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Category:INTERVENTION PETITIONS
MONTHYEARML20106D3131992-10-0505 October 1992 Suppl to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SM Hasan.* Board Should Admit Petitioner Contention 1 for Listed Reasons.W/Certificate of Svc ML20099J8751992-08-14014 August 1992 TU Electric Answer to Petition for Intervention & Request for Hearings by Dows.* Petition to Intervene Should Not Be Accepted for Filing Because Petition Contains Untrue & Scandalous Allegations.Certificate of Svc & Other Info Encl ML20099H1071992-08-0606 August 1992 TU Electric Answer to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SMA Hasan.* Petition Should Be Denied Re Macktal & Hasan Since Neither Showed Standing to Intervene.W/Notices & Certificate of Svc ML20114A9331992-07-28028 July 1992 Petition of SL Dow Dba Disposable Workers of Comanche Peak Ses & RM Dow for Intervention & Request for Hearings.* Licensee Seeks to Extend Expiration Date of CP for Period of Addl 3 Yrs.W/Certificate of Svc ML20099H0921992-07-27027 July 1992 Petition to Intervene & Request for Hearing of Bi Orr, Di Orr,Jj Macktal & SMA Hasan.* Requests That Hearing Be Convened to Determine Whether Good Cause Exists for Extension of CP Completion Date.Certificate of Svc Encl ML19325D6381989-10-20020 October 1989 Request to Continue Proceedings & Petition to Intervene by Citizens for Fair Util Regulation & Greater Fort Worth Group of Lone Star Chapter of Sierra Club.* Petitioners Have Requisite Interest to Establish Standing ML20154G7591988-09-12012 September 1988 Citizen for Fair Util Regulation (Cfur) First Suppl to 880811 Request for Hearing & Petition for Leave to Intervene.* Cfur 880811 Request for Hearing & Petition for Leave to Intervene Should Be Granted.W/Certificate of Svc ML20153D1361988-08-26026 August 1988 Applicant Answer to Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* Request Should Be Denied Based on Inability to Develop Allegations. Certificate of Svc Encl ML20207E5261988-08-11011 August 1988 Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* ML20150E2131988-07-13013 July 1988 Citizens Audit Motion for Stay & Motion for Sua Sponte Relief.* Requests Time to Review Concerns of J Doe & for Relief for Listed Items in Order to Act as Intervenor in Proceeding.W/Certificate of Svc ML20150E2071988-07-11011 July 1988 Second Group of Individual Residents Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released.W/Certificate of Svc ML20150E3301988-07-11011 July 1988 Greater Fort Worth Sierra Club Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That Relief for Listed Items Be Granted Sua Sponte to Address Complex safety-related Issues.W/Certificate of Svc ML20150D5371988-07-0808 July 1988 Individual Residents Motion to Intervene & for Sua Sponte Relief.* Listed Petitioners Request Relief That All Settlement Agreements Re Joint Stipulation Be Publicly Released & 880713 Hearing Be Extended.W/Certificate of Svc ML20150D5141988-07-0808 July 1988 Citizens for Fair Util Regulation Motion to Intervene & for Sua Sponte Relief.* Petitioner Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released & That 880713 Hearing Be Continued for 60 Days ML20211H3921986-10-31031 October 1986 Consolidated Intervenors Motion to Dismiss Pending Appeal as Moot &/Or for Lack of Jurisdiction & to Immediately Dissolve Order Staying Discovery.Certificate of Svc Encl ML20210N2811986-09-30030 September 1986 Consolidated Intervenors Amended Contentions 1 & 2 Re Reinsp Efforts & Const Delay.Certificate of Svc Encl ML20203G4731986-04-18018 April 1986 Answer Opposing M Gregory & Case 860407 Petition for Leave to Intervene Re NRC 860210 Order Extending Completion Date for CPPR-126 to 880801.Contentions Fail to Satisfy 10CFR2.714(b) Criteria.W/Certificate of Svc ML20203D5681986-04-17017 April 1986 Permittees Answer to Petitions to Intervene of Case & M Gregory.Certificate of Svc Encl ML20199K7401986-04-0707 April 1986 Petition of M Gregory for Leave to Intervene Re Improper Const & Invalid Util Justification for Delay.Affidavit of M Gregory & Certificate of Svc