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| | issue date = 10/27/1980 | | | issue date = 10/27/1980 |
| | title = Statement of Matl Facts Re Absence of Genuine Issue to Be Heard,In Support of Summary Disposition of Contention 16 on Cooling Tower Discharge.Sys Designed to Evaporate Water Daily from Towers W/O Radioactive Releases | | | title = Statement of Matl Facts Re Absence of Genuine Issue to Be Heard,In Support of Summary Disposition of Contention 16 on Cooling Tower Discharge.Sys Designed to Evaporate Water Daily from Towers W/O Radioactive Releases |
| | author name = SILBERG J E, TRAVIESODIAZ | | | author name = Silberg J, Traviesodiaz |
| | author affiliation = ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE | | | author affiliation = ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| | addressee name = | | | addressee name = |
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| {{#Wiki_filter:0October27,19rddd+I~*~~'~UNITEDSTATESOFAFRICAd'INUCLZARREGULATORYCOMMISSIONBEFORETHEATOMICSAFETYANDLICENSINGBOARDdlZntheMatterofPENNSYLVANIAPOWERandALLZGHENYELECTRIC(SusquehannaSteamUnits1and2)))LIGHTCOMPA~i))COOPERATIVEZNC-))ElectricStation,))DocketNos.50-38750-388APPLICANTS'TATEMENTTOMATERIALFACTSASTOWHICHTHEREISNOGENUINEISSUETOBEHEARD(CONTENTION16)Pursuantto10C.F.R.52.749(a)Applicantsstate,insupport.oftheirMotionforSummaryDispositionofContention16(CoolingItTowerDischarge)inthisproceeding,thatthereisnogenuine',issuetobeheardwithrespecttothefollowingmaterialfacts:1.Wate'revaporatedfromtheSusquehannacoolingtowerscomesfromthethreesourcesofwatersuppliedtothetowers:makeupwater,thereturnflowfromtheCirculatingWaterSystem,andthereturn.flowfromtheServiceWaterSystem.AffidavitofWalterJ.RhoadesInSupportofSummaryDispositionofContention16(CoolingTowerDischarge)(hereinafter"RhoadesAffidavit"),para.3.2.Sincenone:ofthethreesourcesofwatesuppliedto'thecoolingtowersisradioactive,thewaterevaporatedfromthe't'owersisnotradioactive.RhoadesAffidavit,para.3.3.Makeupwatersuppliedtothe,coolingtowerstoreplacewaterlostbyevaporationcomesfromtheSusquehannaRiver,isnot801030o~I3d 0 | | {{#Wiki_filter:0 UNITED STATES OF AFRICA October 27, d |
| mixedwithanyotherplantwaterandthereforecannotbethesourceofradioactivecontamination.RhoadesAffidavit,paras.4-5.4.TwoindependentmethodskeepradioactivefluidsfromcomingintocontactwiththeCirculatingWaterandServiceWaterSystems.RhoadesAffidavit,para.6.5.Thefirst,independentmethodwhichkeepsradioactivefluidsfromcomingintocontactwiththeCirculatingWaterandServiceWaterSystemsisthepresenceofphysicalbarriers,(i.e.tubewallsinheatexchangers)betweenthewaterwhicheventuallyflowstothecoolingtowersandanyradioactivefluids.RhoadeshAffidavit,para.6.I6.ThesecondindependentmethodwhichkeepsradioactivefluidsfromcomingintocontactwiththeCirculatingWaterandIServiceWaterSystemsisthepressuredifferentialsbetweentheradioactivefluidsandthetwoSystems.RhoadesAffidavit,para.'.I47.BecausetheCirculatingWaterandServiceWaterSystemsoperateatahigherpressurethanthesystemswhichcontainradio-activefluids,'fthereisabreachinanyofthephysicalbarriers,theflowwillbefromtheCirculatingWaterandServiceWaterSystemsi'ntothesystemscontainingradioactivefluidsratherthanfromthesystemscontainingradioactivefluidsintotheCirculatingWaterandServiceWaterSyst'ems.RhoadesAffidavit,para.6.8.',TheonlyequipmentcooledbytheCirculatingWaterSystemisthemainturbinecondenser.RhoadesAffidavit,para.7.9.WithrespecttotheCirculatingWaterSystem,boththephysicalbarriers(i.e.stainlesssteelcondensertubes)andthe pressuredifferentialassurethattherewillbenoexchangebe-tweenthesteamwhichiscondensedinthemainturbinecondenserafterpassingthroughtheturbineandtheCirculatingWaterSystem.'ERhoadesAffidavit,para.7.10.TheServiceWaterSystemcoolsnineteengroupsofequip-mentofwhichonlyfourcontainpotentiallyradioactivefluids.IIRhoadesAffidavit,para.8.11.WithrespecttotheServiceWaterSystem,boththephysicalbarriers(i.e.tubewallsinheatexchangers)andthepressuredifferentialsassurethattherewillbenoexchangebe-tweenpotentiallyradioactivefluidsandtheServiceWaterSystem.'4RhoadesAffidavit,para.9.C12.BaseduponthesystemdesignoftheSusquehannafacility,~~thewaterwhichwillbeevaporatedfromtheSusquehannacoolingtowersonadailybasiswillnotcontainradioactivityfromthefacility.RhoadesAffidavit,paras.2,10.'IRespectfullysubmitted,SHANgPITT~l~POTTS&TROWBRIDGEByJyE.MaasCounseSilrgP.TraviesoDiazforApplicants1800,MStreet,N.W.Washington,D.C.20036(202)331-4100Dated:October27,1980
