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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 ML20096A0641992-04-28028 April 1992 Comment Supporting NRC Elimination of Requirements Important to Safety from 57FR4166,dtd 920205 ML20059A9401990-08-0808 August 1990 Settlement Agreement.* Agreement Between Nrc,Rl Dickherber & Util ML20056B2031990-08-0101 August 1990 Memorandum & Order (Approving Settlement Agreement & Terminating Proceedings).* Settlement Agreement Between Rl Dickherber & NRC Approved & Proceedings Terminated Per 10CFR2.203.W/Certificate of Svc.Served on 900803 ML20056A4011990-07-30030 July 1990 Joint Motion of NRC Staff & Rl Dickherber for Approval of Settlement Agreement.* Requests That ASLB Approve Settlement Agreement & Upon Receipt of Signed Original Thereof,Enter Order & Terminate Proceeding.W/Certificate of Svc ML20055F5861990-07-0202 July 1990 Memorandum & Order (Further Deferral of Filing Dates).* Joint Motion of Rl Dickherber & NRC Filed on 900628 to Defer Filing Date for Responses to Answer of Rl Dickherber Until 900730 Granted.W/Certificate of Svc.Served on 900703 ML20055C2871990-02-23023 February 1990 Order Suspending License,Effective Immediately & Order to Show Cause Why License Should Not Be Revoked ML20011E4861990-02-0707 February 1990 Comment on Proposed Rule 10CFR71 Re Compatibility of Pu Air Transport Regulations W/Iaea Stds.Supports EEI-UWASTE/NUMARC Comments to Be Provided to NRC by 900209 ML20248D2831989-09-28028 September 1989 Notice of Appearance.* Advises That Author Will Enter Appearance in Proceeding on Behalf of Nrc.W/Certificate of Svc ML20247Q2661989-09-26026 September 1989 Establishment of Aslb.* Board Will Comprise of Mb Margulies, Chairman & Oh Paris & Fj Shon,Members.W/Certificate of Svc. Served on 890926 B13367, Comment on Proposed Rules 10CFR30,40,50,60,70,72 & 150 Re Preserving Free Flow of Info to Commission.Nrc Made Wise Choice to Not Impose Any Obligation on Private Parties to Include Affirmative Statement in Employment Agreements1989-09-20020 September 1989 Comment on Proposed Rules 10CFR30,40,50,60,70,72 & 150 Re Preserving Free Flow of Info to Commission.Nrc Made Wise Choice to Not Impose Any Obligation on Private Parties to Include Affirmative Statement in Employment Agreements ML20248C8751989-09-13013 September 1989 Response to Order Modifying Licenses & Order to Show Cause Why Licenses Should Not Be Revoked.* Requests Hearing on Issues,Including Funds for Equipment.Supporting Info Encl ML20246C7141989-08-18018 August 1989 Order to Show Cause Why CPs CPEP-1 & CPEP-2 Should Not Be Revoked & Requiring Licensee to Notify Commission at Least 30 Days Before Taking Possession of Any Classified Equipment ML20245G0721989-08-0303 August 1989 Comment on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. Recommends That NRC Recommendation on Trust Agreement Wording Be Deleted or NRC Should Grandfather Existing Trusts Such as for Plants ML20248B6201989-08-0202 August 1989 Comments on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. NRC Should Permit Use of Potential Tax Refund as Source of Decommissioning Funds ELV-00674, Comment Opposing Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites. 10CFR72.6(c) Should Be Revised to Provide for Storage W/O ISFSI Requirement1989-07-0707 July 1989 Comment Opposing Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites. 10CFR72.6(c) Should Be Revised to Provide for Storage W/O ISFSI Requirement ML20246K4801989-07-0505 July 1989 Comment Opposing Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ELV-00679, Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Agrees W/Numarc Comments Provided to NRC on 8906261989-07-0505 July 1989 Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Agrees W/Numarc Comments Provided to NRC on 890626 ML20246D8811989-06-30030 June 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20245D2481989-06-16016 June 1989 Comment on Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites. NRC Must Consider Provision in Rule to Permit Indiscriminate Storage of Spent Fuel at Reactors ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246A0091989-05-0303 May 1989 Order Imposing Civil Monetary Penalty in Amount of $75,000, Based on Util Lack of Demonstration That AMP Splices Environmentally Qualified ML20245J0191989-04-14014 April 1989 Comment Re Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20244B3241989-04-10010 April 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20247A2971989-04-0404 April 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246M2771989-03-20020 March 1989 Decision.