Similar Documents at Byron |
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Category:INTERVENTION PETITIONS
MONTHYEARML20092H9591984-06-0707 June 1984 Forwards Proposed Financial Qualification Contention.Const Cannot Be Completed in Manner Resulting in Safe Plant. Evacuation Plan Will Be Terrible Financial Burden.Served on 840625 ML20024A1201983-02-21021 February 1983 Amend & Consolidation of Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 & Rockford League of Women Voters Contentions 19 & 108 ML20024A1181983-02-21021 February 1983 Motion to Amend & Consolidate Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 W/Rockford League of Women Voters Contentions 19 & 108 ML20062B0591982-07-30030 July 1982 Need for Power & Alternative Energy Source Contention ML20062B0471982-07-30030 July 1982 Financial Qualifications Contention ML20054C6741982-04-15015 April 1982 Revised Contentions 10-12.Certificate of Svc Encl ML19310A1801980-05-0909 May 1980 Supplemented Statement of Contentions Alleging Lack of Technical Qualifications to Operate Station.Dose Impacts of Projected Routine Releases of Radioactive Matls Should Be re-evaluated.Certificate of Svc Encl ML19323C6711980-04-18018 April 1980 Response to Rockford League of Women Voters Revised Contentions.Urges Admission of Contentions 50,85,104,112(d) & 119(a)(b),consolidation of Contentions 2,5,88,90 & 116 & Rejection of Remaining Contentions.W/Certificate of Svc ML20028B9861980-03-10010 March 1980 Revised Contentions.Ols Should Be Denied 1984-06-07
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20092H9591984-06-0707 June 1984 Forwards Proposed Financial Qualification Contention.Const Cannot Be Completed in Manner Resulting in Safe Plant. Evacuation Plan Will Be Terrible Financial Burden.Served on 840625 ML20024A1201983-02-21021 February 1983 Amend & Consolidation of Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 & Rockford League of Women Voters Contentions 19 & 108 ML20024A1181983-02-21021 February 1983 Motion to Amend & Consolidate Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 W/Rockford League of Women Voters Contentions 19 & 108 ML20062B0591982-07-30030 July 1982 Need for Power & Alternative Energy Source Contention ML20062B0471982-07-30030 July 1982 Financial Qualifications Contention ML20054C6741982-04-15015 April 1982 Revised Contentions 10-12.Certificate of Svc Encl ML19310A1801980-05-0909 May 1980 Supplemented Statement of Contentions Alleging Lack of Technical Qualifications to Operate Station.Dose Impacts of Projected Routine Releases of Radioactive Matls Should Be re-evaluated.Certificate of Svc Encl ML19323C6711980-04-18018 April 1980 Response to Rockford League of Women Voters Revised Contentions.Urges Admission of Contentions 50,85,104,112(d) & 119(a)(b),consolidation of Contentions 2,5,88,90 & 116 & Rejection of Remaining Contentions.W/Certificate of Svc ML20028B9861980-03-10010 March 1980 Revised Contentions.Ols Should Be Denied 1984-06-07
[Table view] 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 ML20149M2951996-11-29029 November 1996 Exemption from Requirements of 10CFR50.60 Re Safety Margins Recommended in ASME Boiler & Pressure Vessel Code Case N-514 TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20044A8111990-06-27027 June 1990 Comment Opposing Closure of Lpdr of Rockford Public Library ML20245J0191989-04-14014 April 1989 Comment Re Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20214X1871987-06-11011 June 1987 Order Imposing Civil Monetary Penalty in Amount of $25,000 Based on Four Severity Level III Violations Noted During 860721-0808 Insp ML20205Q1711987-04-0202 April 1987 Order Imposing Civil Monetary Penalty in Amount of $25,000. App Re Evaluations & Conclusions Encl IR 05000812/20100311987-02-26026 February 1987 Order Imposing Civil Monetary Penalty in Amount of $100,000 Based on Violations Noted During Insps on 850812-1031 ML20210T7321987-02-11011 February 1987 Unexecuted Amend 6 to Indemnity Agreement B-97 Substituting Item 3 of Attachment to Indemnity Agreement in Entirety W/ Listed License Numbers,Effective 870130 ML20209J3251987-01-30030 January 1987 Transcript of 870130 Commission Discussion/Possible Vote on Full Power OL for Facility.Pp 1-72.Supporting Viewgraphs Encl ML20213G4381986-10-24024 October 1986 Unexecuted Amend 5 to Indemnity Agreement B-97,substituting Item 3 of Attachment to Agreement in Entirety W/Listed License Numbers,Effective on 861106 ML20211B0841986-08-0505 August 1986 Transcript of 860805 Meeting Between Region Iii,Computer