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Category:INTERVENTION PETITIONS
MONTHYEARML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20206J9151986-06-24024 June 1986 Response to Petition of Coalition for Alternatives to Shearon Harris (Cash) for Leave to Intervene.Petition Filed on 860609,4 Yrs After Deadline.Cash Should Be Foreclosed from Participation.W/Certificate of Svc ML20205T4071986-06-0909 June 1986 Petition of Coalition for Alternatives to Shearon Harris for Leave to Intervene & Request for Hearing.Certificate of Svc Encl ML20204A4891986-05-0808 May 1986 Response to Conservation Council of North Carolina & W Eddleman Request for Admission of New Contention WB-4 Re Falsification of Exposure Records.Request Should Be Denied. Certificate of Svc & SA Browne Affidavits Encl ML20210K6981986-04-22022 April 1986 Motion for Admission of New Contention WB-4, Falsification of Exposure Records. Records Systematically Falsified to Reflect Lower Doses to Workers.Requests Opportunity to Respond If Contention Opposed ML20136J4171986-01-0303 January 1986 Answer to W Eddleman 851223 Response to Contention 57-C-57 Re Contaminated Injured Persons.Contentions Should Be Limited to Issues Heard in Guard Vs Nrc.Contention Opposed. Certificate of Svc Encl ML20137H7251985-11-22022 November 1985 Petition of Atty General of State of Nc for Leave to Intervene ML20133J2301985-10-15015 October 1985 Response in Opposition to W Eddleman Proposed Contention Re Emergency Planning Exercise.Svc List,Exercise Evaluation Rept,Operations Journal & Insp Rept 50-400/85-20 Encl ML20133K6601985-10-15015 October 1985 Response to W Eddleman 850930 Proposed Contentions Based on Emergency Planning Exercise.Certificate of Svc Encl ML20133F3661985-09-30030 September 1985 Requests That Listed Contentions Based on May 1985 Emergency Planning Exercise Be Admitted as There Are No Other Means or Parties to Protect or Represent Author Interests in Matters.Certificate of Svc Encl ML20134H2051985-08-26026 August 1985 Response in Opposition to W Eddleman Contentions Re Spill of Reactor Water.Contention Should Be Rejected for Failure to Comply w/10CFR2.714(b).Certificate of Svc Encl ML20134H2201985-08-23023 August 1985 Response to W Eddleman Proposed Contentions EM-1,EM-2 & EM-3 Re Notification of State & Local Emergency Mgt Agencies. Contentions Should Not Be Admitted Due to Lack of Requisite Basis & Specificity.Certificate of Svc Encl ML20133A0341985-07-31031 July 1985 Petition of Lh Thornburg for Leave to Intervene ML20128H4071985-05-22022 May 1985 Response Opposing W Eddleman 850429 Proffered Contentions 227-CC & 227-DD Re Allegations That Public Info Brochure Must Provide Directions to Evacuation Shelters & Title on Evacuation Routes Chart Misleading.Certificate of Svc Encl ML20117H6751985-05-0909 May 1985 Response Opposing Eddleman Proposed Contentions 227-CC & 227-DD Re Brochure Evacuation Route Chart.Contentions Constitute Editing of Brochure & Therefore Not Litigable. Certificate of Svc Encl ML20116L7211985-04-29029 April 1985 Petition Requesting Admittance of Contentions 227-CC & DD Re Brochure Additions Served on 850416 Concerning Emergency Plan Evacuation & Shelter for Settlement or Litigation. Certificate of Svc Encl ML20102A7691985-02-0606 February 1985 Response Opposing Intervenor 850118 Request for New Contention WB-3 Re Drug Use During Const.Contention Lacks Basis & Specificity & Unsubtantiated Broad Issues Delay Proceeding.Certificate of Svc Encl ML20102A4201985-02-0404 February 1985 Submits Diesel Generator Info & Contentions 178-AA & 179-AA for Litigation,In Response to Past ASLB Order ML20113D9501985-01-18018 January 1985 Request for Admission of New Contention WB-3 Re Drug & Alcohol Abuse at Const Site.News Article Supporting Contention & Certificate of Svc Encl ML20108A2281984-11-13013 November 1984 Response to Late Filed Contentions of W