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Category:INTERVENTION PETITIONS
MONTHYEARML20101M7061992-06-30030 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 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 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 ML20195E8551986-05-28028 May 1986 Petition for Leave to Intervene in Matter of Contamination of Navarre Marsh,Toussaint Creek & Lake Erie by Util.Served on 860606 ML20197G7621986-05-13013 May 1986 Response Opposing Licensee 860428 Brief Opposing 851110 Petition for Hearings & Intervention Procedure for Disposal of Low Level Radwaste at Facility.Util Request Should Be Denied.Affidavits Encl ML20197G7401986-05-0606 May 1986 Petition of Save Our State from Radwaste,Consumers League of Ohio,A Gleisser & Gs Cook for Leave to Intervene & Request for Hearing.Served on 860513 ML20155G8131986-04-30030 April 1986 Appeal of Denial of G Zatroch 860408 Petition to Intervene. Petitioner Resides 53 Miles from Facility,Within Zone of Interest & Alleges That Injury Will Probably Result.Served on 860505 ML20155G6891986-04-29029 April 1986 Licensee Response to State of Oh 860414 Petition for Leave to Intervene & Request for Hearing.Petition Should Be Dismissed.Certificate of Svc Encl ML20205N3781986-04-28028 April 1986 Response Opposing Save Our State from Nuclear Wastes, Consumers League of Ohio 860411 Petition for Leave to Intervene & Request for Hearing.Certificate of Svc Encl ML20210N7121986-04-28028 April 1986 Responds Opposing Toledo Coalition for Safe Energy & SA Carter 851105 Petition for Leave to Intervene & Request for Hearing.Petition Should Be Treated as Limited Appearance Statement.W/Certificate of Svc ML20205N3241986-04-28028 April 1986 Response Opposing Petition of Western Reserve Alliance for Leave to Intervene in Proceeding Re Low Level Radwaste Burial.Petition Should Be Treated as Limited Appearance Statement.Certificate of Svc Encl ML20210K7511986-04-25025 April 1986 Response Opposing Petition of PE Dornbusch for Leave to Intervene.Suggests That Petition Be Treated as Limited Appearance Statement.Dornbusch Ltr Fails to Comply w/860310 Memorandum & Order.W/Certificate of Svc ML20141H1931986-04-22022 April 1986 Response Opposing Citizens for Land & Water Use 860411 Petition for Leave to Intervene.Petitioner Failed to Plead Admissible Contention to Identify Deficiencies in Licensee Method of Low Level Waste Disposal.W/Certificate of Svc ML20203B3231986-04-16016 April 1986 Petition of Save Our State from Nuclear Wastes,Consumers League of Ohio,A Gleisser & Gs Cook for Leave to Intervene & Request for Hearing on Radioactive Sludge Disposal Issue. Served on 860416 ML20155E8571986-04-14014 April 1986 Petition of State of Oh for Leave to Intervene as Party. W/Certificate of Svc.Served on 860417 ML20203B3501986-04-14014 April 1986 Petition of Ef Feighan for Leave to Intervene & Request for Hearing Re Util Proposal to Store Low Level Radioactive Sludge Onsite.Served on 860416 ML20203A0261986-04-11011 April 1986 Petition of Citizens for Land & Water Use,Inc for Leave to Intervene & Request for Hearing Re Util Request to Bury Low Level Radioactive Dreggings Onsite.Served on 860415 ML20202J8231986-04-0808 April 1986 Petition of G Zatroch for Leave to Intervene & Request for Hearing Re Radioactive Sludge Disposal at Plant Site.Served on 860415 ML20210A5181985-11-10010 November 1985 Request for Hearings & Leave to Intervene on Behalf of Western Reserve Alliance Re NRC Current Consideration for Approval of Procedure for Disposal of Low Level Waste Proposed by Toledo Edison Co ML20209H2271985-11-0606 November 1985 Petition of Toledo Coalition for Safe Energy & SA Carter for Leave to Intervene & Request for Adjudication Hearing. Intervenors Oppose Util Petition to Bury Low Level Radioactive Dredgings Onsite.W/Certificate of Svc ML20198C9311985-11-0505 November 1985 Petition of Save Our State from Radwaste for Leave to Intervene & Request for Hearing ML19330A8191980-07-25025 July 1980 Response in Opposition to City of Cleveland,Oh 800609 Request for Hearing Re Director of Nuclear Reactor Regulation 800513 Order.Filing,Requesting Tariff W/Ferc, Brings Controversy to End W/O Litigous Course ML19329D4681973-06-0202 June 1973 