Similar Documents at Salem |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML19259B7611979-02-15015 February 1979 Amended Answers by Intervenor Lower Alloways Creek Township, Nj,To Licensee'S Interrogatories.Professional Qualifications of G Luchak & Certificate of Svc Encl ML19282A5711979-02-0505 February 1979 Licensee'S Response to Interrogatory 20 of Intervenor'S First Set of Interrogatories Dtd 781121. Certificate of Svc Encl ML20064J0011978-12-11011 December 1978 Response by Licensee PSEG to Intervenors a & E Colemans' First Set of Interrogs Dated 781121.Interrogs Concern,Inter Alia,Spent Fuel Reprocessing & Radiat Levels in Spent Fuel Pool.Cert of Svc Encl ML19270E8421978-11-21021 November 1978 Intervenors' First Set of Interrogatories.Intervenors Alfred & Eleanor Coleman Are Represented by Public Advocate of Nj. Questions Are Based on Licensee'S Application for Increased Capacity Fuel Racks.Certificate of Svc Encl 1979-02-05
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation ML18106A8811998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG ML18106A8731998-09-15015 September 1998 Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998 Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991 LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis ML18102B4361997-07-0707 July 1997 Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst ML20132A8961996-12-0606 December 1996 Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry ML20084H9251995-06-0202 June 1995 Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs ML20134K5021995-02-24024 February 1995 Transcript of 950224 Enforcement Conference in King of Prussia,Pa Re C Vondra.Pp 1-136 ML20134K4511995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re Plant.Pp 1-93 ML20134K4791995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re V Polizzi.Pp 1-115 ML20134K4971995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re L Reiter.Pp 1-64 ML20080G8321995-02-0606 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary ML20077L8631995-01-0303 January 1995 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities ML20132B2281994-08-0202 August 1994 Transcript of 940802 Enforcement Conference in Salem,Nj W/Salem Senior Nuclear Shift Supervisor Involved in 940407 Event ML20067C1591994-02-17017 February 1994 Comments on NUREG/CR-5884 Re Analyses of Decommissioning for Ref PWR Power Station ML18100A5591993-08-26026 August 1993 Comment Opposing Proposed Rule Re Whistleblower Protection ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20072T2421991-04-11011 April 1991 Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20195H0331988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing ML20153F9681988-08-17017 August 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged ML20154G1421988-04-20020 April 1988 Comment Opposing Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization Program.Nrc Should Establish Program Mutually Agreed Upon Between Union & Util,Per Hope Creek & Salem Programs ML20154G4601988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility ML18093A6331988-02-0101 February 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods ML20151B3641987-02-24024 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning ML20079N4271984-01-25025 January 1984 Response to State of DE 840120 Motion to Withdraw Petition for Leave to Intervene.Licensee Concurs in Motion.Dismissal of Proceeding Requested.Certificate of Svc Encl ML20079K9311984-01-20020 January 1984 Motion to Withdraw Petition for Leave to Intervene & Request for Hearing Re Extension of Time for Type a Test.Certificate of Svc Encl ML20078P6771983-11-0404 November 1983 Answer to State of DE Atty General 831021 Petition for Leave to Intervene & Request for Hearing on License Amend Re Inservice Integrated Leak Tests.Notices of Appearance & Certificate of Svc Encl ML20078M1551983-10-21021 October 1983 Petition for Leave to Intervene & Request for Hearing on Proposed Issuance of Amend to License DPR-70 Re Inservice Integrated Leak Tests.Affidavit of Mailing Encl ML18087A8331983-04-12012 April 1983 Petition for Order to Show Cause Why Util Should Not Be Restrained from Restarting Facility Until Qualifications for Operation Demonstrated at Public Hearing ML18087A8341983-04-11011 April 1983 Affidavit of DG Bridenbaugh Re Delay of Facility Restart. Full Review of safety-related Equipment Must Be Completed & Appropriate Changes Implemented.Prof Qualifications Encl ML20213E3601983-03-0808 March 1983 Testimony Before Subcommittee on Energy & Environ Re Plant Licensing Concerns ML18086A9691981-10-14014 October 1981 Affidavit Confirming Validity of Util 811009 Response to IE Insp Repts 50-272/81-15 & 50-311/81-14 ML20005B6831981-08-20020 August 1981 Petition for Review of Aslab 810717 Order,Permitting OL Amend,Allowing Installation of New Storage Racks & Increasing Pool Capacity.Notice of Appearance & Affidavit of Svc Encl.Related Correspondence ML20010C1481981-08-14014 