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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20209H6691999-07-12012 July 1999 Comment Supporting Proposed Rule 10CFR50 Re Elimination of Requirement for Licensees to Update Inservice Insp & Inservice Testing Programs Beyond Baseline Adition & Addenda of ASME BPV Code ML20203G6131998-01-26026 January 1998 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Interim Rept 739459-97,dtd 971015 Be Withheld from Public Disclosure ML20203G6031997-12-0404 December 1997 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 Be Withheld from Public Disclosure PLA-4330, Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control1995-06-0808 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control PLA-4193, Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety1994-08-31031 August 1994 Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety ML20046A9531993-07-20020 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. Opposes Rule ML20045F7971993-06-21021 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule in Part & Opposes Rule in Part ML20045D7461993-06-21021 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Disagrees W/Maintaining 100% Rate for Contractor & Vendor Employees ML20044F8361993-05-24024 May 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. Opposes Rules ML20044F7511993-05-24024 May 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. PLA-3744, Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners1992-03-0909 March 1992 Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners PLA-3568, Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a1991-04-0808 April 1991 Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a PLA-3462, Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants1990-10-15015 October 1990 Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants ML19332G5261989-12-0606 December 1989 Comments on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Industry Has Made Substantial Progress Re Maint Performance as Indicated by Respective Performance Indicators,Commission Insps & Plant Conditions PLA-3175, Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants1989-03-29029 March 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235V4001989-03-0202 March 1989 Comment on Proposed Rule 10CFR50 Re Maint Program at Nuclear Plants.Proposed Maint Rule Has Potential to Significantly Undermine Util Initiatives & Direct Limited Resources Away from Real Improvements in Maint PLA-3157, Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained1989-02-24024 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained PLA-3118, Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule1988-11-17017 November 1988 Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule 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 PLA-3019, Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking1988-04-15015 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking PLA-2726, Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift1986-09-25025 September 1986 Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift ML20138A9521985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20027D4441982-11-0202 November 1982 Response to Aslab 821026 Order Requesting Info on RCS Leak Rate Detection.Util Preparing Tech Spec to Limit Increase in Unidentified RCS Leakage to 2 Gpm within 4-h Period ML20027D4471982-11-0101 November 1982 Affidavit of Wj Rhoades Correcting Response to Hearing Question on Leak Rates.Leak Rate Sys Capable of Detecting 1 Gpm Per Hour.Tech Specs Will Require Shutdown for Unidentified Leakage of 5 Gpm.Certificate of Svc Encl ML20069D8321982-09-0909 September 1982 Original Signature Page to Sh Cantone Affidavit.Svc List Encl ML20027B2291982-09-0909 September 1982 Stipulation of Withdrawal of Commonwealth of PA 820428 Exceptions Re Supply of TLD ML20065A9541982-09-0909 September 1982 Affidavit of Sh Cantone Re Dosimetry for Emergency Workers at Plant.Prof Qualifications Encl ML20027B2231982-09-0909 September 1982 Motion to Withdraw Commonwealth of PA 820428 Exceptions to Initial Decision,Contingent Upon Approval of Util & Commonwealth of PA 820909 Stipulation ML20027B2351982-09-0808 September 1982 Affidavit of AL Belser & Rj Hippert Responding to Questions in Aslab 820820 Order & Supporting Stipulation Withdrawing Exceptions.When Stipulated Number of Dosimeters Available, Emergency Workers Will Be Protected.W/Certificate of Svc ML20027B2331982-09-0808 September 1982 Affidavit of Ma Reilly Responding to Question in Aslab 820820 Order & Supporting 820909 Stipulation. TLD Necessary to Document Exposure of Officials Helping Contaminated Evacuees ML20063A4041982-08-18018 August 1982 Petition for Reconsideration of Commission 820809 Order Rendering ASLB Initial Decision Effective.Exceptions to Decision Require Resolution.Commission Order Premature. Certificate of Svc Encl ML20062J6391982-08-13013 August 1982 Order Directing Parties to Identify Person Presenting Arguments at 820908 Hearing in Bethesda,Md.Response Requested No Later than 820831 ML20058J6651982-08-0909 August 1982 Order Rendering ASLB 820412 Decision Authorizing OL Issuance Effective.Full Power OL Not Yet Authorized ML20054L5081982-07-0606 July 1982 Brief Opposing Commonwealth of PA 820428 & Citizens Against Nuclear Dangers 820421 Exceptions to ASLB 820412 Initial Decision.Pa Fails to Prove Dosimetry Issue Timely Raised. Citizens Failed to Comply W/Procedure.W/Certificate of Svc ML20054L2841982-07-0202 July 1982 Brief Opposing Commonwealth of PA 820428 Exceptions to ASLB 820412 Initial Decision Authorizing OL Issuance.Commonwealth Fails to Justify License Condition Imposition Re Availability of Dosimetry.Certificate of Svc Encl ML20054J5611982-06-25025 June 1982 Brief Opposing Citizens Against Nuclear Danger 820421 Exceptions to ASLB 820412 Initial Decision.Exceptions Fail to Comply W/Commission Regulations & Raise Issues Not Presented Before Aslb.Certificate of Svc Encl ML20053D2191982-05-28028 May 1982 Brief Supporting Commonwealth of PA Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20053D0801982-05-28028 May 1982 Brief in Support of Exceptions to ASLB 820412 Initial Decision Authorizing Issuance of Ols.Shortage in Supply of Dosimeters for Emergency Workers Clear & Uncontroverted. Certificate of Svc Encl ML20052B7461982-04-28028 April 1982 Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20052A2751982-04-21021 April 1982 Exceptions to ASLB Initial Decision.Certificate of Svc Encl ML20054C6551982-04-15015 April 1982 Response Opposing Citizens Against Nuclear Dangers 820402 Proposed Findings of Fact & Conclusions of Law.Requirements for Reopening Record Not Met.No Showing That Allegations Raise Significant Safety Issues.Certificate of Svc Encl ML20050D4191982-04-0202 April 1982 Proposed Findings of Fact & Conclusions of Law Based on Important New Info & Recommendations to NRC Commissioners & Congress.Certificate of Svc Encl ML20042C2701982-03-26026 March 1982 Proposed Findings of Fact & Conclusions of Law Re Emergency Evacuation Plan ML20042C2781982-03-26026 March 1982 Motion for Order That Applicants Conduct Complete Retest of Emergency Plan W/All 20 Communities Participating.Testimony on Contentions 6 & 20 Should Be Reviewed to Identify Perjury by Fema,Applicants & State of Pa.Certificate of Svc Encl ML20069B0301981-12-22022 December 1981 Reply to Parties' Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20039B0791981-12-16016 December 1981 Proposed Transcript Corrections.Certificate of Svc Encl ML20062M2141981-12-0909 December 1981 Proposed Transcript Corrections ML20039A1951981-12-0909 December 1981 Proposed Findings of Fact & Conclusions of Law ML20038C0131981-12-0303 December 1981 Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20038A8891981-11-17017 November 1981 Motion to Take Official Notice of Existence & Content of Listed Documents Relevant to Contention 21.Validity of Info in Documents Could Be Subj to Dispute.Certificate of Svc Encl.Related Correspondence 1999-07-12
[Table view] Category:PLEADINGS