Petition for Leave to Intervene.Certificate of Svc & Affirmation of E Stebbins Encl ML19326B0621973-05-30030 May 1973 Petition & Affidavit for Leave to Intervene in Facility OL Proceedings.Issuance of License Should Have Conditioned Requirement That Utils Grant Facility Participation Through Ownership Participation or Through Unit Power Sales ML19326B2381973-04-26026 April 1973 Utils' Answer to Amended Petition to Intervene of Coalition for Safe Nuclear Power.Organization Failed to Submit Suitable Petition to Intervene.Petition Should Be Denial. Certifiate of Svc Encl ML19329D4141973-04-16016 April 1973 Coalition for Safe Nuclear Power Amended Petition to Intervene.Petition Should Be Granted.Petition Encl 1992-06-30
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20101M7061992-06-30030 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 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 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 ML20195E8551986-05-28028 May 1986 Petition for Leave to Intervene in Matter of Contamination of Navarre Marsh,Toussaint Creek & Lake Erie by Util.Served on 860606 ML20197G7621986-05-13013 May 1986 Response Opposing Licensee 860428 Brief Opposing 851110 Petition for Hearings & Intervention Procedure for Disposal of Low Level Radwaste at Facility.Util Request Should Be Denied.Affidavits Encl ML20197G7401986-05-0606 May 1986 Petition of Save Our State from Radwaste,Consumers League of Ohio,A Gleisser & Gs Cook for Leave to Intervene & Request for Hearing.Served on 860513 ML20155G8131986-04-30030 April 1986 Appeal of Denial of G Zatroch 860408 Petition to Intervene. Petitioner Resides 53 Miles from Facility,Within Zone of Interest & Alleges That Injury Will Probably Result.Served on 860505 ML20155G6891986-04-29029 April 1986 Licensee Response to State of Oh 860414 Petition for Leave to Intervene & Request for Hearing.Petition Should Be Dismissed.Certificate of Svc Encl ML20205N3781986-04-28028 April 1986 Response Opposing Save Our State from Nuclear Wastes, Consumers League of Ohio 860411 Petition for Leave to Intervene & Request for Hearing.Certificate of Svc Encl ML20210N7121986-04-28028 April 1986 Responds Opposing Toledo Coalition for Safe Energy & SA Carter 851105 Petition for Leave to Intervene & Request for Hearing.Petition Should Be Treated as Limited Appearance Statement.W/Certificate of Svc ML20205N3241986-04-28028 April 1986 Response Opposing Petition of Western Reserve Alliance for Leave to Intervene in Proceeding Re Low Level Radwaste Burial.Petition Should Be Treated as Limited Appearance Statement.Certificate of Svc Encl ML20210K7511986-04-25025 April 1986 Response Opposing Petition of PE Dornbusch for Leave to Intervene.Suggests That Petition Be Treated as Limited Appearance Statement.Dornbusch Ltr Fails to Comply w/860310 Memorandum & Order.W/Certificate of Svc ML20141H1931986-04-22022 April 1986 Response Opposing Citizens for Land & Water Use 860411 Petition for Leave to Intervene.Petitioner Failed to Plead Admissible Contention to Identify Deficiencies in Licensee Method of Low Level Waste Disposal.W/Certificate of Svc ML20203B3231986-04-16016 April 1986 Petition of Save Our State from Nuclear Wastes,Consumers League of Ohio,A Gleisser & Gs Cook for Leave to Intervene & Request for Hearing on Radioactive Sludge Disposal Issue. Served on 860416 ML20155E8571986-04-14014 April 1986 Petition of State of Oh for Leave to Intervene as Party. W/Certificate of Svc.Served on 860417 ML20203B3501986-04-14014 April 1986 Petition of Ef Feighan for Leave to Intervene & Request for Hearing Re Util Proposal to Store Low Level Radioactive Sludge Onsite.Served on 860416 ML20203A0261986-04-11011 April 1986 Petition of Citizens for Land & Water Use,Inc for Leave to Intervene & Request for Hearing Re Util Request to Bury Low Level Radioactive Dreggings Onsite.Served on 860415 ML20202J8231986-04-0808 April 1986 Petition of G Zatroch for Leave to Intervene & Request for Hearing Re Radioactive Sludge Disposal at Plant Site.Served on 860415 ML20210A5181985-11-10010 November 1985 Request for Hearings & Leave to Intervene on Behalf of Western Reserve Alliance Re NRC Current Consideration for Approval of Procedure for Disposal of Low Level Waste Proposed