| | r 19 dd+I ~ |
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| | 'I NUCLZAR REGULATORY COMMISSION dl BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Zn the Matter of ) |
| | ) |
| | PENNSYLVANIA POWER LIGHT COMPA~i ) Docket Nos. 50-387 and ) 50-388 ALLZGHENY ELECTRIC COOPERATIVE ZNC- ) |
| | ) |
| | (Susquehanna Steam Electric Station, ) |
| | Units 1 and 2) ) |
| | APPLICANTS'TATEMENT TO MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (CONTENTION 16) |
| | Pursuant to 10 C.F.R. 52.749(a) Applicants state, in support. |
| | of their Motion for Summary Disposition of Contention 16 (Cooling It Tower Discharge) in this proceeding, that there is no genuine', |
| | issue to be heard with respect to the following material facts: |
| | : 1. Wate'r evaporated from the Susquehanna cooling towers comes from the three sources of water supplied to the towers: |
| | makeup water, the return flow from the Circulating Water System, and the return. flow from the Service Water System. Affidavit of Walter J. Rhoades In Support of Summary Disposition of Contention 16 (Cooling Tower Discharge) (hereinafter "Rhoades Affidavit"), |
| | para. 3. |
| | : 2. Since none:of the three sources of wate supplied to 'the cooling towers is radioactive, the water evaporated from the't'owers is not radioactive. Rhoades Affidavit, para. 3. |
| | : 3. Makeup water supplied to the, cooling towers to replace water lost by evaporation comes from the Susquehanna River, is not 8 01030o ~ I3 d |
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| }} | | 0 mixed with any other plant water and therefore cannot be the source of radioactive contamination. Rhoades Affidavit, paras. 4-5. |
| | : 4. Two independent methods keep radioactive fluids from coming into contact with the Circulating Water and Service Water Systems. Rhoades Affidavit, para. 6. |
| | : 5. The first, independent method which keeps radioactive fluids from coming into contact with the Circulating Water and Service Water Systems is the presence of physical barriers,(i.e. |
| | tube walls in heat exchangers) between the water which eventually flows to the cooling towers and any radioactive fluids. Rhoades h Affidavit, para. 6. |
| | I |
| | : 6. The second independent method which keeps radioactive fluids from coming into contact with the Circulating Water and I |
| | Service Water Systems is the pressure differentials between the radioactive fluids and the two Systems. Rhoades Affidavit, para.'. |
| | I 4 |
| | : 7. Because the Circulating Water and Service Water Systems operate at a higher pressure than the systems which contain radio-active fluids,'f there is a breach in any of the physical barriers, the flow will be from the Circulating Water and Service Water Systems i'nto the systems containing radioactive fluids rather than from the systems containing radioactive fluids into the Circulating Water and Service Water Syst'ems. Rhoades Affidavit, para. 6. |
| | 8.', The only equipment cooled by the Circulating Water System is the main turbine condenser. Rhoades Affidavit, para. 7. |
| | : 9. With respect to the Circulating Water System, both the physical barriers (i.e. stainless steel condenser tubes) and the |
| | |
| | pressure differential assure that there will be no exchange be-tween the steam which is condensed in the main turbine condenser after passing through the turbine and the Circulating Water System. |
| | 'E Rhoades Affidavit, para. 7. |
| | : 10. The Service Water System cools nineteen groups of equip-ment of which only four contain potentially radioactive fluids. II Rhoades Affidavit, para. 8. |
