____-"-:'~ -~? ?- : !'-: - - -Z':~ /:b~:~:=---....0-"<..._~-*6;_;!(
CARL J:::VALORE/,, .... *
/ --
April 18, 1980
Gary L. Milhollin, Esq. Richard Fryling, Jr., Esquire Chainnan, Atanic Safety Assistant General Solicitor
& Licensing Board Public.Service Electric &
1815 Jefferson* Street Gas C.anpany M:idison, Wisconsin 53711 80 Park Place Newark, N. J. 07101 Glen O. Bright Member, Atanic Safety Keith Ansdorff, Esquire
& Licensing Board Assistant Deputy Public Advocate U. S. Nuclear Regulatory C'.amlission Department of the Public Advocate Washington, D. C. 20555 Divisicin of Public Interest Advocacy
- P. O. Box 141 Dr. Janes C. Lamb, III Trenton, New Jersey 08601 Member, Atanic Safety &
Licensing Board Panel Sandra T. Ayres , Esquire 313 Wocrlhaven Road Department of the Public Advocate Chapel Hill, N. C. 27514 520 E:ast State Street Trenton, N. J. 08625 Chairrran, Atanic Safety arrl Licensing Appeal Board-Panel Mr. Alfred C. Coleman, Jr.
U. S. Nuclear Regulatory Carmission Mrs. Eleanor G. Coleman Washington, D. C. 20555 35 "K" Drive i Pennsville, N. J. 08070 Chairrran, Atanic Safety &
Licensing Board Panel Office of the Secretary U. S. Nuclear Regulatory Comnission Docketing and Service Section Washington, D. C. 20555 U. S. Nuclear Regulatory Comnission
' Washington, D. C. 20555 Jan:; ce E. _Hoo!e, Esq.
Office of the Executive Legal Director June D. MacArtor, Esquire U. S. Nuclear Regulatory C.orrrnission Deputy Attorney General Washington, D. C. 20555 Tatnall Building, P. O. Box 1401 Dover,* Delaware 19901 Mark L. First, Esquire.
Deputy Attorney General Mr. Frederick J. Shon Department of Law & Public Safety Atanic Safety arrl Licensing*Boa.rd Environmental Protection Section U. S. Nuclear Regulatory <:annission.
36 West State Street Washington, D. C. 20555 Trenton, N. J. 08625 Mary O. Herrlerson, Clerk Mark J. Wetterhahn, Esquire Township of Lower Alloways Creek for Troy B. Conner, Jr., Esq. Municipal Building 1747 Pennsylvania Avenue, N. W. Hancock's Bridge, N. J. 08038 Suite 1050 Washington, D. C. 20006