* Affirms Board Decision LBP-89-05 Granting CP & OL to Licensee.Certificate of Svc Encl.Served on 890321 ML20246N9471989-03-0808 March 1989 Comment on Proposed Rev 3 to Reg Guide 1.9 Re Selection Design,Qualification,Testing & Reliability of Diesel Generator Units Used as Onsite Electric Power Sys at Nuclear Power Plants B13113, Comment on Proposed Rev 3 to Reg Guide 1.9, Selection, Design,Qualification,Testing & Reliability of Diesel Generator Units.... Util Recommends Rule Be Revised to Incorporate Addl Flexibility in Considering Age of Diesel1989-03-0808 March 1989 Comment on Proposed Rev 3 to Reg Guide 1.9, Selection, Design,Qualification,Testing & Reliability of Diesel Generator Units.... Util Recommends Rule Be Revised to Incorporate Addl Flexibility in Considering Age of Diesel ML20236B4641989-03-0808 March 1989 Comments on Proposed Rev 3 to Reg Guide 1.9, Selection, Design,Qualification,Testing & Reliability of Diesel Generator Units Used as Onsite Electric Power Sys at Nuclear Power Plants. Reg Guide Does Not Provide Flexibility 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 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 B13136, Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule on Maint Will Not Improve Maint in Plants Nor Improve Safety or Reliability of Plants.Proposed Rule Much Too Vague1989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule on Maint Will Not Improve Maint in Plants Nor Improve Safety or Reliability of Plants.Proposed Rule Much Too Vague ML20235V8541989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Util Committed to Goal of Achieving Improved Reliability & Safety Through Better Maint 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 JPN-89-008, Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants1989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20235S8371989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235T3581989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint Programs for Nuclear Power Plants.Util Endorses Comments Filed by NUMARC & Nuclear Util Backfitting & Reform Group.Rule Fails to Provide Basis for Determining Effective Maint Program 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 ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20235T7391989-02-23023 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 1999-03-02
[Table view] Category:PLEADINGS
MONTHYEARML20056A4011990-07-30030 July 1990 Joint Motion of NRC Staff & Rl Dickherber for Approval of Settlement Agreement.* Requests That ASLB Approve Settlement Agreement & Upon Receipt of Signed Original Thereof,Enter Order & Terminate Proceeding.W/Certificate of Svc ML20248C8751989-09-13013 September 1989 Response to Order Modifying Licenses & Order to Show Cause Why Licenses Should Not Be Revoked.* Requests Hearing on Issues,Including Funds for Equipment.Supporting Info Encl ML20151E2551988-07-15015 July 1988 Opposition of City of Clyde,Oh to Application to Amend Plants OLs to Suspend Antitrust Conditions ML20236B8541987-07-21021 July 1987 Motion on Notification of Meetings,Establishment of Seismic Review Committee & Govt Exam of Design Calculations.* Motion Undated ML20215D6741987-06-12012 June 1987 Suppl 4 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.Ucs Reply to Responses from NRC & B&W Owners Group.* Certificate of Svc Encl ML20210C4191987-04-0606 April 1987 Principal Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Petition Should Be Denied ML20205F2911987-03-23023 March 1987 Suppl 3 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Requests That Listed Names Be Added to List in Paragraph 1 of 870210 Petition ML20210C2691987-03-0606 March 1987 Initial Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Request for Immediate Suspension Should Be Summarily Denied.W/Certificate of Svc ML20211F5091987-02-20020 February 1987 Suppl 2 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Lists Names to Be Added to 870210 Petition & Corrects Address for Save Our State from Radwaste ML20210N4861987-02-10010 February 1987 Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W Co.