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Category:INTERVENTION PETITIONS
MONTHYEARML20059L9391993-11-12012 November 1993 Petitioners Supplemental Petition for Leave to Intervene.* Court Held That NRC May Not Eliminate Public Participation on Matl Issue in Interest of Making Process More Efficient. W/Certificate of Svc ML20101M7061992-06-30030 June 1992 Applicant Answer in Opposition to Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Untimely Intervention Petition Should Be Denied.W/Certificate of Svc ML20101E1261992-06-15015 June 1992 Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Should Be Granted Discretionary Intervention & Amended Petition for Leave to Intervene Granted for Listed Reasons.W/Certificate of Svc ML20086G6401991-11-22022 November 1991 Petitioners Amended Petition for Leave to Intervene.* Amended Petition of Ohio Citizens for Responsible Energy,Inc for Leave to Intervene to Respond to Arguments Made in Licensee & NRC Intervention Petition.W/Certificate of Svc ML20083B7981991-09-16016 September 1991 Answer of Util to City of Brook Park,Oh Suppl to Petition for Leave to Intervene.* Concluded That City Petition Failed to Satisfy Any of Three Criteria for Intervention,Therefore Leave to Intervene Should Be Denied.W/Certificate of Svc ML20083B7901991-09-16016 September 1991 Answer of Util to Petition of City of Brook Park,Oh for Leave to Intervene & Suppl Thereto.* Petition Should Be Denied Based on Listed Reasons.W/Certificate of Svc ML20083B3581991-09-0404 September 1991 City of Brook Park Suppl to Petition for Leave to Intervene.* in Consideration of Foregoing,Petition of City of Brook Park,Oh for Leave to Intervene Should Be Granted. W/Certificate of Svc & Svc List ML20082P1611991-08-23023 August 1991 Petition for Leave to Intervene & Request for Hearing.* Petitioners Have Demonstrated Right to Be Made Parties to Proceeding and Instant Petition for Leave to Intervene Should Be Granted & Proposed Contention Admitted ML20082G8921991-07-31031 July 1991 Petition of City of Brook Park,Oh for Leave to Intervene.* City Requests That NRC & ASLB Deny Applicant Request for Hearing.W/Svc List & Certificate of Svc ML20082D4411991-07-10010 July 1991 Supple by American Municipal Power-Ohio,Inc to Petition for Leave to Intervene.* Facility Requests Addl Time to Mod Suppl.W/Certificate of Svc ML20082B5111991-07-10010 July 1991 10CFR2.714(b)(1) Suppl to Conditional Petition to Intervene of City of Cleveland,Oh Submitted in Connection w/910725 Prehearing Conference.W/Certificate of Svc & Svc List ML20082B2511991-07-0303 July 1991 Petition of Util for Leave to Intervene.* If License Conditions Can Disappear & Reappear W/Shifting Economics of Electric generation,AMP-Ohio Future Will Be Seriously Jeopardized.W/Certificate of Svc ML20077G2661991-05-30030 May 1991 Petition of Alabama Electric Cooperative,Inc for Leave to Intervene.* Util Requests Intervention in Further Proceedings on Applications of Ohio Edison & Other Applicants.W/Certificate of Svc ML20043D6751990-06-0101 June 1990 Ocre Response to Licensee & NRC Staff Answers to Ocre Contention.* Ocre Contention Should Be Granted Since NRC Has No Valid Argument to Preclude Admission of Contention & 10CFR2.714(b)(2) Requirements Met.W/Certificate of Svc ML20012E6901990-03-23023 March 1990 Licensee Answer to Ocre Petition for Leave to Intervene & Request for Hearing.* Concludes That Ocre Lacks Requisite Interest in License Amend Proceeding & Requests That ASLB Rule on Ocre Petition.W/Certificate of Svc & Svc List ML20012E6771990-03-0808 March 1990 Petition for Leave to Intervene & Request for Hearing.* Ocre Requests Hearing on Util 891219 Amend Request & Submits Petition W/Intention of Becoming Full Party.Petition Should Be Granted Since Ocre Demonstrated Right to Be Made Party ML20148D0511988-01-0707 January 1988 Petition for Leave to Intervene & Request for Formal Adjudicatory Hearing.* Ocre Demonstrated Right to Be Made Party in Proceeding & Petition Should Be Granted ML20214W6371987-06-0505 June 1987 Petition of Toledo Coalition for Safe Energy,Sunflower Alliance,Inc,S Sass & SB Carter for Revocation,Mod or Suspention of OL Per 10CFR2.206.* No Regulatory Review Has Taken Place at Plant in Response to Reed Rept.W/Svc List ML20215N2451986-10-29029 October 1986 Second Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State Emergency Evacuation Review Team Not Convinced Plan Adequate.Certificate of Svc Encl ML20215H6861986-10-21021 October 1986 Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State of Oh Emergency Plan Should Be Reviewed Before Full Operation Granted.Certificate of Svc Encl ML20214U9901986-09-29029 September 1986 Reply to Licensee Response to State of Oh 860904 Petition for Leave to Intervene.State Seeking Opportunity to Advise Commission as to Serious Safety Concern Re Eventual Full Power Licensing.W/Certificate of Svc ML20214R3381986-09-23023 September 1986 Response Granting State of Oh Petition to Intervene as Interested State,To Allow Entering Proceeding to Advise Commission on Pending Immediate Effectiveness Review.W/ Certificate of Svc ML20214R5671986-09-19019 September 1986 Response to State of Oh 860904 Petition for Leave to Intervene & Request That Petition Be Denied.Certificate of Svc Encl ML20212Q8461986-09-0404 