Encl.Served on 860409 ML20202G4751986-04-0707 April 1986 Petition of Case for Leave to Intervene & Request for Hearing.Certificate of Svc & Jl Howard Affidavit Encl ML20151U6791986-02-0505 February 1986 Response to Ha Stiner Request to Intervene late.Late-filed Petition Should Be Denied.W/Certificate of Svc ML20137Q0151985-12-0202 December 1985 Answer Supporting Applicant 851105 Petition for Directed Certification of ASLB 851031 Order for Review.Order Adversely Affects Basic Structure of OL Proceeding. Certificate of Svc Encl ML20086B0001983-11-0808 November 1983 Response Opposing Citizens Concerned About Nuclear Power 831020 Motion for New Contention Re Alleged Instability of Soil Beneath Site.Good Cause Not Shown for Late Filing. Certificate of Svc Encl ML20081G7771983-11-0303 November 1983 Answer Opposing Citizens Assoc for Sound Energy (Case) 831024 Motions to Add New Contention & for Discovery Re Hot Functional Test Results.Case Should Have Begun to Pursue Subj Matter by 830513 ML20081A4291983-10-20020 October 1983 Motion for New Contention Re Instability of Soil Beneath Facility.Recently Submitted Deficiency Rept Provides Sufficient Evidence to Warrant Inquiry.Certificate of Svc Encl ML20080S3261983-10-13013 October 1983 Motion to Add Proposed Contention 26 Re Hot Functional Test, Motion for Discovery & Offer of Proof.Certificate of Svc Encl ML20024A5251983-06-12012 June 1983 Answer Opposing State of Tx 830609 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Proposed Contention Lacks Requisite Specificity & Bases for late-filed Contentions.Certificate of Svc Encl ML20024A0311983-06-0909 June 1983 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Somervell County & Hood County Commitment,Expertise & Resources Inadequate to Adopt & Implement Emergency Plans.Certificate of Svc Encl ML20071P7651983-05-30030 May 1983 Suppl to 830318 Motion to Admit New Contention on Util Financial Qualifications.Adequate Grounds for Waiver of Rule of Financial Qualifications Review Established & Good Cause Shown for Late Filing ML20072S7011983-04-0404 April 1983 Response Opposing Citizens Concerned About Nuclear Power 830318 Motion for Admission of New Contention on Financial Qualifications.Citizens Failed to Comply W/Procedural Requirements.Certificate of Svc Encl ML20072P9581983-03-29029 March 1983 Corrections to Citizens Concerned About Nuclear Power 830322 Motion for New Contention.Certificate of Svc Encl ML20069F5561983-03-18018 March 1983 Motion for New Contention Re Util Lack of Financial Qualifications to Complete & Operate Plant Safely.Puc of Tx Denied Util Rate Increase Request & City of Austin,Tx Sued Util for Refund of Investment.Certificate of Svc Encl ML20063H0351982-08-26026 August 1982 Motion to Add New Contention 26 Re Apparent Applicant Violation of 10CFR50,App A,Criterion 1,requiring Possession of Design Criteria for Pipe Support Sys & Components at Site.Certificate of Svc Encl ML19340D3001980-11-25025 November 1980 Supplemental Response,Submitted to Ferc,On DOJ 800917 Petition to Intervene.Doj Position Is Irrelevant to Approval of Supplemental Offer of Settlement & Should Be Denied W/O Prejudice.Supporting Info & Certificate of Svc Encl ML19338E9471980-09-17017 September 1980 Petition for Leave to Intervene ML19331C5331980-08-13013 August 1980 Answer in Support of Tx Border Cooperatives 800731 Petition to Intervene.Good Cause Shown for Late Filing.No Other Means Exist to Protect Interests.Intervention Would Assist in Development of Sound Record.Certificate of Svc Encl ML19338C4101980-08-13013 August 1980 Response in Support of Tx Border Cooperatives Petition to Intervene.Nexus Requirement for Util Operations Affected by Dc Interconnection Satisfied.Untimeliness Is Measured by Necessity to Preserve Rights.Certificate of Svc Encl ML19330C5831980-08-0707 August 1980 Response in Opposition to Tx Border Cooperative Petition to Intervene.Good Cause Not Shown.Cooperative Interests Can Be Protected in Pending FERC Hearing.Petitioners Failed to Show Participation Would Assist in Development of Record ML19330B5911980-07-31031 July 1980 Petition for Untimely