Interference Elimination & Util in Redmond,Wa Re Plant as-built Drawing Review.Pp 1-200 IR 05000506/20070221986-05-0202 May 1986 Order Imposing Civil Monetary Penalty in Amount of $25,000 for Violations Noted During Insp on 850506-0722.Violations Noted:Failure to Establish Radiological Safety Procedures & to Adequately Train Personnel ML20138C7301985-12-0909 December 1985 Order Imposing Civil Penalty in Amount of $25,000 Per 850606 Notice of Violation & Proposed Imposition of Civil Penalty.Licensee May Request Hearing within 30 Days of Date of Order ML20205E8741985-10-28028 October 1985 Exemption from GDC 4 of 10CFR50,App a Requirement to Install Protective Devices Associated W/Postulated Pipe Breaks Primary Coolant Sys.Topical Rept Evaluation Encl ML20102A2981985-01-0707 January 1985 Petition Requesting Aslab Grant Intervenor Appeal & Order Further Hearings on Safety of Plant ML20099L2581984-11-27027 November 1984 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20099G5381984-11-23023 November 1984 Supplemental Appeal Brief in Response to Intervenor 841106 Supplemental Brief on Appeal & in Support of ASLB 841016 Supplemental Initial Decision Authorizing Issuance of Ol. Certificate of Svc Encl ML20100K0411984-11-22022 November 1984 Submits Concerns Re Safety of Local Residents in Event of Accident & Excessively High Cost of Projected Operation of Facility ML20107H7841984-11-0606 November 1984 Supplemental Brief on Appeal of ASLB 841016 Supplemental Initial Decision Granting Authority for Issuance of Ol. Decision Should Be Reversed.Certificate of Svc Encl ML20140E4081984-10-31031 October 1984 Executed Amend 1 to Indemnity Agreement B-97,deleting Items 2A & 3 in Entirety ML20098G8841984-10-0202 October 1984 Joint Statement of RW Manz & W Faires Re Findings 3-11 Through 3-17 of NRC 830930 Integrated Design Insp Rept. Certificate of Svc Encl ML20098G8681984-10-0202 October 1984 Answer to Intervenor Motion to Reopen Record Re Bechtel Independent Design Review.Motion Should Be Denied ML20098G8901984-10-0202 October 1984 Joint Statement of Kj Green & RW Hooks Re Integrated Design Insp ML20098G8911984-10-0202 October 1984 Joint Statement of Cw Dick & EM Hughes Re Independent Design Insp ML20098G8821984-10-0101 October 1984 Affidavit of Kj Green Re Integrated Design Insp Concerning Mechanical Engineering Work ML20098G8741984-10-0101 October 1984 Affidavit of Br Shelton Re Integrated Design Insp ML20098G8881984-09-29029 September 1984 Affidavit of RW Hooks Re Integrated Design Insp Concerning Structural Design ML20098G8831984-09-28028 September 1984 Affidavit of W Faires Re Findings 3-15 & 3-16 of NRC 830930 Integrated Design Insp Rept ML20098G8811984-09-28028 September 1984 Affidavit of Cw Dick Re Independent Design Review ML20098G8791984-09-28028 September 1984 Affidavit of RP Tuetken Re Readiness for Fuel Loading ML20098G8781984-09-28028 September 1984 Affidavit of RW Manz Concerning Findings 3-11 Through 3-14 & 3-17 of NRC 830930 Integrated Design Insp Re Westinghouse ML20098G8871984-09-28028 September 1984 Affidavit of EM Hughes Re Idvp ML20098G8851984-09-27027 September 1984 Affidavit of Rl Heumann Re Costs of Delay in Startup & Operation of Unit 1 ML20098E2371984-09-24024 September 1984 Reply to Intervenor 840918 Proposed Supplemental Initial Decision.Certificate of Svc Encl ML20097E7221984-09-13013 September 1984 Agreed Motion for Time Extension Until 841101 to File Petition for Hearing Re Emergency Planning Commitment W ML20097C5311984-09-12012 September 1984 Motion to Reopen Record to Include Plant Design as Issue. Supporting Documentation & Certificate of Svc Encl ML20097B7791984-09-10010 September 1984 Proposed Supplemental Initial Decision Re Reinsp Program. Certificate of Svc Encl ML20096A6391984-08-30030 August 1984 Rebuttal Testimony of RW Hooks Re Validity of Info in Attachment 7 to Stokes Testimony Concerning Design Assumption for Plant.Stokes Info Inapplicable to Plant. Related Correspondence ML20096A6191984-08-30030 August 1984 Rebuttal Testimony of B Erler Re Stokes Allegations Concerning Evaluations of Discrepancies in Calculated Actual Stress Performed by Sargent & Lundy.Related Correspondence ML20096A6261984-08-30030 August 1984 Summary of Rebuttal Testimony & Testimony of ML Somsag, Eb Branch,D Demoss,Mr Frankel,Bf Maurer & Jk Buchanan Re Plant QC Inspector Reinsp Program & C Stokes Allegations Re Welds.Related Correspondence ML20096A6441984-08-28028 August 1984 Notice of Withdrawal of Appearance in Proceeding.Related Correspondence ML20112D5271984-08-24024 August 