Eddleman & Conservation Council of North Carolina Based on Cv Vo Affidavit.Contentions WB-1-2 & 41C-414H Should Be Rejected. Certificate of Svc Encl ML20096B8661984-08-31031 August 1984 Responses to Discovery on Emergency Planning Contentions (First Set).Certificate of Svc Encl.Related Correspondence ML20096B5131984-08-28028 August 1984 Response to Eddleman 840810 Contentions on Emergency Plan Brochure.Certificate of Svc Encl ML20094N1511984-08-10010 August 1984 Eddleman Contentions on Emergency Plan Brochure, Safety Info for Shearon Harris Nuclear Power Plant. Certificate of Svc Encl ML20093G1341984-07-20020 July 1984 Response in Support of Preamble to Revised Contention 9 Re Environ Qualification of Electrical Equipment.Certificate of Svc Encl ML20092N7151984-06-29029 June 1984 Response to Eddleman Proposed Contentions 65-A & 65-B Re Questionable Structural Integrity Due to Voids from out-of-spec Sump & Improper Vibration Technique. Certificate of Svc Encl ML20092D9521984-06-19019 June 1984 Response Opposing W Eddleman 840605 Motion to Reinstate Contention 58(2d) Re Financial Qualifications.Certificate of Svc Encl ML20197H3921984-06-14014 June 1984 New Eddleman Contention 65-A Re Questionable Structural Integrity Due to Voids from out-of-spec Slump,Improper Vibration Technique & Inadequate Strength of Harris Containment Concrete ML20091M5611984-06-0505 June 1984 Withdrawal of Eddleman Contentions 85/86 & Second Motion to Reinstate Contention 58(2d) Re Financial Qualifications ML20084E1331984-04-28028 April 1984 Answer Opposing Eddleman Proposed Contentions on Emergency Response Plans.Certificate of Svc Encl ML20084D0341984-04-27027 April 1984 Response Opposing R Wilson 840413 Contentions Re State of Nc Emergency Response Plan.All Contentions Should Be Rejected. Certificate of Svc Encl ML20083P7471984-04-16016 April 1984 Motion to Require Svc of All Amends & Changes to Emergency Plan on Intervenor & Motion to Amend Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence ML20083L2951984-04-13013 April 1984 Contentions on State of Nc Emergency Response Plan. Certificate of Svc Encl ML20083M0871984-04-12012 April 1984 Contentions on Emergency Plan (Second Set).Plan Fails to Indicate Number of Volunteer Personnel Necessary or Assuredly Available to Perform Assigned Responsibilities. Certificate of Svc Encl ML20088A0771984-04-0505 April 1984 Suppl to Feb 1984 Petition for Leave to Intervene in Intervenor Charge Re State of Nc Emergency Response Plan. Certificate of Svc Encl ML20087P5211984-04-0303 April 1984 Partial Response & Contentions 157 & 151 Re Offsite Emergency Plan ML20087P8701984-04-0303 April 1984 Contentions Arising from Review of Emergency Response Plan, Per ASLB 840308 Order.Certificate of Svc Encl ML20086R9141984-02-28028 February 1984 Response Opposing W Eddleman Motion to Admit Contention 58(2d) on Financial Qualifications of co-applicants.ASLB Has No Basis or Authority to Reconsider Original Ruling on Contention & Motion Must Be Denied.Certificate of Svc Encl ML20086M8231984-02-15015 February 1984 Certification to Applicant 840118 Motion for Summary Disposition of Eddleman Contention 65.Motion Identifies One Instance of Honeycombing or Voids in Containment Base Mat, Exterior Walls & Dome.Certificate of Svc Encl ML20086N5051984-02-15015 February 1984 Motion to Withdraw Contention III Re Mgt Capability. Certificate of Svc Encl ML20080L0401984-02-13013 February 1984 Motion to Reconsider & Admit Contention 58 Re Financial Qualifications of co-applicants.Certificate of Svc Encl ML20080D2701984-02-0606 February 1984 Answer to W Eddleman Motion for Further Deferral of Parts of Contention 107 & Eddleman New Contentions & Amended Deferred Contentions in Response to NRC Ser.Aslb Should Deny Motion & Reject New SER Contentions.Certificate of Svc Encl ML20080G2391984-02-0606 February 1984 Request for Clarification & Objections to