September 1986 Petition of State of Oh for Leave to Intervene.Requests Participation in Evaluating Adequacy of Licensee Offsite Evacuation Plans.Certificate of Svc Encl ML20115A5681985-03-0808 March 1985 Petition for Suspension of CPs & Nuclear Fuel Shipments & Conduct of Investigation to Ascertain Whether Central Area Power Coordinating Group Financially Qualified to Design & Construct Facility ML20078K3501983-10-14014 October 1983 Response to Util & NRC 831003 & 06 Answers,Respectively,To Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2.NRC Misunderstood Thrust of Motion. Contention Should Be Admitted.W/Certificate of Svc ML20078E5161983-10-0303 October 1983 Answer Opposing Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2 Re Diesel Generator Reliability.Motion Fails to Meet Criteria of Adequate Basis & Specificity.Certificate of Svc Encl ML20080H2651983-09-16016 September 1983 Motion to Resubmit Contention 2 on Diesel Generator Reliability.Good Cause Contained in Recent Documents Describing Generator Failure of Type to Be Used at Plant. Certificate of Svc Encl ML20024B7491983-07-0505 July 1983 Reply Opposing Util & NRC Responses Opposing Ohio Citizens for Responsible Energy 830510 Motion to File Contentions on SNM License Application.Certificate of Svc Encl ML20024A2871983-06-13013 June 1983 Answer Opposing Ohio Citizens for Responsible Energy 830510 Motion to Admit Five New Contentions on SNM License Application.Contentions Unjustifiably Late,Outside ASLB Jurisdiction or Moot.Certificate of Svc Encl ML20066B9791982-11-0404 November 1982 Answer to Sunflower Alliance 821019 Reply Brief to NRC & Util Answers to Sunflower Motion to Submit Addl Contention on Shift Rotation.No Support Exists for Sunflower Untimeliness Argument.Certificate of Svc Encl ML20069J9811982-10-19019 October 1982 Reply Brief Supporting Motion to Submit Addl Contention.Good Cause for Late Filing Demonstrated.Applicant Shift Rotation Plans May Not Be Incorporating Circadian Principles ML20027C5851982-10-12012 October 1982 Reply Opposing NRC & Applicant Responses to Oh Citizens for Responsible Energy Motion for Leave to File Contentions 21-26.Good Cause,Specificity & Basis Requirements Met. Certificate of Svc Encl ML20069G0481982-09-24024 September 1982 Answer Opposing Sunflower Alliance 820910 Motion to Submit Addl Contention.Good Cause for Late Filing,Basis for Contention & Nexus Between Contention & Facility Not Shown. Certificate of Svc Encl ML20027B5751982-09-16016 September 1982 Answer Opposing Oh Citizens for Responsible Energy 820818 Motion for Leave to File Contentions 21-26.Adequate Basis, Specificity or Good Cause Not Demonstrated.Certificate of Svc Encl ML20063M6271982-09-10010 September 1982 Motion to Submit Addl Contention Re Unnatural Shift Rotations.Good Cause Shown for Late Filing as Basis of Contention Is Recently Published Research.Certificate of Svc Encl ML20063J4651982-08-31031 August 1982 Answer Opposing Oh Citizens for Responsible Energy 820809 Motion for Leave to File Contention 20 Re Inadequate Consideration of Economic Consequences of Accidents.No Basis for Assertion of Deficiency Shown.Certificate of Svc Encl ML20063D0551982-08-18018 August 1982 Motion for Leave to File Contentions 21-26 Re Turbine Missiles,New Mark III Containment Concerns,Seismic Evaluation of BWR Core Thermal Hydraulics & in-core Thermocouples.W/Certificate of Svc ML20058J8551982-08-0909 August 1982 Motion for Leave to File Contention 20 Re Adequacy of Consideration of Economic Consequences of Accidents.Des (NUREG-0884) Deficient Due to Failure to Include Assessment of Disruption Caused by Accident.Certificate of Svc Encl ML20055A3641982-07-13013 July 1982 Response Opposing Conservation Council of Nc Additions to Suppl to Petition to Intervene.Opposes Contentions Under Same Rationale Identical Contentions of W Eddleman Opposed. Certificate of Svc Encl ML20052A2821982-04-22022 April 1982 Motion for Leave to File Contentions 17,18 & 19.Certificate of Svc Encl ML20004E8381981-06-0808 June 1981 Amended Contention of T Kenney.Facility Evacuation Plan Fatally Defective Since Applicant Definitions of Affected Persons,Contaminated Area,Dose Projection & Emergency Action Levels Are Deficient.Certificate of Svc Encl ML20008G1571981-05-0808 May 1981 Amended Sunflower Alliance,Inc,North Shore Alert & Citizens for Safe Energy Petition for Intervenor Status.Contentions Set Forth in Original Petition Are Adopted by Ref.Svc List Encl ML20003H5211981-04-30030 April 1981 Suppl to Oh Citizens for Responsible Energy 810311 Petition to Intervene,Enumerating Contentions to Be Litigated. Contentions Concern Clam Biofouling,Steam Generator Reliability,Radiation Blocking Agent & Steam Injury ML19345G5941981-03-20020 March 1981 Response in Opposition to Oh Citizens for Responsible Energy 810306 Petition to Intervene in OL Proceeding.Petition Fails to Establish Organizational Interest Required by 10CFR2.714.Certificate of Svc Encl ML19345G5471981-03-20020 March 1981 Response in Opposition to Sunflower Alliance,Inc Et Al 810315 Petition to Intervene in OL Proceeding.Individual Petitioners Satisfy Interest Requirements But Organization Petitioners Do Not.Certificate of Svc Encl ML19343C7791981-03-16016 March 1981 Petition to Intervene in Proceeding ML19350B9871981-03-16016 March 1981 Petition to Intervene in Licensing Proceeding.W/Certificate of Svc ML20126F5351981-03-0606 March 1981 Petition for Leave to Intervene.Util May Not Be Financially Capable to Operate Plant Safely.Requests Fes & Info Re Prehearing Conference ML20126F5291981-03-0505 March 1981 Petition to Intervene in Licensing Proceeding & Request for Hearing.Proof of Svc Encl 1993-11-12
