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| Presently pending before this Board is another | | Presently pending before this Board is another |
| " Motion for a Partial Initial Decision" filed by Applicant on July 24, 1981. This motion expands upon the July 24, 1981 motion in that Applicant is now requesting not only a decision on those issues addressed in the evidentiary hearings, but also on its request to install five new storage racks. | | " Motion for a Partial Initial Decision" filed by Applicant on July 24, 1981. This motion expands upon the July 24, 1981 motion in that Applicant is now requesting not only a decision on those issues addressed in the evidentiary hearings, but also on its request to install five new storage racks. |
| Approval of installing all (33) of the proposed storage racks is not requested at this time; Applicant is informed | | Approval of installing all (33) of the proposed storage racks is not requested at this time; Applicant is informed that the Staff believes this will take five to six more weeks of reviewers' time (which, when added to the time necessary for Applicant to perform the additional nonlinear analyses requested by tNe Staff, me.ans a delay of several l months?. Our understanding is chat the Staff intends to I |
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| that the Staff believes this will take five to six more weeks of reviewers' time (which, when added to the time necessary for Applicant to perform the additional nonlinear analyses requested by tNe Staff, me.ans a delay of several l months?. Our understanding is chat the Staff intends to I | |
| j update its Board Notification fortnally advising She L aard I | | j update its Board Notification fortnally advising She L aard I |
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| ; both meetings but apparently Intervenor had not received minutes of the second meeting as of August 6, 1981. | | ; both meetings but apparently Intervenor had not received minutes of the second meeting as of August 6, 1981. |
| In addition, Applicant supplied responses to NRC questions on June 12, 1981 and on August 10, 1981. | | In addition, Applicant supplied responses to NRC questions on June 12, 1981 and on August 10, 1981. |
| Both sets of responses were served on Intervenor and on Intervenor's consultant, Richard Hubbard, although Intervenor states that it did not receive Applicant's June 12, 1981 response prior _to August 6, 1981. Inter-venor now has been supplied with copies of all of the | | Both sets of responses were served on Intervenor and on Intervenor's consultant, Richard Hubbard, although Intervenor states that it did not receive Applicant's June 12, 1981 response prior _to August 6, 1981. Inter-venor now has been supplied with copies of all of the abovo documents. |
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| abovo documents. | |
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| Res ctfully submitted, o | | Res ctfully submitted, o |
| \ r ,l f | | \ r ,l f |
| ) n W One'ofthe{tt6rneysfor Commonwealth Edison Company | | ) n W One'ofthe{tt6rneysfor Commonwealth Edison Company ISHAM, LIMCOLN & BEALE - |
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| ISHAM, LIMCOLN & BEALE - | |
| Suite 4200 Cne First National Plaza Chicago, Illinois 60603 312/558-7500 Dated: August 13, 1981 i. | | Suite 4200 Cne First National Plaza Chicago, Illinois 60603 312/558-7500 Dated: August 13, 1981 i. |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20141K3801997-05-27027 May 1997 Order Prohibiting Involvement in NRC-licensed Activities (Effective Immediately) for Dr Baudino for Period of Five Years ML20080A6081994-10-24024 October 1994 Refers to Pierce Actions Re Util Failure to Provide Adequate Training or Guidance Concerning Applicability of Doa 300-12 While Expert Present Directing Control Rod Movements ML20070B0081994-06-20020 June 1994 Response to Order Prohibiting Involvement in NRC-licensed Activities.