1984 Applicant Exhibit A-R-4,consisting of Feb 1984 Rept on Bryon QC Inspector Reinsp Program ML20112D5031984-08-24024 August 1984 Applicant Exhibit A-R-5,consisting of June 1984 Suppl to Rept on Bryon QC Inspector Reinsp Program ML20112D7441984-08-23023 August 1984 Intervenor Exhibit I-R-1,consisting of Undated List of Teutken Safety Category Insp Types ML20112D7511984-08-21021 August 1984 Staff Exhibit S-R-1,consisting of 840813 Instruction for Walkdown of Cable Tray Hanger Connection Welds ML20112D4641984-08-21021 August 1984 Intervenor Exhibit I-R-11,consisting of Undated Chronological Date Listing of Util Responses to Interrogatory 12.VA Judson to Mi Miller Re Interrogatory 12 & Supplemental Responses Encl 1999-03-02
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
't In The Matten of )
COMMONWEALTH EDISON COMPANY Docket Nos. 50-454 OL
) 50-455 OL
-)
(Byron Nuclear Power Station, )
Units 1 & 2) ) ,
AMENDMENT AND CONSOLIDATION OF DAARE/ SAFE CONTENTION 3 AND ROCKFORD LEAGUE OF WOMEN VOTER'S CONTENTIONS 19 AND 108 The Emergency Plans 'for the Byron Station contains the -
fallowing defects which will prohibit the Atomic Licensing and Safety Board from making the findings of fact required by 10 CFR Sections 50.47 (a), 50 57- (a) (3) (1), and 50 57 (a) (6):
- 1. In violation of 10 CFR Section 50.47 (b) (10), the l evacuation plans for public and private schools within the EPZ do not provide for the evacuation of students within si period of time which will minimize
..mo _
Inter alia, 88 .their exposure to ionizing radiation.
on tv " -
tha pl'ans do not adequately address the fact that l is these schools lack the communication systems neces-g gg J w<
$g sary to initiate and coordinate an evacuations no
- that they lack a sufficient number of buses and
2-support personnel to conduct a safe evacuation
) that they cannot coordinate their efforts during an evacuation in order to render mutual aid to each others and that there is no reliable means of notifying school administrators that an evacuation should be conducted.
L. In violation of 10 CFR Section 50.47 (b) (10).
Commonwealth Edison's " Evacuation Time Estimates for the Plume Exposure Pathway Emergency Planning Zone of the Byron Nuclear Generating Station" does not conform to NUREG 0654, Appendix 4 and will not provide accurate or useful guidelines for the choice of protective actions during an emergency because the study:
i (a) uses fall clous transient population figures (b) does not indicate all of the actual assumptions which underlie the time estimates:
l (c) does not address the relative significance of alternative assumptions:
(d) does not make evacuation time estimates for each E[iYYtb facility on an individual basis
, . , . ( e) does not consider the impact of peak.
populations, including behavioral aspects:
(f) does not make any substantial recommenda-l
) tions for actions that could be taken to significantly improve evacuation times (g) does not contain comments from the
. - . . . ... . , m o w-- y - - + -
their review of a draft time estimate J study (h) does not translate population data into auto-owning and transportation-dependent groups:
(i) does not give attention to special services required by households not owning autos (j) does not describe the means of transpor-tation available to each /pecial facility:
l (k) does not use site weather characteristics as presented in the FSAR l
(1) falsely claims to have obtained mobilization
! and loading times for special facilities
from administrators of those facilities; (m) incorrectly assumes that IFRA Byron, Revision 0 has made adequate provisions for the evacuation of special facilities and the general populace; and (n) makes further assumptions which contradict IPRA Byron, Revision 0, and the Byron Annex to the GSEP.
'3 In violation of 10 CFR Section 50.47 (b) (12), the emergency, planning for the ingestion exposure EPZ
- of the Byron Station does not sufficiently address the fact that there are inadequate medical facilities
,to provide the required bed space for an evacuations that there is an insufficient number of medical and j '
! para-medical personnel to render medical assistance during an evacuations that there are insufficient
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procedures for the screening, treatment, and
)
isolation of persons sustaining radiological injuries: and that there is an insufficient number of materials, supplies, equipment, and vehicles to provide for the transportation of injured persons during a radiological disaster.
