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| : 3. All correspondence and requests for information, data, and docmnentation pertaining to radiation monitoring submitted by NP.C to the Applicant, Commonwealth, and any other agencies of government or private organizations in consequence of and/or subsequent to the March 28, 1979, accident atiThree Mile Island, Unit 2. | | : 3. All correspondence and requests for information, data, and docmnentation pertaining to radiation monitoring submitted by NP.C to the Applicant, Commonwealth, and any other agencies of government or private organizations in consequence of and/or subsequent to the March 28, 1979, accident atiThree Mile Island, Unit 2. |
| : 4. All federal radiation monitoring data from Three Mile Island, Unit 2, in possession of the NRC, subsequent to March 28, 1979, in order to establish whether the NRC, or other involved federal agency, has monitored'to a distance and extent to be able to establish radiation doses to the public with a reasonable degree of accuracy and tineliness, in the event of a serious radiological emergency at Susquehanna. | | : 4. All federal radiation monitoring data from Three Mile Island, Unit 2, in possession of the NRC, subsequent to March 28, 1979, in order to establish whether the NRC, or other involved federal agency, has monitored'to a distance and extent to be able to establish radiation doses to the public with a reasonable degree of accuracy and tineliness, in the event of a serious radiological emergency at Susquehanna. |
| : 3. For Contention 7, referring to unresolved safety problems, supply copies of | | : 3. For Contention 7, referring to unresolved safety problems, supply copies of the following: |
| "; ,
| |
| the following: | |
| PTR-815 BNL-17608 PTR-738 WASH-1246 SAND 77-1371 NUREG/CR-0649 NUREG-140 Any reports on ATWS published subsequent to WASH-1270. | | PTR-815 BNL-17608 PTR-738 WASH-1246 SAND 77-1371 NUREG/CR-0649 NUREG-140 Any reports on ATWS published subsequent to WASH-1270. |
| " Meteorology and Atomic Energy-1978", USAEC, TID-24190. | | " Meteorology and Atomic Energy-1978", USAEC, TID-24190. |
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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 ML20203G6131998-01-26026 January 1998 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 ML20053D2191982-05-28028 May 1982 Brief Supporting Commonwealth of PA Exceptions to ASLB 820412 Initial Decision.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 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 ML20042C2701982-03-26026 March 1982 Proposed Findings of Fact & Conclusions of Law Re Emergency Evacuation Plan 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 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
[Table view] |
Text
.NRC FUBLIC DOCIDW 10@M com_spoxugygg ,,
& s UNITED STATES OF AMERICA Of c:cmo 4
. NUCLEAR REGULATORY CCM.'iISSION ,
B_EFORE THE ATOMIC SAFETY AND LICENSING BOARD 6 JW 8 M > 2 m .n s. w i In the Matter of ) g "N Y
) 6%
PENNSYLVANIA POWER & LIGHT COMPANY ) N
- and ) Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC. ) 50-388 (Susquehanna Steam Electric Station,. )
Units 1 & 2) )
ENVIRONMENTAL COALITION ON NUCLEAR POWER (ECNP) FIRST ROUND DISCOVERY REQUESTS TO NRC STAFF, APPLICANT, AND COMMONWEALTH Pursuant to 10 C.F.R. 2.744 and the Licensing Board's Special Prehearing Conference Order of March 7,1979, the Environmental Coalition on Nuclear Power (ECNP), intervenors in the captioned proceeding, hereby serve upon the Executive Director for Operations, the following list of documents for production to these intervenors:
- 1. For ECNP Contention 1, 2, 3, 5, which refer to the cost-benefit analysis and to the various aspects of the health effects of the nuclear fuel cycle, the following documents:
ORNL-4903, Vol .1&2 NUREG/CR-0311 o -5315 NUREG/CR-0597 ei -TM-4154 NUREG/CR-Oll4
" -TM-5251 NUREG/CR-0649 NUREG-0456 ORNL/NUREG/TM-102 CONF- 720805-GJ0-100(78) and-100(79) CONF-730907 GJ0-ll(1973) MIT-952-5 a -1540
" -1559-1 GJT-2, -4, -6, -12, -18, -21 NUREG-OlC9 FECU-218-1
-0119 FBDU-224-10
-0322 NUREG/CR-0573 USGS Professional Paper 820 NUREG/CR-0574 o Open File Report 78-1050 29[ b[O _
7 9070 6 0yff
ERDA-93 ENWL-2190 NIOSH-75-ll7 UCRL-50163 (1968)
" Reserves and Resources of Uranium", Supplement to Mineral Resources and the Environment Nat. Acad. Sci .,1975
" President's Repcrt on Occupational Safety and Health",1972 Bureau of Mines Publ.'RI 8254 Draft Recort of Task Force on Uranium Mill Tailings, Argonne National Labs.,1976 "Monticello Mill Tailings Erosion Control Project: Monticello, Utah," Report and Supplemental Report, USAEC,1966 USPHS Tech. Report W62-19 (1962)
Jan.,1979, Draf t Report of NCRP Sci . Conn. 40 Copy of the NRC Translation of a report by Dieter Teutel of the University of Heidelberg And also supply:
- 1. All assumptions, references, and calculations used in arriving at the radon-daughter air-concentration to . dose to the bronchial epithelium of 0.625 mrem /pci m3 in NUREG-0511, Vol. II, p. G-44. Cite all references.
