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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20049J1761982-03-0808 March 1982 Partial Reply to First Set of Interrogatories.Requests Parts A,B & C of Contention 7 Be Withdrawn ML20041E3451982-03-0808 March 1982 Partial Reply to Util & IA-IL Gas & Electric Co First Set of Interrogatories on Contention 7 Re Vent Stack Reanalysis Rept ML20041C3551982-02-17017 February 1982 Partial Reply to First Set of Interrogatories & Request for Production of Documents.Requests Permission to Withdraw Contested Contentions 1-4.Related Correspondence ML20005C0561981-11-0909 November 1981 First Set of Interrogatories & Request for Production of Documents.Contested Contentions & Certificate of Svc Encl 1982-03-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20096A0641992-04-28028 April 1992 Comment Supporting NRC Elimination of Requirements Important to Safety from 57FR4166,dtd 920205 ML20059A9401990-08-0808 August 1990 Settlement Agreement.* Agreement Between Nrc,Rl Dickherber & Util ML20056B2031990-08-0101 August 1990 Memorandum & Order (Approving Settlement Agreement & Terminating Proceedings).* Settlement Agreement Between Rl Dickherber & NRC Approved & Proceedings Terminated Per 10CFR2.203.W/Certificate of Svc.Served on 900803 ML20056A4011990-07-30030 July 1990 Joint Motion of NRC Staff & Rl Dickherber for Approval of Settlement Agreement.* Requests That ASLB Approve Settlement Agreement & Upon Receipt of Signed Original Thereof,Enter Order & Terminate Proceeding.W/Certificate of Svc ML20055F5861990-07-0202 July 1990 Memorandum & Order (Further Deferral of Filing Dates).* Joint Motion of Rl Dickherber & NRC Filed on 900628 to Defer Filing Date for Responses to Answer of Rl Dickherber Until 900730 Granted.W/Certificate of Svc.Served on 900703 ML20055C2871990-02-23023 February 1990 Order Suspending License,Effective Immediately & Order to Show Cause Why License Should Not Be Revoked ML20246A0091989-05-0303 May 1989 Order Imposing Civil Monetary Penalty in Amount of $75,000, Based on Util Lack of Demonstration That AMP Splices Environmentally Qualified ML20155A6591988-09-0303 September 1988 Comment Supporting Petition to Rescind Paragraphs (X)(Y) of Section 10CFR50.54 Re Cases of Hazardous Practices Including Util Authorizing Senior Operator to Turn Off Safety Sys in Emergency Before Sys Has Finished Job ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons ML20133P8521985-08-0909 August 1985 Order Imposing Civil Monetary Penalty in Amount of $50,000 Based on Violation Re Operators Not Remaining at Controls During Operation of Facility ML20063A2551982-08-18018 August 1982 Response to ASLB 820728 Order.Requests Leave to Withdraw Application W/O Prejudice.Need for Transshipment in near- Term Reduced Due to Approval of Installation of High Density Spent Fuel Racks.Certificate of Svc Encl ML20051J1841982-05-11011 May 1982 Notice of Change of Address.Certificate of Svc Encl ML20050H0121982-04-0707 April 1982 List of Expert Witnesses to Be Presented on Indicated Contentions,Per ASLB 820324 Order.Certificate of Svc Encl ML20049J1761982-03-0808 March 1982 Partial Reply to First Set of Interrogatories.Requests Parts A,B & C of Contention 7 Be Withdrawn ML20041E3451982-03-0808 March 1982 Partial Reply to Util & IA-IL Gas & Electric Co First Set of Interrogatories on Contention 7 Re Vent Stack Reanalysis Rept ML20041E2101982-03-0505 March 1982 Motion to Enter Stipulated Protective Order to Govern Util Production of Proprietary & Confidential Info. Certificate of Svc Encl ML20041E2241982-02-28028 February 1982 Stipulated Protective Order Governing Intervenor