MONTHYEARML20027B2231982-09-0909 September 1982 Motion to Withdraw Commonwealth of PA 820428 Exceptions to Initial Decision,Contingent Upon Approval of Util & Commonwealth of PA 820909 Stipulation ML20063A4041982-08-18018 August 1982 Petition for Reconsideration of Commission 820809 Order Rendering ASLB Initial Decision Effective.Exceptions to Decision Require Resolution.Commission Order Premature. Certificate of Svc Encl ML20052B7461982-04-28028 April 1982 Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20042C2781982-03-26026 March 1982 Motion for Order That Applicants Conduct Complete Retest of Emergency Plan W/All 20 Communities Participating.Testimony on Contentions 6 & 20 Should Be Reviewed to Identify Perjury by Fema,Applicants & State of Pa.Certificate of Svc Encl ML20038A8891981-11-17017 November 1981 Motion to Take Official Notice of Existence & Content of Listed Documents Relevant to Contention 21.Validity of Info in Documents Could Be Subj to Dispute.Certificate of Svc Encl.Related Correspondence ML20011A2321981-10-0101 October 1981 Support for Contention 4 & Position on New Contentions. Motion for Summary Disposition of Contention 4 Should Be Denied Since Util Cancellation of Unit 2 May Be Best Solution.Certificate of Svc Encl ML20011A2121981-09-30030 September 1981 Appeal of ASLB 810924 Memorandum & Order,Section 5,granting Applicant Motion for Summary Disposition of Portion of Contention 2 Re Magnitude of Doses from Releases of Radioactive Matl.No Basis to Decision.W/Certificate of Svc ML20010J6231981-09-30030 September 1981 Response Supporting NRC 810911 Motion for Summary Disposition of Portion of Contention 1 Re Radiological Health Effects of Isotopes Other than Rn-222 & Tc-99.Health Effects Adequately Addressed in Fes ML20010H7931981-09-22022 September 1981 Answer Opposing Citizens Against Nuclear Dangers 810912 Notice of Appearance for Purposes of Presenting Direct Testimony & Motions Before Aslb.Consolidation of Contentions Unnecessary.Certificate of Svc Encl.Related Correspondence ML20140B1981981-09-10010 September 1981 Response Supporting Applicants 810828 Motion for Partial Summary Disposition of Contention 1 Re Fuel Cycle Doses.Also Moves for Summary Disposition of Portion of Contention 1 Re Radiological Health Effects of All Isotopes ML20140B1931981-09-10010 September 1981 Answer Opposing Susquehanna Environ Advocates 810822 Motion for Allowance of New Contention.Motion Is Untimely & Balancing Factors Do Not Weigh in Intervenors Favor. Certificate of Svc Encl ML20140B1651981-09-10010 September 1981 Motion for Summary Disposition of Contention 14 Re cost-benefit Balance.No Genuine Issue of Matl Fact Exists & NRC Entitled to Favorable Decision as Matter of Law ML20010G2271981-09-0808 September 1981 Comments on Susquehanna Environ Advocates 810831 Filing on Expert Witnesses.Filing Inadequate & Fails to Meet ASLB 810814 Mandate.Reserves Right to Seek Relief If Intervenor Files Testimony.W/Certificate of Svc.Related Correspondence ML20010G2981981-09-0808 September 1981 Response to ASLB 810814 Memorandum & Order,Filing Qualifications,Identities,Subj Matter & Substance of Testimony of Expert Witnesses for Contentions 2,6,9,11,14,20 & 21.Certificate of Svc Encl.Related Correspondence ML20140B4381981-09-0202 September 1981 Answer to Citizens Against Nuclear Dangers 810827 Filing. Applicants Oppose Several Motions & Arguments.Allegations Re Chlorine Portion of Contention 2 Are Moot.No Valid Reason for Addl Prehearing Conference.Certificate of Svc Encl ML20010F4541981-08-31031 August 1981 Motion for Summary Disposition of Contention 7C Re BWR Core Spray Nozzle Cracking.No Genuine Issue of Matl Fact Exists. Certificate of Svc Encl.Related Correspondence ML20010F5411981-08-31031 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 7B.Certificate of Svc Encl ML20010F4741981-08-31031 August 1981 Motion for Summary Disposition of Contention 7B Re Cracking of Stainless Steel Piping in BWR Coolant Water Environ Due to Stress Corrosion.No Genuine Issue of Matl Fact Exists ML20010F4431981-08-31031 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 7C.Related Correspondence ML20005B7991981-08-28028 August 1981 Motion for Partial Summary Disposition of Portion of Contention 1 Re Magnitude of Radioactive Doses That Will Be Imparted on Public by Release of All Isotopes During Fuel Cycle.Certificate of Svc Encl.Related Correspondence