| | : 11. With respect to the Service Water System, both the physical barriers (i.e. tube walls in heat exchangers) and the pressure differentials assure that there will be no exchange be-tween potentially radioactive fluids and the Service Water System. |
| | '4 Rhoades Affidavit, para. 9. |
| | : 12. Based upon the system design of the Susquehanna facility, C |
| | the water which will be evaporated from the Susquehanna cooling |
| | ~ ~ |
| | towers on a daily basis will not contain radioactivity from the facility. 'I Rhoades Affidavit, paras. 2, 10. |
| | Respectfully submitted, SHAN g P ITT~l ~ POTTS & TROWBRIDGE By JyE. Sil rg Ma as P. Travieso Diaz Counse for Applicants 1800,M Street, N. W. |
| | Washington, D. C. 20036 (202) 331-4100 Dated: October 27, 1980}} |
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|---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20209H6691999-07-12012 July 1999
Comment Supporting Proposed Rule 10CFR50 Re Elimination of Requirement for Licensees to Update Inservice Insp & Inservice Testing Programs Beyond Baseline Adition & Addenda of ASME BPV Code
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Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Interim Rept 739459-97,dtd 971015 Be Withheld from Public Disclosure
ML20203G6031997-12-0404 December 1997
Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 Be Withheld from Public Disclosure
PLA-4330, Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control1995-06-0808 June 1995
Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control
PLA-4193, Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety1994-08-31031 August 1994
Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety
ML20046A9531993-07-20020 July 1993
Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rule
ML20045F7971993-06-21021 June 1993
Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule in Part & Opposes Rule in Part
ML20045D7461993-06-21021 June 1993
Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Disagrees W/Maintaining 100% Rate for Contractor & Vendor Employees
ML20044F8361993-05-24024 May 1993
Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rules
ML20044F7511993-05-24024 May 1993
Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93.
PLA-3744, Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners1992-03-0909 March 1992
Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners
PLA-3568, Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a1991-04-0808 April 1991
Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a
PLA-3462, Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants1990-10-15015 October 1990
Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants
ML19332G5261989-12-0606 December 1989
Comments on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Industry Has Made Substantial Progress Re Maint Performance as Indicated by Respective Performance Indicators,Commission Insps & Plant Conditions
PLA-3175, Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants1989-03-29029 March 1989
Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants
ML20235V4001989-03-0202 March 1989
Comment on Proposed Rule 10CFR50 Re Maint Program at Nuclear Plants.Proposed Maint Rule Has Potential to Significantly Undermine Util Initiatives & Direct Limited Resources Away from Real Improvements in Maint
PLA-3157, Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained1989-02-24024 February 1989
Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained
PLA-3118, Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule1988-11-17017 November 1988
Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule
ML20247N7531988-07-28028 July 1988
Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons
PLA-3019, Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking1988-04-15015 April 1988
Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking
PLA-2726, Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift1986-09-25025 September 1986
Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift
ML20138A9521985-10-0909 October 1985
Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl
