|
---|
Category:INTERVENTION PETITIONS
MONTHYEARML20040G6171982-02-10010 February 1982 Response to Citizens Action for Safe Energy,Younghein & Burrell 820201 Reworded Contention on Financial Qualifications.Contention Should Be Admitted.Certificate of Svc Encl ML20040F3741982-02-0101 February 1982 Reworded Contention Re Financial Qualifications Per ASLB 811217 Order.Certificate of Svc Encl ML20040F3641982-02-0101 February 1982 Proposed Contentions in Light of SER Suppl 3 ML20039C2351981-12-22022 December 1981 Response to NRC & Applicant Responses to Contentions Re Hydrogen Control Issues.Contention Should Be Accepted by Aslb.Certificate of Svc ML20062M3441981-12-0808 December 1981 Response to Citizens Action for Safe Energy,L Burrell & I Younghein 811120 Proposed Contentions.Opposes Hydrogen Control Contention as No Issue of Fact Suitable for Resolution Stated & Contention Lacks Reasonable Specificity ML20005C0201981-11-0505 November 1981 Proposed Contentions for Continued Radiological & Safety Hearings ML19320A7861980-06-24024 June 1980 Motion to Intervene as Interested State in Case 80-1566 Before Us Court of Appeals for DC Circuit.Nrc Regulations Grant States Legal Right to Intervene at Appeal Stage. Certificate of Svc Encl.Related Correspondence 1982-02-10
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20040G6171982-02-10010 February 1982 Response to Citizens Action for Safe Energy,Younghein & Burrell 820201 Reworded Contention on Financial Qualifications.Contention Should Be Admitted.Certificate of Svc Encl ML20040F3741982-02-0101 February 1982 Reworded Contention Re Financial Qualifications Per ASLB 811217 Order.Certificate of Svc Encl ML20040F3641982-02-0101 February 1982 Proposed Contentions in Light of SER Suppl 3 ML20039C2351981-12-22022 December 1981 Response to NRC & Applicant Responses to Contentions Re Hydrogen Control Issues.Contention Should Be Accepted by Aslb.Certificate of Svc ML20062M3441981-12-0808 December 1981 Response to Citizens Action for Safe Energy,L Burrell & I Younghein 811120 Proposed Contentions.Opposes Hydrogen Control Contention as No Issue of Fact Suitable for Resolution Stated & Contention Lacks Reasonable Specificity ML20005C0201981-11-0505 November 1981 Proposed Contentions for Continued Radiological & Safety Hearings ML19320A7861980-06-24024 June 1980 Motion to Intervene as Interested State in Case 80-1566 Before Us Court of Appeals for DC Circuit.Nrc Regulations Grant States Legal Right to Intervene at Appeal Stage. Certificate of Svc Encl.Related Correspondence 1982-02-10
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20138G3821985-12-12012 December 1985 Order Denying Utils 851029 Request for NRC to Reconsider 850918 Denial of Fee Exemption Request.Situation Does Not Merit Special Treatment.Final Action Will Be Taken After Fee Correctness Matters Resolved.Served on 851212 ML20138K0661985-12-12012 December 1985 Transcript of 851212 Affirmation/Discussion & Vote in Washington,Dc Re SECY-85-367A on Palo Verde 1 Leaseback & SECY-85-371 on Refund on Black Fox License Fee.Pp 1-4 ML20127B0071985-06-14014 June 1985 Application for Waiver of Withdrawal Fees Under 10CFR170.12 for Plant.Assessment of Fees Would Violate Fairness, Public Policy & Value to Applicant Principles.Cancellation of Project Due to NRC Actions.Certificate of Filing Encl ML20127B0221985-06-12012 June 1985 Brief in Support of Application for Waiver of Withdrawal Fees Under 10CFR170.12.Unique Circumstances Described. Informal Hearing Requested.Certificate of Filing Encl ML20132B4341985-06-12012 June 1985 Application for Waiver of Withdrawal Fees Under 10CFR170.12(b).Assessment of Fees Violates Fairness,Public Policy & value-to-applicant Principles of Independent Ofcs Appropriation Act of 1952.Supporting Brief Encl.W/O Encl ML20073B9761983-04-0707 April 1983 Motion to Dismiss Remaining Environ Issue.Aslb 830307 Order Revoked Plant LWA & Published Notice of Withdrawal of Application for Cps.Certificate of Svc Encl