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20059L9391993-11-12012 November 1993 Petitioners Supplemental Petition for Leave to Intervene.* Court Held That NRC May Not Eliminate Public Participation on Matl Issue in Interest of Making Process More Efficient. W/Certificate of Svc ML20101M7061992-06-30030 June 1992 Applicant Answer in Opposition to Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Untimely Intervention Petition Should Be Denied.W/Certificate of Svc ML20101E1261992-06-15015 June 1992 Amended Petition of City of Brook Park,Oh for Leave to Intervene Out of Time.* City of Brook Park Should Be Granted Discretionary Intervention & Amended Petition for Leave to Intervene Granted for Listed Reasons.W/Certificate of Svc ML20086G6401991-11-22022 November 1991 Petitioners Amended Petition for Leave to Intervene.* Amended Petition of Ohio Citizens for Responsible Energy,Inc for Leave to Intervene to Respond to Arguments Made in Licensee & NRC Intervention Petition.W/Certificate of Svc ML20083B7981991-09-16016 September 1991 Answer of Util to City of Brook Park,Oh Suppl to Petition for Leave to Intervene.* Concluded That City Petition Failed to Satisfy Any of Three Criteria for Intervention,Therefore Leave to Intervene Should Be Denied.W/Certificate of Svc ML20083B7901991-09-16016 September 1991 Answer of Util to Petition of City of Brook Park,Oh for Leave to Intervene & Suppl Thereto.* Petition Should Be Denied Based on Listed Reasons.W/Certificate of Svc ML20083B3581991-09-0404 September 1991 City of Brook Park Suppl to Petition for Leave to Intervene.* in Consideration of Foregoing,Petition of City of Brook Park,Oh for Leave to Intervene Should Be Granted. W/Certificate of Svc & Svc List ML20082P1611991-08-23023 August 1991 Petition for Leave to Intervene & Request for Hearing.* Petitioners Have Demonstrated Right to Be Made Parties to Proceeding and Instant Petition for Leave to Intervene Should Be Granted & Proposed Contention Admitted ML20082G8921991-07-31031 July 1991 Petition of City of Brook Park,Oh for Leave to Intervene.* City Requests That NRC & ASLB Deny Applicant Request for Hearing.W/Svc List & Certificate of Svc ML20082D4411991-07-10010 July 1991 Supple by American Municipal Power-Ohio,Inc to Petition for Leave to Intervene.* Facility Requests Addl Time to Mod Suppl.W/Certificate of Svc ML20082B5111991-07-10010 July 1991 10CFR2.714(b)(1) Suppl to Conditional Petition to Intervene of City of Cleveland,Oh Submitted in Connection w/910725 Prehearing Conference.W/Certificate of Svc & Svc List ML20082B2511991-07-0303 July 1991 Petition of Util for Leave to Intervene.* If License Conditions Can Disappear & Reappear W/Shifting Economics of Electric generation,AMP-Ohio Future Will Be Seriously Jeopardized.W/Certificate of Svc ML20077G2661991-05-30030 May 1991 Petition of Alabama Electric Cooperative,Inc for Leave to Intervene.* Util Requests Intervention in Further Proceedings on Applications of Ohio Edison & Other Applicants.W/Certificate of Svc ML20043D6751990-06-0101 June 1990 Ocre Response to Licensee & NRC Staff Answers to Ocre Contention.* Ocre Contention Should Be Granted Since NRC Has No Valid Argument to Preclude Admission of Contention & 10CFR2.714(b)(2) Requirements Met.W/Certificate of Svc ML20012E6901990-03-23023 March 1990 Licensee Answer to Ocre Petition for Leave to Intervene & Request for Hearing.* Concludes That Ocre Lacks Requisite Interest in License Amend Proceeding & Requests That ASLB Rule on Ocre Petition.W/Certificate of Svc & Svc List ML20012E6771990-03-0808 March 1990 Petition for Leave to Intervene & Request for Hearing.* Ocre Requests Hearing on Util 891219 Amend Request & Submits Petition W/Intention of Becoming Full Party.Petition Should Be Granted Since Ocre Demonstrated Right to Be Made Party ML20148D0511988-01-0707 January 1988 Petition for Leave to Intervene & Request for Formal Adjudicatory Hearing.* Ocre Demonstrated Right to Be Made Party in Proceeding & Petition Should Be Granted ML20214W6371987-06-0505 June 1987 Petition of Toledo Coalition for Safe Energy,Sunflower Alliance,Inc,S Sass & SB Carter for Revocation,Mod or Suspention of OL Per 10CFR2.206.