ML20027D4441982-11-0202 November 1982
Response to Aslab 821026 Order Requesting Info on RCS Leak Rate Detection.Util Preparing Tech Spec to Limit Increase in Unidentified RCS Leakage to 2 Gpm within 4-h Period
ML20027D4471982-11-0101 November 1982
Affidavit of Wj Rhoades Correcting Response to Hearing Question on Leak Rates.Leak Rate Sys Capable of Detecting 1 Gpm Per Hour.Tech Specs Will Require Shutdown for Unidentified Leakage of 5 Gpm.Certificate of Svc Encl
ML20069D8321982-09-0909 September 1982
Original Signature Page to Sh Cantone Affidavit.Svc List Encl
ML20027B2291982-09-0909 September 1982
Stipulation of Withdrawal of Commonwealth of PA 820428 Exceptions Re Supply of TLD
ML20065A9541982-09-0909 September 1982
Affidavit of Sh Cantone Re Dosimetry for Emergency Workers at Plant.Prof Qualifications Encl
ML20027B2231982-09-0909 September 1982
Motion to Withdraw Commonwealth of PA 820428 Exceptions to Initial Decision,Contingent Upon Approval of Util & Commonwealth of PA 820909 Stipulation
ML20027B2351982-09-0808 September 1982
Affidavit of AL Belser & Rj Hippert Responding to Questions in Aslab 820820 Order & Supporting Stipulation Withdrawing Exceptions.When Stipulated Number of Dosimeters Available, Emergency Workers Will Be Protected.W/Certificate of Svc
ML20027B2331982-09-0808 September 1982
Affidavit of Ma Reilly Responding to Question in Aslab 820820 Order & Supporting 820909 Stipulation. TLD Necessary to Document Exposure of Officials Helping Contaminated Evacuees
ML20063A4041982-08-18018 August 1982
Petition for Reconsideration of Commission 820809 Order Rendering ASLB Initial Decision Effective.Exceptions to Decision Require Resolution.Commission Order Premature. Certificate of Svc Encl
ML20062J6391982-08-13013 August 1982
Order Directing Parties to Identify Person Presenting Arguments at 820908 Hearing in Bethesda,Md.Response Requested No Later than 820831
ML20058J6651982-08-0909 August 1982
Order Rendering ASLB 820412 Decision Authorizing OL Issuance Effective.Full Power OL Not Yet Authorized
ML20054L5081982-07-0606 July 1982
Brief Opposing Commonwealth of PA 820428 & Citizens Against Nuclear Dangers 820421 Exceptions to ASLB 820412 Initial Decision.Pa Fails to Prove Dosimetry Issue Timely Raised. Citizens Failed to Comply W/Procedure.W/Certificate of Svc
ML20054L2841982-07-0202 July 1982
Brief Opposing Commonwealth of PA 820428 Exceptions to ASLB 820412 Initial Decision Authorizing OL Issuance.Commonwealth Fails to Justify License Condition Imposition Re Availability of Dosimetry.Certificate of Svc Encl
ML20054J5611982-06-25025 June 1982
Brief Opposing Citizens Against Nuclear Danger 820421 Exceptions to ASLB 820412 Initial Decision.Exceptions Fail to Comply W/Commission Regulations & Raise Issues Not Presented Before Aslb.Certificate of Svc Encl
ML20053D0801982-05-28028 May 1982
Brief in Support of Exceptions to ASLB 820412 Initial Decision Authorizing Issuance of Ols.Shortage in Supply of Dosimeters for Emergency Workers Clear & Uncontroverted. Certificate of Svc Encl
ML20053D2191982-05-28028 May 1982
Brief Supporting Commonwealth of PA Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl
ML20052B7461982-04-28028 April 1982
Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl
ML20052A2751982-04-21021 April 1982
Exceptions to ASLB Initial Decision.Certificate of Svc Encl
ML20054C6551982-04-15015 April 1982
Response Opposing Citizens Against Nuclear Dangers 820402 Proposed Findings of Fact & Conclusions of Law.Requirements for Reopening Record Not Met.No Showing That Allegations Raise Significant Safety Issues.Certificate of Svc Encl
ML20050D4191982-04-0202 April 1982
Proposed Findings of Fact & Conclusions of Law Based on Important New Info & Recommendations to NRC Commissioners & Congress.Certificate of Svc Encl
ML20042C2781982-03-26026 March 1982
Motion for Order That Applicants Conduct Complete Retest of Emergency Plan W/All 20 Communities Participating.Testimony on Contentions 6 & 20 Should Be Reviewed to Identify Perjury by Fema,Applicants & State of Pa.Certificate of Svc Encl
