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Category:INTERVENTION PETITIONS
MONTHYEARML20092H9591984-06-0707 June 1984 Forwards Proposed Financial Qualification Contention.Const Cannot Be Completed in Manner Resulting in Safe Plant. Evacuation Plan Will Be Terrible Financial Burden.Served on 840625 ML20024A1201983-02-21021 February 1983 Amend & Consolidation of Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 & Rockford League of Women Voters Contentions 19 & 108 ML20024A1181983-02-21021 February 1983 Motion to Amend & Consolidate Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 W/Rockford League of Women Voters Contentions 19 & 108 ML20062B0591982-07-30030 July 1982 Need for Power & Alternative Energy Source Contention ML20062B0471982-07-30030 July 1982 Financial Qualifications Contention ML20054C6741982-04-15015 April 1982 Revised Contentions 10-12.Certificate of Svc Encl ML19310A1801980-05-0909 May 1980 Supplemented Statement of Contentions Alleging Lack of Technical Qualifications to Operate Station.Dose Impacts of Projected Routine Releases of Radioactive Matls Should Be re-evaluated.Certificate of Svc Encl ML19323C6711980-04-18018 April 1980 Response to Rockford League of Women Voters Revised Contentions.Urges Admission of Contentions 50,85,104,112(d) & 119(a)(b),consolidation of Contentions 2,5,88,90 & 116 & Rejection of Remaining Contentions.W/Certificate of Svc ML20028B9861980-03-10010 March 1980 Revised Contentions.Ols Should Be Denied 1984-06-07
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20092H9591984-06-0707 June 1984 Forwards Proposed Financial Qualification Contention.Const Cannot Be Completed in Manner Resulting in Safe Plant. Evacuation Plan Will Be Terrible Financial Burden.Served on 840625 ML20024A1201983-02-21021 February 1983 Amend & Consolidation of Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 & Rockford League of Women Voters Contentions 19 & 108 ML20024A1181983-02-21021 February 1983 Motion to Amend & Consolidate Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 3 W/Rockford League of Women Voters Contentions 19 & 108 ML20062B0591982-07-30030 July 1982 Need for Power & Alternative Energy Source Contention ML20062B0471982-07-30030 July 1982 Financial Qualifications Contention ML20054C6741982-04-15015 April 1982 Revised Contentions 10-12.Certificate of Svc Encl ML19310A1801980-05-0909 May 1980 Supplemented Statement of Contentions Alleging Lack of Technical Qualifications to Operate Station.Dose Impacts of Projected Routine Releases of Radioactive Matls Should Be re-evaluated.Certificate of Svc Encl ML19323C6711980-04-18018 April 1980 Response to Rockford League of Women Voters Revised Contentions.Urges Admission of Contentions 50,85,104,112(d) & 119(a)(b),consolidation of Contentions 2,5,88,90 & 116 & Rejection of Remaining Contentions.W/Certificate of Svc ML20028B9861980-03-10010 March 1980 Revised Contentions.Ols Should Be Denied 1984-06-07
[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 ML20149M2951996-11-29029 November 1996 Exemption from Requirements of 10CFR50.60 Re Safety Margins Recommended in ASME Boiler & Pressure Vessel Code Case N-514 TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20044A8111990-06-27027 June 1990 Comment Opposing Closure of Lpdr of Rockford Public Library ML20245J0191989-04-14014 April 1989 Comment Re Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20214X1871987-06-11011 June 1987 Order Imposing Civil Monetary Penalty in Amount of $25,000 Based on Four Severity Level III Violations Noted During 860721-0808 Insp ML20205Q1711987-04-0202 April 1987 Order Imposing Civil Monetary Penalty in Amount of $25,000. App Re Evaluations & Conclusions Encl IR 05000812/20100311987-02-26026 February 1987 Order Imposing Civil Monetary Penalty in Amount of $100,000 Based on Violations Noted During Insps on 850812-1031 ML20210T7321987-02-11011 February 1987 Unexecuted Amend 6 to Indemnity Agreement B-97 Substituting Item 3 of Attachment to Indemnity Agreement in Entirety W/ Listed License Numbers,Effective 870130 ML20209J3251987-01-30030 January 1987 Transcript of 870130 Commission Discussion/Possible Vote on Full Power OL for Facility.Pp 1-72.Supporting Viewgraphs Encl ML20213G4381986-10-24024 October 1986 Unexecuted Amend 5 to Indemnity Agreement B-97,substituting Item 3 of Attachment to Agreement in Entirety W/Listed License Numbers,Effective on 861106 ML20211B0841986-08-0505 August 1986 Transcript of 860805 Meeting Between Region Iii,Computer Interference Elimination & Util in Redmond,Wa Re Plant as-built Drawing Review.Pp 1-200 IR 05000506/20070221986-05-0202 May 1986 Order Imposing Civil Monetary Penalty in Amount of $25,000 for Violations Noted During Insp on 850506-0722.Violations Noted:Failure to Establish Radiological Safety Procedures & to Adequately Train Personnel ML20138C7301985-12-0909 December 1985 Order Imposing Civil Penalty in Amount of $25,000 Per 850606 Notice of Violation & Proposed Imposition of Civil Penalty.Licensee May Request Hearing within 30 Days of Date of Order ML20205E8741985-10-28028 October 1985 Exemption from GDC 4 of 10CFR50,App a Requirement to Install Protective Devices Associated W/Postulated Pipe Breaks Primary Coolant