Handling of Util Proprietary & Confidential Info ML20041C3551982-02-17017 February 1982 Partial Reply to First Set of Interrogatories & Request for Production of Documents.Requests Permission to Withdraw Contested Contentions 1-4.Related Correspondence ML20040G3571982-02-0101 February 1982 Request for Extension of Time to Answer Contention 1. Transcript of Special Prehearing Conference Needed to Complete Evaluation.Contention 2 Being Withdrawn.Related Correspondence ML20005C0561981-11-0909 November 1981 First Set of Interrogatories & Request for Production of Documents.Contested Contentions & Certificate of Svc Encl ML19346A3791981-06-12012 June 1981 Answer Opposing Quad-City Alliance for Safe Energy & Survival,Citizens for Safe Energy & Older Americans for Elderly Rights Petitions to Intervene.Contentions Irrelevant.W/Notices of Appearance & Certificate of Svc ML20004C4921981-05-29029 May 1981 Petition to Intervene in Spent Fuel Pool Expansion Hearing ML19346A0441981-05-29029 May 1981 Petition to Intervene in Proceeding & Request for Hearing ML20126L5431981-05-28028 May 1981 Petition to Intervene in Proceeding & Request for Hearing ML20126L5371981-05-28028 May 1981 Petition to Intervene in Proceeding & Request for Hearing ML19246C0671979-05-22022 May 1979 NRDC Response in Opposition to Comm Ed Motion for Reconsideration Or,In Alternative,For Clarification or Referral Re Adequacy of Safeguards for Spent Fuel Shipments. Motion Is Unwarranted & Inconsistent w/10CFR73 ML19246C0701979-05-18018 May 1979 NRDC Staff Scientist Statement Re Safeguards for Spent Fuel Shipments.Proposed Rule to Protect Spent Fuel Shipments Against Sabotage,Presented in 790429 Memo to Commission,Is Most Likely Adequate.Certificate of Svc Encl ML19241A9891979-05-17017 May 1979 State of Il Opposition to NRC 790504 & Comm Ed 790507 Motions for Reconsideration &/Or Clarification & Referral of ASLB 790419 Memo & Order Admitting Contentions 6 & 11 ML19241A9781979-05-10010 May 1979 NRDC Opposition to NRC Motion for Reconsideration of ASLB 790419 Memo & Order Following Special Prehearing Conference.Certificate of Svc Encl ML19269D9271979-05-0707 May 1979 Applicant Motion for Reconsideration of 790419 Memo & Order of Clarification of 780419 Order Re Physical Security of Snm.Supporting Documentation & Certificate of Svc Encl ML17266A3541979-03-27027 March 1979 Endorsement 99 to Maelu Policy MF-22 ML19274D6911979-01-26026 January 1979 Memorandum Re State of Il Contentions.Withdraws Contentions 10-12,14,15 & 17 & Submits Revised Contentions 3,10,& 11. Related Correspondence,Stipulation of Contentions,State Law & Certificate of Svc Encl ML19282A7571979-01-26026 January 1979 Nrdc'S Response to Applicant'S & Nrc'S Objections to Contentions.Urges That NRC Did Not Validly Challenge Its Contentions & That Its Contentions Should Be Admitted. Certificate of Svc Encl ML19289C9321979-01-12012 January 1979 Applicant'S Answer & Motion to Strike Re Contentions Filed by Petitioners to Intervene Nrdc,Citizens for a Better Environ & State of Il.Contentions Fail to State Claim for Which Relief May Be Granted.W/Certificate of Svc ML19263B5221979-01-0202 January 1979 State of Il Contentions Re Amends to Operating License for Transport of Spent Fuel Between Units.Contentions Assert Applicant'S Submittals Are Insufficient.W/Affidavit & Certificate of Svc ML19269C3001978-12-28028 December 1978 NRDC & Citizens for a Better Environ Statement of Contentions.Asserts Action Would Violate Nepa,Provide No Adequate Analysis of Alternatives & Increase Exposure of Workers to Radiation.W/Certificate of Svc ML19259A9271978-12-19019 December 1978 Reply by NRDC & Citizens for Better Environ to Suppl Brief of Commonwealth Edison Co.Asserts That Util Errs in Claiming That Only Direct Personal case-by-case Authorization of Litigation Can Confer Standing.Certificate of Svc Encl ML19305A0241978-12-15015 December 1978 Suppl Brief of Commonwealth Edison Co on Authorization Question.Members of NRDC & Citizens for a Better Environ Must Be Consulted Before They Are Authorized to Be Represented in Proceedings.Certificate of Svc Encl ML20064J0681978-12-11011 December 1978 Parties Agree That NRDC & Cbe Have Adequately Identified at Least One Member Whose Interest May Be Adversely Affected by the Proposed Action.Auth to Represent These Interested Members Has Not Been Agreed Upon ML19263B5291978-12-0606 December 1978 NRDC & Citizens for a Better Environ Contentions Re Util'S License Amend Re Transport of Spent Fuel Between Units. Asserts Proposed Action Violates NEPA ML20064G7001978-11-21021 November 1978 Gives Notice That a Bielawski Enters an Appearance on Behalf of Applicant Ceil in Proceedings Re Subj Facils.Cert of Svc Encl ML20064E5051978-10-30030 October 1978 Request by Comm Ed for Leave to File a Response to NRDC Brief Which Argues That Organizations May Show Standing to Participate in NRC Proceedings Merely by Alleging That They Represent Anonymous Members.Cert of Svc Encl ML20064E2511978-10-23023 October 1978 Natural Resources Defense Council Response to Commonwealth Edison'S & Staff'S Answers to Petition for Leave to Intervene.Intervenor Urges Bd to Establish a Schedule for Briefing Challenges to Contentions ML20062B4171978-10-10010 October 1978 Request for Leave to File Response to Applicant Contention Re Constitutionality of Forced Disclosure of Group Members Names in Order to Operate within State ML20058K7101973-12-18018 December 1973 Memorandum & Order.* Order Requesting Derating of Certain BWRs ML20058K5131973-12-13013 December 1973 Requests for Decision Re Immediate Derating of Nine BWRs & Implementation of Procedures to Be Followed for Consideration of Any Subsequent Action Concerning Safety Issue Raised About Plants 1999-03-02
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pf l Citizens For Safe Energy 47 P.O. DOX 23
',4' . HILLSDALE. IL 61257 Il e Cochairpersons Artyn Dad - Ere. it 1, i Boo Mdier - Chaton. l A a Secretary Marilyn 80s - Hallsdae,1L
/~ $ froasurer Phylles Hohenboken - Hillsdale.lL
- 4 Board Members Deanes Helfer - Prophetstown. lL 4i %"; ) -
Jarn Jacobs - coneseo,IL J .
h#p g . Lantz Ropp - Geneseo.lL f }l ' iff.'.e FI..-
i 3 1 Jack San:th Rock tsland.lL T ,l t3'D.F - xaren vro, nan - o4e. it
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In the n'atter of ) Docket Nos. 50-254-SY
) 50-265-SP Commonaealth Edison Company )
(Quad Cities Station, )
Units 1 and 2) )
Citizens for Safe Energy's and the Quad Cities Alliance for Safe Energy and Survival's partial reply to Co.monwealth Edison Company's and Iowa-Illinois Cas and Electric Comrnny's First Set of Interrogatories.
Contention 7:
A. Intervenors believe the letter from James R. Mcdonald of Mcdonald *tehta and Minor .
Consulting Firls and the Vant St ack Re-Analvsis Report for the Quad Cities Nuclear Power Station was helpful in sking a decision on Nrt A of Contension 7. It is stated in the conclusion of the Vent Stack Re Analysin Heoort that is would be theoretically possible for a portion of the vent stack to fall into the spent fuel pool.
Intervenors believe the addtional proposed spent fuel could be critical in case of an accident involvin6 the vent stack. However, Intervenors believe the additional purposed spent fuel will not make a vent stack accident more likely.
