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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20211N5231999-09-10010 September 1999
Memorandum & Order (CLI-99-24).* Grants Util Motion to Withdraw Without Prejudice Pending Appeal of ASLB Memorandum & Order LBP-99-14 & Vacates LBP-99-14 & LBP-99-17.With Certificate of Svc.Served on 990910
ML20211J8041999-09-0303 September 1999
Order.* Time within Which Commission May Take Sua Sponte Review Pursuant to 10CFR2.786(a) of Board Order (LBP-99-27) Hereby Extended to 990910.With Certificate of Svc.Served on 990903
ML20216D6571999-07-28028 July 1999
Memorandum & Order (Termination of Proceeding).* Orders That Intervenor 990517 Contentions Be Dismissed as Moot & Licensee Motion to Terminate Proceeding Be Granted.With Certificate of Svc.Served on 990729
ML20196K5271999-07-0606 July 1999
NRC Staff Response to Yankee Atomic Electric Co Motion to Terminate Proceeding.* for Listed Reasons,Licensing Board Should Grant Motion to Withdraw Application & Terminate Proceedings.With Certificate of Svc
ML20212J5661999-07-0101 July 1999
Notice of Withdrawal.* Notice Given That Effective 990701 ML Zobler Withdraws Appearance in Yankee Atomic Electric Co Proceeding.All Mail & Service Lists Should Be Amended to Delete Name After That Date.With Certificate of Svc
ML20212J6251999-06-29029 June 1999
Motion for Leave to Reply (Intervenor 990623 & 24 Filings).* Board Should Enter Order Terminating Proceeding,Without Prejudice & Without Conditions.With Certificate of Svc
ML20196F1321999-06-24024 June 1999
Necnp Reply to LBP-99-22.* Recommends That Panel Should Grant Relief That Intervenors Requested for Reasons Stated. with Certificate of Svc
ML20196F3801999-06-23023 June 1999
CAN Reply to Board Order of 990614.* Board Should Find Way to Satisfy Public Right to Know Answers to Questions CAN & Others Raised Re Yankee Rowe Site Contamination.Fees,Costs & Expenses Justified.With Certificate of Svc
ML20196F1651999-06-22022 June 1999
Response to Board Request for Answers to Questions & Other Matters.* Contends That Intervenors & Public Interest Have Been Severely Prejudiced by Failure of Proceeding to Adjudicate Matters at Issue.With Certificate of Svc
ML20196B1621999-06-17017 June 1999
Response of Yankee Atomic Electric Company to LBP-99-22.* Informs That Board Should Enter an Order Terminating Proceeding,Without Prejudice & Without Conditions. with Certificate of Svc
ML20195H1911999-06-15015 June 1999
Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer
ML20195H3941999-06-15015 June 1999
NRC Staff Response Re Yaec Board Notification (Withdrawal of Application) & Motion to Terminate Proceeding & Dismiss Appeal.* Commission Should Hold Abeyance Any Action on Yaec Motion to Dismiss Appeal.With Certificate of Svc
ML20195F5551999-06-14014 June 1999
Memorandum & Order (Requesting Replies to Necnp Response to Termination Motion).* Parties Invited to Reply to Necnp 990607 Response No Later than 10 Days Following Svc of This Memorandum & Order.With Certificate of Svc.Served on 990614
ML20207H5791999-06-14014 June 1999
Motion of Yankee Atomic Electric Co for Leave to Respond to Intervenor Opposition To...Motion to Terminate (Etc).* Board Should Enter Order Terminating Proceeding,Without Prejudice & Without Conditions.With Certificate of Svc
ML20207G2021999-06-0707 June 1999
Yankee Response to Intervenors Motion in Support of Yankee Motion for Dismissal of Appeal.* Recommends That Appeal Should Be Dismissed as Moot for Reasons Stated.With Certificate of Svc
ML20195D7081999-06-0707 June 1999
Intervenor Opposition to Yankee Atomic Electric Co Motion to Terminate & Proposed Form of Order for Expenses,Fees & Responses to Discovery.* Panel Requested to Grant Motion to Withdraw by Imposing Conditions
ML20195D7871999-06-0707 June 1999