- 2. All calculations, assumptions, with references cited, used in cost-benefit analysis for Susq.1&2, with emphasis on compliance with 10 CFR 51.20(c) .
- 3. All references in which particular values used in a cost-benefit are singled out for comparison with some parameter not used in the analysis, so as to create the illusion that the singled out parameter is insignificant and need not be included in the cost-benefit analysis. The comparison; here refers to"the comparison of radon-222 emissions to natural releases of radon-222 so as to obscure the health effects caused by the operation of Susquehanna 1&2.
This should also include the references to justifications for, in detail, tampering with one side of the analysis balance and not the other.
- 4. Transcripts of each and every meeting of the NRC Commissioners, with all attachments and discussicn papers, in which the quantity of radon-222 in Table S-3 is discussed, and all Staff position papers and recommendations pertaining to radon-222.
2Ih f !b
- 2. For ECNP Contention 6 on Evacuation, supply the following information:
- 1. All presently (as of May 25, 1979) applicable and proposed revisions of NRC detailed requirements for emergency response and evacuation plans to be met by Applicant, agencies of the Commonwealth, local govern-mental agencies, and federal agencies, including full specification of the legal responsibilities of all institutions (agencies) and personnel for
- a. reporting of accidents ~ ,
- b. recommendations for' evacuation,
- c. decisions to implement energency and/or evacuation plans, and
- d. the actual conduct of these plans.
- 2. All correspondence and requests for information, documentation and data pertaining to emergency prepar_edness and evacuation planning submitted by NRC to the Applicant, Commonweal th, and any other agencies of government or private organizations in consequence of and/or subsequent to the March' 28,1979, accident at Three Mile Island, Unit 2,
- 3. All correspondence and requests for information, data, and docmnentation pertaining to radiation monitoring submitted by NP.C to the Applicant, Commonwealth, and any other agencies of government or private organizations in consequence of and/or subsequent to the March 28, 1979, accident atiThree Mile Island, Unit 2.
- 4. All federal radiation monitoring data from Three Mile Island, Unit 2, in possession of the NRC, subsequent to March 28, 1979, in order to establish whether the NRC, or other involved federal agency, has monitored'to a distance and extent to be able to establish radiation doses to the public with a reasonable degree of accuracy and tineliness, in the event of a serious radiological emergency at Susquehanna.
- 3. For Contention 7, referring to unresolved safety problems, supply copies of the following:
PTR-815 BNL-17608 PTR-738 WASH-1246 SAND 77-1371 NUREG/CR-0649 NUREG-140 Any reports on ATWS published subsequent to WASH-1270.
" Meteorology and Atomic Energy-1978", USAEC, TID-24190.
OGl
.is 0b
-4~-
The rest recant report to Congress describing unresolved generic safety problems.
Those portions of the transcripts of the hear-ings in the Black Fox proceeding in which unresolved safety problems were discussed.