* Informs That Order Will Have Negative Impact on Health & Safety of Public ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20245J0191989-04-14014 April 1989 Comment Re Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20235T9661989-03-0101 March 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Will Reduce Experience Level of Senior Operators ML20235T8701989-02-28028 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Rule Will Cause Career Stagnation & Animosity Among Operators ML20235T8251989-02-28028 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Proposed Rules Provide No Enhancement of Reactor Safety ML20235T1551989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Education & Experience Requirements for Senior Reactor Operators & Supervisors.Alternative Provides No Enhancement of Reactor Safety & Will Reduce Experience Level of Senior Operators ML20235T1231989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Reduce Experience Level of Senior Operators ML20235S9791989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Both Alternatives Would Eventually Reduce to Nothing Reactor Operators Advancing to Senior Operator ML20235S8371989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235S8241989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Proposed Rule Alternatives Would Reduce to Nothing Reactor Operators Advancing to Senior Operator ML20235T1361989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternative Provides No Enhancement of Reactor Safety & Will Reduce Experience Level of Senior Operators ML20235T0911989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Reduce Experience Level of Senior Operators ML20235T7041989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235T7951989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Both Alternatives Do Not Provide Enhancement of Reactor Safety ML20235T0461989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Both Alternatives Would Reduce Number of Reactor Operators Advancing to Senior Operator to Nothing ML20235T8381989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235S9541989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Reduce Experience Level of Senior Operators ML20205T0891988-10-28028 October 1988 Comment Opposing Proposed Rule 10CFR26 Re Fitness for Duty Program.Proposed Rule Unnecessary as Utils Have Effective Fitness for Duty Program ML20205N0941988-10-24024 October 1988 Comments on Petition for Rulemaking PRM-50-50 Re Authorization of Reactor Licensees to Depart from License Conditions & Tech Specs in Emergency Situations.Young Criticism of Inerting Practices at Plant W/O Credence ML20155A6591988-09-0303 September 1988 Comment Supporting Petition to Rescind Paragraphs (X)(Y) of Section 10CFR50.54 Re Cases of Hazardous Practices Including Util Authorizing Senior Operator to Turn Off Safety Sys in Emergency Before Sys Has Finished Job 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 ML20207T2351987-02-16016 February 1987 Endorsement 16 to Maelu Policy MF-114 ML20207T2281987-01-28028 January 1987 Endorsement 21 to Nelia Policy NF-277 ML20213D3421986-08-11011 August 1986 Endorsement 79 to Maelu Policy MF-54 ML20213D3461986-08-11011 August 1986 Endorsement 78 to Maelu Policy MF-54 ML20213D3491986-08-11011 August 1986 Endorsement 94 to Nelia Policy NF-187 ML20213D3501986-08-11011 August 1986 Endorsement 95 to Nelia Policy NF-187 ML20213D3791986-08-0808 August 1986 Endorsement 178 to Nelia Policy NF-43 ML20213D3761986-08-0808 August 1986 Endorsement 84 to Nelia Policy NF-201 ML20213D3691986-08-0808 August 1986 Endorsement 72 to Maelu Policy MF-64 ML20213D3681986-08-0808 August 1986 Endorsement 73 to Maelu Policy MF-64 ML20213D3591986-08-0808 August 1986 Endorsement 154 to Maelu Policy MF-22 ML20213D3521986-08-0808 August 1986 Endorsement 153 to Maelu Policy MF-22 ML20213D3511986-08-0808 August 1986 Endorsement 179 to Nelia Policy NF-43 ML20063M3061982-09-0101 September 1982 Response Opposing Reopening of Record Re Comm Ed Use of 9-ton Auxiliary Hook of Main Overhead Crane Sys During 1981 Installation of High Density Spent Fuel Racks.Incident Not Relevant to Proceeding.Svc List Encl.Related Correspondence ML20063A2551982-08-18018 August 1982 Response to ASLB 820728 Order.Requests Leave to Withdraw Application W/O Prejudice.Need for Transshipment in near- Term Reduced Due to Approval of Installation of High Density Spent Fuel Racks.Certificate of Svc Encl ML20055B4521982-07-20020 