Sys.Topical Rept Evaluation Encl ML20102A2981985-01-0707 January 1985 Petition Requesting Aslab Grant Intervenor Appeal & Order Further Hearings on Safety of Plant ML20099L2581984-11-27027 November 1984 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20099G5381984-11-23023 November 1984 Supplemental Appeal Brief in Response to Intervenor 841106 Supplemental Brief on Appeal & in Support of ASLB 841016 Supplemental Initial Decision Authorizing Issuance of Ol. Certificate of Svc Encl ML20100K0411984-11-22022 November 1984 Submits Concerns Re Safety of Local Residents in Event of Accident & Excessively High Cost of Projected Operation of Facility ML20107H7841984-11-0606 November 1984 Supplemental Brief on Appeal of ASLB 841016 Supplemental Initial Decision Granting Authority for Issuance of Ol. Decision Should Be Reversed.Certificate of Svc Encl ML20140E4081984-10-31031 October 1984 Executed Amend 1 to Indemnity Agreement B-97,deleting Items 2A & 3 in Entirety ML20098G8841984-10-0202 October 1984 Joint Statement of RW Manz & W Faires Re Findings 3-11 Through 3-17 of NRC 830930 Integrated Design Insp Rept. Certificate of Svc Encl ML20098G8681984-10-0202 October 1984 Answer to Intervenor Motion to Reopen Record Re Bechtel Independent Design Review.Motion Should Be Denied ML20098G8901984-10-0202 October 1984 Joint Statement of Kj Green & RW Hooks Re Integrated Design Insp ML20098G8911984-10-0202 October 1984 Joint Statement of Cw Dick & EM Hughes Re Independent Design Insp ML20098G8821984-10-0101 October 1984 Affidavit of Kj Green Re Integrated Design Insp Concerning Mechanical Engineering Work ML20098G8741984-10-0101 October 1984 Affidavit of Br Shelton Re Integrated Design Insp ML20098G8881984-09-29029 September 1984 Affidavit of RW Hooks Re Integrated Design Insp Concerning Structural Design ML20098G8831984-09-28028 September 1984 Affidavit of W Faires Re Findings 3-15 & 3-16 of NRC 830930 Integrated Design Insp Rept ML20098G8811984-09-28028 September 1984 Affidavit of Cw Dick Re Independent Design Review ML20098G8791984-09-28028 September 1984 Affidavit of RP Tuetken Re Readiness for Fuel Loading ML20098G8781984-09-28028 September 1984 Affidavit of RW Manz Concerning Findings 3-11 Through 3-14 & 3-17 of NRC 830930 Integrated Design Insp Re Westinghouse ML20098G8871984-09-28028 September 1984 Affidavit of EM Hughes Re Idvp ML20098G8851984-09-27027 September 1984 Affidavit of Rl Heumann Re Costs of Delay in Startup & Operation of Unit 1 ML20098E2371984-09-24024 September 1984 Reply to Intervenor 840918 Proposed Supplemental Initial Decision.Certificate of Svc Encl ML20097E7221984-09-13013 September 1984 Agreed Motion for Time Extension Until 841101 to File Petition for Hearing Re Emergency Planning Commitment W ML20097C5311984-09-12012 September 1984 Motion to Reopen Record to Include Plant Design as Issue. Supporting Documentation & Certificate of Svc Encl ML20097B7791984-09-10010 September 1984 Proposed Supplemental Initial Decision Re Reinsp Program. Certificate of Svc Encl ML20096A6391984-08-30030 August 1984 Rebuttal Testimony of RW Hooks Re Validity of Info in Attachment 7 to Stokes Testimony Concerning Design Assumption for Plant.Stokes Info Inapplicable to Plant. Related Correspondence ML20096A6191984-08-30030 August 1984 Rebuttal Testimony of B Erler Re Stokes Allegations Concerning Evaluations of Discrepancies in Calculated Actual Stress Performed by Sargent & Lundy.Related Correspondence ML20096A6261984-08-30030 August 1984 Summary of Rebuttal Testimony & Testimony of ML Somsag, Eb Branch,D Demoss,Mr Frankel,Bf Maurer & Jk Buchanan Re Plant QC Inspector Reinsp Program & C Stokes Allegations Re Welds.Related Correspondence ML20096A6441984-08-28028 August 1984 Notice of Withdrawal of Appearance in Proceeding.Related Correspondence ML20112D5271984-08-24024 August 1984 Applicant Exhibit A-R-4,consisting of Feb 1984 Rept on Bryon QC Inspector Reinsp Program ML20112D5031984-08-24024 August 1984 Applicant Exhibit A-R-5,consisting of June 1984 Suppl to Rept on Bryon QC Inspector Reinsp Program ML20112D7441984-08-23023 August 1984 Intervenor Exhibit I-R-1,consisting of Undated List of Teutken Safety Category Insp Types ML20112D7511984-08-21021 August 1984 Staff Exhibit S-R-1,consisting of 840813 Instruction for Walkdown of Cable Tray Hanger Connection Welds ML20112D4641984-08-21021 August 1984 Intervenor Exhibit I-R-11,consisting of Undated Chronological Date Listing of Util Responses to Interrogatory 12.VA Judson to Mi Miller Re Interrogatory 12 & Supplemental Responses Encl 1999-03-02
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Sinnissippi Alliance L F for the Environmpt 326 North Avon Street Rockford, Illinois 61.103 c
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June 7',d '8'i9 4 SERVED JUii 2 a EM Commissioners
- u. s. nuclear regulatory commission . . . . - . ,
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Washington D.C. 20555 -
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Dear Commissioners:
We are waiting patiently for our day in court. Our financial qualifications contention was filed almost five years ago with the Atomic Safety and Licensing Board (Docket No. 50-454, 455 OL, Byron Units 1 & 2).