ML20042C2701982-03-26026 March 1982
Proposed Findings of Fact & Conclusions of Law Re Emergency Evacuation Plan
ML20069B0301981-12-22022 December 1981
Reply to Parties' Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl
ML20039B0791981-12-16016 December 1981
Proposed Transcript Corrections.Certificate of Svc Encl
ML20062M2141981-12-0909 December 1981
Proposed Transcript Corrections
ML20039A1951981-12-0909 December 1981
Proposed Findings of Fact & Conclusions of Law
ML20038C0131981-12-0303 December 1981
Findings of Fact & Conclusions of Law.Certificate of Svc Encl
ML20038A8891981-11-17017 November 1981
Motion to Take Official Notice of Existence & Content of Listed Documents Relevant to Contention 21.Validity of Info in Documents Could Be Subj to Dispute.Certificate of Svc Encl.Related Correspondence
1999-07-12
[Table view]
Category:PLEADINGS
MONTHYEARML20027B2231982-09-0909 September 1982
Motion to Withdraw Commonwealth of PA 820428 Exceptions to Initial Decision,Contingent Upon Approval of Util & Commonwealth of PA 820909 Stipulation
ML20063A4041982-08-18018 August 1982
Petition for Reconsideration of Commission 820809 Order Rendering ASLB Initial Decision Effective.Exceptions to Decision Require Resolution.Commission Order Premature. Certificate of Svc Encl
ML20052B7461982-04-28028 April 1982
Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl
ML20042C2781982-03-26026 March 1982
Motion for Order That Applicants Conduct Complete Retest of Emergency Plan W/All 20 Communities Participating.Testimony on Contentions 6 & 20 Should Be Reviewed to Identify Perjury by Fema,Applicants & State of Pa.Certificate of Svc Encl
ML20038A8891981-11-17017 November 1981
Motion to Take Official Notice of Existence & Content of Listed Documents Relevant to Contention 21.Validity of Info in Documents Could Be Subj to Dispute.Certificate of Svc Encl.Related Correspondence
ML20011A2321981-10-0101 October 1981
Support for Contention 4 & Position on New Contentions. Motion for Summary Disposition of Contention 4 Should Be Denied Since Util Cancellation of Unit 2 May Be Best Solution.Certificate of Svc Encl
ML20011A2121981-09-30030 September 1981
Appeal of ASLB 810924 Memorandum & Order,Section 5,granting Applicant Motion for Summary Disposition of Portion of Contention 2 Re Magnitude of Doses from Releases of Radioactive Matl.No Basis to Decision.W/Certificate of Svc
ML20010J6231981-09-30030 September 1981
Response Supporting NRC 810911 Motion for Summary Disposition of Portion of Contention 1 Re Radiological Health Effects of Isotopes Other than Rn-222 & Tc-99.Health Effects Adequately Addressed in Fes
ML20010H7931981-09-22022 September 1981
Answer Opposing Citizens Against Nuclear Dangers 810912 Notice of Appearance for Purposes of Presenting Direct Testimony & Motions Before Aslb.Consolidation of Contentions Unnecessary.Certificate of Svc Encl.Related Correspondence
ML20140B1981981-09-10010 September 1981
Response Supporting Applicants 810828 Motion for Partial Summary Disposition of Contention 1 Re Fuel Cycle Doses.Also Moves for Summary Disposition of Portion of Contention 1 Re Radiological Health Effects of All Isotopes
ML20140B1931981-09-10010 September 1981
Answer Opposing Susquehanna Environ Advocates 810822 Motion for Allowance of New Contention.Motion Is Untimely & Balancing Factors Do Not Weigh in Intervenors Favor. Certificate of Svc Encl
ML20140B1651981-09-10010 September 1981
Motion for Summary Disposition of Contention 14 Re cost-benefit Balance.No Genuine Issue of Matl Fact Exists & NRC Entitled to Favorable Decision as Matter of Law
ML20010G2271981-09-0808 September 1981
Comments on Susquehanna Environ Advocates 810831 Filing on Expert Witnesses.Filing Inadequate & Fails to Meet ASLB 810814 Mandate.Reserves Right to Seek Relief If Intervenor Files Testimony.W/Certificate of Svc.Related Correspondence
ML20010G2981981-09-0808 September 1981
Response to ASLB 810814 Memorandum & Order,Filing Qualifications,Identities,Subj Matter & Substance of Testimony of Expert Witnesses for Contentions 2,6,9,11,14,20 & 21.Certificate of Svc Encl.Related Correspondence