Declaration of Jm Block,Attorney,New England Coalition on Nuclear Pollution,Inc.* Informs That Necnp Has Incurred Listed Expenses & Generated Listed Attorney Hours in Course of Proceeding.With Certificate of Svc
ML20195D7281999-06-0606 June 1999
Declaration of F Katz,President,Citizens Awareness Network, Inc.* Informs That CAN Has Incurred Listed Expenses in Course of Entire Proceeding to Date
ML20195C9301999-06-0505 June 1999
Motion in Support of Yankee Atomic Electric Co Motion for Dismissal of Appeal.* Commission Should Immediately Grant Yankee Atomic Electric Co Motion to Dismiss Pending Appeal & Dismiss Appeal with Prejudice.With Certificate of Svc
ML20207D7031999-05-26026 May 1999
Board Notification (Withdrawal of Application) & Motion to Terminate Proceeding & Dismiss Appeal.* Commission Suggests That Pending Appeal by Licensee from LBP-99-14,should Be Dismissed.With Certificate of Svc
ML20206Q2051999-05-17017 May 1999
Necnp Request for Permission to File Contentions & Contentions on Inadequacy of NRC Staff 990412 Environ Assessment & Finding of No Significant Impact of Approval of Yankee Nuclear Power Co License Termination Plan.*
ML20206Q2391999-05-14014 May 1999
Declaration of Rj Ross,Cgwp,Hydrogeologist.* Declaration of Rj Ross Re NRC Staff Environ Assessment & Finding of No Significant Impact on License Termination Plan for Yankee Nuclear Power Station
ML20206P1481999-05-13013 May 1999
Board Notification.* Informs That Yankee Determined to Modify Plan for Final Status Survey of Ynps Site So as to Employ so-called Marssim Survey Methodology Instead of 5849 Survey Methodology.With Certificate of Svc
ML20206Q2261999-05-13013 May 1999
Second Declaration of M Resnikoff.* Declaration of M Resnikoff Re NRC Staff Environmental Assessment on Yankee License Termination Plan
ML20206D1931999-04-30030 April 1999
CAN First Set of Interrogatories & Requests to Produce Served Upon Yaec.* Incorporates & Republishes General Instructions in Necnp First Set of Interrogatories & Requests.With Certificate of Svc.Related Correspondence
ML20206B7131999-04-27027 April 1999
NRC Staff Response to Letter from Necnp.* Recommends That Jm Block 990424 Request That Board Take Action Re EA Prepared in Connection with Staff Review of LTP Filed by Yaec Be Denied for Reasons Stated.With Certificate of Svc
ML20205R4631999-04-22022 April 1999
Memorandum & Order (Denying Motion for Reconsideration of Contention 4).* Yaec Motion for Reconsideration of Portion of LBP-99-14 That Admitted Necnp/Can Contention 4 Denied. with Certificate of Svc.Served on 990422
ML20205Q6921999-04-19019 April 1999
Erratum to Reply Brief of Intervenor Citizens Awareness Network,Inc to Yaec Appeal of Prehearhing Conference Order of ASLB (LBP-99-14) on 990317.* Reply Included Draft Front Page.With Certificate of Svc
ML20205S0181999-04-19019 April 1999
Erratum,Reply Brief of Intervenor Citizens Awareness Network Inc to Yaec Appeal of Prehearing Conference Order of ASLB (LBP-99-14) on 990317.* Draft Front Page Was Inadvertently Included in Reply Brief.With Certificate of Svc
ML20205S0251999-04-17017 April 1999
Necnp First Set of Interrogatories & Requests to Produce Served Upon Yaec.* Answers & Documents Should Be Provided to Listed Persons,At Each Round of Discovery Re License Termination Plan
ML20205Q9151999-04-16016 April 1999
on Appeal from Prehearing Conference Order of ASLB Issued 990317 (LBP-99-14).Reply Brief of Intervenor Necnp.* LBP-99-14 Should Be Upheld.Preceeding Should Go Forward. with Certificate of Svc
ML20205Q0661999-04-16016 April 1999
Citizens Awareness Network,Inc Reply to Yaec Appeal of Prehearing Conference Order.* Requests That Yaec Appeal of ASLB Prehearing Conference Order Be Denied for Foregoing Reasons of Law,Regulations & Fact.With Certificate of Svc
ML20205P8821999-04-16016 April 1999