July 1982 Transcript of 820720 Hearing in Bethesda,Md Re Spent Fuel Pool Mods.Pp 1,192-1,284 ML20055A6681982-07-14014 July 1982 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20054L9371982-07-0808 July 1982 Memorandum in Response to Applicant Motion for Reconsideration or Clarification of Notice of Hearing Re Issue of Whether Spent Fuel Pool Floor Can Withstand Loads Imposed by New High Density Fuel Racks During Seismic Event ML20054L9591982-07-0101 July 1982 Testimony of Oo Rothberg & G Harstead.Spent Fuel Pool Expansion for Full 33 Rack Installation Is Acceptable.Spent Fuel Pool Floor Can Withstand Impact If All 33 Racks Tip During Seismic Event ML20054K6511982-07-0101 July 1982 Response Supporting Applicant 820616 Motion for Reconsideration or Clarification of Notice of Hearing.Aslb Should Render Final Decision on Basis of Supplemental SER & ASLB Former Findings.Certificate of Svc Encl ML20054G0051982-06-16016 June 1982 Motion for Reconsideration or Clarification of Hearing Scheduled for 820713 by ASLB 820609 Notice of Hearing. Further Evidentiary Sessions Unnecessary & Improper.Final Decision Proper.Certificate of Svc Encl ML20054F5391982-06-0909 June 1982 Notice of 820713 Hearing in Bethesda,Md,To Continue to 0714 If Necessary.Evidence Relevant to Issue of Whether Spent Fuel Pool Floors Can Withstand Loads Which Could Be Imposed by New Fuel Racks During Seismic Event Will Be Taken ML20054F7151982-06-0707 June 1982 Testimony of DB Davidoff & LB Czech on Commission Questions 3 & 4.NY State Radiological Emergency Preparedness Plan Discussed.Certificate of Svc Encl 1999-03-02
[Table view] Category:PLEADINGS
MONTHYEARML20063M3061982-09-0101 September 1982 Response Opposing Reopening of Record Re Comm Ed Use of 9-ton Auxiliary Hook of Main Overhead Crane Sys During 1981 Installation of High Density Spent Fuel Racks.Incident Not Relevant to Proceeding.Svc List Encl.Related Correspondence ML20063A2551982-08-18018 August 1982 Response to ASLB 820728 Order.Requests Leave to Withdraw Application W/O Prejudice.Need for Transshipment in near- Term Reduced Due to Approval of Installation of High Density Spent Fuel Racks.Certificate of Svc Encl ML20054K6511982-07-0101 July 1982 Response Supporting Applicant 820616 Motion for Reconsideration or Clarification of Notice of Hearing.Aslb Should Render Final Decision on Basis of Supplemental SER & ASLB Former Findings.Certificate of Svc Encl ML20054G0051982-06-16016 June 1982 Motion for Reconsideration or Clarification of Hearing Scheduled for 820713 by ASLB 820609 Notice of Hearing. Further Evidentiary Sessions Unnecessary & Improper.Final Decision Proper.Certificate of Svc Encl ML20010C2861981-08-13013 August 1981 Motion for Partial Initial Decision Approving Installation of Five Spent Fuel Storage Racks.Facility Must Begin to Shift Fuel to Prepare for Next Refueling Outage No Later than 810901 Unless Racks Are Approved.W/Certificate of Svc ML20010B2991981-08-0606 August 1981 Response in Opposition to Applicant Motion for Partial Initial Decision Re Issue of Sliding & Tilting of Proposed Spent Fuel Racks During Seismic Events.Certificate of Svc Encl ML19246C0671979-05-22022 May 1979 NRDC Response in Opposition to Comm Ed Motion for Reconsideration Or,In Alternative,For Clarification or Referral Re Adequacy of Safeguards for Spent Fuel Shipments. Motion Is Unwarranted & Inconsistent w/10CFR73 ML19246C0701979-05-18018 May 1979 NRDC Staff Scientist Statement Re Safeguards for Spent Fuel Shipments.Proposed Rule to Protect Spent Fuel Shipments Against Sabotage,Presented in 790429 Memo to Commission,Is Most Likely Adequate.Certificate of Svc Encl ML19241A9891979-05-17017 May 1979 State of Il Opposition to NRC 790504 & Comm Ed 790507 Motions for Reconsideration &/Or Clarification & Referral of ASLB 790419 Memo & Order Admitting Contentions 6 & 11 ML19241A9781979-05-10010 May 1979 NRDC Opposition to NRC Motion for Reconsideration of ASLB 790419 Memo & Order Following Special Prehearing Conference.Certificate of Svc Encl ML19269D9271979-05-0707 May 1979 Applicant Motion for Reconsideration of 790419 Memo & Order of Clarification of 780419 Order Re Physical Security of Snm.Supporting Documentation & Certificate of Svc