August 1981 Response in Opposition to Lower Alloways Creek Township 810803 Petition for Review of ALAB-650.Petitioner Has Raised No Issue Which Warrants Commission Consideration.Certificate of Svc Encl ML20009H2221981-08-0303 August 1981 Petition Supporting Review of Aslab Decision.Case Involves Matter That Could Significantly Affect Environ,Public Health & Safety & Involves,Important Procedural Issues & Public Policy Questions.Certificate of Svc Encl ML18086A5181981-05-15015 May 1981 Answer Opposing AC Coleman 810504 Request for Stay of Initial decision,LBP-80-27,pending Appeal.Request Untimely & Fails to Meet Requirements for Issuance of Stay. Certificate of Svc Encl ML18085A8401981-02-17017 February 1981 Brief Supporting ASLB 801027 Decision Authorizing OL Amend to Permit Storage of 1,170 Spent Fuel Elements in Facility Spent Fuel Pool.All Exceptions Should Be Denied.Aslb Has Adequately Weighed Evidence.Certificate of Svc Encl ML18085A5231981-01-13013 January 1981 Findings of Fact & Conclusions of Law in Support of 801111 Exceptions to ASLB 801027 Initial Decision Re Applicant Proposed Expansion of Fuel Storage.Certificate of Svc Encl ML18085A4091980-12-0808 December 1980 Response to Intervenors Eg & a Coleman Motion for Extension Until 810131 to File Brief in Support of Exceptions.Opposes Motion But Would Not Object to 2-wk Extension.Certificate of Svc Encl ML18085A4081980-12-0404 December 1980 Appeal from ASLB Initial Decision Granting Util Right to Increase Spent Fuel Pool Storage Capacity.Nepa Requires Detailed Analysis of Safety & Health Problems Posed by Reracking.Certificate of Svc Encl ML19340D3431980-11-30030 November 1980 Request for Extension to 810131 to File Brief in Support of Exceptions to ASLB 801027 Initial Decision Re Spent Fuel Pool Proceeding.Certification of Svc Encl ML18085A2791980-11-20020 November 1980 Notice of Withdrawal of Appearance as Counsel for Intervenors Coleman.Intervenors Coleman to Remain Parties to Proceeding.Certificate of Svc Encl ML18085A2501980-11-11011 November 1980 Appeal from ASLB 801027 Initial Decision.Alleges Erroneous Finding of Facts Re Contentions 2 & 6,evaluation of Eia, Acceptance of Pasedag Testimony & Rejection of Benjamin Testimony.Counsel Withdrawal & Certificate of Svc Encl ML18085A2161980-11-0404 November 1980 Exceptions & Appeal from ASLB 801027 Initial Decision. Exclusion of as Benjamin of Sandia Labs Testimony Is Arbitrary Due to Relevant Evidence Re Oxidation That Could Propagate to Older Fuel.Certificate of Svc Encl ML20062J4921980-10-21021 October 1980 Addl Testimony Presented Before ASLB to Correct & Clarify 800710 Testimony Re Loss of Water from Spent Fuel Storage Pool ML18082A7101980-07-11011 July 1980 Reply Findings of Fact & Conclusions of Law in Form of Partial Initial Decision Substituting for Licensee 800613 Findings,In Response to ASLB 800509 Order & ASLB 800626 Question 5 on away-from-reactor Issues.W/Certificate of Svc 1998-09-15
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UNITED STATES OF AMERICA p rgp COMpg8 DES @ REF.0LATORY COMMISSION NUCLEAR
. In the Matter of : DOCKET NO. STN-50-272 Proposed Isruance of Public Service: Electric : Amendment to Facility
& Gas Co. Operating License (Salem Nuclear Generating : No. DPR-70 g
Station, Unit #1)
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[ 4, = V ,d THE JNTERVENOR LGiER ALLGiAYS CREEK TOWNSIIIP QhD
- s A AMENDED ANSWERS TO LICENSEE 'S 'IUTERROGATORIES
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- 1. The calcu]ations may be referrec to which are contained in NUREG-404, Vol. 1 and 2, and the Report to the President by the Interagency Task Force dated October, 1978 -
Draft # TID-2 8 817.
- 2. Insofar as NUREG-404, Vol. 1 and 2, and the Report to the President by the Interagency Task Force Dated October, 1978 - Draft # TID-2 8817 are a study or analysis there may be some reliance on conclusions and data.
- 3. NUREG-404, Vol. 1 and 2, and the Report to the President by the Interagency Task Force Dated October, 1978 -
Draft # TID-28817.
- 4. Yes - research is presently being done b'y Dr. John Lamarsh, Dr. William liarding and Dr. George Luchak.
a) The research is ongoing and has not produced any document - the next work sessicn is scheduled for February 9, 1979.
I The research is being cenducted independently b) by the above named persons.
c) --
7803230@ %
Gary L. Milhollin, Esq. Richard Fryling, Jr., Esq.
Chairman, Atomic Safety Assistant General Solicitor
& Licensing Board Public Service Electric &
1815 Jefferson Street Gas Company Madison, Wisconsin, 53711 80 Park Place Newark, N.J., 07101 Glen O. Bright Member, Atomic Safety R. William Potter, Esq.
& Licensing Board Assistant Deputy Public Advocate U.S. Nuclear Regulatory Commission Department of the Public Advocatt Washington, D.C, 20555 Division of Public Interest Advocacy Dr. James C. Lamb, III P.O. Box 141 Member, Atomic Safety & Trenton, N.J., 08601 Licensing Board Panel 313 Woodhaven Road Sandra T. Ayres, Esq.
