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| {{#Wiki_filter:'.#EE*CRE THE AT0"IG SATE"'Y & LICENSIt'G AFFEAL 30ABD 12/19/79''Re: Hope Creek Docket Fos. 50-354 | | {{#Wiki_filter:' |
| & 5G-355 Response of David A. Caccia to AIA3-W footnote V2"y participatior ir 'he Rador issue has consisted of two br e's, the latest one dated 1/3/?9, a copy of which is enclosed. | | . |
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| | EE*CRE THE AT0"IG SATE"'Y & LICENSIt'G AFFEAL 30ABD 12/19/79 |
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| | Re: Hope Creek Docket Fos. 50-354 & 5G-355 Response of David A. Caccia to AIA3-W footnote V2 "y participatior ir 'he Rador issue has consisted of two br e's, the latest one dated 1/3/?9, a copy of which is enclosed. |
| i Essentially I take issue with the Boards conclusion that the few deaths due to the radon released in con.iunction with Perkins is insignificant. | | i Essentially I take issue with the Boards conclusion that the few deaths due to the radon released in con.iunction with Perkins is insignificant. |
| If the cost / benefit relation between a nuclear Fenerator and another source of power is at exact equipoise, then any adverse health effects of nuclear would shif t the balance against nuclear. | | If the cost / benefit relation between a nuclear Fenerator and another source of power is at exact equipoise, then any adverse health effects of nuclear would shif t the balance against nuclear. |
| A recent study done by the Environmental Defense Fund, comparing nuclear power with the energy alternatives of solar, conservation, etc., found nuclear to be less cost-efficient than the energy alternatives. | | A recent study done by the Environmental Defense Fund, comparing nuclear power with the energy alternatives of solar, conservation, etc., found nuclear to be less cost-efficient than the energy alternatives. From this, I conclude that a sinilar study for Hope Creek would show similar results. But assume such a study fer Hope Creek should find nuclear and the energy alternatives to be in exact equipoise. Then even one death due to radon would tip the balance aGainst nuclear. In all probability the balance is arainst nuclear already, so the radon effects only tips'the balance further. |
| From this, I conclude that a sinilar study for Hope Creek would show similar results. | | The Board has not responded to my brief of 1/3/79 It would be difficult for me to attend the upcomming evidentiary hearines. If any of the other intervenors would be willine to incorperate my contention with their case. I would be Flad to work with them. Please contact me at the address below. |
| But assume such a study fer Hope Creek should find nuclear and the energy alternatives to be in exact equipoise. | | Respectf lly submitted, oA&-5. |
| Then even one death due to radon would tip the balance aGainst nuclear. | | David A. Caccia RD#2 Sox 70-A Sewell, N.J. 08080 |
| In all probability the balance is arainst nuclear already, so the radon effects only tips'the balance further. | | /* * , |
| The Board has not responded to my brief of 1/3/79 It would be difficult for me to attend the upcomming evidentiary hearines. | | *'' Chairman, Atomic Safety & Licensing Appeal Board Troy Conner Richard Black Chauncy Kepford |
| If any of the other intervenors would be willine to incorperate my contention with their case. I would be Flad to work with them. Please contact me at the address below. | | - Ecology Action i t ; 'i Edward Luton d ' O, |
| Respectf lly submitted, oA&-5.David A.Caccia RD#2 Sox 70-A Sewell, N.J. | | '' |
| 08080/* * ,*'' Chairman, Atomic Safety & Licensing Appeal Board Troy Conner Richard Black Chauncy Kepford- Ecology Action i; 'i t d' O, Edward Luton
| | Docketing & Service Section g , |
| ''Docketing & Service Section | | . |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation ML18106A8811998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG ML18106A8731998-09-15015 September 1998 Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998 Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991 LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis ML18102B4361997-07-0707 July 1997 Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst ML20132A8961996-12-0606 December 1996 Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry ML20084H9251995-06-0202 June 1995 Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs ML20080G8321995-02-0606 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary ML20077L8631995-01-0303 January 1995 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities ML20056G4121993-08-31031 August 1993 Comment Supporting Proposed Rule 10CFR2 Re Review of 2.206 Process ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20095B2411992-04-10010 April 1992 Comment on Draft NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us ML20072T2421991-04-11011 April 1991 Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams ML20246H8141989-07-0505 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20195H0331988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing ML20153F9681988-08-17017 August 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged 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 ML20154G1421988-04-20020 April 1988 Comment Opposing Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization Program.Nrc Should Establish Program Mutually Agreed Upon Between Union & Util,Per Hope Creek & Salem Programs ML20154G4601988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility ML18093A6331988-02-0101 February 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods ML20203D9661986-07-21021 July 1986 Corrected Page 5 to 860721 Transcript Re Facility ML20207H6521986-07-21021 July 1986 Transcript of Commission 860721 Discussion/Possible Vote on Full Power OL for Facility in Washington,Dc.Pp 1-76. Supporting Documentation Encl ML20107A5261985-02-19019 February 1985 Joint Motion for Leave to Withdraw as Party to Proceeding & Dismissal of Admitted Contentions.Draft Order Approving Both Requests,Settlement Agreement & Certificate of Svc Encl ML20114A6911985-01-23023 January 1985 Response Opposing Intervenor,Public Advocate of State of Ny Notice of Deposition & Motion for Protective Order. Certificate of Svc Encl.Related Correspondence ML20113H7211985-01-22022 January 1985 Response Opposing Applicant Motion for Sanctions Re Discovery.Certificate of Svc Encl.Related Correspondence ML20114B7361985-01-21021 January 1985 Applicant Response to Intervenor Third Set of Interrogatories & Request for Production of Documents Re Pipe Cracks.Related Correspondence ML20113H7321985-01-21021 January 1985 Second Supplemental Response to Preliminary & First Sets of Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20113H9671985-01-18018 January 1985 Fourth Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20113H9441985-01-18018 January 1985 Notice of H Sonn 850130 Deposition in Trenton,Nj.Concurrent Depositions of Listed Applicant Employees Requested.Related Correspondence ML20113H8091985-01-17017 January 1985 Response to Applicant 850114 Objections to Intervenor 850104 Third Set of Interrogatories & Request for Production of Documents & Motion for Protective Order.Certificate of Svc Encl.Related Correspondence ML20112J2841985-01-15015 January 1985 Second Set of Interrogatories Requesting Production of Documents Re Listed Definitions & Instructions to Public Advocate.Certificate of Svc Encl.Related Correspondence ML20112G4171985-01-14014 January 1985 Applicant Objections to Intervenor 850107 Third Set of Interrogatories & Request for Production of Documents to Applicants & Motion for Protective Order.Certificate of Svc Encl.Related Correspondence ML20112G3921985-01-14014 January 1985 Motion That ASLB Impose Sanction of Dismissal of Contentions Due to Intervenor Failure to Respond to ASLB 841121 Order to Show Cause Why OL Proceeding Should Not Be Dismissed. Related Correspondence ML20112D8631985-01-10010 January 1985 Response Opposing Intervenor 850107 Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20112C9651985-01-0707 January 1985 Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor 841213 Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20112C0001985-01-0707 January 1985 Joint Motion for Issuance of Protective Order Re Personnel Info.Draft Protective Order,Unexecuted Affidavit & Certificate of Svc Encl.Related Correspondence ML20101Q7911985-01-0404 January 1985 Intervenors Supplemental Response to Applicants Preliminary & First Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101Q6111985-01-0404 January 1985 Third Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101P9441984-12-31031 December 1984 Response to Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101M5731984-12-28028 December 1984 Response to Applicant Objections to Intervenor 841213 Second Set of Interrogatories & Request for Production.Document Request & Motion for Protective Order Should Be Denied. W/Certificate of Svc.Related Correspondence ML20101L1861984-12-28028 December 1984 Motion to Correct 841224 Record.Applicants Never Agreed to Discovery & Trial Preparation Schedule.Certificate of Svc Encl ML20101E8381984-12-21021 December 1984 Objections to State of Nj Second Set of Interrogatories & Request for Production of Documents & Motion for Protective Order.Disclosure Will Constitute Unwarranted Invasion of Privacy.Related Correspondence ML20101E7821984-12-21021 December 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20101E8511984-12-20020 December 1984 Affidavit of RM Nelson Re Info Requested by State of Nj 841213 Second Set of Interrogatories & Request for Production of Documents.Personnel Files Maintained in Confidence.Related Correspondence ML20101A1651984-12-13013 December 1984 Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20108E1161984-12-10010 December 1984 Response to ASLB 841121 Order Directing Public Advocate to Show Cause Re Dismissal of Contentions.State of Nj Safety & Environ Concerns Essential.Prehearing & Hearing Schedule Rerequested.Certificate of Svc Encl ML20099E7201984-11-23023 November 1984 Notice of Appearance in Proceeding 1998-09-15