Intervention.Petitioners Had Reason to Believe That Interests Would Be Adequately Protected by Other Utils,But Significant Developments Created Concerns Re Dc Interconnections.Certificate of Svc Encl ML19331D9051980-07-31031 July 1980 Response to Applicants,Central & South West Corp & City of Austin,Tx Objections to Tx Border Cooperative Petition to Intervene.Asserts Interests Under LBP-74-13.Urges Full Party Participation.W/Certificate of Svc ML19309H6591980-04-10010 April 1980 Statement of Position in Opposition to Citizens Association for Sound Energy Proposed Contentions.Intervenor Failed to Submit Allegations Warranting Admission in Proceeding. Proposed Contentions & Certificate of Svc Encl ML19323B5551980-04-10010 April 1980 Statement of Position in Opposition to Tx Association of Community Organizations for Reform Now Proposed Contentions. Intervenor Failed to Submit Allegations Warranting Admission in Proceeding.Certificate of Svc Encl ML19344D5751980-03-25025 March 1980 Response in Opposition to Public Utils Board of City of Brownsville,Tx 800317 Comments Requesting Admittance as Party in Consolidated Proceeding.Statement of Interest Untimely & Vague.Certificate of Svc Encl 1992-08-06
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20106D3131992-10-0505 October 1992 Suppl to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SM Hasan.* Board Should Admit Petitioner Contention 1 for Listed Reasons.W/Certificate of Svc ML20099J8751992-08-14014 August 1992 TU Electric Answer to Petition for Intervention & Request for Hearings by Dows.* Petition to Intervene Should Not Be Accepted for Filing Because Petition Contains Untrue & Scandalous Allegations.Certificate of Svc & Other Info Encl ML20099H1071992-08-0606 August 1992 TU Electric Answer to Petition to Intervene & Request for Hearing of Bi Orr,Di Orr,Jj Macktal & SMA Hasan.* Petition Should Be Denied Re Macktal & Hasan Since Neither Showed Standing to Intervene.W/Notices & Certificate of Svc ML20114A9331992-07-28028 July 1992 Petition of SL Dow Dba Disposable Workers of Comanche Peak Ses & RM Dow for Intervention & Request for Hearings.* Licensee Seeks to Extend Expiration Date of CP for Period of Addl 3 Yrs.W/Certificate of Svc ML20099H0921992-07-27027 July 1992 Petition to Intervene & Request for Hearing of Bi Orr, Di Orr,Jj Macktal & SMA Hasan.* Requests That Hearing Be Convened to Determine Whether Good Cause Exists for Extension of CP Completion Date.Certificate of Svc Encl ML19325D6381989-10-20020 October 1989 Request to Continue Proceedings & Petition to Intervene by Citizens for Fair Util Regulation & Greater Fort Worth Group of Lone Star Chapter of Sierra Club.* Petitioners Have Requisite Interest to Establish Standing ML20154G7591988-09-12012 September 1988 Citizen for Fair Util Regulation (Cfur) First Suppl to 880811 Request for Hearing & Petition for Leave to Intervene.* Cfur 880811 Request for Hearing & Petition for Leave to Intervene Should Be Granted.W/Certificate of Svc ML20153D1361988-08-26026 August 1988 Applicant Answer to Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* Request Should Be Denied Based on Inability to Develop Allegations. Certificate of Svc Encl ML20207E5261988-08-11011 August 1988 Request for Hearing & Petition for Leave to Intervene by Citizens for Fair Util Regulation.* ML20150E2131988-07-13013 July 1988 Citizens Audit Motion for Stay & Motion for Sua Sponte Relief.* Requests Time to Review Concerns of J Doe & for Relief for Listed Items in Order to Act as Intervenor in Proceeding.W/Certificate of Svc ML20150E2071988-07-11011 July 1988 Second Group of Individual Residents Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released.W/Certificate of Svc ML20150E3301988-07-11011 July 1988 Greater Fort Worth Sierra Club Motion for Leave to Intervene & Motion for Sua Sponte Relief.* Requests That Relief for Listed Items Be Granted Sua Sponte to Address Complex safety-related Issues.W/Certificate of Svc ML20150D5371988-07-0808 July 1988 Individual Residents Motion to Intervene & for Sua Sponte Relief.