* No Regulatory Review Has Taken Place at Plant in Response to Reed Rept.W/Svc List ML20215N2451986-10-29029 October 1986 Second Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State Emergency Evacuation Review Team Not Convinced Plan Adequate.Certificate of Svc Encl ML20215H6861986-10-21021 October 1986 Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State of Oh Emergency Plan Should Be Reviewed Before Full Operation Granted.Certificate of Svc Encl ML20214U9901986-09-29029 September 1986 Reply to Licensee Response to State of Oh 860904 Petition for Leave to Intervene.State Seeking Opportunity to Advise Commission as to Serious Safety Concern Re Eventual Full Power Licensing.W/Certificate of Svc ML20214R3381986-09-23023 September 1986 Response Granting State of Oh Petition to Intervene as Interested State,To Allow Entering Proceeding to Advise Commission on Pending Immediate Effectiveness Review.W/ Certificate of Svc ML20214R5671986-09-19019 September 1986 Response to State of Oh 860904 Petition for Leave to Intervene & Request That Petition Be Denied.Certificate of Svc Encl ML20212Q8461986-09-0404 September 1986 Petition of State of Oh for Leave to Intervene.Requests Participation in Evaluating Adequacy of Licensee Offsite Evacuation Plans.Certificate of Svc Encl ML20115A5681985-03-0808 March 1985 Petition for Suspension of CPs & Nuclear Fuel Shipments & Conduct of Investigation to Ascertain Whether Central Area Power Coordinating Group Financially Qualified to Design & Construct Facility ML20078K3501983-10-14014 October 1983 Response to Util & NRC 831003 & 06 Answers,Respectively,To Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2.NRC Misunderstood Thrust of Motion. Contention Should Be Admitted.W/Certificate of Svc ML20078E5161983-10-0303 October 1983 Answer Opposing Ohio Citizens for Responsible Energy 830916 Motion to Resubmit Contention 2 Re Diesel Generator Reliability.Motion Fails to Meet Criteria of Adequate Basis & Specificity.Certificate of Svc Encl ML20080H2651983-09-16016 September 1983 Motion to Resubmit Contention 2 on Diesel Generator Reliability.Good Cause Contained in Recent Documents Describing Generator Failure of Type to Be Used at Plant. Certificate of Svc Encl ML20024B7491983-07-0505 July 1983 Reply Opposing Util & NRC Responses Opposing Ohio Citizens for Responsible Energy 830510 Motion to File Contentions on SNM License Application.Certificate of Svc Encl ML20024A2871983-06-13013 June 1983 Answer Opposing Ohio Citizens for Responsible Energy 830510 Motion to Admit Five New Contentions on SNM License Application.Contentions Unjustifiably Late,Outside ASLB Jurisdiction or Moot.Certificate of Svc Encl ML20066B9791982-11-0404 November 1982 Answer to Sunflower Alliance 821019 Reply Brief to NRC & Util Answers to Sunflower Motion to Submit Addl Contention on Shift Rotation.No Support Exists for Sunflower Untimeliness Argument.Certificate of Svc Encl ML20069J9811982-10-19019 October 1982 Reply Brief Supporting Motion to Submit Addl Contention.Good Cause for Late Filing Demonstrated.Applicant Shift Rotation Plans May Not Be Incorporating Circadian Principles ML20027C5851982-10-12012 October 1982 Reply Opposing NRC & Applicant Responses to Oh Citizens for Responsible Energy Motion for Leave to File Contentions 21-26.Good Cause,Specificity & Basis Requirements Met. Certificate of Svc Encl ML20069G0481982-09-24024 September 1982 Answer Opposing Sunflower Alliance 820910 Motion to Submit Addl Contention.Good Cause for Late Filing,Basis for Contention & Nexus Between Contention & Facility Not Shown. Certificate of Svc Encl ML20027B5751982-09-16016 September 1982 Answer Opposing Oh Citizens for Responsible Energy 820818 Motion for Leave to File Contentions 21-26.Adequate Basis, Specificity or Good Cause Not Demonstrated.Certificate of Svc Encl ML20063M6271982-09-10010 September 1982 Motion to Submit Addl Contention Re Unnatural Shift Rotations.Good Cause Shown for Late Filing as Basis of Contention Is Recently Published Research.Certificate of Svc Encl ML20063J4651982-08-31031 August 1982 Answer Opposing Oh Citizens for Responsible Energy 820809 Motion for Leave to File Contention 20 Re Inadequate Consideration of Economic Consequences of Accidents.No Basis for Assertion of Deficiency Shown.Certificate of Svc Encl ML20063D0551982-08-18018 August 1982 Motion for Leave to File Contentions 21-26 Re Turbine Missiles,New Mark III Containment Concerns,Seismic Evaluation of BWR Core Thermal Hydraulics & in-core Thermocouples.W/Certificate of Svc ML20058J8551982-08-0909 August 1982 Motion for Leave to File Contention 20 Re Adequacy of Consideration of Economic Consequences of Accidents.Des (NUREG-0884) Deficient Due to Failure to Include Assessment of Disruption Caused by Accident.Certificate of Svc Encl ML20055A3641982-07-13013 July 1982 Response Opposing Conservation Council of Nc Additions to Suppl to Petition to Intervene.Opposes Contentions Under Same Rationale Identical Contentions of W Eddleman Opposed. Certificate of Svc Encl ML20052A2821982-04-22022 April 1982 Motion for Leave to File Contentions 17,18 & 19.Certificate of Svc Encl ML20004E8381981-06-0808 June 1981 Amended Contention of T Kenney.Facility Evacuation Plan Fatally Defective Since Applicant Definitions of Affected Persons,Contaminated Area,Dose Projection & Emergency Action Levels Are Deficient.Certificate of Svc Encl ML20008G1571981-05-0808 May 1981 Amended Sunflower Alliance,Inc,North Shore Alert & Citizens for Safe Energy Petition for Intervenor Status.Contentions Set Forth in Original Petition Are Adopted by Ref.Svc List Encl ML20003H5211981-04-30030 April 1981 Suppl to Oh Citizens for Responsible Energy 810311 Petition to Intervene,Enumerating Contentions to Be Litigated. Contentions Concern Clam Biofouling,Steam Generator Reliability,Radiation Blocking Agent & Steam Injury ML19345G5941981-03-20020 March 1981 Response in Opposition to Oh Citizens for Responsible Energy 810306 Petition to Intervene in OL Proceeding.Petition Fails to Establish