Since that time applicant Commonwealth Edison has worsened financially.They are not financially qualified to complete construction of both Byron units in a manner which will result in a safe plant, nor are they capable of safely operating Byron Unit 1 (which they hope to load by September 15th!), nor will they be able to decommission Byron safely if their present trend continues.
They are banking on the Illinois Commerce Commission's tolerance' of continuous rate requests (five within the last six years). This year they goofed: based upon their estimation of an early fuel load for Byron, which was wrong, the ICC cut their billion dollar request in half. Needless to say, Com Ed is sorely pressed to get a license by September and, we feel, may be passing that
" impression" on to the Board.
There is e terribly large amount of work to be done at Byron.
The present hearings on QA/QC should bear that out. Their evacuation plan, though improving, will be a tremendous financial burden. LaSalle Unit i has not been performing as profitably as expected for the consumer.
We, above all other intervenors, have a right to present our case that Commonwealth Edisoniis not financially qualified to complete construction of both Byron units'.in a manner which will resul,t in a safe plant, nor to operate Byron safely, nor to decommission Byron safely. The operating license for Byron should be denied.
Sincerely:
(IG f 8406260319 840607 Stanl E. Cam/[ ell secretary, SAFE PDR ADOCK 05000454 O PDR b
[..o *
- PROPOSED FINANCIAL QUALIFICATIONS CONTENTION I. , Commonwealth Edison is not financially qualified to complete . construction of both Byron units in a manner which will result in a safe plant', nor to operate Byron safely, nor to decommission Byron safely. Specifically, Intervenors contend that:
- a. Commonwealth Edison ("CE") does not possess or have reasonable assurance of obtaining the funds necessary to complete construction of both units at Byron, to cover related fuel cycle costs, to cover operation costs for the period of the license, as well as to cover the costs of permanently shutting down the facility and maintaining it in a safe condition,
- b. There is no reasonable assurance that the Illinois Commerce Commission will raise CE's rates high enough to enable CE- to complete construction of both units at Byron in such a manner as to result in a safe plant and to safely operate Byron.
- c. CE's cost projections for completion of construction, operation and decommissioning of Byron are. understated and more reasonable projections are so high that CE does not possess or, have reasonable assurance of obtaining the necessary funds,
- d. There is no reasonable assurance that CE will possess adequate funds to safely decommission Byron either at the end of its useful life or in the event that premature decommissioning is necessary. While Edison collects funds for decommissioning '
of its operating nuclear plants, such a system fails to provide reasonable assurance because (i) Edison does not segregate the money in any manner, but spends it for general corporate purposes.
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/[ (ii) Edison's decomissioning estimates are out-
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dated and too low.
/ (iii) Edison has no insurance that will cover decomissioning costs in the event of premature decomissioning.
- e. As a result of CE's lack of financial qualifications, operation of Byron will jeopardize the public health and safety.
II. The Safety Evaluation Report (SER) issued by the NRC staff in February,1982, analyzes in part the financial quali-fications of CE. The SER nust be supplemented in at least two respects:
- a. the estimated costs of the Byron plant are understated and should be revised in light of actual expenditures and revised new estimates of both CE and of Intervenors,
- b. the conclusion that CE is financially qualified safely to operate and decomission Byron is erroneous and must be changed. The SER must be supplemented to reflect that the Company is not financially qualified and that there is no reasonable assurance that it will be able to obtain sufficient funds to complete construction of both units at Bryon in such a manner as to result in a safe plant, and to cover the costs, and safe operation, and related fuel cycle costs and to decommission Byron.
Thqrefore, the operating license for Byron should be denied.