ASLB 840127 Order Re Eddleman Contentions 37A,37B & 8F2.Certificate of Svc Encl ML20079L4371984-01-23023 January 1984 Response Opposing Eddleman Contentions 169-172 Re Safety Parameter Display Sys.Contentions Wholly W/O Basis, Operate on Faulty Understanding of Sys & Should Not Be Admitted.Certificate of Svc Encl ML20079H4571984-01-17017 January 1984 New Contentions & Amended Deferred Contentions,In Response to NRC SER ML20083H5711984-01-0303 January 1984 Filing of New Contentions 169,170,171 & 172 Re Inadequate Safety Parameter Display Sys Design ML20081K0091983-11-0404 November 1983 Response to Applicant & NRC 830929 Responses to Joint Intervenors 830906 Contentions Re Security Plan.Encl Withheld (Ref 10CFR73.21).Certificate of Svc Encl ML20081E0091983-10-28028 October 1983 Response to Util Motion for Summary Disposition of Contention Ii.Veracity of All General Facts Disputed.List of Matters in Dispute on Contention II & Certificate of Svc Encl 1999-05-05
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20206J9151986-06-24024 June 1986 Response to Petition of Coalition for Alternatives to Shearon Harris (Cash) for Leave to Intervene.Petition Filed on 860609,4 Yrs After Deadline.Cash Should Be Foreclosed from Participation.W/Certificate of Svc ML20205T4071986-06-0909 June 1986 Petition of Coalition for Alternatives to Shearon Harris for Leave to Intervene & Request for Hearing.Certificate of Svc Encl ML20204A4891986-05-0808 May 1986 Response to Conservation Council of North Carolina & W Eddleman Request for Admission of New Contention WB-4 Re Falsification of Exposure Records.Request Should Be Denied. Certificate of Svc & SA Browne Affidavits Encl ML20210K6981986-04-22022 April 1986 Motion for Admission of New Contention WB-4, Falsification of Exposure Records. Records Systematically Falsified to Reflect Lower Doses to Workers.Requests Opportunity to Respond If Contention Opposed ML20136J4171986-01-0303 January 1986 Answer to W Eddleman 851223 Response to Contention 57-C-57 Re Contaminated Injured Persons.Contentions Should Be Limited to Issues Heard in Guard Vs Nrc.Contention Opposed. Certificate of Svc Encl ML20137H7251985-11-22022 November 1985 Petition of Atty General of State of Nc for Leave to Intervene ML20133J2301985-10-15015 October 1985 Response in Opposition to W Eddleman Proposed Contention Re Emergency Planning Exercise.Svc List,Exercise Evaluation Rept,Operations Journal & Insp Rept 50-400/85-20 Encl ML20133K6601985-10-15015 October 1985 Response to W Eddleman 850930 Proposed Contentions Based on Emergency Planning Exercise.Certificate of Svc Encl ML20133F3661985-09-30030 September 1985 Requests That Listed Contentions Based on May 1985 Emergency Planning Exercise Be Admitted as There Are No Other Means or Parties to Protect or Represent Author Interests in Matters.Certificate of Svc Encl ML20134H2051985-08-26026 August 1985 Response in Opposition to W Eddleman Contentions Re Spill of Reactor Water.Contention Should Be Rejected for Failure to Comply w/10CFR2.714(b).Certificate of Svc Encl ML20134H2201985-08-23023 August 1985 Response to W Eddleman Proposed Contentions EM-1,EM-2 & EM-3 Re Notification of State & Local Emergency Mgt Agencies. Contentions Should Not Be Admitted Due to Lack of Requisite Basis & Specificity.Certificate of Svc Encl ML20133A0341985-07-31031 July 1985 Petition of Lh Thornburg for Leave to Intervene ML20128H4071985-05-22022 May 1985 Response Opposing W Eddleman 850429 Proffered Contentions 227-CC & 227-DD Re Allegations That Public Info Brochure Must Provide Directions to Evacuation Shelters & Title on Evacuation Routes Chart Misleading.Certificate of Svc Encl ML20117H6751985-05-0909 May 1985 Response Opposing Eddleman Proposed Contentions 227-CC & 227-DD Re Brochure Evacuation Route Chart.Contentions Constitute Editing of Brochure & Therefore Not Litigable. Certificate of Svc Encl