Intervenors request to drop Part A of Contention 7.
- 3. - C. The Intervenors have extensively researched Special Report #28 and Addendums 1 and 2, Analysis and Procedures fcr Handline General Electrie IP-300 Spent Puel' Shiceine Cask. ihe Intervenors believe modifications of the reactor building crane should stop any cask drop.
The Intervenors believe the process of placing the spent fuel in the proposed high density racks in the pool should be done in a safe and acceptable manner, not only for the worker's safety but that of the general public as well.
The Intervenors request to drop Part 3 & C of Contention 7.
Subcil ted hpMN gY Douglas all s Communicator for Citizens for Safe Energy and The Quad Cities Alliance for Safe Energy and Survival 1
8203120218 820308 PDR ADOCK 050002S4 G PDR
\
- 1. Intervenors contend that the additional spent fuel assemblies which will be stored in the proposed high density spent fuel storage racks will increase the temperature of the spent fuel pool water and cause the cladding of the fuel rods to corrode, thereby endangering the public health and safety. .
- 2. Intervenors contend that the increased amounts of irradiated fuel in the proposed spent fuel pools will increase radiological releases from the pools and occupational exposures in the pools area. In light of this, the present radiation monitoring system is' inadequate to provide a reasonable assurance of public health and safety.
Specifically, reanalysis of the present system should be required and should consider:
- a. increasing the capacity of the venti-lation system, and
- b. increasing the range, sensitivity and o
number of area radiation monitors, including Geiger-
! Mueller monitors, and monitors of the pool water I
itself.
- 3. Intervenors contend that Licensees' appli-I cation to install its proposed spent fuel storage racks should be denied, as
- a. the durability and performance of the Boraflex in the spent fuel pool water environment is
(. .jb' unknown and unsubstantiated, and l
i ammwcuurum un 1
~
Jf b. the corrosion rate of the stainless steel in the racks is unknown, and may result in their struc-tural failure, thereby failing to provide a reasonable assurance of public health and safety.
- 4. Intervenors contend that in light of the increase in decay heat which will result from the proposed increase in the spent fuel pools' storage capacity, the current capacity of the radioactive waste treatment and cooling system for the spent fuel pools will be inadequate for the proposed modification, thereby failing to provide the requisite assurance of public health and safety.
- 5. Intervenors contend that potentially exces-sive occupational exposure will occur due to removal, dismantling and dispositon of the present racks, and instal-lation and routine maintenance of the proposed high density racks, in violation of 10 C.F.R. Part 20.
- 6. Intervenors contend that the presence of l
bowed fuel assembly channels and bowed fuel rods at Quad Cities Nuclear Station will present an unacceptable risk of radiation exposure to workers and the environment during the reracking operation.
- 7. Intervenors contend that the high density fuel storage, as proposed by Licensee will present an unacceptable risk to the public health and safety, because
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of increased consequences of the following accidents:
- a. The consequences of the chimney falling on the spent fuel pool containing additional spent fuel as a result of the requested modification;
- b. The consequences of a fuel drop accident in the modified spent fuel storage pools;
- c. The consequences of a dropped fuel assembly on the five special plutonium bearing experi-mental fuel assemblies in a spent fuel pool containing more densely compacted additional spent fuel as a result of the requested modificatio:-
- 8. Quad Cities Nuclear Station's quality assurance programs and inspection procedures which will be utilized during the installation of the proposed racks and removal of existing racks are not set forth by Licensees with sufficient specificity to provide reasonable assurance of public health and safety during the reracking operations.
- 9. Intervenors contend that the proposed racks are not adequately designed to withstand the Safe Shutdown Earthquake (SSE) and Operating Basis Earthquake (OBE) established at the operating license proceeding for the Quad Cities Nuclear Station, which could lead to the release of radioactive materials which would have a detrimental effect not only on the State of Illinois but on other states as
- well.
-