* Listed Petitioners Request Relief That All Settlement Agreements Re Joint Stipulation Be Publicly Released & 880713 Hearing Be Extended.W/Certificate of Svc ML20150D5141988-07-0808 July 1988 Citizens for Fair Util Regulation Motion to Intervene & for Sua Sponte Relief.* Petitioner Requests That All Settlement Agreements Re Joint Stipulation Be Ordered Publicly Released & That 880713 Hearing Be Continued for 60 Days ML20211H3921986-10-31031 October 1986 Consolidated Intervenors Motion to Dismiss Pending Appeal as Moot &/Or for Lack of Jurisdiction & to Immediately Dissolve Order Staying Discovery.Certificate of Svc Encl ML20210N2811986-09-30030 September 1986 Consolidated Intervenors Amended Contentions 1 & 2 Re Reinsp Efforts & Const Delay.Certificate of Svc Encl ML20203G4731986-04-18018 April 1986 Answer Opposing M Gregory & Case 860407 Petition for Leave to Intervene Re NRC 860210 Order Extending Completion Date for CPPR-126 to 880801.Contentions Fail to Satisfy 10CFR2.714(b) Criteria.W/Certificate of Svc ML20203D5681986-04-17017 April 1986 Permittees Answer to Petitions to Intervene of Case & M Gregory.Certificate of Svc Encl ML20199K7401986-04-0707 April 1986 Petition of M Gregory for Leave to Intervene Re Improper Const & Invalid Util Justification for Delay.Affidavit of M Gregory & Certificate of Svc Encl.Served on 860409 ML20202G4751986-04-0707 April 1986 Petition of Case for Leave to Intervene & Request for Hearing.Certificate of Svc & Jl Howard Affidavit Encl ML20151U6791986-02-0505 February 1986 Response to Ha Stiner Request to Intervene late.Late-filed Petition Should Be Denied.W/Certificate of Svc ML20137Q0151985-12-0202 December 1985 Answer Supporting Applicant 851105 Petition for Directed Certification of ASLB 851031 Order for Review.Order Adversely Affects Basic Structure of OL Proceeding. Certificate of Svc Encl ML20086B0001983-11-0808 November 1983 Response Opposing Citizens Concerned About Nuclear Power 831020 Motion for New Contention Re Alleged Instability of Soil Beneath Site.Good Cause Not Shown for Late Filing. Certificate of Svc Encl ML20081G7771983-11-0303 November 1983 Answer Opposing Citizens Assoc for Sound Energy (Case) 831024 Motions to Add New Contention & for Discovery Re Hot Functional Test Results.Case Should Have Begun to Pursue Subj Matter by 830513 ML20081A4291983-10-20020 October 1983 Motion for New Contention Re Instability of Soil Beneath Facility.Recently Submitted Deficiency Rept Provides Sufficient Evidence to Warrant Inquiry.Certificate of Svc Encl ML20080S3261983-10-13013 October 1983 Motion to Add Proposed Contention 26 Re Hot Functional Test, Motion for Discovery & Offer of Proof.Certificate of Svc Encl ML20024A5251983-06-12012 June 1983 Answer Opposing State of Tx 830609 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Proposed Contention Lacks Requisite Specificity & Bases for late-filed Contentions.Certificate of Svc Encl ML20024A0311983-06-0909 June 1983 Motion for Admission of New Contention Re Adequacy of Emergency Planning.Somervell County & Hood County Commitment,Expertise & Resources Inadequate to Adopt & Implement Emergency Plans.Certificate of Svc Encl ML20071P7651983-05-30030 May 1983 Suppl to 830318 Motion to Admit New Contention on Util Financial Qualifications.Adequate Grounds for Waiver of Rule of Financial Qualifications Review Established & Good Cause Shown for Late Filing ML20072S7011983-04-0404 April 1983 Response Opposing Citizens Concerned About Nuclear Power 830318 Motion for Admission of New Contention on Financial Qualifications.Citizens Failed to Comply W/Procedural Requirements.Certificate of Svc Encl ML20072P9581983-03-29029 March 1983 Corrections to Citizens Concerned About Nuclear Power 830322 Motion for New Contention.Certificate of Svc Encl ML20069F5561983-03-18018 March 1983 Motion for New Contention Re Util Lack of Financial Qualifications to Complete & Operate Plant Safely.Puc of Tx Denied Util Rate Increase Request & City of Austin,Tx Sued Util for Refund of Investment.Certificate of Svc Encl ML20063H0351982-08-26026 August 1982 Motion to Add New Contention 26 Re Apparent Applicant Violation of 10CFR50,App A,Criterion 