* OLs & CPs for Facilities Should Be Suspended Until Listed NRC Actions Taken ML20199G7671986-06-11011 June 1986 Request for Admission That Technical Review Team Found Lack of Awareness on Part of QC Electrical Inspectors to Document in Insp Repts Witnessing of Installation of Nuclear heat-shrinkable Cable Insulation Sleeves ML20137L5911985-09-10010 September 1985 Response Opposing Jf Doherty 850611 Petition for Show Cause Order Requesting NRC to Institute Consolidated Proceeding Per 10CFR2.202.Certificate of Svc Encl ML20126A3531985-06-11011 June 1985 Petition/Request for Order to Show Cause Why Plants Should Not Be Shut Down Until CRD Mechanisms Inspected ML20205Q7741984-09-19019 September 1984 Reply to Case Answer to Applicant 840806 Motion for Summary Disposition Re Consideration of Friction Forces in Design of Pipe Supports.Affidavit of Jc Finneran & Certificate of Svc Encl.Related Info Encl ML20205Q7791984-05-0101 May 1984 Response to Applicant 840411 Motion for Authorization to Issue License to Load Fuel & Conduct Certain Precritical Testing.Affidavit of Gn Lauber & Certificate of Svc Encl ML20083G0531984-01-0606 January 1984 Addendum to Petition for Emergency Relief Per 10CFR2.206 Re Integrated Leak Rate Testing.All Documentation Re Integrated Leak Rate Tests Must Be Made Public ML20079H6901983-12-14014 December 1983 Petition Per 10CFR2.206 to Defer Judgment or Decision on Proposed Course of Action for Completion of Facility Until Suppl Created for Record of J Keppler 831215 Briefing.W/O Encls ML20083C2771983-11-29029 November 1983 Petition for Emergency Relief Re Primary Containment Leak Rate at Facilities.Unsafe Condition Exists Re Ability of Primary Containment to Fulfill Design Function ML20083C2741983-11-29029 November 1983 Petition for Emergency Relief Concerning Unsafe Conditions Re Integrated Leak Rate Testing for Us Nuclear Power Reactor Containments.Severe Errors,Defects & Loopholes Exist in Current Methodology ML20082M6711983-11-29029 November 1983 Petition for Emergency Relief Concerning Unsafe Conditions Re Integrated Leak Rate Testing of Us Nuclear Power Reactor Containments.Severe Errors,Defects & Loopholes Exist in Current Methodology 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 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 ML20052D1081982-05-0404 May 1982 Response to City of Brownsville,Tx Filing Per Administrative Law Judge 820415 Order.Settlement License Conditions Should Be Approved & Made Effective Immediately.Certificate of Svc Encl ML20050E2831982-04-0909 April 1982 Motion for Extension of Time to File Statement of Position & for Prehearing Conference Date.Certificate of Svc Encl ML20041F6671982-03-10010 March 1982 Withdrawal of 780828 Request That Commission Institute Section 105a Proceeding Against Util.Fl Cities Has Settled All Differences W/Util.Certificate of Svc Encl ML20041E2101982-03-0505 March 1982 Motion to Enter Stipulated Protective Order to Govern Util Production of Proprietary & Confidential Info. Certificate of Svc Encl ML20071H9771982-02-0808 February 1982 Petition for Review of Director'S Decision 81-21 Denying 10CFR2.206 Petition to Shut Down Reactors for Steam Generator Insp.Certificate of Svc Encl ML20040G3571982-02-0101 February 1982 Request for Extension of Time to Answer Contention 1. Transcript of Special Prehearing Conference Needed to Complete Evaluation.Contention 2 Being Withdrawn.Related Correspondence ML20041F8751981-12-0303 December 1981 Motion for Independent Audit of Plant Const 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 ML19346A3791981-06-12012 June 1981 Answer Opposing Quad-City Alliance for Safe Energy & Survival,Citizens for Safe Energy & Older Americans for Elderly Rights Petitions to Intervene.Contentions Irrelevant.W/Notices of Appearance & Certificate of Svc 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 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 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 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 1990-07-30
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, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter Of :
COMMONWEALTH EDISON CO., et al.