Organizational Interest Required by 10CFR2.714.Certificate of Svc Encl ML19345G5471981-03-20020 March 1981 Response in Opposition to Sunflower Alliance,Inc Et Al 810315 Petition to Intervene in OL Proceeding.Individual Petitioners Satisfy Interest Requirements But Organization Petitioners Do Not.Certificate of Svc Encl ML19343C7791981-03-16016 March 1981 Petition to Intervene in Proceeding ML19350B9871981-03-16016 March 1981 Petition to Intervene in Licensing Proceeding.W/Certificate of Svc ML20126F5351981-03-0606 March 1981 Petition for Leave to Intervene.Util May Not Be Financially Capable to Operate Plant Safely.Requests Fes & Info Re Prehearing Conference ML20126F5291981-03-0505 March 1981 Petition to Intervene in Licensing Proceeding & Request for Hearing.Proof of Svc Encl 1993-11-12
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212J1581999-09-30030 September 1999 Order Approving Transfer of License & Conforming Agreement. Orders That License Transfer Approved,Subj to Listed Conditions ML20205D4901999-02-22022 February 1999 Transcript of 990222 Informal Public Hearing on 10CFR2.206 Petition in Rockville,Md.Pp 1-105.Supporting Documentation Encl ML20198D9711998-11-0909 November 1998 Petition Per 10CFR2.206 Requesting That Facility Be Immediately Shut Down & OL Be Suspended or Modified Until Such Time That Facility Design & Licensing Bases Properly Updated to Permit Operation with Failed Fuel Assemblies ML20155F4561998-08-26026 August 1998 Demand for Info Re False Info Allegedly Provided by Wh Clark to Two NRC Licensees.Nrc Considering Whether Individual Should Be Prohibited from Working in NRC-licensed Activities for Period of 5 Yrs ML20236V5261998-07-20020 July 1998 Computer Access & Operating Agreement Between Cleveland Electric Illuminating Co & NRC PY-CEI-NRR-2284, Comment Opposing Proposed Generic Communication, Lab Testing of Nuclear-Grade Activated Charcoal1998-05-21021 May 1998 Comment Opposing Proposed Generic Communication, Lab Testing of Nuclear-Grade Activated Charcoal ML20216B5111998-04-0909 April 1998 Order Imposing Civil Monetary Penalty.Denies Request for Remission of Violation C,Ea 97-430 & Orders Licensee to Pay Civil Penalty in Amount of $50,000 within Next 30 Days PY-CEI-NRR-2269, Comment on Proposed Rule 10CFR50.NRC Should Demonstrate That Not Only Is Code Process Flawed,But That Proposed Change Justified from Cost Versus Safety Protective1998-04-0303 April 1998 Comment on Proposed Rule 10CFR50.NRC Should Demonstrate That Not Only Is Code Process Flawed,But That Proposed Change Justified from Cost Versus Safety Protective ML20216G3821998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Duquesne Light Co & Allegheny Power Systems,Inc ML20217J0661998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Dqe, Inc & Allegheny Power System,Inc ML20198P9311997-11-0707 November 1997 Comments of American Municipal Power-Ohio,Inc.NRC Should Require Allegheny Power Sys,Inc to Affirm That Capco Antitrust License Conditions Will Be Followed ML20134L3401997-01-22022 January 1997 Resolution 96-R-85, Resolution Supporting Merger of Centerior Energy Corp & Ohio Edison Under New Holding Co Called Firstenergy ML20133B6941996-12-18018 December 1996 Submits Ordinance 850-96 Re Approval of Merger of Centerior & Oh Edison Into Firstenergy ML20135F4731996-12-0606 December 1996 Memorandum & Order CLI-96-13.* Commission Reverses & Vacates ASLB LBP-95-17 Which Granted Motion for Summary Disposition Submitted by Ocre & Hiatt.W/Certificate of Svc.Served on 961206 ML20132A8461996-12-0202 December 1996 Resolution 20-1996 Supporting Merger of Ohio Edison & Centerior Corp Under New Holding Company Called Firstenergy ML20134M6191996-10-28028 October 1996 Proclamation of Support by City of Sandusky,Oh Re Merger of Ohio Edison and Centerior Energy Corp ML20112J8281996-06-18018 June 1996 Licensee Reply Brief on Review of Licensing Board Decision LBP-95-17.* W/Certificate of Svc ML20112D8721996-05-29029 May 1996 Intervenor Brief in Support of Commission Affirmation of LBP-95-17.* Commission Should Affirm Licensing Board Decision.W/Certificate of Svc ML20108D9571996-05-0303 May 1996 CEI Response to City of Cleveland 2.206 Petition.Nrc Should Deny Petition ML20108B7571996-04-26026 April 1996 Licensee Brief on Review of Licensing Board Decision LBP-95-17.* Recommends That Commission Reverse Board Memorandum & Order Issued 951004.W/Certificate of Svc & Svc List PY-CEI-NRR-2034, Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matl1996-03-11011 March 1996 Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matl ML20101B5841996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement Or,In Alternative,For Severance of Issue & Expedited Hearing Procedures.W/Certificate of Svc ML20097B8721996-01-23023 January 1996 Petition of City of Cleveland,Oh for Expedited Issuance of Nov,Enforcement of License Conditions & Imposition of Appropriate Fines,Per 10CFR2.201,2.202,2.205 & 2.206 ML20097B8911996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement or in Alternative,For Severance of Issue & Expedited Hearing Procedures ML20096E2471996-01-0303 January 1996 Comment on PRM 50-64 Re Stockpiling Ki for Use as Thyroid Protectant in Event of Nuclear Accident.Supports Distribution of Ki to Public ML20094N1951995-11-17017 November 1995 Oh Edison Application for License Transfer in Connection W/ Sale & Related Transactions ML20094M5941995-11-15015 November 1995 Intervenors Answer to Licensees Petition for Review.