[Table view] Category:PLEADINGS
MONTHYEARML20107A5261985-02-19019 February 1985 Joint Motion for Leave to Withdraw as Party to Proceeding & Dismissal of Admitted Contentions.Draft Order Approving Both Requests,Settlement Agreement & Certificate of Svc Encl ML20114A6911985-01-23023 January 1985 Response Opposing Intervenor,Public Advocate of State of Ny Notice of Deposition & Motion for Protective Order. Certificate of Svc Encl.Related Correspondence ML20113H7211985-01-22022 January 1985 Response Opposing Applicant Motion for Sanctions Re Discovery.Certificate of Svc Encl.Related Correspondence ML20112G3921985-01-14014 January 1985 Motion That ASLB Impose Sanction of Dismissal of Contentions Due to Intervenor Failure to Respond to ASLB 841121 Order to Show Cause Why OL Proceeding Should Not Be Dismissed. Related Correspondence ML20112D8631985-01-10010 January 1985 Response Opposing Intervenor 850107 Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20112C0001985-01-0707 January 1985 Joint Motion for Issuance of Protective Order Re Personnel Info.Draft Protective Order,Unexecuted Affidavit & Certificate of Svc Encl.Related Correspondence ML20112C9651985-01-0707 January 1985 Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor 841213 Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101L1861984-12-28028 December 1984 Motion to Correct 841224 Record.Applicants Never Agreed to Discovery & Trial Preparation Schedule.Certificate of Svc Encl ML20108E1161984-12-10010 December 1984 Response to ASLB 841121 Order Directing Public Advocate to Show Cause Re Dismissal of Contentions.State of Nj Safety & Environ Concerns Essential.Prehearing & Hearing Schedule Rerequested.Certificate of Svc Encl ML20099E6631984-11-21021 November 1984 Response to Applicant Amended Motion to Dismiss Proceeding. Motion Lacks Basis in Fact or Law.Dismissal of Motion Advised.Establishment of Prehearing Discovery Schedule Requested.Certificate of Svc Encl ML20108A1311984-11-13013 November 1984 Amended Motion to Discuss Public Advocate of New Jersey Contentions for Failure to Comply W/Aslb Discovery Orders. Certificate of Svc Encl ML20097C5421984-09-11011 September 1984 Response Opposing Applicant 840827 Third Motion to Dismiss Proceeding.Certificate of Svc Encl ML20095G8491984-08-24024 August 1984 Motion to Dismiss Proceeding as Result of Default by Public Advocate in Not Complying W/Aslb 840810 Order to Identify Witnesses by 840820 & Answer Opposing Intervenor Motion for Addl Delay.Certificate of Svc Encl ML20095H5081984-08-20020 August 1984 Petition for Addl Time to Make Expert Witnesses Available for Depositions.Scheduling of Depositions in Oct Requested. Certificate of Svc Encl.Related Correspondence ML20094D4361984-08-0707 August 1984 Answer Opposing Public Advocate Motion for Extension of Time to Respond to Applicant 840730 Motion to Compel Public Advocate to Designate Expert Witnesses & Make Available for Depositions.W/Certificate of Svc.Related Correspondence ML20094E5741984-08-0303 August 1984 Motion for Extension of Time to Respond to Applicant Motion to Compel Designation of Witnesses & Availability for Depositions &/Or Dismiss Proceeding.Certificate of Svc Encl. Related Correspondence ML20093N2471984-07-30030 July 1984 Motion to Compel Designation of Witnesses & Availability for Depositions &/Or to Dismiss Proceeding.Aslb Should Set Date for Public Advocate to Furnish Info Re Expert Witnesses. Certificate of Svc Encl.Related Correspondence ML20084F4111984-04-30030 April 1984 Response Opposing Applicant Motion to Dismiss Proceeding. Applicants Mischaracterized & Misapplied Governing Law & Demonstrated No Basis for Dismissal.Certificate of Svc Encl ML20083K6021984-04-12012 April 1984 Motion to Dismiss Proceeding Due to Lack of Bases of Contentions.Certificate of Svc Encl ML20087M7551984-03-29029 March 1984 Answer to Public Advocate of State of Nj Motion to Quash Suppoena Requiring Attendance & Testimony of Jh Rodriguez. Motion Does Not Satisfy Stay Criteria.W/Certificate of Svc. Related Correspondence ML20087M8071984-03-26026 March 1984 Motion to Quash Applicant Subpoena of Jh Rodriguez.Related Correspondence ML20081C7931984-03-13013 March 1984 Response Opposing Public Advocate 840227 Motion to Vacate Applicant 840222 Notice of Deposition & for Protective Order in Form of Declaratory Ruling.Related Correspondence