ML20116L7211985-04-29029 April 1985 Petition Requesting Admittance of Contentions 227-CC & DD Re Brochure Additions Served on 850416 Concerning Emergency Plan Evacuation & Shelter for Settlement or Litigation. Certificate of Svc Encl ML20102A7691985-02-0606 February 1985 Response Opposing Intervenor 850118 Request for New Contention WB-3 Re Drug Use During Const.Contention Lacks Basis & Specificity & Unsubtantiated Broad Issues Delay Proceeding.Certificate of Svc Encl ML20102A4201985-02-0404 February 1985 Submits Diesel Generator Info & Contentions 178-AA & 179-AA for Litigation,In Response to Past ASLB Order ML20113D9501985-01-18018 January 1985 Request for Admission of New Contention WB-3 Re Drug & Alcohol Abuse at Const Site.News Article Supporting Contention & Certificate of Svc Encl ML20108A2281984-11-13013 November 1984 Response to Late Filed Contentions of W Eddleman & Conservation Council of North Carolina Based on Cv Vo Affidavit.Contentions WB-1-2 & 41C-414H Should Be Rejected. Certificate of Svc Encl ML20096B8661984-08-31031 August 1984 Responses to Discovery on Emergency Planning Contentions (First Set).Certificate of Svc Encl.Related Correspondence ML20096B5131984-08-28028 August 1984 Response to Eddleman 840810 Contentions on Emergency Plan Brochure.Certificate of Svc Encl ML20094N1511984-08-10010 August 1984 Eddleman Contentions on Emergency Plan Brochure, Safety Info for Shearon Harris Nuclear Power Plant. Certificate of Svc Encl ML20093G1341984-07-20020 July 1984 Response in Support of Preamble to Revised Contention 9 Re Environ Qualification of Electrical Equipment.Certificate of Svc Encl ML20092N7151984-06-29029 June 1984 Response to Eddleman Proposed Contentions 65-A & 65-B Re Questionable Structural Integrity Due to Voids from out-of-spec Sump & Improper Vibration Technique. Certificate of Svc Encl ML20092D9521984-06-19019 June 1984 Response Opposing W Eddleman 840605 Motion to Reinstate Contention 58(2d) Re Financial Qualifications.Certificate of Svc Encl ML20197H3921984-06-14014 June 1984 New Eddleman Contention 65-A Re Questionable Structural Integrity Due to Voids from out-of-spec Slump,Improper Vibration Technique & Inadequate Strength of Harris Containment Concrete ML20091M5611984-06-0505 June 1984 Withdrawal of Eddleman Contentions 85/86 & Second Motion to Reinstate Contention 58(2d) Re Financial Qualifications ML20084E1331984-04-28028 April 1984 Answer Opposing Eddleman Proposed Contentions on Emergency Response Plans.Certificate of Svc Encl ML20084D0341984-04-27027 April 1984 Response Opposing R Wilson 840413 Contentions Re State of Nc Emergency Response Plan.All Contentions Should Be Rejected. Certificate of Svc Encl ML20083P7471984-04-16016 April 1984 Motion to Require Svc of All Amends & Changes to Emergency Plan on Intervenor & Motion to Amend Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence ML20083L2951984-04-13013 April 1984 Contentions on State of Nc Emergency Response Plan. Certificate of Svc Encl ML20083M0871984-04-12012 April 1984 Contentions on Emergency Plan (Second Set).Plan Fails to Indicate Number of Volunteer Personnel Necessary or Assuredly Available to Perform Assigned Responsibilities. Certificate of Svc Encl ML20088A0771984-04-0505 April 1984 Suppl to Feb 1984 Petition for Leave to Intervene in Intervenor Charge Re State of Nc Emergency Response Plan. Certificate of Svc Encl ML20087P5211984-04-0303 April 1984 Partial Response & Contentions 157 & 151 Re Offsite Emergency Plan ML20087P8701984-04-0303 April 1984 Contentions Arising from Review of Emergency Response Plan, Per ASLB 840308 Order.Certificate of Svc Encl ML20086R9141984-02-28028 February 1984 Response Opposing W Eddleman Motion to Admit Contention 58(2d) on Financial Qualifications of co-applicants.ASLB Has No Basis or Authority to Reconsider Original Ruling on Contention & Motion Must Be Denied.Certificate of Svc Encl