ML20140B4381981-09-0202 September 1981
Answer to Citizens Against Nuclear Dangers 810827 Filing. Applicants Oppose Several Motions & Arguments.Allegations Re Chlorine Portion of Contention 2 Are Moot.No Valid Reason for Addl Prehearing Conference.Certificate of Svc Encl
ML20010F4541981-08-31031 August 1981
Motion for Summary Disposition of Contention 7C Re BWR Core Spray Nozzle Cracking.No Genuine Issue of Matl Fact Exists. Certificate of Svc Encl.Related Correspondence
ML20010F5411981-08-31031 August 1981
Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 7B.Certificate of Svc Encl
ML20010F4741981-08-31031 August 1981
Motion for Summary Disposition of Contention 7B Re Cracking of Stainless Steel Piping in BWR Coolant Water Environ Due to Stress Corrosion.No Genuine Issue of Matl Fact Exists
ML20010F4431981-08-31031 August 1981
Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 7C.Related Correspondence
ML20005B7991981-08-28028 August 1981
Motion for Partial Summary Disposition of Portion of Contention 1 Re Magnitude of Radioactive Doses That Will Be Imparted on Public by Release of All Isotopes During Fuel Cycle.Certificate of Svc Encl.Related Correspondence
ML20005B8241981-08-28028 August 1981
Statement of Matl Fact as to Which There Is No Genuine Issue,Supporting Applicants Motion for Summary Disposition of Contention 1 Re Fuel Cycle Doses.Related Correspondence
ML20010F4001981-08-27027 August 1981
Response in Opposition to ASLB 810814 Directives & Motions on Testimony & Public Hearings Conference.Date That Correspondence Is Required to Be Mailed Is Incorrect & Only Two Aspects of Contention 2 Are Listed for Consideration
ML20010C9811981-08-19019 August 1981
Statement of Issues for Commonwealth of PA Participation,Per ASLB 810727 Memorandum & Order.Particular Interest Shown in Contentions 5,7(D),11 & 21.Related Correspondence
ML20010C8631981-08-18018 August 1981
Renewed Motion for Summary Disposition of Contention 17.No Genuine Issue of Matl Fact to Be Heard.Applicants Are Entitled to Favorable Decision as Matter of Law
ML20010C8671981-08-18018 August 1981
Memorandum Supporting Applicants' 810818 Renewed Motion for Summary Disposition of Contention 17.Michaelson Affidavit Sufficiently Addresses Issues & Constitutes Adequate Basis for Granting Motion
ML20010C9491981-08-18018 August 1981
Statement of Matl Facts as to Which There Is No Geniune Issue to Be Heard Re Contention 17.Certificate of Svc Encl
ML20010C0771981-08-13013 August 1981
Motion for Partial Summary Disposition of Contention 2 Which Questions Magnitude of Facility Low Level Radioactive Releases.Certificate of Svc Encl
ML20010C1471981-08-13013 August 1981
Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 2 on Source Term
ML20010C9781981-08-10010 August 1981
Memorandum of Law in Response to Applicants' 810727 Ltr.All Parties in Proceeding Have Right to Present Rebuttal Evidence.Related Correspondence
ML20010B3971981-08-0707 August 1981
Memorandum in Support on 810807 Motion for Summary Disposition of Contention 1 Re Quantity of Rn-222 to Be Released During Fuel Cycle
ML20010B4091981-08-0707 August 1981
Statement of Matl Fact as to Which There Is No Genuine Issue Re Contention 1 Concerning Rn-222
ML20010B4041981-08-0707 August 1981
Motion for Summary Disposition of Contention 1 Re Rn-222. Issue Should Not Be Relitigated Under Accepted Principles of Collateral Estoppel & Stare Decisis.No Genuine Issue to Be Heard
ML20009H2281981-08-0404 August 1981
Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard in Support of Motion for Summary Disposition of Contention 7(a).Related Correspondence
ML20009H2301981-08-0404 August 1981
Motion for Summary Disposition of Contention 7(a).No Genuine Issue of Matl Fact Exists.Certificate of Svc Encl. Related Correspondence
ML20009G9951981-08-0303 August 1981
Memorandum Supporting Applicant Motion for Summary Disposition of Contention 3.Assertions Refuted in Jm Vallance Affidavit & Some Assumptions Are Contrary to Aslab Rulings
ML20009H0251981-07-30030 July 1981