ML20071B8151983-02-25025 February 1983 Response to Applicant Motion for Termination of Proceeding & Withdrawal of Application.State of Ok Does Not Intend to File Objections to Motion.Certificate of Svc Encl ML20064N5181983-02-0707 February 1983 Motion for Extension Until 830223 to Respond to Util 830123 Motion for Termination of Proceeding & Withdrawal of Application.W/Certificate of Svc ML20028F1971983-01-24024 January 1983 Notice of Substitution of ML Bardrick for Sj Drake as State of Ok Representative.Certificate of Svc Encl ML20070N7831983-01-23023 January 1983 Motion for 2-day Extension to Respond to ASLB 830107 Order Until 830123.Certificate of Svc Encl ML20070N8211983-01-23023 January 1983 Motion for Termination of Proceeding & Withdrawal of Application.Site Will Be Used for Alternative Power Generation Facility.Site Redress Plan Will Address Return of Site to Undisturbed Condition.Certificate of Svc Encl ML20028C3361983-01-0404 January 1983 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20054J8331982-06-23023 June 1982 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20054G1811982-06-18018 June 1982 Memorandum & Order Denying W/O Prejudice,Applicant 820406 Motion for Termination of Proceeding & Withdrawal of Application.Insufficient Info Exists to Grant Motion Since Util Undecided on Future Plans for Site ML20053D1951982-05-24024 May 1982 Affidavit of JB West on NRC Concerns Expressed During 820517 Site Visit Re Potential Offsite Environ Impact of Erosion & Siltation in Area of Inclined Reactor Pressure Vessel Haul Road Leading from Barge Slip Facilities ML20052G8341982-05-14014 May 1982 Response to ASLB 820429 Order Re Site Redress.Final Decision on Site Redress Should Be Deferred Until Decision Made by End of 1982 on Future Power Projects.Certificate of Svc Encl ML20052G8381982-05-13013 May 1982 Affidavit of JB West Describing Preliminary Site Const Activities Undertaken & Current Plans for Site Redress ML20050E2821982-04-0606 April 1982 Motion for Termination of Proceeding & Withdrawal of Application W/O Prejudice.Util on 820216 Decided to Cancel Plants.Certificate of Svc Encl ML20040H4671982-02-12012 February 1982 Response to NRC & Applicant Opposition to Intervenor Motion to Reopen Record on ECCS Matters ML20040H4741982-02-11011 February 1982 Affidavit of Gc Minor Re ECCS Issues.Results of Tests or Analyses Which Erode Basis for Assumed Adequacy Must Be Resolved or Possible Design Deficiencies Corrected to Assure Safe Operation.Certificate of Svc Encl ML20040G6171982-02-10010 February 1982 Response to Citizens Action for Safe Energy,Younghein & Burrell 820201 Reworded Contention on Financial Qualifications.Contention Should Be Admitted.Certificate of Svc Encl ML20040F3641982-02-0101 February 1982 Proposed Contentions in Light of SER Suppl 3 ML20040F3741982-02-0101 February 1982 Reworded Contention Re Financial Qualifications Per ASLB 811217 Order.Certificate of Svc Encl ML20040D5691982-01-25025 January 1982 Interrogatories & Request for Production of Documents,Per ASLB 811014 & 1217 Orders.Certificate of Svc Encl ML20040D5711982-01-25025 January 1982 Interrogatories & Request for Production of Documents,Per ASLB 811014 & 1217 Orders.Certificate of Svc Encl ML20040D8371982-01-25025 January 1982 Reply Opposing Citizens Action for Safe Energy,L Burrell & I Younghein 820120 Motion to Abate Proceedings.Ok Corporation Commission Opinion Only Advisory & Alternatives to Cancellation Are Viable.Certificate of Svc Encl ML20040C0801982-01-21021 January 1982 Motion for Extension of Time Until 820102 to Respond to Intervenors' Motion to Reopen Record Re ECCS Models Deficiencies.Licensee Affiant Seriously Ill & No Other Affiant Available.Certificate of Svc Encl ML20040C0591982-01-20020 January 1982 Motion to Abate Proceedings Until 820125.OK Corp Commission 820115 Order Directed Applicants to Advise Commission of Decision on Whether to Proceed W/Const within 30 Days. Certificate of Svc Encl ML20040A9641982-01-15015 January 