ML20086M8231984-02-15015 February 1984 Certification to Applicant 840118 Motion for Summary Disposition of Eddleman Contention 65.Motion Identifies One Instance of Honeycombing or Voids in Containment Base Mat, Exterior Walls & Dome.Certificate of Svc Encl ML20086N5051984-02-15015 February 1984 Motion to Withdraw Contention III Re Mgt Capability. Certificate of Svc Encl ML20080L0401984-02-13013 February 1984 Motion to Reconsider & Admit Contention 58 Re Financial Qualifications of co-applicants.Certificate of Svc Encl ML20080D2701984-02-0606 February 1984 Answer to W Eddleman Motion for Further Deferral of Parts of Contention 107 & Eddleman New Contentions & Amended Deferred Contentions in Response to NRC Ser.Aslb Should Deny Motion & Reject New SER Contentions.Certificate of Svc Encl ML20080G2391984-02-0606 February 1984 Request for Clarification & Objections to ASLB 840127 Order Re Eddleman Contentions 37A,37B & 8F2.Certificate of Svc Encl ML20079L4371984-01-23023 January 1984 Response Opposing Eddleman Contentions 169-172 Re Safety Parameter Display Sys.Contentions Wholly W/O Basis, Operate on Faulty Understanding of Sys & Should Not Be Admitted.Certificate of Svc Encl ML20079H4571984-01-17017 January 1984 New Contentions & Amended Deferred Contentions,In Response to NRC SER ML20083H5711984-01-0303 January 1984 Filing of New Contentions 169,170,171 & 172 Re Inadequate Safety Parameter Display Sys Design ML20081K0091983-11-0404 November 1983 Response to Applicant & NRC 830929 Responses to Joint Intervenors 830906 Contentions Re Security Plan.Encl Withheld (Ref 10CFR73.21).Certificate of Svc Encl ML20081E0091983-10-28028 October 1983 Response to Util Motion for Summary Disposition of Contention Ii.Veracity of All General Facts Disputed.List of Matters in Dispute on Contention II & Certificate of Svc Encl 1999-05-05
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
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UNITED STATES OF AMERICA August 4,1983 NUCLEAR BEGULATORY COMMISSION f arcttrra 3-BEFORE THE ATOMIC SAFETY AND LICENSING BOAED s Glenn O. Bri D Dr. James H.ght Carpenter
@ 3 7903 > ;sc James L. Kelley, Chairman #
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. Pcrt In the Matter of wr yc '"
Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50-401 OL (Shearon Harris Nuclear Power Plant, )
Units 1 ar:12) ) ASLBP No. 82-h68-01
) OL New Contentions re Spent Fuel Cask Safety
(& 5 factors for each) by Wells Eddle-an Following the breakdown of settlenent negotiations on Contention 6hf on 7-29-83, Applicants' attorney O'Neill informs me that there is nothing to preclude my bringing basis matters of the following contentions before the Board. I reasonably i
l believed that a condition of the negotiations erecluded my doing l
l so earlier. This is discussed under the 5 factors. O'Neill has a different view as I now understand it, but I was only apprised of this 7/29 to the best of my recollection. I'll let him speak to that.
CONTENTION 164 Applicants and NRC Staff have not denonstrated that shipment of failed fuel (fuel that is spent, and also has leaks in the cladding) would not release unaccentable amounts of uraniun 0 0:
$N aerosols and other radioactive materials during an accident. The l 88 use of a rupture disk (an all-or-nothing device that cannot reseal) gg O
@g conpounds this risk. The health and safety of the public is Nu 0 insufficiently protected during soent fuel shionents to or from m
gg Harris if this situation is not nrevented from occurring.
ma.o BASIS: PATRAM '80, pp 646-653, details the nroduction of
uranium aerosols possibly including U 0 and U O g as well as UO2 '
7 and release of Ce-lhh, Ru-106, Cs-13h, Cs-137 and actinides, from a shipning cask containing failed PWR fuel (oxidation inside cask, aerosolization, see at 6h8-649). These are released as finely divided particulates (see 653,650, etc).