NRC Staff Response in Support of Yankee Atomic Electric Co Appeal of LBP-99-14.* Commission Should Grant Licensee Appeal & Reverse ASLB Decision in LBP-99-14.With Certificate of Svc
ML20205P9161999-04-15015 April 1999
Opposition to Appeal from Prehearing Conference Order of Atomic Safety & Licensing Board Filed by Yae Issued 990317 (LBP-99-14).* Petitioner Requests That Commission Deny Appeal & Uphold LBP-99-14.With Certificate of Svc
ML20205P8851999-04-14014 April 1999
Erratum (Reconsideration of Portion of Prehearing Conference Order).* Licensee Learned That Yae Incorrect in Stating That Decommissioning Plan Had Been Approved on Basis of TEDE Analysis.With Certificate of Svc
ML20205P1851999-04-12012 April 1999
Motion for Leave to Reply (Reconsideration of Portion of Prehearing Conference Order).* Util Requests That Board Reconsider LBP-99-14 & Upon Consideration, Contention 4 Be Excluded.With Certificate of Svc
ML20205P1151999-04-12012 April 1999
Motion for Leave to Reply to Yaec Motion for Leave to Reply (Reconsideration of Portion of Prehearing Order) & Yaec Reply.* Moves for Leave to Submit Reply to Yaec Reply or to Supplement Necnp Orginal Reply.With Certificate of Svc
ML20205K9541999-04-0909 April 1999
Necnp Opposition to Yaec Motion to Reconsider Part of Prehearing Conference Order.* Necnp Requests That Panel Either Deny Yaec Omr Outright or Reconsider & Modify Contention 4 Only in Ways Suggested.With Certificate of Svc
ML20205J3421999-04-0909 April 1999
NRC Staff Response to Yae Objection to & Motion for Reconsideration of Portion of Prehearing Conference Order.* Staff Agrees with Yae Arguments Supporting Motion.Board Should Grant Motion.With Certificate of Svc
ML20205K8691999-04-0909 April 1999
Citizens Awareness Network,Inc Reply to Yankee Atomic Electric Co Objection to & Motion for Reconsideration of Portion of Prehearing Conference Order.* Licensee Motion for Reconsideration Should Be Denied.With Certificate of Svc
ML20205K9181999-04-0808 April 1999
Opposition to Objection to & Motion for Reconsideration of Portion of Prehearing Conference Order Filed by Yaec.* Franklin Regional Council of Governments Opposes Motion & Requests That Board Deny Motion.With Certificate of Svc
ML20205G0961999-04-0606 April 1999
Notice of Hearing.* Hearing Will Be Conducted in Proceeding Re License Termination Plan.With Certificate of Svc.Served on 990406
ML20205G0791999-04-0101 April 1999
on Appeal from Prehearing Conference Order of Atomic Safety & Licensing Board Issued 990317 (LBP-99-14)Brief of Licensee.* LBP-99-14 Should Be Reversed & Proceeding Should Be Dismissed.With Certificate of Svc
ML20205G0661999-04-0101 April 1999
Notice of Appeal.* Util Appeals Prehearing Conference Order of Slb Denominated LBP-99-14,issued on 990317 & Served on Util on 990317.With Certificate of Svc
ML20205E2861999-04-0101 April 1999
Memorandum & Order (Telephone Conference on 990331).* Orders That Responses by Intervenors & NRC Staff to Reconsideration Motion Are to Be Filed with ASLB by COB 990409.With Certificate of Svc.Served on 990401
ML20205G1461999-03-31031 March 1999
Transcript of Util (Yankee Nuclear Power Station) Telcon.* Telcon Held on 990331 in Rockville,Md.Pp 283-329
ML20205E2071999-03-28028 March 1999
Objection to & Motion of Yaec for Reconsideration of Portion of Prehearing Conference Order.* as Listed,Yaec Requests That Board Reconsider as Listed & Requests That Contention 4 of LBP-96-18 Be Excluded.With Certificate of Svc
ML20205A8111999-03-25025 March 1999
Notice of Change of Address.* D Curran Hereby Gives Notice That as of 990329,Curran Mailing & e-mail Address Will Change to Address Listed.With Certificate of Svc
ML20207M3491999-03-17017 March 1999
Prehearing Conference Order (Ruling on Contentions).* Approves Four Contentions Advanced by Necnp & CAN & Grants Requests for Hearing & Petitions for Leave to Intervene of Petitioners.With Certificate of Svc.Served on 990318