1,requiring Possession of Design Criteria for Pipe Support Sys & Components at Site.Certificate of Svc Encl ML19340D3001980-11-25025 November 1980 Supplemental Response,Submitted to Ferc,On DOJ 800917 Petition to Intervene.Doj Position Is Irrelevant to Approval of Supplemental Offer of Settlement & Should Be Denied W/O Prejudice.Supporting Info & Certificate of Svc Encl ML19338E9471980-09-17017 September 1980 Petition for Leave to Intervene ML19331C5331980-08-13013 August 1980 Answer in Support of Tx Border Cooperatives 800731 Petition to Intervene.Good Cause Shown for Late Filing.No Other Means Exist to Protect Interests.Intervention Would Assist in Development of Sound Record.Certificate of Svc Encl ML19338C4101980-08-13013 August 1980 Response in Support of Tx Border Cooperatives Petition to Intervene.Nexus Requirement for Util Operations Affected by Dc Interconnection Satisfied.Untimeliness Is Measured by Necessity to Preserve Rights.Certificate of Svc Encl ML19330C5831980-08-0707 August 1980 Response in Opposition to Tx Border Cooperative Petition to Intervene.Good Cause Not Shown.Cooperative Interests Can Be Protected in Pending FERC Hearing.Petitioners Failed to Show Participation Would Assist in Development of Record ML19330B5911980-07-31031 July 1980 Petition for Untimely Intervention.Petitioners Had Reason to Believe That Interests Would Be Adequately Protected by Other Utils,But Significant Developments Created Concerns Re Dc Interconnections.Certificate of Svc Encl ML19331D9051980-07-31031 July 1980 Response to Applicants,Central & South West Corp & City of Austin,Tx Objections to Tx Border Cooperative Petition to Intervene.Asserts Interests Under LBP-74-13.Urges Full Party Participation.W/Certificate of Svc ML19309H6591980-04-10010 April 1980 Statement of Position in Opposition to Citizens Association for Sound Energy Proposed Contentions.Intervenor Failed to Submit Allegations Warranting Admission in Proceeding. Proposed Contentions & Certificate of Svc Encl ML19323B5551980-04-10010 April 1980 Statement of Position in Opposition to Tx Association of Community Organizations for Reform Now Proposed Contentions. Intervenor Failed to Submit Allegations Warranting Admission in Proceeding.Certificate of Svc Encl ML19344D5751980-03-25025 March 1980 Response in Opposition to Public Utils Board of City of Brownsville,Tx 800317 Comments Requesting Admittance as Party in Consolidated Proceeding.Statement of Interest Untimely & Vague.Certificate of Svc Encl 1992-08-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206H2221999-05-0404 May 1999 Exemption from Requirements of 10CFR50.60 That Would Allow STP Nuclear Operating Co to Apply ASME Code Case N-514 for Determining Plant Cold Overpressurization Mitigation Sys Pressure Setpoint.Commission Grants Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20195C7541998-11-0505 November 1998 Order Approving Application Re Proposed Corporate Merger of Central & South West Corp & American Electric Power Co,Inc.Commission Approves Application Re Merger Agreement Between Csw & Aep ML20155H5511998-11-0202 November 1998 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20248K5051998-06-0909 June 1998 Confirmatory Order Modifying License (Effective Immediately).Answer for Request for Hearing Shall Not Stay Immediate Effectiveness of Order ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys NOC-AE-000109, Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20137U3531997-04-0808 April 1997 Order Approving Application Re Formation of Operating Company & Transfer of Operating Authority ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste 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 ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20092C3911993-11-15015 November 1993 Partially Deleted Response of Rl Balcom to Demand for Info ML20092C4031993-11-15015 November 1993 Partially Deleted Response of Hl&P to Demand for Info ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20044D3311993-05-0404 May 1993 Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied 1999-06-18
[Table view] |
Text
_ _
Y ~.