A letter from Battelle Colunbus Laboratories (Ad Hoc Comnittee to D.A. McKown, 5-19-80) describes the release of a " blackish cloud" from the cask that obscured visibility (underwater), and the release of an aerosol from the pool in which the cask was opened (despite its being opened underwater). This last event casts doubt on the idea that uraniu aerosols and other . radioactive materials would be entrained even by solid water; atmospheric release is a virtual certainty if the cask is breached.
As to the extraordinary radiotoxicity of uraniun aerosols and airborne carticulates of radioactive naterial, see e.g. Gofnan, Radiation and Hunan Health, 1981, 564-5, h92, h 88 -90. 509 , 56h , h41 -492 ,
and chapters 12-18 of the book which give background to the detailed cancer-dose estinates for lung cancer fr. rom inhaled nawticles, especially transuranics and uranium.
According tc the Battelle letter cited above, the est?-Ated decay heat for the assembly involved in nro lucing aerosols was 3 1kW (about 10,500 BTU ner hour 3. Annlicants, interrogatory resronses on 6hf, 5-27-83 at 13, say their cask can handle 40,000 BTU per hour. The Battelle letter (p.2) says that "The nature of the (aerosol release) incident could have widespread implications about dry shipments of fuel ..."
Applicants' use of a ruuture disk (they now say they are going to do that for sure, 7/29 interrogatory res-onse to 6h-lh(a),
at-page 10, compounds these troblems, for a rupture disk nay
fail in transit (and then cannot be reclosed), e.g. in a fire or crash, releasing radioactive aerosols to the environnent.
Dr. Marvin Resnikoff in The Next Nuclear Ganble (1983) 263-4,265-72, (See p. 165 re failure of rupture disks in fire) docunents these risks as exceeding URC estimates.
CP&L',has had, substan,tf al amounts of failed, fuel at Brunswick l
which they may seek to ship to Harris.
There are no restrictions in CP&L's orcrosed license (allowing possession of spent fuel at Harris) on the amount of failed fuel that may be stored at Harris. If it can be stored there, then it can be shipned there. Thus, if CP&L ships any snent fuel to Harris at all, failed fuel nay be included. I an not aware of any CP&L position against shipning failed fuel to Harris.
The abcve also applies to failed fuel fron the Robinson reactor.
Although P',fR fuel (like Robinson's) was oxidized in the incident referred to above, there is no indication it can't happen with l
B'da fuel (see PATRAM '80 at 652, " FINDINGS", "the source terr.
l was particulate spent fuel material released fron the f ailed rods.
1 i Such carticulate matter was Generated either by the normal cracking l
i of fuel cellets during overstion,"(or by heat in transit, "e-oxidation).
See aise Battelle letter (supra) at 2, " Alternative exnlanatiens for the release of uraniun oxide powder from the pins are that it fell l
out of breaches in the cladding as the result of vibrations during shipnent, or was spalled off the fuel surface as the result of quenching with water during cooldown orier to unloading the cask."
The vibration, crack, and normal cracking during oneration methods of uraniun oxide aerosol / particulate release surely arnly to BWR fuel i
(they logically apoly to all fuel assemblies with pellets and cladding). Possibly the other methods, heat & quenching, would annly.
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CONTENTION 165: Anplicants and NnC Staf* have not demenstrated that in the event of (1) a fire during shipnent of snent fuel, or (ii) a crash of the cask in transit, that uraniun aerosols and other radioactive naterials including Cs-134 and -137, Ru-106, Ce-lhh and actinide oxides, will not be released to the environment.
With a rupture disk in niace, once release starts it cannot be readily stopped, narticularly under fire conditions but also during regular accident conditions. Persons ecuinned to go into a radmioactive release to reseal the cask are not available in many towns along CF&L's rail routes to Harris.