1982 Decision of Ok Corporation Commission Denying Util Request for Rate Base Treatment of Const Investment for Facility. Proposes Facility Be Converted to Coal.Nrc Dilatory Actions Re TMI Accident Cited as Influencing Factors ML20040A8221982-01-11011 January 1982 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20039G1041982-01-0707 January 1982 Motion for Extension of Time Until 810122 to Reply to Intervenor Motion to Reopen Record Re ECCS Model Deficiencies.Info Supporting Motion to Reopen Record within GE Custody So GE Must Review Matl.Certificate of Svc Encl ML20039E8671982-01-0505 January 1982 Affidavit That Neither Interim Containment Loads Rept, Mark III Containment, Revisions 3 or 4 or Info in Mb Fields Dec 1981 Memo Have Any Significant Effect on Preliminary Mark III Containment Design of Facility ML20039E1111981-12-29029 December 1981 Motion to Reopen Record Re ECCS Model Deficiencies.Board Notification 81-49 Indicates Discovery of Info of Matters of Serious Safety Significance & Warrants Reopening of Record. Certificate of Svc Encl ML20039C2351981-12-22022 December 1981 Response to NRC & Applicant Responses to Contentions Re Hydrogen Control Issues.Contention Should Be Accepted by Aslb.Certificate of Svc ML20039B0841981-12-14014 December 1981 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20062M3441981-12-0808 December 1981 Response to Citizens Action for Safe Energy,L Burrell & I Younghein 811120 Proposed Contentions.Opposes Hydrogen Control Contention as No Issue of Fact Suitable for Resolution Stated & Contention Lacks Reasonable Specificity ML20039A1791981-12-0808 December 1981 Notice of Appearance in Proceeding ML20005C0661981-11-10010 November 1981 Reply to Intervenors 811105 Motion for Extension Until 811121 to File Addl Contentions.Util Does Not Opppose Motion.Response Date of 811208 Should Be Established. Certificate of Svc Encl ML20005C1051981-11-0505 November 1981 Motion to Modify ASLB 811014 Order by Extending Until 811121,time within Which to Identify & Propose Contentions Re Hydrogen Control.J Callo 811021 Ltr & Certificate of Svc Encl ML20005C0201981-11-0505 November 1981 Proposed Contentions for Continued Radiological & Safety Hearings ML20010D1671981-08-18018 August 1981 Notice of Change of Svc List.Ja Basile Should Replace Vl Conrad ML19345A7161980-10-31031 October 1980 Order Transferring Civil Action 80-2659 to Us District Court for Central District of Il.Reed Rept May Not Be Released Pending Disposition ML19344E2531980-08-25025 August 1980 Motion for Appearance of FW Taylor & Withdrawal of Rf Berger in Civil Action 80-1566 Before Us Court of Appeals for DC Circuit ML19344B3121980-08-18018 August 1980 Notice of Withdrawal in Proceeding.Certificate of Mailing Encl ML19344B3131980-08-18018 August 1980 Notice of Appearance in Proceeding.Certificate of Mailing Encl ML19330B2201980-06-30030 June 1980 Notices of Jg Thomas & CS Rogers Withdrawal & Rf Berger Appearance in Proceeding.Certificate of Svc Encl ML19320A7861980-06-24024 June 1980 Motion to Intervene as Interested State in Case 80-1566 Before Us Court of Appeals for DC Circuit.Nrc Regulations Grant States Legal Right to Intervene at Appeal Stage. Certificate of Svc Encl.Related Correspondence ML19344D7871980-04-0707 April 1980 Brief Amicus Curiae Re Certified Question of Whether Litigation of Health Effects of Normal Radioactive Releases Is Barred as Matter of Law.Issue Is Precluded in Absence of Special Circumstances.W/Certificate of Svc ML19305E0841980-04-0707 April 1980 Memorandum Stating Views Re Question Certified in ALAB-573. Consideration of Health Effects from Emission within App 1 Limits Is Central & Controlling Factor.Certificate of Svc Encl ML19305E1741980-04-0101 April 1980 Statements of Position Re Certified Question of App 1 of 10CFR50 Concerning Litigation of Health Effects of Routine Radioactive Emissions.Urges Dismissal of Inquiry.Certificate of Svc Encl 1985-06-14
[Table view] |
Text
. .a, 00(.XET ED : -- ,
u ;'? C mt .