Motion for Summary Disposition of Contention 3.No Genuine Issue of Matl Fact Exists & Applicants Are Entitled to Decision as Matter of Law.Certificate of Svc Encl
ML20009F8371981-07-28028 July 1981
Statement of Matl Fact as to Which There Is No Genuine Issue to Be Heard Re Contention 11 on Onsite Storage of Spent Fuel
ML20009F8431981-07-28028 July 1981
Motion for Partial Summary Disposition of Contention 11 Re Onsite Storage of Spent Fuel.No Genuine Issue of Matl Fact Exists.Motion Supported by C Herrington & DW James Affidavits.Certificate of Svc Encl
ML19345G8391981-04-0909 April 1981
Answer Opposing Citizens Against Nuclear Danger 810327 Motion Requesting Hearing on Applicants' 801223 SNM License Application.Motion Does Not Comply W/Commission Regulations. Certificate of Svc Encl
ML19290G6301980-11-24024 November 1980
Request to Deny Applicants' Motion for Summary Disposition of Contention 2 Re Chlorine Due to Studies Demonstrating Relationship Between Cancer Rates & Chlorinated Compounds in Drinking Water.W/Certificate of Svc
ML18030A4731980-11-0606 November 1980
Motion for Partial Summary Disposition of Contention 2 Re Health Effects of Discharged Chlorine.Responses Due within Three Wks from Present Filing
ML18030A4131980-11-0606 November 1980
Statement of Matl Facts Re Absence of Issue to Be Heard,In Support of Motion for Partial Summary Disposition of Contention 2 on Health Effects of Discharged Chlorine
ML18030A0181980-11-0606 November 1980
Pleading in Support of Motion for Partial Summary Disposition of Contention 2 Re Health Effects of Discharged Chlorine.Issue Narrowed by Intervenor/Sponsor Via Response to NRC Interrogatories.W/Certificate of Svc
ML18030A1621980-10-29029 October 1980
Response in Opposition to Environ Coalition on Nuclear Power Petition for Commission Review of ALAB-613.Intervenor Petition Sets Forth Nothing Which Warrants Different Conclusion.Certificate of Svc Encl
ML18030A1591980-10-27027 October 1980
Statement of Matl Facts Re Absence of Genuine Issue to Be Heard,In Support of Summary Disposition of Contention 16 on Cooling Tower Discharge.Sys Designed to Evaporate Water Daily from Towers W/O Radioactive Releases
ML18026A3101980-10-10010 October 1980
Response in Opposition to Applicant Request Re Interrogatories on Safety Issues.Environ Phase Must Take Priority Over safety-related Discovery Per ASLB 791030 Order.Certificate of Svc Encl
ML18030A1401980-08-22022 August 1980
Statement of Matl Facts as to Which No Genuine Issue Exists to Be Heard in Support of Request for Summary Disposition of Ozone Portion of Contention 17.Max Ground Level Ozone Concentrations Near Lines Will Be Far Below Allowable Limit
ML18030A1431980-08-22022 August 1980
Request for Free Hearing Transcripts Per 800725 Fr Notice Re Procedural Assistance Change in Adjudicatory Licensing Proceedings.Prior Denials Damaged Ability to Properly Litigate Contentions.Certificate of Svc Encl
ML18030A4411980-08-22022 August 1980
Request for Summary Disposition of Portion of Contention 17 Dealing W/Ozone.No Genuine Issue of Matl Fact Exists to Be Heard.Responses Due in Three Wks
ML18026A3001980-06-13013 June 1980
Response to Aslab 800521 Memorandum & Order ALAB-593, Requesting Environ Coalition on Nuclear Power to Inform Aslab of Extent of Relief Sought.Intervenor 800530 Request Must Be Dismissed as Moot.Certification of Svc Encl
1982-09-09
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0 UNITED STATES OF AFRICA October 27, d
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'I NUCLZAR REGULATORY COMMISSION dl BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Zn the Matter of )
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PENNSYLVANIA POWER LIGHT COMPA~i ) Docket Nos. 50-387 and ) 50-388 ALLZGHENY ELECTRIC COOPERATIVE ZNC- )
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(Susquehanna Steam Electric Station, )
Units 1 and 2) )
APPLICANTS'TATEMENT TO MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (CONTENTION 16)
Pursuant to 10 C.F.R. 52.749(a) Applicants state, in support.