BAS 75: Sane as for 164 (incornorated here by reference, no use retyping it as it's innediately above for easy reference).
Towns lacking nrenaredness: NC o a diation Protection Section has stated that only Greensboro in NC is now equinned to deal with a nuclear transnort accident. Greensboro is cutside CP&L's service area.
$ factors (the sane for contentions 16h and 165):
Good cause for failure to file on tine: I understand CP&L has still not completed changing its cask valve to a rupture disk.
Prior to this acticn (which they annear to connit to as of 7/29, see resnonse to Interrogatory 1h(a) on Eddlenan 6hr, 7-29-83 at 10) they could readily have sought denial of such a contention for nootness. In addid on, I understood directly from Apnlicants that a condition of our negotiations on 6hf was that I not bring certain facts before the Board; one such fact was the runture disk being planned to be used. Annlicants' counsel 7-29 says this fact is in the public donain and I can use it. I also thought it not prudent to file such a contention during negotiations for fear of upsetting the negotiations.
7
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Now that negotiations have terminated unsuccessfully (7-29) I am filing these cententions as nromptly as nracticable. In light of Anplicants' changing the basis of Eddleman 6hr, I think it reasonable to allow me an opportunity to file new or amended contentions in the light of this change in spent fuel shipment equipment. As noted above, an earlier filing re the ruuture disk could have brought the renly, "We have no definite plans to use a rupture disk"(or, "We 're not using a runture disk now"), "so your contention has no basis and is noot, speculative, renote."
These contentions will not broaden the issues, since the safety of snent fuel shipnents and radioactive releases to atmosphere therefrom in accidents or fireshave been issues from the begir.ning (in Eddleman 64f). In any case, the broadening is not significant, as the basic rroblen (atmospheric release of radioactivity from a spent fuel shinnent) is the same, and the basic causes (Bilure of sealing) are the sane.
These contentions cannot delay the croceed?.ng because they are safety contentions and discovery doesn't open on safety cententions until about 5 nonths fren now (early 1984).
There are no other parties pursuing contentions on snent fuel safety that I an aware of. There are no other means to nrotect ny interest in these matters: Annlicants won't do it, Staff (resnonse to interrogatories at 71,77, June '83) does not agree with .
64f. There can be no hearing on these issues without a contention.
I believe my discovery on 6hf does show that I have the ability to help develop a sound record on these issues. I understand the technical aspects of heat and nressure and have worked on industrial sealing systens. I can do technical cross-examination.
I have access to information about snent fuel cask design & analysis.
~
To the extent that the tinaliness factor above nay weigh against adnission of either Eddleman 16h or 165, I argue that the need for a sound record offsets that weight (when considered in conjunction with the other 3 factors, n.5 above, which favor admission of both).
There can be no sound reco*d on the question of svent cuel accidents without a contention. I can assist in develoning that "ecord. (see above)
These accidents can have severe impact (see Resnikoff, Next Nuclear Ganble, Chapter 6; Sandia study referenced in Eddlenan 6hf). This possible severe impact on nublic health and safety (and also on property and troperty values -- uranium aerosols are awfully hand to clean up) is reason for more detailed exanination of the issues of snent fuel transnort safety. The use of a "unture disk which cannot be r8 closed conclicates these problems. At least with a valve the uroblen was that it night not reseat, or could have connonents telt. A rupture disk will ructure (see 9esnikoff at 165, TNL study cited therein). That leads to great risk to the public, and that risk should be examined in this proceeding (unless Apulicants withdvaw their annlication to store svent large fuel from other nlants ut Harris) . The amount cf fa*1ed fuel Apelicants have at Bnunswick, and their apnarent intent to ship fuel, failed or not, plus the existence of failed fuel at Robinson, are additional reasons why the scenarios of Eddlenan 164 and 165 are credible and these issues should be examined.
. CONTENTION 166: The IF-300 spent fuel cask (which Applicants use for spent fuel shipnents) has a basket that cannot assure that suent fuel contained in it will not exnerience nuclear criticality (self-sustaining nuclear chain react'on) under all conditions. Use of the cask with this problem is unaccentable for the protection of nublic health and safety.