ML20005B8241981-08-28028 August 1981 Statement of Matl Fact as to Which There Is No Genuine Issue,Supporting Applicants Motion for Summary Disposition of Contention 1 Re Fuel Cycle Doses.Related Correspondence ML20010F4001981-08-27027 August 1981 Response in Opposition to ASLB 810814 Directives & Motions on Testimony & Public Hearings Conference.Date That Correspondence Is Required to Be Mailed Is Incorrect & Only Two Aspects of Contention 2 Are Listed for Consideration ML20010C9811981-08-19019 August 1981 Statement of Issues for Commonwealth of PA Participation,Per ASLB 810727 Memorandum & Order.Particular Interest Shown in Contentions 5,7(D),11 & 21.Related Correspondence ML20010C8631981-08-18018 August 1981 Renewed Motion for Summary Disposition of Contention 17.No Genuine Issue of Matl Fact to Be Heard.Applicants Are Entitled to Favorable Decision as Matter of Law ML20010C8671981-08-18018 August 1981 Memorandum Supporting Applicants' 810818 Renewed Motion for Summary Disposition of Contention 17.Michaelson Affidavit Sufficiently Addresses Issues & Constitutes Adequate Basis for Granting Motion ML20010C9491981-08-18018 August 1981 Statement of Matl Facts as to Which There Is No Geniune Issue to Be Heard Re Contention 17.Certificate of Svc Encl ML20010C0771981-08-13013 August 1981 Motion for Partial Summary Disposition of Contention 2 Which Questions Magnitude of Facility Low Level Radioactive Releases.Certificate of Svc Encl ML20010C1471981-08-13013 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Contention 2 on Source Term ML20010C9781981-08-10010 August 1981 Memorandum of Law in Response to Applicants' 810727 Ltr.All Parties in Proceeding Have Right to Present Rebuttal Evidence.Related Correspondence ML20010B3971981-08-0707 August 1981 Memorandum in Support on 810807 Motion for Summary Disposition of Contention 1 Re Quantity of Rn-222 to Be Released During Fuel Cycle ML20010B4091981-08-0707 August 1981 Statement of Matl Fact as to Which There Is No Genuine Issue Re Contention 1 Concerning Rn-222 ML20010B4041981-08-0707 August 1981 Motion for Summary Disposition of Contention 1 Re Rn-222. Issue Should Not Be Relitigated Under Accepted Principles of Collateral Estoppel & Stare Decisis.No Genuine Issue to Be Heard ML20009H2281981-08-0404 August 1981 Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard in Support of Motion for Summary Disposition of Contention 7(a).Related Correspondence ML20009H2301981-08-0404 August 1981 Motion for Summary Disposition of Contention 7(a).No Genuine Issue of Matl Fact Exists.Certificate of Svc Encl. Related Correspondence ML20009G9951981-08-0303 August 1981 Memorandum Supporting Applicant Motion for Summary Disposition of Contention 3.Assertions Refuted in Jm Vallance Affidavit & Some Assumptions Are Contrary to Aslab Rulings ML20009H0251981-07-30030 July 1981 Motion for Summary Disposition of Contention 3.No Genuine Issue of Matl Fact Exists & Applicants Are Entitled to Decision as Matter of Law.Certificate of Svc Encl ML20009F8371981-07-28028 July 1981 Statement of Matl Fact as to Which There Is No Genuine Issue to Be Heard Re Contention 11 on Onsite Storage of Spent Fuel ML20009F8431981-07-28028 July 1981 Motion for Partial Summary Disposition of Contention 11 Re Onsite Storage of Spent Fuel.No Genuine Issue of Matl Fact Exists.Motion Supported by C Herrington & DW James Affidavits.Certificate of Svc Encl ML19345G8391981-04-0909 April 1981 Answer Opposing Citizens Against Nuclear Danger 810327 Motion Requesting Hearing on Applicants' 801223 SNM License Application.Motion Does Not Comply W/Commission Regulations. Certificate of Svc Encl ML19290G6301980-11-24024 November 1980 Request to Deny Applicants' Motion for Summary Disposition of Contention 2 Re Chlorine Due to Studies Demonstrating Relationship Between Cancer Rates & Chlorinated Compounds in Drinking Water.W/Certificate of Svc ML18030A4731980-11-0606 November 1980 Motion for Partial Summary Disposition of Contention 2 Re Health Effects of Discharged Chlorine.Responses Due within Three Wks from Present Filing ML18030A4131980-11-0606 November 1980 Statement of Matl Facts Re Absence of Issue to Be