of their Motion for Summary Disposition of Contention 16 (Cooling It Tower Discharge) in this proceeding, that there is no genuine',
issue to be heard with respect to the following material facts:
- 1. Wate'r evaporated from the Susquehanna cooling towers comes from the three sources of water supplied to the towers:
makeup water, the return flow from the Circulating Water System, and the return. flow from the Service Water System. Affidavit of Walter J. Rhoades In Support of Summary Disposition of Contention 16 (Cooling Tower Discharge) (hereinafter "Rhoades Affidavit"),
para. 3.
- 2. Since none:of the three sources of wate supplied to 'the cooling towers is radioactive, the water evaporated from the't'owers is not radioactive. Rhoades Affidavit, para. 3.
- 3. Makeup water supplied to the, cooling towers to replace water lost by evaporation comes from the Susquehanna River, is not 8 01030o ~ I3 d
0 mixed with any other plant water and therefore cannot be the source of radioactive contamination. Rhoades Affidavit, paras. 4-5.
- 4. Two independent methods keep radioactive fluids from coming into contact with the Circulating Water and Service Water Systems. Rhoades Affidavit, para. 6.
- 5. The first, independent method which keeps radioactive fluids from coming into contact with the Circulating Water and Service Water Systems is the presence of physical barriers,(i.e.
tube walls in heat exchangers) between the water which eventually flows to the cooling towers and any radioactive fluids. Rhoades h Affidavit, para. 6.
I
- 6. The second independent method which keeps radioactive fluids from coming into contact with the Circulating Water and I
Service Water Systems is the pressure differentials between the radioactive fluids and the two Systems. Rhoades Affidavit, para.'.
I 4
- 7. Because the Circulating Water and Service Water Systems operate at a higher pressure than the systems which contain radio-active fluids,'f there is a breach in any of the physical barriers, the flow will be from the Circulating Water and Service Water Systems i'nto the systems containing radioactive fluids rather than from the systems containing radioactive fluids into the Circulating Water and Service Water Syst'ems. Rhoades Affidavit, para. 6.
8.', The only equipment cooled by the Circulating Water System is the main turbine condenser. Rhoades Affidavit, para. 7.
- 9. With respect to the Circulating Water System, both the physical barriers (i.e. stainless steel condenser tubes) and the
pressure differential assure that there will be no exchange be-tween the steam which is condensed in the main turbine condenser after passing through the turbine and the Circulating Water System.
'E Rhoades Affidavit, para. 7.
- 10. The Service Water System cools nineteen groups of equip-ment of which only four contain potentially radioactive fluids. II Rhoades Affidavit, para. 8.
- 11. With respect to the Service Water System, both the physical barriers (i.e. tube walls in heat exchangers) and the pressure differentials assure that there will be no exchange be-tween potentially radioactive fluids and the Service Water System.
'4 Rhoades Affidavit, para. 9.
- 12. Based upon the system design of the Susquehanna facility, C
the water which will be evaporated from the Susquehanna cooling
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towers on a daily basis will not contain radioactivity from the facility. 'I Rhoades Affidavit, paras. 2, 10.
Respectfully submitted, SHAN g P ITT~l ~ POTTS & TROWBRIDGE By JyE. Sil rg Ma as P. Travieso Diaz Counse for Applicants 1800,M Street, N. W.
Washington, D. C. 20036 (202) 331-4100 Dated: October 27, 1980
