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05000352/LER-1985-080, Motions to Reopen Record on Contentions V-3a & 3b & to Stay Operation of Unit 1.LER 85-80 Reported Potential Threat in Possible Failure of Cooling for Control Structure Affecting Safe Shutdown of Plant12 November 1985Motions to Reopen Record on Contentions V-3a & 3b & to Stay Operation of Unit 1.LER 85-80 Reported Potential Threat in Possible Failure of Cooling for Control Structure Affecting Safe Shutdown of PlantSafe Shutdown
ML20023A83715 October 1982Answer Opposing Del-Aware Unlimited,Inc Revised Proposed Contention V-24.Subj of Contention Previously Litigated, Rejected by ASLB & Irrelevant.Certificate of Svc Encl
ML20023D76931 May 1983Response Supporting NRC Reply to ASLB 830516 Order Re Use of PRA & Subsequent risk-related Documents.Certificate of Svc & Rk Weatherwax Prof Qualifications EnclProbabilistic Risk Assessment
ML20024A08710 June 1983Response to NRC Use of Facility PRA & Limerick Ecology Action Response to ASLB 830516 Memorandum & Order Confirming Schedules.Certificate of Svc EnclProbabilistic Risk Assessment
ML20024D6111 August 1983Motion for Extension Until 830808 to Obtain & Serve Subpoenas to Potential Experts.Granted by ASLB on 830803
ML20027C58727 September 1982Motion to Strike Eh Bourguard Testimony Re Impacts of Intake of Biological Species.No Expertise Shown by Witness Re Subj Matter of Testimony.Related Correspondence
ML20027C58827 September 1982Motion for Change of Hearing Schedule,For Consolidation All Water Cooling Issues & to Strike NRC Testimony.Aslb Should Certify Issue of Inclusion to Commission.Certificate of Svc Encl.Related Correspondence
ML20027C59027 September 1982Motion to Strike MT Masnik Testimony Due to Prejudice,Bias & Fact That Testimony Not Based on Fes.Related Correspondence
ML20027C59127 September 1982Brief Supporting Motion for Suspension of Proceedings & Consolidation or to Strike NRC Testimony.Issuance of Initial Decision Before Full NEPA Consideration Will Substantially Prejudice Del-Aware Interests & Public in General
ML20027C59327 September 1982Motion to Strike J Lear Testimony.Testimony Shows Extreme Bias & Goes Beyond Witness Statement of Purpose.Related Correspondence
ML20040C12422 January 1982Response Opposing W Lochstet Matl Filed Subsequent to 820106-08 Prehearing Conference.Petitioner Has Failed to Demonstrate Standing.Certificate of Svc Encl
ML20040D79228 January 1982Motion for Extension of Time Until 820215 within Which to Reply to Memorandum of Clarification on Probabilistic Risk Assessment Contentions for Limerick Ecology Action & Keystone Alliance.Certificate of Svc EnclProbabilistic Risk Assessment
ML20040E9871 February 1982Response Opposing ASLB Order to Show Cause Why J Shniper Should Not Be Dismissed for Default.Petitioner Failed to Realize Response to Objections Must Be Filed Due to Qualified Acceptance by NRC of One Contention
ML20040F9974 February 1982Response to Sh Lewis 820128 Ltr,To Corrections in Transcript & to Fr Romano 820129 Statement
ML20052A26923 April 1982Response to Licensee 820419 Suggestion of Mootness Re Probabilistic Risk Assessment.Chairman Palladino Informal Remarks Before ANS Do Not Constitute Official Commission Policy & ASLB Cannot Take Notice.Certificate of Svc EnclProbabilistic Risk Assessment
ML20052E5326 May 1982Answer Concurring in NRC 820426 Motion to Reject Proposed Contentions II-1,III-1 & in part,III-2,since Need for Power & Alternative Sources Issues Will No Longer Be Considered in OL Hearings.Certificate of Svc Encl
ML20052F2524 May 1982Response Opposing Applicant 820419 Suggestion of Mootness. as Matter of Law,Chairman Palladino Comments Bear No Weight Before Aslb.Nrc Specifically Directed That Probabilistic Risk Assessment Be Used in OL Review.W/Certificate of SvcProbabilistic Risk Assessment