Heard,In Support of Motion for Partial Summary Disposition of Contention 2 on Health Effects of Discharged Chlorine ML18030A0181980-11-0606 November 1980 Pleading in Support of Motion for Partial Summary Disposition of Contention 2 Re Health Effects of Discharged Chlorine.Issue Narrowed by Intervenor/Sponsor Via Response to NRC Interrogatories.W/Certificate of Svc ML18030A1621980-10-29029 October 1980 Response in Opposition to Environ Coalition on Nuclear Power Petition for Commission Review of ALAB-613.Intervenor Petition Sets Forth Nothing Which Warrants Different Conclusion.Certificate of Svc Encl ML18030A1591980-10-27027 October 1980 Statement of Matl Facts Re Absence of Genuine Issue to Be Heard,In Support of Summary Disposition of Contention 16 on Cooling Tower Discharge.Sys Designed to Evaporate Water Daily from Towers W/O Radioactive Releases ML18026A3101980-10-10010 October 1980 Response in Opposition to Applicant Request Re Interrogatories on Safety Issues.Environ Phase Must Take Priority Over safety-related Discovery Per ASLB 791030 Order.Certificate of Svc Encl ML18030A1401980-08-22022 August 1980 Statement of Matl Facts as to Which No Genuine Issue Exists to Be Heard in Support of Request for Summary Disposition of Ozone Portion of Contention 17.Max Ground Level Ozone Concentrations Near Lines Will Be Far Below Allowable Limit ML18030A1431980-08-22022 August 1980 Request for Free Hearing Transcripts Per 800725 Fr Notice Re Procedural Assistance Change in Adjudicatory Licensing Proceedings.Prior Denials Damaged Ability to Properly Litigate Contentions.Certificate of Svc Encl ML18030A4411980-08-22022 August 1980 Request for Summary Disposition of Portion of Contention 17 Dealing W/Ozone.No Genuine Issue of Matl Fact Exists to Be Heard.Responses Due in Three Wks ML18026A3001980-06-13013 June 1980 Response to Aslab 800521 Memorandum & Order ALAB-593, Requesting Environ Coalition on Nuclear Power to Inform Aslab of Extent of Relief Sought.Intervenor 800530 Request Must Be Dismissed as Moot.Certification of Svc Encl 1982-09-09
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v7 In the Matter of )
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PENNSYLVANIA POWER & LIGHT COMPANY ) Docket Nos. 50-387 and ) 50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC. )
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(Susquehanna Steam Electric Station, )
Units 1 and 2) )
APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD +
(CONTENTION 11 -- ONSITE STORAGE OF SPENT FCEL)
Pursuant to 10 CFR S2.749(a) Applicants state, in support of their Motion for Partial Summary Disposition of that portion of Contention ~ll in this proceeding which deals with on-site storage of spent fuel, that there is no genuine issue to be heard with respect to the following material facts:
- 1. At the Susquehanna Steam Electric Station ("Susquehanna"),
nuclear fuel which has been discharged from the reactor is stored in water-filled basins called spent fuel pools. The water pro-vides both for heat removal and for radiation shielding. Affidavit of D. W. James in Support of Partial Summary Disposition of Conten-tion 11 (" James Aff."), para. 3.
- 2. Each of the Susquehanna units has its own spent fuel storage facility. This facility, located in the reactor building, consists of a water-filled, reinforced concrete basin lined with stainless-steel ("the spent fuel pool"), racks for storing the 8108030084 810728 hQ PDR ADOCK 05000387 g l G PDR r,
fuel, cranes and material handling equipment, a heat exchanger for cooling the water, a clean-up system for controlling water purity, and pumps to circulate the water. Both units share a ccmmon cask pit that accepts the spent fuel shipping casks and accommodates underwater fuel transfer from either unit through its respective transfer canal. Id., para. 4.
- 3. The. spent fuel pool walls are six foot thick reinforced l concrete. The spent fuel pools themselves are part of the reactor i
building structure and meet all the codes and standards for the l reactor building. The pools are also designed for the same loads i
l and loading conditions as the reactor building. Id., para. 5.