UNITED STATES OF K4 ERICA -
E'T NUCLEAR REGULATORY COMMISSION b hp 9, '
i BEFORE THE ATOMIC SAFETY AND LICENSING-rBOARD ~Lf ant i .u a BC $0.
s amC S/ ,0EM,gip
-c "11 r
In the Matter of the Application of ) ,
Public Service Company of Oklahoma, ) , - gess4T 88 p' j ss .
Associated Electric Cooperative, Inc. )
~
wt s- .
~
' ~
and ) ,
~]'
Western Farmers Electric Cooperative } Docket Nos. N =
n
) STN 50-556CP s 's (Black Fox Units 1 and 2) ) STN 50-557CP .
m N %~ ,-] 4 INTERVENORS' ARGUMENTS IN RESPONSE 6 '
TO NRC STAFF AND APPLICANT'S RESPONSES ,
Te CONTENTIONS CONCERNING HYDROGEN CONTROL ISSUES m On November 20, 1981, the Intervenors proposed certain ^
~
Hydrogen Control Contentions in response to the Applicant'd Amendment No. 18 to the PSAR. Both Staff and Applicants ' ,
~
filed responses to these proposed contentions on December Bj 1981. Pursuant to oral application of the Intervenors, the' Board decided at the December 19, 1981, prehearing conference s
to accept Intervenors' written arguments on this issue within" ,
fourteen (14) days of the prehearing conferen,ce. The following are Intervenors' comments and arguments in respon~se to the ,
-s staff and Applicant: u e
A. Response to Applicant & Staff Responses Staff argues that there is insufficient basis for the i
Intervenors contention and that it requires the Applicant to ,
- e 8112290096 811222' PDR ADOCK 05000556 h0 '
G PDR ,
= =w-m-, -,-,--w- ,-,-m -p y -y m - .- , - -----~..,.m ..v
+r- m. ---y - wy v
,-3.- --y, -.c, , . , _ . . - - ,
I
. '2
= ..' -
~
j ,
do more'than the Applicant is compelled by the proposed rule
- (S taf f at' p. 6) . Tne proposed rule defining hydrogen control
- issues,'and_ design analyses for BWR Mark III containments has not yet been issued (see SECY-81-245A) and thus there is no basis to evaluate whether intervonors have required more or
" less. The information provided to date does not provide the necessary information to satisfy the needs for preliminary design informatioh in the areas detailed in the intervenors' contention.
_ B. Issues Supportive of Intervenor Contention on Hydrogen Control
~There i.a insufficient preliminary design data provided to insure that'the Applicant has considered the worst case accident (and potential for local concentrations) in terms of hydrogen
~
generatiori and release rate and its effect on the containment and
^
safety.related equipment potentially subjected to repeated hydrogen burns. 53r has the Applicant described the nature and accepta-u.
. bility of'the decision criteria to be used by the operators in determining.when to activate the DIS. There is insufficient
- preliminary ' design data to show that the ignitors and other safety.-related equipment (such as containment penetrations) will be qualified to assure the ability to withstand all potential l ' . '
I dent conditions. There is insufficient preliminary design
.nformation to-chow how the Applicant plans to verify that the requireil surveillance tests and procedures will in fact insure the op.erabil'ity and functionability of the DIS for the full range m -
1 l 'of accident condition.
m" l
/ ,
2
r F .
)
Further,' there are features of the Mark III containment which introduce safety related equipment to a different accident l
environment than previous containment designs. An example is
/ c
~
' the_ location of the Hydraulic Control Units. The Applicant
,;, f j? ' , has not included adequate consideration of the potential effects of hydrogen burns on these critical safety-related com-47 ponents.
In addition, the Applicant described research and development R- u j
./ programs to be performed by many different organizations.