ML20052F3106 May 1982Memorandum Opposing NRC Motion to Reject Cepa Contention II-1.Environ Aspects of Economic Issues Can Still Be Litigated.Certificate of Svc Encl
ML20054C63219 April 1982Suggestion of Mootness of Probabilistic Risk Assessment Contentions.Chairman Palladino Statement Confirms Commission Policy That Probabilistic Risk Assessment Analysis Has No Place in Licensing Hearings.Certificate of Svc EnclProbabilistic Risk Assessment
ML20054F66911 June 1982Request for Reconsideration of Denial of Contention on Electromagnetic Pulse Or,Alternatively,Request for Certification to Commission.Informal Discovery Should Be Allowed on Contention IV-2.Certificate of Svc EnclScram Discharge Volume
ML20054G21817 June 1982Objections to ASLB 820601 Special Prehearing Conference Order.Aslb Lacks Jurisdiction to Stay Const of Point Pleasant Pumping Station or Bradshaw Reservoir.Certificate of Svc Encl.Related CorrespondenceSafe Shutdown
Probabilistic Risk Assessment
Affidavit
ML20054G31416 June 1982Joint Petition for Leave to File Fuel Cycle Contention Based on New Info.Decision of 820427 in NRDC Vs NRC Raises Question About Validity of Table S-3 Rule.Certificate of Svc Encl
ML20054H29716 June 1982Request for Reconsideration of 820601 Special Prehearing Conference Order Denying Contentions.Misinterpretation, Technicalities & Typographical Errors Caused Misunderstanding.Proof of Svc Encl
ML20054H53121 June 1982Request for Reconsideration of Aspects of 820601 Prehearing Order.De River Basin Commission Decision Should Not Be Regarded as Binding Re Environ Effects of Taking Water from DE River.Certificate of Svc Encl
ML20054H55817 June 1982Requests Clarification of ASLB 820601 Special Prehearing Conference Order Admitting Large Number of Contentions W/ Direction for Future Spec.Board Should Set Time Limits & Should Outline Procedure for Spec.Certificate of Svc Encl
ML20054K17729 June 1982Motion for Extension of Time to File Answer to Environ Coalition on Nuclear Power & Limerick Ecology Action,Inc 820616 Petition to File New Fuel Cycle Contention.Commission Intends to Establish Policy Guidance Soon
ML20054K61128 June 1982Request for Reconsideration of ASLB 820601 Special Prehearing Conference Requiring Expedited Hearing to Consider Environ Impacts from Changes to Point Pleasant Diversion Plan.Certificate of Svc EnclAffidavit
ML20054L2912 July 1982Request for Action Under 10CFR2.206 to Suspend or Revoke Cps.In Causing Point Pleasant Pumping Station to Be Built for Facility,Util Is Causing Const of Critical Portion of Facility W/O Cp.No Other Need Exists for Pumping Station
ML20058J7178 August 1982Motion to Compel Applicant Answers to Listed Interrogatories Re Const of Pumping Stations in DE River.Info May Lead to Relevant Evidence.Related Documentation Encl.Related Correspondence
ML20058J7278 August 1982Application for Reconsideration of ASLB 820714 Order. Decision Should Be Reversed to Hold That Federal Member of DE River Basin Commission Did Not Finally Concur in Disposition of Diversion.Certificate of Svc Encl
ML20059B03022 October 1993NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance
ML20059B11120 October 1993Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel
ML20062F65910 August 1982Opposition to Del-Aware Unlimited,Inc 820809 Application for Issuance of Subpoenas to Gm Hansler,G Pence & W Marazzo. Application to Subpoena Gm Hansler Inexcusably Late.G Pence & W Marazzo Testimony Irrelevant.Certificate of Svc EnclSafe Shutdown
Ultimate heat sink
ML20062G75910 August 1982Suppl to 820809 Motion for Order Compelling Applicant to Respond to Interrogatories.Info Requested in Interrogatory 1(d),(e) & (F) Relevant to Admitted Issues.Certificate of Svc Encl