- Docket Nos. 50-237 50-249 (Amendments to Operating Licenses) :
50-254 50-265 NATURAL RESOURCES DEFENSE COUNCIL AND CITIZENS FOR A BETTER ENVIRONMENT'S STATEMENT OF CONTENTIONS Contention 1 - The proposed action violates the National Environmental Policy Act because it is a commitment to a program which precedes the completion of the required programmatic impact statements.
- a. NRC and DOE havs announced a proposed program for storage of spent fuel away from the reactors where the spent fuel is generated and have agreed to prepare and are preparing programmatic impact statements under NEPA
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to evaluate that p_cposed action.
- b. Included among the options examined is consideration of transshipment of spent fuel between reactors as proposed here.
- c. Approval of this proposed action by applicant would permit the adoption of the transshipment option for it would forestall development of preferable alternative plans to meet the spent fuel storage program, particularly expansion of spent fuel storage at each plant site, and 790118oJ5T
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by the application of the sunk cost doctrine (New Encland Coalition on Nuclear Pollution v. NRC, Dkt. Nos. 77-1219, 77-1306, 77-1342, 78-1013 (decided August 22, 1978),
F.2d (1st Cir. 1978)) tend to foreclose the prefer-able options.
Contention 2 - Approval of the proposed actions would violate NEPA because it is a major federal action for which no impact statement has been prepared,
- a. The quantity of spent fuel to be moved, the number of casks, trucks and shipments required, the number of members of the public and workers which will be and could be exposed to radiation due to routine, accidental or intentional releases from handling and shipping spent fuel, the alleged dollar and environmental benefits of the proposed action over allowing the reactors to be shut down, the increased risks to the health and safety
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of the public living in the vicinity of the facilities and along the shipment route without any comparable increase in benefits to that public, the foreclosing of the environmentally preferable option of expanded storage of spent fuel at each plant site, and the long-term implications of another spent fuel storage half-measure which allows increasing nuclear wastes without a solution and without progress toward a solution for the permanent and safe storage of such waste are all factors which make approval of the proposed action a major federal action with significant impact on the environment.
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Contention 3 - There has been no adequate analysis of the alter-natives to the proposed action.
- a. The alternative of using any of the reactors as a last on, first off, plant to reduce spent fuel discharge requirements is not considered.
- b. There are not technological or economic disadvantages to expanding spent fuel pool capacity at each plant site if it is assumed that all spent fuel will be stored there until it is shipped to a legally approved permanent storage facility for nuclear wastes. This option will reduce the risks of routine, accidental and intentional releases of radioactivity,
- c. Applicant has not fully utilized all of the potential it has to store spent fuel in existing pools at each plant.
Contention 4 - The proposed action increases the exposure to radiation of workers and the general public beyond what is ALARA.
- a. ALARA can be achieved by on-site expansion of spent fuel -
pool storage capacity at each plant site, including 9
building another spent fuel pool.
- b. The residual health risks which remain even if the pre-sent NRC regulations on exposures to workers are met are major costs of the proposed action which tip the balance against the proposed action. The health hazards include increased genetic mutations which affect the entire population directly and increased somatic effects which
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affect the workers directly and the general population indirectly as lost productivity, higher health costs and the loss of family or friends. Recent evidence by Drs.
Mancuso and Bross indicates that the dangers from low levels of radiation are greater than originally assumed by the BEIR Committee. The NRC regulations set levels for workers 10 times higher than acceptable even if the BEIR Committee calculation of health effects is used.
See Natural Resources Defense Council Petition to Amend 10 CFR 20.101 Exposure of Individuals to Radiation in Restricted Areas, October 29, 1975, and Supplement to Petition and Request for Hearings, November 4, 1977.