3 ASIS: Resnikoff, Next Nuclear Ganble, p.16k, footnote.
Applicants state they only use the IF-300, 5-27-83 answers to W.E. interrogatories; it 's the only scent fuel cask they have.
re " sound reco"d".
Additional basis 5 factors: is below,ikoff The Resn study just becane available as urinted (I have never nossessed a cory of any draft of it) and I received it in nid-July. I filed as cronntly as nossible once I got the information. This is the good cause #cr failuwe to file on tine; additionally, the info on which this contention is based did not exist 5-lh-82 and was unavailable to ne until I got the Resnikoff book. I didn't know it otherwise existed.
TheThis use contention of a ruuture disk (new basis) didn't exist 5-lh-62 either.
will broaden the issues, in the sense that a6cidental criticality in the spent fuel pool (Eddlenan and Wilson contentions) had been ruled out of the nroceeding nreviously.
This issue (criticality in snent fuel casks) had net been adnitted before.
It will not delay the proceeding. It is a safety contention, i.e.
on which discovery would not beei ng for some 5 nonths, until 1984 I know of no other parties pursuing this issue. Thus, no other narties can be exnected to renresent ny interests.
I know of no other neans than having a contention in which ny interest in this natter will be urotected.
I can assist in develoning a sound record on this issue, first by having the contention (withcut which there is no reco-d on this issue),
and also by conducting technical cross-exanination, discovery, and possibly by nroducing a witness or witnesses. The issue is an incortant one because criticality in snent fuel is a beyond-design-basis accident for spent fuel casks and could have large radiological consecuences and do great damage. Direct radiati_on from the criticality wculd be a risk,
but the great energy released by criticality, and fornation of fission products, increased nressure in old fuel rods (which may have failed in the reactor or in storage nrior to shionent, or during shinnent, e.g. in an accident whichhelus cause accidental criticality), and potential to rupture the ruptu"e disk on the CP&L cask (which cannot then be resealed).
The notential cf such events for harm to the public health and safety is good cause for them to be investigated in this proceeding. I an not aware of any other nroceeding where they are being adjudicated before N90 at oresent.
CP&L's use of c rupture disk means that the accident would be alnost incossible to control once the disk were ruptured.
Because of these serious consequences, any negative weight of tinely filing and broadening of issues is outweighed when all 5 factorn (inziuding those discussed p.7 above) are considered.
UCTE: I understand that Arnlicants' counsel 0 "Teill, who hns been dealing with these irsues, will not be available until about August 15 I will not ornose a reasonable extension of time for response by Ap"licants to these contentions, due to his absence. The Staff can have as nuch t!me as the App 14. cants Eet, so far a s I'm concerned. If any rarty wants nore time, over this, please ask ne; on these contentions I an likely to agree.
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UNITED STATES OF AMERICA O NUCLTAR REGUIATORY COMMISSION /pg /
In the matter of CAROLIKA POWER & LIGHT CO. Et al. /4 geAs 50 ell o Shearon Harris Nuclear Power Plant, Units 1 and 2 }lp a 56401.,6.L. ,. <
. O 'l' CERTIFICATE 0F SERVICE I hereby certify that copies of MOTOM 70 lbMPEL D 'S C6M'
@C 4 i +6F), l[Nb OF RESfCnsE To wrhRo6Hnces by '15 f Dlgy USM) @gTCNno* LC ff gf[gf fyD_
p pib OP HAVE been served this 4% day of A uS&Sr 198],bydepositin the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose nanes are parked with an asterisk, for whom service was acconplished by
+ fubiG YSfpf -4 C} Scwila o iv ik & ,ta k o v a t> ,9 v.e 5 , y '
(Dochdwg ' SerWe Shl! Sef S 3 Qf &)
Y Judges James Kelley, Glenn Bright and James Carpenter (1 copy each)
Atomic Safety and Licensire Board US Nuclear Regulatory Commission Washin6 ton DC 20555 i
George F. Trowbridge (attorney for Applicants)
Shaw, Pittman, Potts & Trowbridge @ R uthanne G. Miller 1800 M St. 274 ASLB Panel Washington, DC 20036 USNRC Washington DC 2055 5
,P0ffice of the Executive Legal Directer Phyllis Lotchin, Ph.D.
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