ML20202E9891999-01-27027 January 1999
Transcript of 990127 Prehearing Conference in Greenfield,Ma Re Yankee Atomic Electric Co (Yankee Nuclear Power Station). Pp 176-282
1999-09-03
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Category:OTHER LEGAL DOCUMENT
MONTHYEARML20212J5661999-07-0101 July 1999
Notice of Withdrawal.* Notice Given That Effective 990701 ML Zobler Withdraws Appearance in Yankee Atomic Electric Co Proceeding.All Mail & Service Lists Should Be Amended to Delete Name After That Date.With Certificate of Svc
ML20196F3801999-06-23023 June 1999
CAN Reply to Board Order of 990614.* Board Should Find Way to Satisfy Public Right to Know Answers to Questions CAN & Others Raised Re Yankee Rowe Site Contamination.Fees,Costs & Expenses Justified.With Certificate of Svc
ML20195H1911999-06-15015 June 1999
Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer
ML20206P1481999-05-13013 May 1999
Board Notification.* Informs That Yankee Determined to Modify Plan for Final Status Survey of Ynps Site So as to Employ so-called Marssim Survey Methodology Instead of 5849 Survey Methodology.With Certificate of Svc
ML20205P8851999-04-14014 April 1999
Erratum (Reconsideration of Portion of Prehearing Conference Order).* Licensee Learned That Yae Incorrect in Stating That Decommissioning Plan Had Been Approved on Basis of TEDE Analysis.With Certificate of Svc
ML20205G0961999-04-0606 April 1999
Notice of Hearing.* Hearing Will Be Conducted in Proceeding Re License Termination Plan.With Certificate of Svc.Served on 990406
ML20205G0661999-04-0101 April 1999
Notice of Appeal.* Util Appeals Prehearing Conference Order of Slb Denominated LBP-99-14,issued on 990317 & Served on Util on 990317.With Certificate of Svc
ML20205A8111999-03-25025 March 1999
Notice of Change of Address.* D Curran Hereby Gives Notice That as of 990329,Curran Mailing & e-mail Address Will Change to Address Listed.With Certificate of Svc
ML20198N1361999-01-0404 January 1999
Certification of Service for New England Coalition on Nuclear Pollution Contentions & Expert Declaration.* Jm Block Certifies That Contentions & Expert Declaration Were Served Upon Listed Party.With Certificate of Svc
ML20196B2811998-11-30030 November 1998
Change in Filing Schedules & Date of Prehearing Conference.* Gives Notice That Prehearing Conference on License Termination Plan for Ynps Has Been Rescheduled to 990126-28. with Certificate of Svc.Served on 981130
CLI-98-21, Notice of Prehearing Conference.* Notifies of Conference on 981216 to Determine Whether Petitioners,Found by Commission in CLI-98-21 to Have Standing,Have Submitted Admissible Contentions.With Certificate of Svc.Served on 9811051998-11-0505 November 1998
Notice of Prehearing Conference.* Notifies of Conference on 981216 to Determine Whether Petitioners,Found by Commission in CLI-98-21 to Have Standing,Have Submitted Admissible Contentions.With Certificate of Svc.Served on 981105
ML20154R4151998-10-26026 October 1998
Notice of Reconstitution of Board.* ASLB Reconstituted by Appointing Administrative Judge C Bechhoefer as Chairman of Licensing Board in Place of Administrative Judge Jp Gleason. with Certificate of Svc.Served on 981026
ML20236M5331998-07-10010 July 1998
New England Coalition on Nuclear Pollution Brief on Appeal of LBP-98-12.* Files Brief on Appeal of LBP-98-12,Licensing Board Memo & Order,Which Denies Request for Hearing on License Termination Plan.W/Certificate of Svc
ML20236M4581998-07-10010 July 1998
Brief of Licensee Yankee Atomic Electric Co.* Insofar as Denied Standing to Intervene as Party to Citizens Awareness Network,LBP-98-12 Should Be Affirmed.W/Certificate of Svc
ML20236M4761998-07-10010 July 1998
Brief of Licensee Yankee Atomic Electric Co.* Insofar as It Denied Standing to Intervene as Party to Planning Board, LBP-98-12 Should Be Affirmed.W/Certificate of Svc