by Toledo Edison Co ML20209H2271985-11-0606 November 1985 Petition of Toledo Coalition for Safe Energy & SA Carter for Leave to Intervene & Request for Adjudication Hearing. Intervenors Oppose Util Petition to Bury Low Level Radioactive Dredgings Onsite.W/Certificate of Svc ML20198C9311985-11-0505 November 1985 Petition of Save Our State from Radwaste for Leave to Intervene & Request for Hearing ML19330A8191980-07-25025 July 1980 Response in Opposition to City of Cleveland,Oh 800609 Request for Hearing Re Director of Nuclear Reactor Regulation 800513 Order.Filing,Requesting Tariff W/Ferc, Brings Controversy to End W/O Litigous Course ML19329D4681973-06-0202 June 1973 Petition for Leave to Intervene.Certificate of Svc & Affirmation of E Stebbins Encl ML19326B0621973-05-30030 May 1973 Petition & Affidavit for Leave to Intervene in Facility OL Proceedings.Issuance of License Should Have Conditioned Requirement That Utils Grant Facility Participation Through Ownership Participation or Through Unit Power Sales ML19326B2381973-04-26026 April 1973 Utils' Answer to Amended Petition to Intervene of Coalition for Safe Nuclear Power.Organization Failed to Submit Suitable Petition to Intervene.Petition Should Be Denial. Certifiate of Svc Encl ML19329D4141973-04-16016 April 1973 Coalition for Safe Nuclear Power Amended Petition to Intervene.Petition Should Be Granted.Petition Encl 1992-06-30
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20198L1911998-12-21021 December 1998 Submits Comments Re Proposed Rule to Revise 10CFR50.59, Changes,Tests & Experiments ML20198L1361998-12-15015 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maint of NPP ML20217J2161998-03-27027 March 1998 Comment on Proposed Generic Communication Re Lab Testing of nuclear-grade Activated Charcoal ML20217F5361998-03-25025 March 1998 Comment Opposing Draft Regulatory Guide DG-1071, Std Format & Content for Post-Shutdown Decommissioning Activities Rept ML20199J4651998-01-22022 January 1998 Comment Opposing Draft RG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. RG Unnecessary Based on Use of EPRI Guideline & Excellent Past History of Commercial Grade Items at DBNPS ML20148M6421997-06-17017 June 1997 Comment on Proposed NRC Bulletin 96-001,suppl 1 Re Control Rod Insertion Problems.Nrc Should Review Info Provided in Licensee 970130 Submittal & Remove Statements of Applicability to B&W Reactors from Suppl Before Final Form 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 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 ML20108D9571996-05-0303 May 1996 CEI Response to City of Cleveland 2.206 Petition.Nrc Should Deny Petition ML20097G5731996-02-13013 February 1996 Comment Supporting Petition for Rulemaking PRM-50-63 Re Use of Potassium Iodide 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 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 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 ML20096E9781996-01-0808 January 1996 Comment on Proposed Suppl to GL 83-11, Licensee Qualification for Performing Safety Analyses in Support of Licensing Actions ML20087J3611995-08-14014 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Rev of NRC Enforcement Policy ML20086M8241995-06-29029 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style ML20083M8701995-05-10010 May 1995 Comment on Proposed Rule 10CFR50 Re Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactor ML20081C8841995-03-0303 March 1995 Comment Re NRC Proposed Generic Communication Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities. Util Ack NRC Efforts to Reduce Scope of GL 88-20,but Believes That Proposed Changes Still Overly Restrictive ML20077M5831995-01-0404 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactors ML20072K3611994-08-16016 August 1994 Comment Opposing Proposed Rule 10CFR72 Re Plans for Storage of Sf at Davis Besse NPP ML20072K4411994-08-14014 August 1994 Comment Opposing Proposed Rule 10CFR72 Re Dry Storage of Nuclear Waste at Facility in Toledo,Oh ML20072K5261994-08-12012 August 1994 Comment Supporting Proposed Rule 10CFR72 Re Addition of Standardized NUHOMS Horizontal Modular Storage Sys to List of Approved Sf Storage Casks ML20072B1581994-08-0909 August 1994 Comment Opposing Proposed Rule 10CFR72 on List of Approved Spent Fuel Storage Casks:Addition ML20029D8221994-04-19019 April 1994 Comments on Proposed Rule 10CFR50 Re Codes & Stds for Nuclear Power Plants;Subsection IWE & Subsection Iwl ML20062M4011993-12-28028 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20046A9561993-07-19019 July 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. 