* Intervenor Conclude That Commission Should Not Review Board Decision.W/Certificate of Svc ML20094J9141995-11-0707 November 1995 Petition for Review.* Submits That Commission Review of Board Decision Appropriate Under 10CFR2.786. W/Certificate of Svc & Svc List ML20093N9491995-10-23023 October 1995 Licensee Request for Extension of Time to File Petition for Review.* Requests That Commission Grant Extension Until 951107 of Deadline for Filing Petition for Review. W/Certificate of Svc ML20065L3571994-04-0505 April 1994 Intervenors Answer to NRC Staff Response to Intervenors Motion for Summary Disposition & Licensees Cross Motion for Summary Disposition.* Urges Board to Deny Licensee Cross Motion.W/Certificate of Svc ML20064N6341994-03-21021 March 1994 Affidavit of RW Schrauder in Support of Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition.W/Certificate of Svc ML20064N6081994-03-21021 March 1994 Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition.* Moves for Decision in Licensee Favor on Ocre Contention ML20064N9201994-03-21021 March 1994 Affidavit of RW Schrauder in Support of Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition. W/Svc List ML20063L4621994-02-0707 February 1994 Motion for Summary Disposition.* Intervenors Request That Board Grant Summary Disposition Favorably & Issue Declaratory Relief by Finding Challenged Portion of Amend 45 to Be in Violation of Aea.W/Certificate of Svc ML20058P4451993-12-13013 December 1993 Licensee Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Supplemental Petition for Leave to Intervene.* W/Certificate of Svc ML20059L9391993-11-12012 November 1993 Petitioners Supplemental Petition for Leave to Intervene.* Court Held That NRC May Not Eliminate Public Participation on Matl Issue in Interest of Making Process More Efficient. W/Certificate of Svc ML20059B1421993-10-19019 October 1993 Order.* Petitioners Shall File Supplemental Petition in Accordance W/Schedule in 931018 Order.W/Certificate of Svc. Served on 931020 ML20059B1761993-10-18018 October 1993 Order.* Informs That for Each Contention,Petitioners Shall Comply Fully W/Requirements of 10CFR2.714(b)(2)(i),(ii) & (III) & Their Filing Should Address Requirements Set Forth in Regulations.W/Certificate of Svc.Served on 931019 ML20059B0701993-10-12012 October 1993 Motion to Defer Consideration of Remanded Issue.* Requests That Licensing Board Defer Consideration of Remanded Issue Pending Outcome of Commission Review of 2.206 Process.W/ Certificate of Svc ML20058M8761993-09-30030 September 1993 Memorandum & Order CLI-93-21.* Appeal for Hearing Re Amend to Plant OL Denied.W/Certificate of Svc.Served on 930930 ML20057C0461993-09-21021 September 1993 Supplemental Director'S Decision DD-93-15 Involving 920929 Request for Certain Actions to Be Taken Re Proposed Construction of Interim onsite,low-level Radioactive Waste Facility at Plant.Request Denied ML20056C8951993-07-19019 July 1993 Order Extending Time within Which Commission May Rule on Petitions for Review of LBP-92-32.W/Certificate of Svc. Served on 930720 ML20045B5661993-06-0707 June 1993 Comment Re Proposed Generic Communication on Mod of TS Administrative Control Requirements for Emergency & Security Plans,As Published in Fr on 930401 (58FR17293).Believes Concept of Technical Review Not Addressed by STS ML20044E2781993-05-13013 May 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re VEPCO Petition to Change Frequency of Emergency Planning Exercise from Annual to Biennial ML20127A6171993-01-0606 January 1993 Order.* Time within Which Commission May Rule on Petitions for Review of Board Order LBP-92-32,dtd 921118,extended Until 930208.W/Certificate of Svc.Served on 930106 ML20126D5171992-12-23023 December 1992 City of Brook Park Answer to Petitions for Review.* Opposes Applicants 921208 Petitions for Review Based on Fact That ASLB Decision in proceeding,LBP-92-32,adequately Addressed Issues Raised in Petitions.W/Certificate of Svc ML20126F6501992-12-23023 December 1992 Answer of City of Cleveland,Oh,Intervenor,In Opposition to Petitions for Review of 921118 Decision of Aslb.* Petitioners Petitions for Review Should Be Denied. Certificate of Svc Encl ML20126D5461992-12-23023 December 1992 Answer of Cleveland Electric Illuminating Co & Toledo Edison Co to Limited Petition for Review of City of Cleveland,Oh of 921118 Decision of Aslb.* Commission Should Deny City of Cleveland Petition.W/Certificate of Svc ML20126D5781992-12-23023 December 1992 Answer of American Municipal Power-OH,Inc in Opposition to Petitions for Review of Oh Edison Co & Cleveland Electric Illuminating Co/Toledo Edison Co.* W/Certificate of Svc ML20126D5801992-12-23023 December 1992 NRC Staff Answer in Response to Petitions for Review Filed by Oh Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & City of Cleveland.* W/Certificate of Svc 1999-09-30
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April 30, 1981 tiNTTED P.!'ATES OF AMERICA I:t' CLEAR E1ULATORY COMMISSION In tre Matter of )
)
THE CLEVELAND ElEC"'RTC I !,Lt!.' INATI: G )
C0'iPAtlY e t c.l. ) Docket flos. 30 440
) 50 44'.