UNITED STATES OF AMERICA ,
NUCLEAR REGULATORY COMMISSION
, In the Matter of )
)
- HOUSTON LIGHTING & POWER CO., ) Docket Nos. 50-498A !
e__t a_l .
) 50-499A ,
)
(South Texas Project, Units )
1 and 2) )
- )
l TEXAS UTILITIES GENERATING ) Docket No. 50-445A COMPANY, - --et al. ) 50-446A
) t (Comanche Peak Steam Electric )
Station, Units 1 and 2) .) l RESP _ON_SE OF TEXAS UT_ILITIES GEN.ERATING COMPANY {
TO THE REQUEST OF THE PUBLIC UTILITIES BOARD OF THE CITY OF ;
BROWNSVILLE, TEXAS THAT IT BE ADMITTED TO THE COMANCHE PEAK PROCEEDING AS A PARTY j i
i On March 17, 1980, the Public Utilities Board of the City [
of Brownsville, Texas (" PUB") filed its " Comments. . . On :
Consolidation of Proceedings" pursuant to the March 7, 1980 l 4 j Licensing Board request. Although PUB took no position on the issue of consolidation, it did request that its right to " cross-examine any witness as to any matter relevant to the South !
Texas proceeding, regardless of which 'p' arty is sponsoring the !
witness" be preserved if the proceedings were consolidated l (Comments at pp. 1-2). PUB also requested, in the alternative, f that if the Board should rule that cross-examination should be j restricted in a consolidated proceeding, that Brownsville be l
I admitted as a party to the Comanche Peak proceeding.
TUGCO believes that the request should be considered moot, in that it has no objection to cross-examination by PUB on ;
i 8004250 0fh0i
any relevant matter (including allegations of concerted action) and subject to the Rules of Practice, as stated more generally in our filing of March 17, 1980 regarding consolidation at page
- 3. Since Brownsville seeks only the right to cross-examinr, and did not timely seek all the attributes of party status, that should end the matter.
However, construing PUB's alternative request for party status as a petition for intervention Texas Utilities Generating !
Company ("TUGCO") opposes it on the grounds that it is untimely,
' that it fails to satisfy the requirements for the acceptance of untimely petitions for intervention under 10 CFR S2.714 (a) (1) ,
and that it fails to " set forth with particularity the interest of the petitioner in the proceeding" as required by S4 714 (a) (2) .
Since it is clear that this " petition for intervention" is untimely, this Licensing Board must consider the five factors set forth in 10 CFR S2.714 (a) (1) to determine whether the non- :
timely filing should be entertained. See Nuclear Fuel Services, Inc. (West Valley Reprocessing Plant) , CLI-75-4,1 NRC 273 (1975). The first of these factors is a requirement that
" good cause" be shown for the late filing. The only reason which PUB offers for its late petition is that it had thought i
the issue of a full right of cross-examination had been fully l
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resolved at the December 5, 1978 prehearing conference and that ,
it was not until the March 7, 1980 hearing that it became aware j that it might not be allowed the full scope of cross-examination that it desired to protect its interest in the South Texas proceeding.
1 TUGCO asserts that this reason hardly constitutes a good cause for an untimely ~ petition for intervention in the Comanche Peak proceeding. The transcript of the December 5, 1978 prehearing conference reveals that the hearing board admonished Brownsville {
l to intervene then or not at all. j
Mr. Glaser: If you have any idea about intervening, you better do it now, because I can assure you you j will have one vote against you if you file a petition ;
to intervene in the middle of a case, and that vote ;
will be mine. (Tr. at p. 62). l In circumstances where no good excuse is tendered for the tardiness of a filing, the petitioners' demonstration on the other factors in 10 CFR S2.714 (a) (1) must be particularly strong.