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 ML20045F8321993-06-22022 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Concurs W/Proposed Rule in Reducing Random Testing Rate of Licensees to 50% & Disagrees W/ Maintaining Random Testing Rate of 100% for Vendors 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 ML20044E1561993-04-29029 April 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re Frequency Change of Emergency Planning Exercises ML20127L8781993-01-19019 January 1993 Comment Supporting Comments Submitted by NUMARC Re Draft Reg Guide DG-1020 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 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 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 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 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 ML20126D4761992-12-22022 December 1992 Alabama Electric Cooperative Answer to Applicants Petitions for Review.* Applicants 921208 Petitions for Review Should Be Denied.W/Certificate of Svc ML20126A5461992-12-10010 December 1992 Order.* Requests That Answers to Petition for Review Be Filed No Later than 921223.W/Certificate of Svc.Served on 921210 ML20126A5751992-12-0808 December 1992 Petition for Review.* Requests That NRC Review LBP-92-32, 921118 Board Decision in Proceeding.Board Erroneously Interpreted Section 105(c) of AEA by Ignoring Fundamental Underpinning of Statute.W/Certificate of Svc ML20126A5871992-12-0808 December 1992 Petition for Review.* Requests That NRC Review ASLB 921118 decision,LBP-92-32.Board Erroneously Interpreted Section 105(c) of AEA by Ignoring Fundamental Underplanning of Statute.Certificate of Svc Encl ML20126A7651992-11-18018 November 1992 Limited Petition for Review of City of Cleveland,Oh of 921118 Decision of Aslb.* City of Cleveland Petition for Review Should Be Granted.W/Certificate of Svc ML20115E1771992-10-0808 October 1992 Comment Supporting Draft Mgt Directive 8.6,GL 92-05 ML20105C8971992-09-16016 September 1992 Comment Opposing Proposed Generic Communication Re Generic Ltr Concerning analog-to-digital Replacements Under 10CFR50.59 ML20114A8841992-08-17017 August 1992 Designation of City of Brook Park,Oh of Adopted Portions of Summary Disposition Pleadings.* Brook Park Not Advancing Any Addl Argument or Analysis in Connection W/Designation,Per 920806 Memorandum & Order.W/Certificate of Svc ML20099E1821992-07-28028 July 1992 Comment Supporting Proposed Rules 10CFR20 & 61 Re LLW Shipment Manifest Info & Reporting ML20099A4051992-07-17017 July 1992 Comment on Proposed Rules 10CFR20 & 50 Re Reducing Regulatory Burden on Nuclear Licensees.Supports Rules ML20101R4831992-07-0808 July 1992 Comment Supporting Proposed Rule 10CFR50 Re Receipt of Byproduct & Special Nuclear Matl 1998-03-27
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% UNITE STATE OF AMERICA pp y... . p, .. g
\ ATOMIC ENMOY C0f0 FISSION P" ' E ' ' #' 5b ' 3 7
BIFORE THE ATOMIC BAFEN A13 LICEScNG E0ARD h b 7 9 IN THS 11TTER OFr ) I
\ h... ED1 SON CO. and
(,1,.,7F1AfD c1ECTRIC IILUMINATIN Dockot No. 50-3h6
)
(Davis-Besse Nuclear Power St.
AMDOED PETITION TO INTERVEE The Coalition for Safe Nuclear Power, in confomity with the Boani
. '- /.
g Ordor of March 30, 1973, but not intendin8 to waive its objection to being again required to secure interrenor status in these proceedings, hereby submits the following statanent of interest in the proccodings and its supplemental list of contentions:
- 1. The Coalition for Safe Nuclear Power is composed of numerous conservation and environmentally oriented groups both incorporated and unincorporated, ard concerned individuals. Its manbership organizatima and their interoat in the temination of Construction Permit No.
CPPR 80 are fully documented in the ASLB hearing record of December 8-10, 1970, and the original intervention petition filod in those initial procoodings.