(Perry fluclear Power i lt.nt, ) (Operating License)
Units 1 and 2) )
_ . )
00DE'S SUPPLEMEllT TO ITS PETITIO!! FOR LMAVE TO IrlTERVENE OCRE (Ohio Citizens for Responsible Energy) filed its Petition for Leave to Inte rvene with Secretary of the Commission on ihrch 11, 1981. 1ursuant to the Federal Rekister notice (February 13, 1981) anet the Atomic Safety and Licensing Board's Memo and Order of April 9, 1931, OCRE now files its Supplement to its Petition, said supplement enumerating those contentions which OCRE seeks to have litigated in this matter. The conten-tions are attached.
Respectfully submitted, Jefi Alexander OCRE Representative
~~~
attachment: Contentions -
cci Executive Le e;al Direc tor, NRC Gerald Charnoff, Esq. .% ,
Docketing an ! ?rvice Sec tion, Of fice of the Secretary, NRC c\
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COMTENTIONS
- 1) Clam biofouling Applicant has not properly accounted for the presence of biofouling organisms in the nuclear power plant's source of process water and the resultant impacts.
Specifically, certain Asiatic clams (corbicula fluminea) have displayed strong biofouling abilities and a proc 14vity for steam-electric generating plants similar to Perry 1 and 2.
L.B . s )ss, .et al,,, " Control Studies On Corbicula For Steam Generating Plants," First International Corbicula Symposium, Tex. Christian U. at 139 (1977). There is at least a fifty per-cent chance that Lake Erie is suitable for corbicula.
Several impacts must be thoroughly considered. First, necessary control methods can cause unacceptable environmental impact. Chemical blocides can alter and severely harm existing aquatic biota other than target species.
Secondly, " chunking"(massive detachment) of clams could cause partial blockage of intake vessels and condensers, leading to a loss of coolant accident.
Finally, the financial aspects of this necessary maintenance must be assessed. If alternative control methods are utilized, eg. manual cleaning, there should be provident allocation of funds to meet the task. Applicant must demonstrate a program for control that will not permit biofouling beyond a certain extent.
Efficiency loss should be minimized and hazardous buildups prevented.
- 2) Diesel generator reliability The plant's diesel generators for on-site electricity gen-eration are not highly reliable. Applicant must provide for further redundancy in this system to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.
10 CFR Part 50, App. A, Criterion 17 The St. Lucie difficulties with this system but three(3) dieselwould mandatesystems generating that Appindependent)
(licant includewith notat two, least two different suppliers / manufacturers for those three
units. Florida Power & Licht Co.__ (St. Lucie Plant, Unit 1),
ALAB-603 (1980).
- 3) Radiation blocking agent To provide further assurance to OCRE members and the public living near the Perry plant, Applicant should include a program to distribute potassium iodide, a radiation blocking agent, to every household within ten miles of the plant in its operation plans.
Dr. Jan Beyea, former consultant to the President's Council on Environmental Quality, indicated in March, 1931 that use of this agent in the area of a nuclear plant (TMI, Unit 1) would both protect the thyroid gland from radioactive iodine and help calm citizen fears during a nuclear crisis. The fact that this type of program is already routine in Sweden lends further support to demanding a similar program of Applicant. UPI, Harrisburg, 3/28/81. '
- 4) Steam injury ,
Applicant must demonstrate that its maintenance program on steam valves is conducted in a safe manner so that technicians and maintenance workers necessary to the safe operation of the plant are not injured by escaping steam.
The recent accident at Seauoyah Unit 2 in which five workers were burned while testing a valve on a steam line points out the need for greater assurance in this area. Personnel loss in strategic areas could easily lead to violations in operating pro-cedures and unsafe operation. (The Saauovah accident occurred
, 4/19/81.)
- 5) Hydrogen bubbles OCRE contends that the Perry containment buildings could not sustain a hydrogen burn similar to the one which occurred at TMI Unit 2. Containment failure could gravely harm the interests of OCRE members ever;where.
- 6) Pressure vessel cracking OCRE contends that Applicant has not provided reasonable assurance that its operating activities can be conducted without endangering the health and safety of OCRE members and the public in that 1
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A. Cracks in the pressure vessel would be very difficult to detect before they led to catastrophic failure:
B. The growth of small cracks, though harmless at first, would necessitate their repair in reactor conditions.
Currently, no equipment is available to crind out and soundly weld up cracked regions in radioactive steel by remote automatic methods. If the cracks were not fixed and permitted to grow, Applicant would then have the deci-sion of either taking the chance of running the reactor or shutting it down at a fraction of its planned economic life, i
Nature, vol. 283 at 84 (Feb. 28, 1980).
- 7) Premature decommissioning Applicant does not have the funds necessary to decommission <
the Perry plant prematurely should a TMI-type accident occur.
In the aftermath of a TMI-type accident, Applicant's sol-vency would be imperative for the health and safety of OCRE members and the public. Applicant will need to promptly insti-tute clean-up procedures to reduce further public jeopardy while ,
maintaining containment integrity throughout that clean-up. The current financial straits of General Public Utilities (TMI) demon-strate that responsible and safe operation of a nuclear plant includes adequate preparation for such contingencies.