- 4. In violation of 10 CFR 50.47 (b) (10) the emergency planning for the Byron Station fails to include an adequate means for protecting those persons re- .
quiring special transportation considerations. The proposed evacuation plans state that local school districts, the Oregon police, and the Oregon Ambulance Service will provide transportation for ,
homebound and nursing home patients despite the fact that all three of these organizations are already l burdened with responsibilities which overestimate l their capabilities and overtax their resources.
\
Furthermore, comprehensive lists of shut-in populations and their specific transportation needs are not available: there has been no analysis conducted regarding the feasability of sheltering or a pro-tactive action. There are no provisions for
' relocation of those whose medic ~al needs require y- hospitalization. There is'no differentiation.of host facilities,to meet specific needs of individual populations. There are no provisions in the plans ,
concerning the method to be used in distributing
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radioprotective drugs to mobility impaired indi-viduals. .
l t . - , . _ _ . . . _ _ _ . _ , . _ _ _ . . _ . _ _ . _ _ . _ . ._ _ _ _ . , _ _ _ _ _ _ . . _ _ . . _ . _ _ . _ _ _ _ _ . . _ _ . , _ _ _ _ _ - . . _ . -
5 In violation of 10 CFR 50.47 (b) (1), (2), (3),
and (12), the emergency planning for the Byron
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St'ation and the Byron Station EPZ does not include written agreements identifying the emergency measures to be provided and mutually accepted criteria for the implementation of procedures by support
. organizations having an emergency response role either inside or outside the EPZ.
- 6. In violation of 10 CFR 50.47 (b) (15), radiological emergency response training has not been provided i
to all response organizations and individuals who may be called upon to assist in an emergency, viz.,
directors and coordinators of the response organiza-tions first aid and rescue personnel: local support services personnels medical support personnels and those offsite organizations having. mutual aid agreements with local agencies.
7 In violation of 10 CFR 50.47 (b) (7), emergency I
planning for the Byron Station has yet to include adequate dissemination.of accurate information to the public regarding the effects of radiation,
[
protective measures to be taken during an emergency, or the special needs of'the handicapped nor has adequater assurance been presented as to the method, manner, and text of t'ho publications to be posted for the information of the transient populations.
- 8. In violation of 10 CFR 50.47 (b) (10), emergency plans are incapable of offoring sufficient guidance
, for the choice of protective actions during an -
emergency since applicant and. state planners have
)
yet to adequately determine the local protection afforded (in dose reduction) by various protective measures including evacuation, sheltering, and radioprotective prophylaxis.
9 In violation of 10 CFR 50.47 (b) (5) and (6),
emergency planning for the Byron Station does not adeqdately provide for notification or communication of and between emergency response organizations and personnel so as to assure that communications necessary to timely and prompt evacuation can be implemented effectively.
- 10. The emergency planning relies too heavily upon
, volunteer personnel to effect an evacuation. The emergency plans fail to indicate the number of volunteer personnel who are necessary or available to perform the responsibilities assigned to them.
l Furthermore, the plans do nots (a) assess the availability of volunteers during hours in which many are employed I
outside the EP3s l
(b) take into consideration inevitable personal conflicts in the responses of
.. . : , .. volunteers who have families in the EPZ:
and (c) give consideration to the possibility
.) that some volunteers who might perform well in non-radiological disasters might refuse to participate in a radiological
- 11. The plan has not been revised on the basis of the
) results obtained from evacuation exercises.
- 12. Emergency planning beyond the EPZ is a recognition of the residual risk associated with major reactor accidents whose consequences could exceed those associated with so-called design basis events.
Emergency plans proposed by the state and the applicant for the ten mile EPZ fail to meet the criteria of NUREG-0654 (p. 12) by failing to provide a substantial base for and analysis of expansion of responsible efforts in the event that this proved necessary due to worst-weather conditions and/or a core melt with breach of containment.
13 In violation of 10 CFR 50.47 (b) (1), the emergency plans, specific tasks, and responsibilities have been formulated without sufficient communication between planning officials and primary and support response organizations so as to enable said organi-zations to fulfill their assigned roles.
The Byron emergency planning and the current preperation for
(
the August, 1983, evacuation test exercise do not comply with 10 CFR 50.47 (b) and NUREG 0654, as outlined above.
These failures to comply render it impossible for the ASLB to,makelthe findings of fact required by 10 CFR 50.47 (a),
50 57 (a) (3) (1) and 50 57 (a) (6) at the operating license stage. DAARE/ SAFE and the Rockford League of Women Voters
)) contend that a comprehensive reassessment of local evacuation needs, capabilities, and resources must be conducted with local input sufficient to render the plan capable of meeting
the specific needs of the intended evacuees.
, J By Diane Chavez DAARE/ SAFE Representative
~
and By7ct him Pat Morrison, League of Women Voters of Rockford Representative February 21, 1983 l
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