Chapel Hill, N.C. 27514 Department of the Public Advocat.
520 East State Street Chairman, Atomic Safety and Trenton, N.J., 08625 Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Mr. Alfred C. Coleman, Jr.
Washington, D.C., 20555 Mrs. Eleanor G. Coleman 35 "K" Drive Chairman, Atomic Safety & Pennsville, N.J., 08070 Licensing Board Panel U.S. Nuclear Regulatory Commission Office of the Secretary Washington, D.C., 20555 Docketing and Service Section U.S. Nuclear Regulatory Commissic Barry Smith, Esq. Washington, D.C., 20555 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission June D. MacArtor, Esq.
Washington, D.C., 20555 Deputy Attorney General Tatnall Building, P.O. Box 1401 Mark L. First, Esq. Dover, Delaware, 19901 Deputy Attorney General Department of Law & Public Safety Environmental Protection Section 36 West State Street Trenton, N.J., 08625 Mark J. Wetterhahn, Esq.
for Troy B. Conner, Jr., Esq.
1747 Pennsylvania Avenue, N.W.
Suite 1050 Washington, D.C., 20006
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atanic Safety and Licensing Board In The Matter of :
DOCKET NO. STN-50-272 PUBLIC SERVICE ELECTRIC :
& GAS dO. :
(Salem Generating Station :
Unit #1) c3 % g
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'NS CERTIFICATE OF SERVICE e{.
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% o I hereby certify that ccpies of Lcwer Alloways Creek Township's Amended Answers to Interrogatories (Set #1) in the above captioned matter have been served upon the attached list by deposit in the United States mail this 15th day of Feb. , 19 79. - /
wssMo CARL VALORE, dR.7 Special LegaQunse TOWNSHIP OF LCWER ALLOWAYS CREEK Dated: February 15, 1979
During the Apollo program proposed a new management system to match the design process necessary for the development of the system.
Prior to civilian career, spent four years with the Canadian Corp. of Signals with a discharge rank of Captain.
-Also graduated frcm the British Air Ministry Weather Forecaster's Course and acted as an Air Force Meterologist, and graduated from the British Joint Services Staf f College which prepares military men and civilian scientists for posts in NATO at the level of Colonel and above.
Various papers on the magnetic fields of the earth, sun and stars to papers on Colloid Chemistry, the theory of queues and the theory of smokes to mechanics.
GEORGE LUCHAK, Ph.D.
59 Maclean Avenue Princeton, N.J.
PROFESSIONAL QUALIFICATIONS Presently a Professor of Civil Engineering at Princeton University teaching undergraduate courses in Systems Engineering and Solid Mechanics and a graduate course on "American Nuclear Power Systems and the Energy Economy".
Graduated from the University of Toronto in 1942 with a B.A., M.A., and a Ph.D. in 1953 in Mathematics and Physics.
Past experience includes seven years with the government in the fields of atomic, biological and chemical warf are,10 years with industry (General Electric and Radio Corporation of America) with team eff orts on an ad-hoc basis with Grumman Aircraft, Lockheed Aircraft and others, and nine years with Princeton as a full professor.
The systems engineering work in industry ranged from ballistics missile early warning system to requirements for missile systems to the design of the lunar excursion modular for Apollo. While involved in ballistics missile early warning systems managed a group responsible for determing the decision process to be used to defend the nation against enemy missile attack and the automation of such processes by computer controls.
In Apollo, managed the system reliability and safety team which was responsible for allocating reliability, performance, weight and cost between the various subsystems of the lunar excursien modular in order to ensure a successful missicn and a safe system.
d) The ongoing research is focused on whether adequate consideration has been given to the alternative of expansion of the spent fuel pool. The alternative of permitting expansion may be a statutory reculatory responsi-bility pursuant to 42 U.S. Code, Section 5877, in that such
' action by the Nuclear Regulatory Commission would insure and prcmote action by the Utilities and the Department of Energy for the immediate safe and permanent disposal of spent fuel away-from-reactor sites. By permitting the alternative of re-racking the Nuclear Regulatory Commission is avoiding its statutory obligation and cerpetuating a potentially unsafe condition. The question of safety and health of the public is paramount. The ramifications of storing 24 cores at Salem #1, Salem #2, and Hope Creek
- 1 and #2, within a 17 year period is the natural consequences of permitting re-racking at Salem 11.
- 5. In addition to the original answers to interroga-tories, the following names are supplied:
George Luchak 59 MacLean Avenue Pricenton, N.J.
William Harding, 113 Valley View Road Norristown, Pennsylvania
- 6. Dr. George Luchak - Dr. Luchak's professional qualifications are attacbed. Other expert witnesses are in the process of being obtained.
LOWER ALLOWAYS C"IEK TOWMSHIP BY: [. .v' N_ ;_ ./Qiayor
- ' SAMUEL E. DOMl;LLLN I