- 3) Computer nurveillance of RPV OCRE contends that Applicant has not met the requirements of 10 CFR Part 50 App. A, Criterion 32 which mandates "an approp-riate material surveillance program for the reactor. pressure vessel (RPV)."
Applicant has not adequately considered all RPV surveillance techniques, specifically the computer mentioned by Oak Ridge Laboratory. ORNL/CSD/TM-135
- 9) Yachining defacts in RPV Applicant has not met the reasonable assurance burden in regard to the RPV integrity and the defects which occurred during machining. Interim report 50 440-148 (Nov. 5, 1975). To assure adequately all OCRE members, Applicant must conduct further test-ing of the RPV prior to criticality stage.
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- 10) Demonstra}ble nee <1 Pursuant to 10 CFR Pnrt 51, Applicant munt show that there is a demonstrable need for the Perry plant. OCRE contends that this requirement has not been met, thus needlessly subjecting !
the public and OC3E members to potential harm from escaped radi-ation.
Applicant has failed to a) Take into account in its growth projection all signi-ficant factors affecting demands b) Provide for a complete internalization of all signifi-cant external costs r.o that the total cost of electricity is charged to those using its c) Account for the impact of energy conservation measures (both voluntary and involuntary):
d) Consider adequately the effect of alternative price designs, such es peak load nricing, which'will discourage demands and e) Take into account the possibili ty of interconnection as a means of meeting peak demand.
A reassessment of these factors by Applicant is necessary to meet the nnplicable regul'tions.
, 11) Plant site OCRE contends that the site is not suitable for the safe operation of a nuclear power plant pursuant to 10 CFR, Part 100 in thats a) The seismology of the site, and specifically the under-lying fault, nre unfavorable and have not been adequately compensated for by increasing the number of engineered safe-guards :
b) The original investigation pursuant to Appendix A of the above-mentioned part and resulting exoneration of the geologic anomaly were tainted by Applicant's financial inter-est in the outcome of that investigations i? is invalid as a basis for safety considerations:
c) The population center distance is too short in li 6ht of the accident at TMI and recommendations in the Rogovin report;
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d) The hypothetical fission product release assumed by Applicant in determinin6 an exclusion zone, low population zone, and a population center distance is underestimated in light of _TMI cccurrence and renders said determinations invalid.
OCRE recommends thats e) An independent and objective investia.ation of the site be conducted pursuant to Appendix A of Part 100:
f) Should this second investigation indicate unfavorable seismic conditions, Applicant must provide additional engineering safeguards to compensate for those conditions or, in the alternative, Applicant must not receive a license to operate the Ferry plants g) Perry plant not be operated beyond fifty percent of its current 3579 megawatts thermal rating: as distance cannot be regarded as an ultimate defense-in-depth barrier to OCRE members living near the plant site, reduce,d power limits are a necessary mitigation and preventive measure to pro-tect the health of those OCRE members. Rogovin Report, Vol.
1 at.130s h) Applicant assume for its hypothetical fission product
. release ;he TMI occurrence.
Following these recor.mendations can help assure that no accidents releasing significant quantities of radioactive fission products will occur and injure OCRE nembers or their children.
- 12) CANDU alternntive Applicant should be required to operate a CANDU nuclear steam system because of its lower occupational and environmental radiation doses. AECL-5523 (1975) . NEPA directives require Applicant to consider those alternatives to its facility which are available and reduce or avoid adverse environmental or other effects.
- 13) pipe break (scram discharge volume) ,
OCRE contends Applicant's reactor trip system is not pro-tected against a pipe break to the scram diacharge vclumes from the hydraulic control units. Upon a reactor trip, hot water rushing from the reactor vessel to the scram discharge volume would thermally shock the connecting pipes to the extent fracture is likely.
This event would be harmful to OCRE members because a rupture of this nature could allow coolant water to continue flowing out of the reactor vessel and/or drown out, short out, or otherwise stop the recirculation pumps located beneath the break. In bath instancen, overhenting of the core can result.
There is no valve unstream of the break locations to permit stopping of loss of coolant. The core overheating could lead to partial or whole meltdown that would breach containment nnd release fisninn products.
This contention is based on a report authored by Carlyle Michelson nnd sent to flRC commissioners April 7,1981. The raport cont 9 ins the results of the investigation of the June 29, 1090 partial scram fnilure at the Brown's Ferry, Unit 3 nuclear pin.nt.
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10: D:)cznent Control Desk, 016 Phillips !
EIOM: Ebcketing & Service Branch, Office of the Secreta f SWUECT: REQtTEST EUR DISrn.T.EION SERVIG 7F2CfJQi Pm"J AIORY A':ORMATION DISTRIBUTION SYSTEM (PlDS)
NOTE:: The attached d:xnrmnt, which relates to a specific licensing docket, is the DOC:2GC CDh'IROL AOTION COPY. It is certified by tr.e Office of the Secretary -
as the test available ccpy.
RIDS CODES A!C TITLES Rids Code Description D501 Antitrust Issuances X;02 Non-Antitn:st Issances Q3S07 Filings (Not Origi:ut'ad by NRC)
DSU4 Antitrust Filings (Originated by Ncn-Parties)
.DS05 Non-Antit:.:st Filings (Originated by Non-Pardes)
DS06 ELD Filings (Antitrust) m07 ELD Filings (Nan-An*dt 2st)
DSOS Antitrust Filings (Not Originated by lGC)
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