- 2. The Coalition, by reason o'r its mcnbor organizations, has a spocial conservational interest in the protection of the natural resources and marsh, ecosystan of Westorn Lake Erio. They will suffer injury in fact to this intoraat from the operation of the Davis-Desse Nucloor Power Station by ronson of the plant 8s anticipated radiological and non-radiological air and water borno caissions ard by ranson of possiblo f
! unanticipated releases of radiological emissicna in excess of 10 CPR 20 limitations. 800306079/ g,,
2
- 3. The Coalition further asserts-its interest as a privato attorney general in sooking adequate and comploto implomontation of the 4
requ.iromonts of the National hvironmental Policy Act of 1969, as that interoct rolatos to the final Environmental Inpact Statoment issued by the Directorato of Licensing and modo the subject matter of those proceedi ngs. In support of this public interest, the Coalition states that the Final Enviremontal Statanent constitutes an arbitrary and capracious refusal to comply with censideratien of alternatives as required by Section 102(2)(c) 111 of the National Enviroraontal Policy Act of 1969, in that the " staff 8' has failed and refused to consider the alternative of conservation.of energy within tho applicant 8s service areas so as to obviato the need for tho 872 FM additional capacity of the Davis-Besse plant. In other words, all alternatives to construction of this plante have not been considerod, including but not limitod to conservation of energy and underground siting.
- h. The Coalition further esserts as a private attorney general, that the omission of the Ehvironmental Conserquences of nC1 css Mino" accidents is a breach of the Commission 8s NEFA responsibilities of substantive project ovaluation. The Environmental consequences of a malt down of the fuel core, total failure of the emergency core coolant n;mton, broach of the centaimont' vossal and emission of over 75% of gaseous radioactive wastos should bo documented and projectod in order to e emply with the HIPA full' disclosuro procedural requirements.
Potitioner contends that the Staff ts Environsontal Stata:ent is insuf- '
ficient because it fails to analyze the envirormental impact of accidants involving a broach of containmont and doposition of fission products in the range frcm 2 x 107 Ci to 1 x 109 C1. Presumably the Staff is taking guidance: fren the Septmber 1,1971 Annox to Appendix D which says of such accidents:
l l
)
3 1 "Their consequences could be sovere. Ilowever, the probability g f their occurrence is ao anall that their environmental risk tremely low. Defense in depth (multiple physical k % iers), quality' assurance for design, manufacturo, and
\
9 ~
poration, continued surv411ance and teating, and conservative design are all applied to provide and maintain the roquired high decree of assurance that potential accidents in this class g are, and will remain, sufficiently remote in probability that tho environmontal risk is extremely 1cw. For these reascns,
% it is not nocessary to discuss such events in applicants 8 Enviromental Reporta."
Petitioner contends that this Annex has not been adopted as a Ccmission regulation and therefore has no force. Petitioner further contends that the language of it clearly applisa only to applicant's J:hvirornental iteports, and does not absolve the Staff from fulfilling its duties under the National Enviremontal Policy Act. Petitioner furtnemore c allengos the trut) of the quotation not forth above. The defenso in dopth concept has never been danonstrated to have any baaia in fact, and the assertions containod within the quotation concerning the icw probability of major accidents ar's purely speculativo and totally incking in any evidentiary basis. Petitioner contends that the Cor:: mission has admitted its lacti of knowledge by comissioning Professor Norman Rasmussen of MIT to make a probability assessmont of major reactor accidents.
Petitioner notes that in its August h,1972 lettor to the Joint Oct:mittee on A comic Energy, the Cornicsien caid:
"fhe present state of knowledge probably will not permit a ccmplete analysis of low-probability accidents in nuclear plants with the precision that would be desirable."
"It may turn out after further rosearch that it is impossible to make such assessments with aufficient precision to be usoful.
In this ovent a longer term effort on the probabilitics of accident-causing events would be requirod."
Petitioner contends that tho probability of a Class 9 acoident is in the range of 1 x 10-2 per reactor po'r hear to 1 x 10-3 por reactor por year.
Therefore the Staff should includo envircraontal impact analyses of this i class of accidents in its Etiviremental Statment, and the failure to
9 !
D\
g h
,; . The Coalition asserts ao a privnte attorney general that there b~ %
nau been no conoideration of an accident, which is entirely possible, which could contaminate Lake Erie as a public water supply. In Nuclear deactor Safety: An Evaluation of New Evidence, July,1971, the Union of Concerned Scientists evaluated the conserquences of a loss of coolant accident for a 650 Mw roacter, which is considerably smaller than Davis-ucaso. They state:
" .... it is not at all impossible to breach the containment vessels.n uA release that involves primarily highly volatile or gaseous materials is more likely than one that involves dispersal of substantial solid material as a smoke or dust, although the lattor may certainly occur. The volatile and gaseous radio-active materials are the halogons and noble gases and include the Ienens, Kryptons, bromines, Iodines and Strontiums and comprise some 20% of the fission product inventory."