- 4. The spent fuel pool stainless steel liner is not load bearing and is directly supported by a system of stiffeners and anchors embedded in the poo] wall. The pool wall with its embeds l
and liner is designed to withstand all credible loading combina-tions resulting from natural phenomena and plant operation. Liner l material is intended to minimize corrosion formation and possible leakage. Experience with stainless steel in demineralized water l service has shown no measurable corrosion. Therefore, liner l
corrosion over the lifetime of the plant is considered insignifi-cant. Id., para. 6. The liner is also capable of withstanding a temperature of 212*F during an accident situation involving pool boiling. Id., para. 7.
l
- 5. A leak detection. system is provided to verify leak tightness following liner installation and during plant operation.
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_3-Any leakage through the liner would be contained by a system of channels welded behind the liner weld joints which permit free gravity flow through isolation valves to a leak detection station.
Liner repairs, if necessary, can be (and have been) made even when there is spent fuel in a pool. Id., para. 7.
i 6.
The spent fuel racks are of all anodized aluminum, bolted construction and are attached to the pool walls through
- embeds and anchors. Seismic restraints of welded stainless steel construction tying to the pool liner embeds are provided to, enable ,
the racks to withstand all credible loading combinations resulting from natural phenomena and plant operation. To reduce any gal-vanic corrosion, inconel pins ara used between the wall seismic restraints:and the racks. For the same purpose, the leveling screws of the racks butt against plastic discs that are crimped into stainlass steel pads. Id., para. 8.
- 7. The spent fuel racks contain " poison cans" which are filled with a neutron absorber material. This material is com-(
j pletely encapsulated in aluminum and is totally isolated from l the pool water. Each poison can is pressure and vacuum leax-tested prior to installation. Id., para. 8.
- 8. The design features of the spent fuel r.acks will pre-vent any significant degradation of the racks from water submer- ,
l sion, radiation, thermal, hydrodynamic, and seismic loading condi-tions over the 40 year desi.gn lifetime of the plant. Furthermore,
! test coupons consisting'of actual poison can sections inst'13.ed f
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i adjacent to the racks will permit verification.of the long-term mechanical and material integrity of the poison cans over the plant lifetime. Id., para. 9.
- 9. The fuel pool water temperature is maintained below 125'F by normal and backup caoling systems. Normally, fuel pool cooling
! is provided by the Fuel Pool Cooling and Cleanup (FPCC) system.
One FPCC system is provided for each spent fuel pool. The fuel pool ecoling pumps circulate the pool water in a closed loop, taking suction from the skimmer surge tank through heat exchangers where the decay heat of the irradiated fuel is transferred to the service water system. A partial flow from the cooling loop is directed through filter demineralizers and returned with the by-pass flow back to the pool. Id., para. 10.
- 10. The FPCC system is sized to cool the maximum normal l
i heat load, which is the heat that would be generated by the 2,840 fuel assemblies which could be placed in the spent fuel pool, assuming that all the fuel assemblies are discharged at the normal refueling rate. Id., para. 10.
- 11. The Residual Heat Removal (RHR) system serves as backup to the FPCC system and would also be used to carry the emergency heat load. The emergency heat load would occur if the fuel pool' i were filled to its maximum capacity,of 2,840 fuel assemblies and l
the last discharge were a full core unload rather than the 1/4 core discharge which would occur in the maximum normal case. Id.,
para. 11.
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- 12. One out of the four RHR pumps and one out of the two RHR heat exchangers will provide sufficient cooling for either the maximum no. mal or emergency heat load. The remaining RHR pumps and heat exchanger provide additional backup capability. The RHR system t.ischarges to the pool through two independent Seismic Categcry I lines. Id., para, 12.
- 13. In the highly unlikely event that both the FPCC system and its backup (the RHR system) are lost, the primary consequence would be to significantly increase the evaporative losses from the pool as a result of pool boiling. (This " boiling" would be in the form of steam escaping from the surface, rather than violent bub-blinc.) Using very conservative assumptions (such as no heat loss through conduction or evaporation), this boiling would not begin until 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> after loss of all external cooling at the maximum normal heat load and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after cooling at the emergency heat load. During these time periods, one or more of the cooling systems could be isolated and repaired to restore cooling.
Neither loss of external cooling nor pool boiling restricts ac-cessiblity to the cooling systems for repairs. Id., para. 13.