In addition, supply a description of each design basis accident, indicating in the resulting analysis, which engineered safeguards upon which reliance for safety is placed, have been tested under realistic accident conditions (temper-ature, pressure, full-scale test) and which are calculated to be effect through analytical technique.
- 4. For Contention 9, concerning decommissioning of nuclear power plants, supply copies of:
(a) the report of the Atomic Industrial Foru:a on deccomissioning; and (b) any NRC reports on reactor deconnissioning.
To Acolicant The following infomation and documents, data, and reports are requested from the Applicant:
- 1. For Intervenors' Contentions 1-18, supply all reports, calculations, revised information, and other responses to any requests from NRC, the Co:r.onwealth of Pennsylvania, or any other agency of government arising out of, anc/or subsequent to the March 28, 1979, accident at Three Mile Island, Unit 2.
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- 2. Fcr ECNP Cor.tention 4, Need for Power, all data and calculations of Applicant's estimated electricity demand, use, and supply projections for the operating life of the reactor. Supply all bases for assumptions of all growth rates and all forecast parameters, as well as all assumptions in Appendix B1 and Appendiy B2, Environmental Report, and ali updated infonnation subsequent to those reports.
- 3. For ECNP Contention 6, on Evacuation, supply:
- a. Applicant's complete emergency preparedness and evacuation plans (which were not provided with the FSAR) and all subsequent rnodification of these documents by the Applicant, including any resulting from the TMI-2 accident of March 28, 1979.
- b. Any calculatiens and the detailed bases of all assumptions used to prepare Applicant's emergency response and evacuation plans, including not readily available studies, and citations to readily availat>1e references, used in the develop.nent of
, those portions of the plans pertaining to:
- 1. traffic studies in Luzerne and adjoining counties and elsewhere;
- 2. evacuee destination planning;
- 3. emergency fuel supply plans; and
- 4. plans for special handling of the infinn and institutionalized persons- which together ensure conformity with Protective Action Guides and any other applicable governmental regulations.
- c. Emergency preparedness and evacuation plans for Class 9 accidents, or any accident more serious than the Applicant's Design Basis accident.
- d. All data and information on radiation monitoring in the vicinity.of the plant requested or required by NRC, Commonwealth, cr any other.
agency of govermlent in consequence of and/or subsequent to the March 28,1979, accident at Three Mile Island, Unit 2.
- 4. For ECN? Contention 7, supply following documents listed in the FSAR, Chap.1.6:
AFID a9S6 NED0-10174 NED0-10958-A AFED-5458 NEDO 10299 NEDO-10959 AFED-54E0 NEDO-10320 NED0-20231 APED-5652 NEDO-10329 NEDO-20340 APED-E750 NEDO-103a9 NECO-20360
- APED-5755 NEDO-10527 NED0-20360-IP 55AF-13112 NEDO-10739 NEDO-20566 NEDE-10313 NEDO-10801 NEDO-20626 NEJE-21175-p NED0-10802 NEDO-20626-1 NE.M-10735 NEDG-10846 NED0-20626-2 N00-10173 NED0-10958 NEDO-20631 9 n
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NED0-20913 ID0-ITR-105 NE00-20922 WACP-6065 NEDO-20939 WAPD-TM-283 NED0-20944 WAPD-TM-416 NEDE-20944-P BN-TOP-1, Rev.1 (11-72)
NED0-20948-P BN-TOP-2, Rev. 2 (5-74)
NE00-21142 BQ-TOP-1, Rev. 2 (1977)
NED0-21143 NEDO-21159 NEDO-26453 (all parts) and The report authored by Dr. Charles Reed of General Electric, concerning tre present and future status of BWRs with regard to, among other thir:gs, safety.
The bases for the assumptions in the " assessment of likelihood" of " rare" and " extremely rare" used in the Environmental Report (ER) Rable 7.1-17 with specifi-cation as to whether these bases are factual, estimated, or speculative.
- 5. For ECNP Contention 9, on Decomissioning, supply all data, cost estimates, and worker exposure estimates now associated with decommissioning which have been developed by the Applicant since filing of the FSAR or subsequent to and/or in consequence of the TMI-2 accident of March 28, 1979.