ML20062H48212 August 1982Answer in Opposition to Del-Aware Unlimited,Inc 820721 Motion to Compel Answers to Interrogatories.Info Requested Beyond Scope of Three Admitted Contentions.W/Certificate of Svc.Related Correspondence
ML20062K58510 August 1982Motion to Quash or Modify Del-Aware Application to Take 820817 Deposition of Gm Hansler.No Individual Can Speak for Commission.If Motion for Deposition Granted,Deposition Cannot Be Scheduled Until 820830
ML20062N26515 December 1981Response Opposing Consideration of Natl Lawyers Guild Philadelphia Chapter,811203 Affidavits from Graterford Prison Inmates.Affidavits Untimely & Fail to Establish Standing.W/Certificate of Svc.Related Correspondence
ML20063A20419 August 1982Response in Opposition to Del-Aware Unlimited,Inc 820809 Request for ASLB to Reconsider 820714 Memorandum & Order Re Federal Representative Concurrence in Decision on Water Allocation.Motion Untimely.Certificate of Svc Encl
ML20063C96020 August 1982Response to Applicant Answer to Motion to Compel Answer to Interrogatories.Applicant Now Admits Availability of Max Flow at Any River Flow.Thus,Interrogatories Re River Flow Below 3,000 Cubic Ft/S Relevant.Certificate of Svc Encl
ML20063K2811 September 1982Answer Opposing Del-Aware Unlimited,Inc Supplemental & New Request for Reconsideration.Requests Untimely & W/O Merit. Requests Based on 810105 Document Which Has Been Publicly Available.Certificate of Svc EnclProbabilistic Risk Assessment
ML20064N9053 September 1982Answer Opposing Del-Aware Unlimited,Inc 820825 Motion for Approval of Petition to Amend Contention V-16c Re Water Quality.Ltrs Re Environ Impact,Public Notice & Certificate of Svc Encl
ML20065F09527 September 1982Response Opposing DE River Basin Commission Motion to Quash Subpoena.Intervenor Does Not Seek Addl Testimony from G Hansler But Believes Deposition Inadmissible.Certificate of Svc Encl.Related Correspondence
ML20065H6121 October 1982Answer Opposing Del-Aware Unlimited,Inc 820927 Motion for Mod to Hearing Schedule,For Consolidation or to Strike NRC testimony.Del-Aware Estopped from Asserting Impropriety or Illegality of ASLB Authority on Cooling Water Contentions
ML20065J1501 October 1982Response in Opposition to Del-Aware 820927 Motion to Strike Testimony of Eh Bourquard Re Design,Configuration & Const of Point Pleasant Intake.Assertions Do Not Affect Relevance of Testimony or Witness Qualifications
ML20069D09914 March 1983Request for Clarification of ASLB 830210 Order & Extension Until 830515 to Review & Comment on BNL PRA Document. Uncertainties Exist Re ASLB Expectations on PRA Contentions & NRC Review of Pra.Certificate of Svc Encl
ML20069F91022 September 1982Motion to Quash Any Subpoena Commanding DE River Basin Commission Executive Director Gm Hansler to Testify at 821004 Hearings.All Info Already Provided in Deposition. Certificate of Svc Encl.Related Correspondence
ML20069G44224 September 1982Motion to Strike Del-Aware Unlimited Testimony & Abandoned Contentions.Testimony Does Not Constitute Matl,Relevant & Reliable Evidence.Witnesses Lack Special Expertise
ML20069G49421 March 1983Exceptions to ASLB 830308 Partial Initial Decision on Supplementary Cooling Water Sys Contentions.Aslb Acted Contrary to Law in Failing to Complete Des Before Issuing Decision.Certificate of Svc Encl
ML20069G53124 September 1982Legible Exhibit 2 to Applicant Trial Brief & List of Exhibits on Supplemental Cooling Water Issues
ML20069L0438 November 1982Suppl to Petition Requesting Suspension/Revocation of CPs Per 10CFR2.202 & 2.206(a),until Environ Review of Point Pleasant Diversion Completed
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