Duke Power Company (Perkins Nuclear Station, Units 1, 2 and 3) , -
ALAB-431, 6 NRC 460, 462 (1977). Brownsville has not addressed I
these factors, so there is nothing for TUGCO to respond to.
i PUB claimed its interest in the Comanche Peak proceeding was set forth in its " Supplemental Petition For Leave To
Intervene," dated June 28, 1978, which it incorporated by {
reference, and which related to TUGCO in the vaguest of ways.
This statement of interest completely fails to satisfy the requirements of 10 CFR S2.714 (a) (2) that the interest of the l
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y rw-y---+- -- w &
i petitioner must be set out with particularity. Indeed, the interest alleged is so vague that TUGCO is not quite sure exactly ,
what it is supposed to respond to.
Since those filing tardy petitions "have a heavy burden 1 of persuasion" Florida Power & Light Company (St. Lucie :
Plant, Unit No. 2), CLI-78-12, 7 NRC 939, 943 (1978), and since for the foregoing reasons it is clear that PUB has failed to satisfy this burden, TUGCO respectfully requests this Licensing Board to deny PUB's request for intervention in the Comanche Peak proceeding.
Respectfully submitted, L 0 avnnu'o C. Dennis Ahearn
., Couase3 for Texas Utilities Gener ating Company DEBEVOlSE & LIBERMAN 1200 Seventeenth Street, N.W.
Washington, D.C. 20036 :
(202) 857-9800 1
March 25, 1980
. ;
UNITED STATES OF AMERICA L NUCLEAR REGULATORY COMMISSION In the Matter of )
} i HOUSTON LIGHTING AND POWER CO., ) Docket Nos. 50-498A i
) 50-499A r
_e _t _a _l .
)
(South Texas Project, Units )
1 and 2) 1
) !
TEXAS UTILITIES GENERATING ) Docket Nos. 50-445A COMPANY, ~et al. ) 50-446A
~
) i i
(Comanche Peak Steen Electric )
Station, Units 1 and 2) ) , j l
CERTIFICATE OF SERVICE f I hereby certify that copies of " Response Of Texas Utilities Generating Company To The Request Of The Public Utilities Board !
Of The City Of Brownsville, Texas That It Be Admitted To The !
Comanche Peak Proceeding As A arty" in the above captioned matters,.were served upon the .ollcwing persons this 26th day of March, .1980.lar deposit in the United States mail, first :
class postage prepaid, and hand-delivered to those persons l indicated by an asterisk. (
- Marshall E. Miller Esq. Mr. Jerome D. Saltzman p U.S. Nuclear Regulatory Chief, Antitrust and Commission Indemnity Group i Washington, D.C. 20555 Nuclear Reactor Regulation (
U.S. Nuclear Regulatory !
- Michael L. Glaser, Esq. Commission l 1150 17th Street, N.W. Washington, D.C. 20555 i Washington, D.C. 20036 l J. Irion Worsham, Esq. l j
- Sheldon J. Wolfe, Esq. Merlyn D. Sampels, Esq. !
U.S. Nuclear Regulatory Spencer C. Relyea, Esq. i Commission Wo rsham, Forsythe & Sampels l Washington, D.C. 20555 2001 Bryan Tower, Suite 2500 l Dallas, Texas 75201 ;
Atomic Safety and Licensing !
Appeal Board Panel Jon C. Wood, Esq. '
U,.S. Nuclear Regulatory W. Roger Wilson, Esq.
Commission Matthews, Nowlin, Macfarlane & l Washington, D.C. 20555 Barrett l
- 1500 Alamo National Building i Chase R. Stephens ,
San Antonio, Texas 78205 Docketing and Service Branch i U.S. Nuclear Regulatory Dick Terrell Brown, Esq. )
Commission 800 Milam Building Washington, D.C. 20555 San Antonio, Texas 78205 i l l
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i Charles G. Thrash, Jr., Esq. Don R. Butler, Esq.