Encl ML19274D6911979-01-26026 January 1979 Memorandum Re State of Il Contentions.Withdraws Contentions 10-12,14,15 & 17 & Submits Revised Contentions 3,10,& 11. Related Correspondence,Stipulation of Contentions,State Law & Certificate of Svc Encl ML19282A7571979-01-26026 January 1979 Nrdc'S Response to Applicant'S & Nrc'S Objections to Contentions.Urges That NRC Did Not Validly Challenge Its Contentions & That Its Contentions Should Be Admitted. Certificate of Svc Encl ML19289C9321979-01-12012 January 1979 Applicant'S Answer & Motion to Strike Re Contentions Filed by Petitioners to Intervene Nrdc,Citizens for a Better Environ & State of Il.Contentions Fail to State Claim for Which Relief May Be Granted.W/Certificate of Svc ML19263B5221979-01-0202 January 1979 State of Il Contentions Re Amends to Operating License for Transport of Spent Fuel Between Units.Contentions Assert Applicant'S Submittals Are Insufficient.W/Affidavit & Certificate of Svc ML19269C3001978-12-28028 December 1978 NRDC & Citizens for a Better Environ Statement of Contentions.Asserts Action Would Violate Nepa,Provide No Adequate Analysis of Alternatives & Increase Exposure of Workers to Radiation.W/Certificate of Svc ML19259A9271978-12-19019 December 1978 Reply by NRDC & Citizens for Better Environ to Suppl Brief of Commonwealth Edison Co.Asserts That Util Errs in Claiming That Only Direct Personal case-by-case Authorization of Litigation Can Confer Standing.Certificate of Svc Encl ML19263B5291978-12-0606 December 1978 NRDC & Citizens for a Better Environ Contentions Re Util'S License Amend Re Transport of Spent Fuel Between Units. Asserts Proposed Action Violates NEPA ML20064E5051978-10-30030 October 1978 Request by Comm Ed for Leave to File a Response to NRDC Brief Which Argues That Organizations May Show Standing to Participate in NRC Proceedings Merely by Alleging That They Represent Anonymous Members.Cert of Svc Encl ML20064E2511978-10-23023 October 1978 Natural Resources Defense Council Response to Commonwealth Edison'S & Staff'S Answers to Petition for Leave to Intervene.Intervenor Urges Bd to Establish a Schedule for Briefing Challenges to Contentions ML20062B4171978-10-10010 October 1978 Request for Leave to File Response to Applicant Contention Re Constitutionality of Forced Disclosure of Group Members Names in Order to Operate within State ML20064B9371978-09-18018 September 1978 Applicant'S Answer to Petition for Leave to Intervene Re Proceeding Filed 780908 by Attorney Gen of St of Il.Includes Notices of Appearance for M.I.Miller,J.R.Rowe,& P.P.Steptoe. Includes Designation of Person Upon Whom Svc Shall Be Made ML20058K5131973-12-13013 December 1973 Requests for Decision Re Immediate Derating of Nine BWRs & Implementation of Procedures to Be Followed for Consideration of Any Subsequent Action Concerning Safety Issue Raised About Plants 1982-09-01
[Table view] |
Text
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- '* - , 8/13 c4 ,
4 co c rn TN UNITED STATES OF AMERICA ,
NUCLEAR REGULATORY COMMISSION h AU'313 jggg , :3 THE ATOMIC SAFETY AND LICENSING BOARD D Ob d h Sq
% Cxkeuz & Sw; ice Bien:'_ 6' In the Matter of ) go g
) Docket Nos. 50-237-SP g,L COMMONWEALTH EDISON COMPANY ) 50-249
) (Spent Fuel Pool pFT teg /N #
(Dresden Station, Units 2 6 3)) Modification) /
APPLICANT'S MOTION FOR PARTIAL T INITIAL DECISION APPROVING INSTALLATIONil 4 p 4 /M ;5' OF FIVE RACKS ~
~ p Qp- p Evidentiary hearings in this case were compigt,ed -p and the parties' proposed findings of fact had been submitted when on May 28, 1981 the NRC Staff notified the Licensing Board that during its Systematic Evaluation Program (SEP) review an issue had arisen requiring further information from Applicant relating to possible sliding and tilting of spent fuel storage racks during a postulated seismic event. On June 16, 1981 the record in this case was closed.1/ The NRC Staff subsequently requested the Licensing Board not to issue a final initial decision pending completion of the Staff's review of this issue.SI A series of written questions and answers and meetings followed between the NRC Staff and Applicant.1/
1/ Memorandma and Order (Corrections in Transcript, ruling on motion, and closing the record).