, 14. Even if boiling occurs, fuel damage cannot take place so long as the fuel remains under water. There are at least four independent sources of makeup water for evaporative losses, each one capable of providing water at a rate greater than the maximum boil-off rate. Makeup for evaporative losses is normally supplied from the Makeup Demineralizer System. Two independent, Seismic Category I backup sources of water are provided from the
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Emergency Service Water System. As further backup to these back-up systems, makeup wa;cr to the pool can be provided through a fire hose on the refueling floor. Because the tops of the spent fuel are under twenty-three feet of water, the plant would have a long time in which to add makeup water before reaching a situa-tion where damage to the fuel could occur. The redundancies in cooling systems and makeur water sources assure that the spent fuel will not be damaged due to failures in cooling or makeup systems. Id., para. 14. ,
- 15. The spent fuel pools have no bottom drains or connec-tions from which the water could be inadvertently drained. Check valves and siphon breakers are provided at the high points of sup-i ply lines.to prevent siphoning of water from the pools. The manual valves for backup cooling or backup water supplies are in access-i ible areas in the reactor building. There is no credible mechanism for a sudden loss of water from the pools. Id., para. 15.
- 16. Fuel storage is essentially a passive system and requires i
little operator intervention. Alarms indicating a high pool water l
temperature, high or low water level in the pool, and high area radiation are provided in the control room. Id., para. 16.
- 17. The spent fuel pool including the spent fuel racks, the l
. redundant fuel pool cooling system (RHR) and the redundant water i makeup provisions, are designated Seismic Category I and, as such, are designed to withstand a Safe Shutdown Earthquake. They are therefore pro'cected against any credible seismic event. Id., para.
17.
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- 18. The spent fuel racks are designed to assure that the spent fuel remains in a subcritical condition under both normal and abncrmal storage conditions. A criticality analysis was per-formed for the Susquehanna spent fuel pools using diffusion theory calculations and conservative assumptions favoring criticality.
Id., para. 18. The analysis shows that the spent fuel will re-main subcritical. Id., para. 19.
- 19. The probability of the spent fuel pool suffering damage as the result of impact from aircraft, spacecraft or meteo,rs is low enough to be negligible. Id., para. 20.
- 20. The spent fuel storage facilities at Susquehanna can safely store spent fuel for at least the duration of the Susquehanna licenses (i.e. , through the year 2013). Id., paras.
2, 21.
- 21. With respect to spent fuel itself, it is best character-ized by its inactivity. There is little stored energy in the spent fuel system which would act as a mechanism for fission product re-lease from it. After fuel is discharged from the reactor to the fuel pool, it continues to generate heat from the decay of fission products. However, the amount of decay heat generated decreases rapidly and continuously. Each fuel assembly's radioactive decay
. power output is reduced by about 97% within one month after shut-down. The overall result is that the heat generation rate dimin-ishes and therefore the margin of safety for the storage system 1
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increases with time in storage. After only a few weeks of pool cooling, the surface cladding temperature is only about 10*C above the bulk water temperature in the pool (30*-60*C) compared to a cladding temperature of 290*-400*C while the fuel is in the reactor. In short, the storage system is a benign environment, particularly in comparison with the pre-storage power generation environment. Affidavit of Clair C. Herrington in Support of Partial Summary Disposition of Contention 11 ("Herrington Af f. ") ,
para. 4. .
- 22. The spent fuel in storage in the spent fuel pool is readily accessible for visual monitoring. This enables the exam-ination for defects as the fuel is brought in for storage; the further examination for defects or review of known defects at later dates; and the final observation as spent fuel is moved for shipment. Visual monitoring of the fuel in storage may also de-tect escaping gas bubbles, and the accessibility permits sampling escaping gas or the water around a suspected " leaker". Radiation levels of the pool water are monitored frequently. Concentrations of airborne radioactive materials above the pool are monitored con-tinuously. Id., para. 6.
- 23. If some mechanism should arise that could allow radio-active material to escape from the spent fuel, its genesis would be gradual because low energy systems do not undergo rapid changes.
Available instrumentation and monitoring programs assure that ade-quate time would be available for identification and development
of remedial action without subjecting plant personnel or the public to significant risk. Id., para. 7.