E.W. Barnett, Esq. 211 East Seventh Street i Theodore F. Weiss, Esq. Austin, Texas 78701 l J. Gregory Copeland, Esq. ;
Baker & Botts
! 3000 One Shell Plaza l
Houston, Texas 77002 Jerry L. Harris, Esq.
i Steven R. Hunsicker, Esq. Richard C. Balough, Esq.
l R.Gordon Gooch, Esq. City of Austin g John P. Mathis, Esq. P.O. Box 1088 r
- Baker & Botts Austin, Texas 78767 ;
I 1701 Pennsylvania Avenue, N.W.
. Washington, D.C. 20006 Robert Lowenstein, Esq. [
J.A. Bouknight, Jr., Esq. [
. Roy P. Lessy, Jr., Esq. William J. Franklin, Esq. i Michael B. Blume, Esq. Douglas G. Green, Esq.
- Fredric D. Chanania, Esq. Lowenstein, Newman, Reis, [
Ann P. Hodgdon, Esq. Axelrad and Toll U.S. Nuclea" Regulatory 1025 Connecticut Avenue, N.W.
!, Commission Washington, D.C. 20036 -
Washington, D.C. 20555 [
John W. Davidson, Esq.
Roff Hardy Sawtelle, Goode, Davidson &
Chairman and Chief Executive Tioilo Officer 1100 San Antonio Savings Bldg.
Central Power and Light Company San Antonio, Texas 78205 P.O. Box 2121
Corpus Christi, Texas 78403 Douglas F. John, Esq. i
- McDermott, Will and Emery i I
Mr. Perry G. Brittain 1101 Connecticut Ave., N.W.
President Suite 1201 -
Texas Utilities Generating Washington, D.C. 20036 !
Company
( 2001 Bryan Tower Bill D. St. Clair, Esq.
Dallas, Texas 75201 Morgan Hunter, Esq. ;
McGinnis, Lockridge & Kilgore l R.L. Hancock, Director Fifth Floor, Texas State !
City of Austin Electric Utility Bank Building I P.O. Box 1096' 900 Congress Avenue ,
l Austin, Texas 78767 Austin, Texas 78701 j G.W. Oprea, Jr.
Executive Vice President Houston Lighting & Power , David M. Stahl, Esq.
Company Isham, Lincoln & Beale P.O. Box 1700 1120 Connecticut Avenue, N.W.
Houston,. Texas 77001_ Suite 325 Washington, D.C. 20036 Susan B. Cyphert, Esq.
l Frederick H. Parmenter, Esq.
l David A. Dopsovic, Esq.
Robert Fabirkant, Esq.
Nancy Luque, Esq. -
Kenneth M. Glazier, Esq.
U.S.. Department of Justice Antitrust Division P.O. Box 14141 Washington, D.C. 20044 .
Sara Welling, Esq. Mr. G. Holman King l Michael I. Miller, Esq. West Texas Utilities Co.
James A. Carney, Esq. P.O. Box 841 ;
Isham, Lincoln & Beale Abilene, Texas 79604 f One First National Plaza Suite 4200 Kevin B. Pratt, Esq. l Chicago, Illinois 60603 Attorney General's Office State of Texas Don H. Davidson P.O. Box 12548 f City Manager Austin, Texas 78711 i City of Austin ,
P.O. Box 1088 Frederick H. Ritts, Esq. ;
Austin, Texas 78767 William H. Burchette, Esq. l Northcutt Ely W. S. Robson Watergate 600 Building ;
General Manager Washington, D.C. 20037 ;
South Texas Electric ;
Cooperative, Inc.
Route 6, Building 102 i Victoria Regional Airport l Victoria, Texas 77901 ;
Robert C. McDiarmid, Esq. A !
Robert Jablon, Esq. L h ,
Marc Poirier, Esq. l Spiegel & McDiarmid i I
2600 Virginia Ave., N.W. Ste. 312 Washington,. D.C. 20037 l W.N. Woolsey, Esq. ;
Dyer and Redford 1030 Petroleum Tower Corpus Christi, Texas 78474 i
Donald M. Clements Gulf States Utilities Company Post Office Box 2951 Beaumont, Texas 77704 !
I Marc J. Wetterhahn, Esq.
Robert M. Rader, Esq.
Conner & Moore 1747 Pennsylvania Avenue, N.W.
Washington, D.C. 20006 Mr. William C. Price
! Central Power & Light Co.
l P.O. Box 2121 Corpus Christi, Texas 78403 l
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