"Somo idea of the ha::ardous nature of the materials involved comos from recognizing that the Strontium-90 inventory in the reactor we are considering is sufficient to contaminate more than 1000 cubic miles of water in excess of pomitted AEC tolerance levels."
In testifying at the State of Ohio hearing on the Davis-Besse Plant, held in July,1971, Dr. Daniel Ford of the Union of Concerned Scientists (page176) stated:
"The deposition of the matorials frem fallout in Lake Erie, the release of the Strontium 90 when the massivo fual would bo entombed below earth, it would surely be continuously releasing for many-tons of years a large amount cf activity into Lako Erie. As I indicated, the calculation that we had made here as to how Bront a volumo of water the Strontium in a hactor would contaminato, it would contaminate over the Atomic Energy Cocaissionis maximum control recommendations a thousand cubic miles of water, which I boliove is scmething like twenty-fivo percent inoro than tho volume of Lako Erio, so it is an evidence of a consequenco of the failure of the emergency cooling syst It is core ralated in a very clear way with the dotomination tha ould be called upon to make on the impact of this plant on water quality."
Therefore, the Staff should havo included envircnmental impact analysos of this accident possibility "ard its environmental effect on Lake Erie, and the failure to do ao is a violation of NEPA.
9 e\ \ h .
5 g 6. The Coalition further asserts as a private attorney general that the AEC rhvironmental Report has not properly evaluated all possible stona damage and the enviromental consequances thereof, such as having the cooling tower lost due to stoms, floodinC of the area, or dar. age to buildings. The high lake levels and severe lake stoms make these events distinctly possible. Sorte of the recent stems in the area l Indicate that there would be difficulty in reaching the site of the reactor even 'if the reactor itself should not be flooded. Therefore, tho Staff should have included environmental impact analyses of possible storm damage, and failure to do so is a violation of NEFA.
- 7. The Coalition further asaerta as a private attomey general that thoro has been no evaluation of the affect of using Flutonium as a fuel in the Davis-Ecase Reactor instsad of Uranium. It is evident from an article in the 711 Street Journal, . March 2,1973, page h, ,
"!!uclear Plant to Use Plutonium Fuel Ends in its own Reactor n , that the nuclear industry is planning to substitute plutonium for uranium in order to save fuol costa. The Big Rock Point plant near Charlevois, Itichigan, will be the first plant to be so : loaded, as stated, large scale
~
production of plutonium fuel rods will require special plants, expected to go into commercial operation in 1977. Therefore, the Staff should include environmental impact analyses hf the alternate use of plutonium ,
and the environmental ccnsequences thereof, and the failure to do so is !
'l a violction of NEPA. -
- 8. The Coalition furtha5 asserts as a private attornoy general, that the proposed Environmental Monitoring dystem violatos the National l Ehvironmental Policy Act of 19d9, ~in that th's "staffn recommands con-1 -
l tinuation of the construction pemit (major federal action) without the ,
! 1
[ roquisite prior knowledge needed to perfom the substantivo balanoing 1
- mm areAlmawas
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- 9. The Coalition further asserta, as a privato attorney general, that sections 5.9.1 through 5.9.5 of the Final Statement fail to ovaluate the environmental consequences of a transportation accident cauaing the releaa,e of radiation frca spent fuel clemento, A conclusion that auch accidents will not occur constitutes an arbitrary and capr$cious refusal to examine possible consequences of the proposed major federal action under the NEA.
hMEREORE, the Coalition for Safe Nuclear Power prays that it be granted intervention status and be, pomitted to present evidence upon its allegations and otherwise participate as a Tarty in these proceedings.
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[Yvelyn S,Jebbind, Cdairman Coaliti5n for Safe Nuclear Power I, Evelyn Stebbins, being first duly deposed and sworn, dopose and say that I have read the above and it is true to the best of my knowledgo. .
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Evelyn Splfbina SWOMI TO BEORE HE and subscribed in my presence this
&day . ,
of April,1973.
Y6 9 Y tu <6 1 ,' NORA E HJbd c h
H r. , ~ ! o t.tmtir.
D - .J hetary Pte .c Ise Cayst.r6 s Cernfy .
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My Comm. nun Lawns Sept. 24,1973
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