How-g ever, there is no assurance that they have provided the necessary V ,_ ;
.,a a ; +
e integration of the projects to produce the desired results and to j ,
fcomply'with the necessary Quality Assurance Criteria (10 CFR 50
,w .;
.. ; i Appendix B).
.o ; CONCLUSION
- b I
- j. 3 Intervenors respectfully submit, therefore, that their l Hydrogen Control Contention (and all subparts thereof) should be accepted by the Board pursuant to 10 CFR S 2.714.
P ,1
~
JOSEPH R. FARRIS NANCY L. WOODS l FELDMAN HAL ,F DEN & WOODARD
./
By b,
[ Aos/dph R. Farris 816 gaterprise Building
+ Tulsa, OK 74103 918/583-7129 ATTORNEYS FOR INTERVENORS f
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
,BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of the Application of )
Public Service Company of Oklahoma, )
Associated Electric Cooperative, Inc. )
and )
Western Farmers Electric Cooperative ) Docket Nos.
) STN 50-556CP (Black Fox Units 1 and 2) ) STN 50-557C; CERTIFICATE OF SERVICE I, Joseph R. Farris, one of the attorneys for Citizens Action for Safe Energy (C. A.S .E . ) , certify that copies of the following:
"Intervenors' Arguments In Response to NRC Staf f and Applicant's Responses to Contentions Concerning Hydrogen Control Issues" have been served on the persons shown on the attached list by United States Mail, postage prepaid, this 22nd day of December , 1981.
[' .
W92 Joseph R. Fa rris ' ~
Sheldon J. Wolfe, Esq. Andrew T. Dalton, Esq.
Atomic Safety and Licensing Attorney at Law Board Panel 1437 South Main Street United States Nuclear Room 302 Regulatory Commission Tulsa, Oklahoma 74119 Washington, D.C. 20555 Mrs. Ilene Younghein Mr. Frederick J. Shon 3900 Cashion Place Atomic Safety and Licensing Oklahoma City, OK 73112 Board Panel United States Nuclear Mrs. Carrie Dickerson Regulatory Commission Citizens Action for Washington, D.C. 20555 Safe Energy P. O. Box 924 Dr. Paul W. Purdom Claremore, Oklahoma 74017 Director, Environmental Studies Group Joseph Gallo, Esq.
Drexel University Martha E. Gibbs 32nd and Chestnut Streets Frederick C. Williams Philadelphia, PA 19104 Isham, Lincoln & Beale 1120 Connecticut Ave.,N.W.
Docketing and Service Section Washington, D.C. 20036 Office of the Secretary of the Commission Michael I. Miller United States Nuclear Phillip P. Steptoe Regulatory Commission Isham, Lincoln & Beale Washington, D. C. 20555 One First National Plaza, (20 copies) Suite 4200 Chicago, Ill. 60603 Atomic Safety and Licensing Board Panel Mr. Maynard Human United States Nuclear General Manager Regulatory Commission Western Farmers Electric Washington, D. C. 20555 Cooperative P. O. Box 429 Atomic Safety and Licensing Anadarko, Oklahoma 73005 Appeal Board Panel United States Nuclear Mr. Gerald F. Diddle Regulatory Commission Associated Electric Washington, D. C. 20555 Cooperative, Inc.
P. O. Box 754 Mr. Clyde Wisner Springfield, Missouri 65801 NRC Region 4 Public Affairs Officer Mr. Lawrence Burrell 611 Ryan Plaza Drive Rt. 1, Box 197 Suite 1000 Fairview, Oklahoma 73737 Arlington, Texas 76011 Dr. M. J. Robinson Black & Veatch P. O. Box 8405 Kansas City, Mo. 64114
Dr. John Zink Public Service Company of Oklahoma P. O. Box 201 Tulsa, Oklahoma 74102 Mr. T. N. Ewing Public Service Company of Oklahoma P. O. Box 201 Tulsa, Oklahoma 74102 Hon. Michael Bardrick
'~
Assistant Attorney General State of Oklahoma State Capitol Building Oklahoma City, Oklahoma 73105 i
Mr. Gregory Minor MHB Technical Associates 1723 Hamiton Ave.
Suite K San Jose, CA 95125 i
Samuel J. Chilk
- Secretary of the Commission United States Nuclear
> Regulatory Commission Washington, D.C. 20555 i
I l
l l
l l
L