- 24. The Zircaloy cladding surrounding the fuel pellets is an important containment barrier that keeps the fission products within the fuel isolated. Zircaloy-clad fuel has been stored satisfactorily in pools for over twenty years. This is as ex-pected, since the cladding has been designed to endure several years of the much more corrosive conditions of reactor operations where one year of reactor exposure is equivalent to many ye,ars of pool storage exposure. The amount of estimated corrosion for Zircaloy cladding in pool storage is 0.037 to 0.062% of the initial Susquehanna cladding thickness over a period of one hundred years.
No other degradation mechanisms have been identified that would pose a substantial threat to fuel cladding integrity. Id., para. 8.
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- 25. The uranium oxide ceramic fuel pellets themselves pro-vide a remarkably efficient barrier to the leaching of radioactive material into basin water. The pellets are virtually inert to pool water and there has been no observable physical degradation in several years of exposure of bare pellets to pool water. This lack of interaction of the fuel pellets with water minimizes the impact of a potential defect in the fuel cladding and enhances the isola-tion of fission products within the fuel. Id., para. 9.
- 26. Defective or failed fuel in spent fuel storage can be isolated by encapsulation. Encapsulation has been routinely used in Canada for the storage of defective fuel, but has not been
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deemed necessary in this country even where known tu!'ad fuel is in storage because the impact of fuel rod failures during storage has been found to be relatively slight. However, encapsulation could be used in the event that severe degradation of the spent fuel assemblies should occur. Id., para. 10.
- 27. The experience with extended storage of spent fuel has been excellent. Assemblies have been stored for a period of some twenty years, with no apparent degrr.dation due to storage. Some Zircaloy-clad PWR fuel has been in water basin storage since 1959.
In addition, at least nine Zircaloy-clad fuel bundles from the Canadian NPD reactor have been in water storage since 1962 and eight bundles loaded in the NPD reactor in 1963 are still incore and intact. Id., para. 11. A survey of pool operators representing some 20 U. S. pools has found no instances of degradation of stored commercial power reactor fuel. Id., para 12. Canadian experience, including occasional examination during 17 years of storage, has also indicated no evidence of significant corrosion or other chem-i l
ical degradation. Even where the uranium oxide pellets were exposed l
1 l to pool water as a result of prior fuel assembly damage, the pellets have been relatively inert t' pool water, a conclusion also demon-strated in J aboratory studics. Id., para. 12.
l EG. Further experience concerning the ability of spent fuel to withstand extended water basin storage includes metallurgical examination of Zircaloy-clad fuel after 11 years of pool storage, metallurgical examination of Zircaloy, clad PWR and BWR
high burn-up fuel after five and six years in pool storage, re-turn of fuel bundles to a reactor after 10 years of pool stor-age, and hot cell examination of high burn-up fuel bundles over 6 years of pool storage at the WAK Fuel Reprocessing Plant in Germany. Favorable experience in other countries with Zircaloy-clad fuel includes United Kingdom, 13 years; Belgium, 12 years; Japan, 11 years; Norway, 11 years; West Germany, 9 years; and Sweden, 7 years. Id., para. 13.
- 29. Since un re have been no indications of spent fuel stor-age problems, either theoretical or actual, major development and test programs to provide safe storage capabilities have not been required. Ongoing development is proceeding, however, to further improve storage efficiencies. Id., para. 3.
- 30. After their review of storage of spent fuel for extended periods of time, the Advisory Committee on Reactor Safeguards stated its belief that the issues and concerns ab>ut storage of spent fuel have been adequately addressed an0 tnat safe interim storage well beyond 30 years can be provided should it be re-quired. Id., para. 3.
- 31. It has been demonstrated that spent fuel can be safely stored in water filled pools on site for extended periods of time.
The Zircaloy-clad fuel to be used at Susquehanna can safely be t
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stored in the spent fuel pools at least through the expiration of the operating licenses.in 2013. Id., para. 14.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By I J$f E. JSilberg }
Mavias F. Travesio- Kaz Counsel for Applicants 1800 M Street, N. W.,
Washington, D. C. 20036 (202) 822-1000 Dated: July 28, 1981 r
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