- 6. For ECNP Contention 18, on Herbicides, supply a detailed description of Applicant's plans to maintain clearance of transmission line rights-of-way, including full infonnation on:
- a. Any chemical herbicides proposed to be used and a full environmental analysis thereof;
- b. Physical or mechanical means of maintenance and their full environmental impacts; and
- c. Detailed provisicns and identification of anu subcontracts and subcontractors and their plans for rights-of-way maintenance, on.',
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To Commonwealth of Pennsvivania The Ccmmonwealth is asked to provide Intervenors with the following information, data, documents and reports:
- 1. For Irtervenors' Contentions 1-18, provide all correspondence and requests for information, data or documents from the Commonwealth to the Applicant subsequent to and/or in consequence of the March 28, 1979 accident at Three Mile Isla'nd, Unit 2.
- 2. For ECNP Contention 6, on Evacuation, supply
- a. The most recent version of the Coroonwealth's energency preparedness and evacuation plans;
- b. All correspondence from, and to, the Bureau of Radiological Protection, the Pennsylvania Emergency Management Agency, the Commonwealth Justice Department, the Applicant, and NRC pertaining to the adequacy and any proposed thanges in emergency preparedness and evacuation plans in consequence of and subsequent to the March 28,1979, THI-2 accident.
- c. All records, documents, and other information detailing the legal. responsibilities and obligations of employees of the Commonwealth with respect to their ability to respond fully, adequately, and timely to a radiological emergency at a nuclear power facility in order to protect the health and safety of the citizens of Pennsylvania.
- d. All radiation monitoring data from Three Mile IsTand, Unit 2, in the possession of the Commonwealth Bureau of Radiological Protection subsequent to March 28, 1979, in order to establish whether the Commonwealth or any other involved institution or agency has monitored to a distance and extent to be able to establish radiaticn doses to the public with a reasonable degree of accuracy and timeliness in the event of a radiological emergency.
- e. Emergency preparedness and evacuation plans of the Pennsylvania Emergency Management Agency and local agencies of government to provide adequately for the protection of the healtn and safety of the citizens of Pennsylvania i; the event cf a radiological accident worse than the Applicant's calculated " design basis accident," or a Class 9 accident.
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RELKIM CORRESPONDENCE CERTIFICATE OF SERVICE I hereby certify that copies of Environmental Coalition on Nuclear Power (ECNP) First Round Discovery Recuests to NRC Staff, Acolicant, and Commonwealth have been served on the following by deposit in the United States mail, first class, this 15 day of May,1979:
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Decketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Ce-inion
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Washington, D. C. 20555 Charles Sechhoefer, Esquire Chair =an, ASL3 Panel Jay Silberg, Escuizo U.S. Nuclear Regulatory C W ssion Shaw, rittman, '/otts, and Trowbridge Vashington, D.C. 20555 1800 M Street W -
Waship;; ton, D .C. 20036 Mr. Glenn O. Bright ASL3 Panel Gerald Schultz, isquire U.S. Nuclear Regulatory Cc==ission Susquehanna ::nviron= ental Advocates .
Washingten, D.C. 20555 , SCO South River Street .
Wilkes-Barre, ta. 18/04 Dr. Usear H. Paris ASL3 /anel Ers. Irene >=novics, Chainerson U.S. Nuclear Regulatory C d ssion Citi:: ens Agai:nst Ncclear ikc2ger Washington, D. C. 20555 P 0. Ecr 377 -
R.D. 1 Atc=:ic Safety and Licensing Berwick, Pa. 18603 Board Panel U.S. Nuclear Regulatory CM ssien Ms. Colleen }".arsh Vasnington, D.C. 20555 5$8 A, R.D. 6 Xountain Top, Pa., 18707 Ate d.c Safety and Licensing Appeal Ecard Panel Mr. *h::ac M. Gera@, Direct =
U.S. Nuclear Regulatory Cc-4 ssion Preau of Radiatim Protectics Washington, D. C. 20553 Deprtment of Envi.w.-a9tal Reso=9. :es
. Cc=:uwealth of Yennsylvania Janes M. Cutchin,17, Isquire P.O. Ecx 2063 Office of the Enecutive Legal F.arrisburg, Pa. 17120 Director U.S. Nuclear Regulate:y CGssion Washington, D.C. 20555 ,
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