ML20080N7481984-02-17017 February 1984 Consent to Util 840203 Motion to Dismiss Contention IV Re Potential Environ Impact of Facility Operation.Util Crude, creationist-inspired,sleight-of-hand Attempts to Rewrite History Should Be Ignored.Certificate of Svc Encl ML20080C5231984-02-0303 February 1984 Motion to Strike Contention 4 Re long-term Ecological Effects on Cropland & Groundwater of Salt Deposition Due to Cooling Tower Operation.Certificate of Svc Encl ML20083G2531984-01-0909 January 1984 Rsponse to Aslab 831228 Order Re Recusal Motion by State of Nj Ofc of Public Advocate.Replacement of Aslab Member Carpenter Urged.Certificate of Svc Encl ML20082D8901983-11-18018 November 1983 Motions for Judge Carpenter Disqualification,Judge Morris Disclosure of Further Biographical Info & ASLB Postponement of Special Prehearing Conference Until Resolution of Motions ML20082D9131983-11-18018 November 1983 Memorandum of Law in Support of State of Nj Public Advocate Motions for Judge Carpenter Disqualification,Judge Morris Disclosure of Addl Info & ASLB Postponement of Special Prehearing Conference.Certificate of Svc Encl ML18081A8881980-01-10010 January 1980 Opposition to Intervenors Coleman 791018 Request for Action Under 10CFR2.206.NRC Fulfilled Statutory Duty Per Endangered Species Act.No New Matters Raised by Intervenors Request ML19211D3711979-12-19019 December 1979 Response to ALAB-566,Footnote 2.Takes Issue W/Aslb Conclusion Re Insignificance of Deaths Due to Radon Releases.Alleges That Nuclear Energy Is Less cost-efficient than Energy Alternatives ML19260A1921979-10-18018 October 1979 Seeks Order to Show Cause & Suspension &/Or Revocation of Cps.No Eia Performed Re Facility Impact on Endangered Fish Species.Certificate of Svc Encl ML19250A7691979-10-18018 October 1979 Petition Seeking NRC Issuance of Show Cause Order for Suspension or Revocation of Ols.Operation of Facility Would Threaten Local Existence of short-nosed Sturgeon.Affidavit & Certificate of Svc Encl ML17207A4061979-08-24024 August 1979 Opposition to Fl Cities 790809 Motion to Lodge FERC Decision Concerning Util.Decision Was Not Issued by Agency of Competent Jurisdiction;Therefore,Motion Will Prejudice Proper Consideration of Matters.Certificate of Svc Encl ML19273B9911979-05-0202 May 1979 Motion for Reconsideration of ALAB-540 & Severence from Consolidation Established by ALAB-540.Admits Issues Not Raised by Any Party & Departs from Lead Case Procedure Previously Adopted.Certificate of Svc Encl ML18078B0821979-02-16016 February 1979 Opposes Storage of Spent Fuel,Enlargement of Spent Fuel Pools & Any Storage within the Township of Lower Alloways Creek,Nj.Requests Programs for Permanent Disposal Outside Township ML19274D7291979-02-0808 February 1979 Intervenors' Petition for Review of ALAB-518 Re Probability of Hazardous Cargo Ship Posing a Danger, & Failure to Order an Eis.Federal Energy Commission 790125 Order Encl 1985-02-19
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EE*CRE THE AT0"IG SATE"'Y & LICENSIt'G AFFEAL 30ABD 12/19/79
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Re: Hope Creek Docket Fos. 50-354 & 5G-355 Response of David A. Caccia to AIA3-W footnote V2 "y participatior ir 'he Rador issue has consisted of two br e's, the latest one dated 1/3/?9, a copy of which is enclosed.
i Essentially I take issue with the Boards conclusion that the few deaths due to the radon released in con.iunction with Perkins is insignificant.
If the cost / benefit relation between a nuclear Fenerator and another source of power is at exact equipoise, then any adverse health effects of nuclear would shif t the balance against nuclear.
A recent study done by the Environmental Defense Fund, comparing nuclear power with the energy alternatives of solar, conservation, etc., found nuclear to be less cost-efficient than the energy alternatives. From this, I conclude that a sinilar study for Hope Creek would show similar results. But assume such a study fer Hope Creek should find nuclear and the energy alternatives to be in exact equipoise. Then even one death due to radon would tip the balance aGainst nuclear. In all probability the balance is arainst nuclear already, so the radon effects only tips'the balance further.
The Board has not responded to my brief of 1/3/79 It would be difficult for me to attend the upcomming evidentiary hearines. If any of the other intervenors would be willine to incorperate my contention with their case. I would be Flad to work with them. Please contact me at the address below.
Respectf lly submitted, oA&-5.
David A. Caccia RD#2 Sox 70-A Sewell, N.J. 08080
/* * ,
- Chairman, Atomic Safety & Licensing Appeal Board Troy Conner Richard Black Chauncy Kepford
- Ecology Action i t ; 'i Edward Luton d ' O,
Docketing & Service Section g ,
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