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Contention 5 - Applicant overstates the need for action at this time by using the one-core discharge capacity reserve standard as if it were a requirement where in fact it is not a requirement of NRC regulations.
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- a. Either applicant should be bound to comply with the one-core discharge capacity standard or it should have to demonstrate on a cost / benefit basis that holding that capability is more valuable than the costs of shipment off-site of one core of spent fuel.
- b. Numerous utilities now are in violation of this standard.
See ERDA 77-25, p. 7; Spent Fuel Storage Study (1976-1986) prepared by AIF (April 1977), p. 11.
Contention 6 - Applicant has failed to disclose any information sufficient to determine whether shipment of spent fuel between the
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plant sites will be vulnerable to sabotage, hijacking or other malevolent acts and whether this represents a serious risk to public health and safety.
- a. A credible threat of an attack against such a shipment would be 3 insiders and 15 outsiders, the latter armed with sophisticated rapid fire automatic weapons, explo-sives, large shell mortars and armored vehicles.
- b. There is no known basis for assuring detection of a threat of this size until it has materialized.
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- c. Unless applicant is taking safety precautions far beyond those routinely used in the nuclear industry, it will be unable to prevent a malevolent act involving spent fuel in transit.
- d. A successful malevolent act directed against a spent fuel shipment could expose thousands of persons to fatal levels of radiation, could severely pollute water supplies and land areas, force long-term evacuation of .
major areas and create a threat of all these events unless certain unacceptable political and/or other demands are met.
Contention 7 - The application provides insufficient information for consideration of the proposed action.
- a. There is no ER.
B. There is no analysis of additional emergcncy planning required by the transportation of spent fuel between the reactor sites.
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Contention 8 - The proposed action violates the standards for
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consideration of proposed spent fuel handling prior to completion of the GEIS on spent fuel handling.
- a. The proposed action has no utility unless it is assumed that in the near future an AFR will be built to accomo-date spent fuel from the reactors. Thus the proposed action will tend to increase pressure for such action.
- b. The proposed action will tend to foreclose the option of expanding spent fuel storage capacity at each plant site to handle their own spent fuel by committing economic resources and time to a measure whose own ,
utility is as a holding action pending construction of an AFR.
Contention 9 - The alleged need for immediate action on the proposal is grossly overstated and no additional spent fuel storage space is required prior to the middle 1980s at the earliest.
- a. Expansion of spent fuel capacity at Dresden was found -
by the Staff to be sufficient to assure full core dis-charge capability through 1984 and normal refueling through 1987 for the Dresden units without transshipment.
Environmental Impact Appraisal Relating to Modification To The Spent Fuel Pool (Jan. 30, 1978) p. 3.
- b. Expansicn of spent fuel capacity at Quad Cities was found by the Staff to be sufficient to assure full core discharge capability through 1985 and normal refueling through 1988 for the Quad Cities units without trans-shipment. Environmental Impact Appraisal Relating to
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Modification To The Spent Fuel Pool (Jan. 30, 1978) p. 3.
Respectfully submitted, Anthony Z. Roisman Natural Resources Defense Council 917 15th Street, N.W.
Washington, D.C. 20005 (202)737-5000 Dated: December 6, 1978
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BEFORE THE NUCLEAR REGULATORY COMMISSION OF THE UNITED STATES OF AMERICA AFFIDAVIT I, SUSAN N. SEKULER, an attorney, hereby certify the following in support of the foregoing Petitioner's Contentions.
- 1. That I am an Assistant Attorney General with the Environmental Control Division of the Office of the Attorney General of Illinois;
- 2. That I am of counscl for the State of Illinois in the matter of Con'.monwealth Edison Co., Docket Nos. 50-237/249/254/265.
- 3. That all facts alleged in the Petitioner's Contentions attached hereto are true to the best of my knowledge and belief.
SUSAN N. SEKULER SUBSCRIBED AND SWORN TO BEFORE ME THIS 29th DAY OF DECEMBER, 1978.
NOTARY PUBLIC
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