~
2/ Letter dated June 29, 1981 to Licensing Board Members 3 from Gus C. Lainas, Assistant Director for Safety Assessments, Division of Licensing, USNRC.
950 5 3/ See footnote 5, infra. /
B102190317 810813 PDR ADOCK 05000237 o PDR
Applicant is now informed that the NRC Staff is satisfied, based on its review of the responses provided by Applicant, that che installation af five racks at the r. orth end of the Dresden 3 pool presents no safety problem.- An affidavit attesting to that conclusicn has been prepared by the NRC Staff and we are informed that it is being sent to the Board. Applicant therefore requests that a Partial Initial Decision be rendered authorizing installation of five new rack ;, based on the record in this case, and on the NRC Staff's affidavib which demonstrates that there is no longer any reason to withhold approval with respect to the five racks.
Presently pending before this Board is another
" Motion for a Partial Initial Decision" filed by Applicant on July 24, 1981. This motion expands upon the July 24, 1981 motion in that Applicant is now requesting not only a decision on those issues addressed in the evidentiary hearings, but also on its request to install five new storage racks.
Approval of installing all (33) of the proposed storage racks is not requested at this time; Applicant is informed that the Staff believes this will take five to six more weeks of reviewers' time (which, when added to the time necessary for Applicant to perform the additional nonlinear analyses requested by tNe Staff, me.ans a delay of several l months?. Our understanding is chat the Staff intends to I
j update its Board Notification fortnally advising She L aard I
I i
. . - .- .=
'^
e.
of the status of its review efforts for the remainder of the proposed racks in the near future.
The Staff has no objection to Applicant's request for a Partial Initial Decision' approving installation of five racks. Intervenor however in its response dated August 6, 1981 to Applicant's~ July 24th Motion for a Partial Initial Decision, has raised several objections. Presumably Intervenor will be no less opposed to this Motion for a Partia)
Initial Decision Approving Installation or Five Racks.
Intervenor argues "There is no specific provision
- in NRC Rules and Regulations for [a partial initial] decision, and it certainly has not been the practice of Atomic Safety and Licensing Boards to issue partial decisions."d! This is nonsense. See 10 CFR Part 2 Appendix A par. I(c);
10 CFR S2.718; Potomac Electric Power Company (Douglas Point Nuclear Generating Station, Units 1 and 2), ALAB-277, 1 NRC 539 (1975); Virginia Electric and Power Company (North Anna l
Nuclear Power Station, Units 1 and 2), ALAB-491, 8 NRC 245 (1978).
Intervenor's argument that Applicant's request is i similar 'o a motion for summary di position is not well taken.
l l'
The sliding and tipping issue described in the Staff's May 28, 1981 Board Notification in not a contention in this proceeding.
The legal standard which Intervenor must meet in opposing this motion for a' Partial Initial Decision Approving Installa-tion of Five Racks is that it must demonstrate that the
(
-4/ "Intervenor's Response to Applicapt's Motion for a l Partial Initial Decision" dated August 6, 1981 at p. 2.
L
installation of five racks is a matter of major significance to safety which requires rgopening the record for further evidentiary hearings. See Vermont Yankee Nuclear Power Corporation (Vermont Yankee Nuclear Power Station), ALAB
- 138, 6 AEC'520 (1973); Carolina Power and Light Company (Shearon Harris Nuclear Power Plant, Units 1, 2, 3 and 4),
LBP-78-2, 7 NRC 83 (1978). We note that despite receipt more than two months ago of the Board Notification, Intervenor has taken no steps at all to request that the record be reopened or to ask that the subject mat er of the Board Notification be a litigated issue in this case. Indeed, despite receipt of the Board Notification, Intervenor has 4
merely claimed that it has "no specific knowledge" of what the sliding and tipping issues are.5/ Therefore, Intervenor to date has not treated the Board Notification as a matter of major significance to plant safety requiring further evidentiary hearings.
- 5/ Following the Board Notification which was of course served on Intervenor, there were two meetings in L Washington,.D.C. between the NRC Staff and Applicant on June 30, 1981 and July 17, 1981. Intervenor was notified in advance of each meeting but chose not to
- attend. The NRC Staff prepared meeting notes for
- both meetings but apparently Intervenor had not received minutes of the second meeting as of August 6, 1981.
In addition, Applicant supplied responses to NRC questions on June 12, 1981 and on August 10, 1981.
Both sets of responses were served on Intervenor and on Intervenor's consultant, Richard Hubbard, although Intervenor states that it did not receive Applicant's June 12, 1981 response prior _to August 6, 1981. Inter-venor now has been supplied with copies of all of the abovo documents.
p , -
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i Dresden Station must begin to shift fuel in preparation for the forthcoming refueling outage no later than September 1, 1981 unless Applicant's five rack proposal is approved by that time. Accordingly, Applicant respect-fully requests that Intervenor expedite service of its response to this motion. This Motion is being served on Intervenor by messenger and on its consultant by Federal
. Express. The NRC Staff's affidavit is being served by express mail. Accordingly, in view of the urgency of this case it seems reasonable to request Intervenor to respond as soon as possible, also by Federal Express.
Applicant will be glad to discuss this Motion in a conference call if the Board believes additional clarifi-cation is necessary.
Res ctfully submitted, o
\ r ,l f
) n W One'ofthe{tt6rneysfor Commonwealth Edison Company ISHAM, LIMCOLN & BEALE -
Suite 4200 Cne First National Plaza Chicago, Illinois 60603 312/558-7500 Dated: August 13, 1981 i.
UNITED STATES OF AMERICA NUCLEAR RESULATORY COMMISSION THE ATOMIC-SAFETY AND LICENSING BOARD In the Matter of )
) Docket Nos. 50-237-SP COMMONWEALTH EDISON COMPANY ) 50-249-SP
) (Spent Fuel Pool (Dresden Station, Units 2 & 3)) Modification)
CERTIFICATE OF SERVICE I hereby certify that copies of Applicant's Motion for Partial Initial Decision Approving Five Racks in the above-captioned proceeding have been served upon the following by deposit in the United States mail, first class, or as indicated below by personal service or Federal Express, on this 13th day of August, 1981.
John F. Wolf, Esquire 3409 Shepherd Street Chevy Chase, Maryland 20015 Dr. Linda W. Little 5000 Hermitage Drive Raleigh, North Carolina 27612 Dr. Forrest J. Remick (Federal Express) 305 East Hamilton Avenue State College, Pennsylvania 16801 Atomic Safety and Licensing Board Panel U.S. Nuclear Egulatory Commission Washington, D.C. 20555 Docketing and Service U.S. Nuclear Regule. tory Commission Washington, D.C. 20555 Mary Jo Murray, Esquire (Personal Service)
Assistant Attorney General Environmenta3 Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601
Richard Goddard (Personal Service)
Office of Executive. Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard Hubbard (Federal Express)
MHB Technical Associates Suite K 1723 Hamilton Avenue San Jose, California 95125
'\ m-By k 4 dA/
Philip Steptoe ISHAM, LINCOLN & BEAI-E One First National Plaza Suite 4200 Chicago, Illinois 60603 312/55/-7500 Dated: August 13, 1981
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