ML20236M5011998-07-10010 July 1998
New England Coalition on Nuclear Pollution Notice of Appeal of LBP-98-12.* Files Brief on Appeal of LBP-98-12,Licensing Board Memorandum & Order Denying Request for Hearing. LBP-98-12 Should Be Reversed & Intervenor Status Granted
ML20236F5351998-06-27027 June 1998
Citizens Awareness Network,Inc Brief on Appeal of ASLBP 98-736-01.* Commission Should Overturn Panel Decision & Grant Citizen Awareness Network Standing to Go Forward & File Contentions.W/Certficate of Svc
ML20217M6161998-04-0606 April 1998
Notification to All Parties Announcing Nirs Withdrawal from Yankee Rowe Nuclear Power Station Proceeding.* Requests That Name Be Removed from Certificate of Svc List.W/Certificate of Svc
ML20217A0921998-03-12012 March 1998
Lead Engineer Response to Demand for Info Re Yankee Atomic Electric Co
ML20217A0831998-03-12012 March 1998
Manager Response to Demand for Info Re Yankee Atomic Electric Co
ML20216H6011998-03-11011 March 1998
Response of Yankee Atomic Electric Co to Demand for Info
ML20217Q3941998-03-0909 March 1998
Establishment of Atomic Safety & Licensing Board.* Board Being Established,Per Requests for Hearing Submitted by Listed Petitioners,Including Nirs & New England Coalition on Nuclear Awareness.W/Certificate of Svc.Served on 980311
ML20203L2271998-02-25025 February 1998
Rept to Duke Engineering & Svcs,Inc,On Allegations of Willfuness Related to Us NRC 971219 Demand for Info
1999-07-01
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l UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of f Q
YANKEE ATOMIC ELECTRIC f COMPANY f Q EA 97-387 and {
f DUKE ENGINEERING SERVICES f MANAGER'S RESPONSE TO DEMAND FOR INFORMATION The individual identified in the above-captioned Demand for Information
(" Demand")' as the Manager of the LOCA Group (the " Manager")2 respectfully submits this response to the Demand:
The Demand does not require the Manager to submit a response and the Manager is not a party to this proceeding. Nonetheless, the Manager recognizes that the issues raised in the Demand are serious and has given the issues careful consideration.
Duke Engineering & Services ("DE&S") responded to the Demand with several reports from multiple teams that imestigated the various issues raised therein. Having reviewed the i i d This response should not be construed as consent to the Commission's authority to either exercise jurisdiction over the Manager or effectively penalize the Manager through issuance of the Demand. 'lhere are unresolved questions regarding the statutory authority of the Commission to exercisc jurisdiction over an employee of an unlicensed vendor. Additionally, informally penalizing the Manager based on a legal standard that has not been adopted into the regulations raises constitutional questions. Although the Manager has chosen to respond to the Demand, he reserves all rights to assert any and all legal challenges to this proceeding.
2 As in the Demand, the individuals specifically identified in the Demand will be referred to as the " Manager" and the " Lead Engineer."
l 1
9003240244 900312 7 i PDR ADOCK 05000029 '
W PDR i
e DEAS response, the Manager generally' agrees with the conclusions stated therein, including that the Manager and Lead Engineer did not carelessly disregard the NRC's requirements.
DE&S is not the only entity to have analyzed these issues. In the aftermath of the December 1995 anonymous allegation letter that was sent to the NRC, there have been numerous lengthy and thorough investigations by Yankee Atomic Electric Company ("YAEC") and Maine .
. Yankee Atomic Power Company (' Maine Yankee"), by outside lawyers and technical experts, and by various agencies of the United States government, including the Justice Department. During the course of these investigations, the Manager always has cooperated and has openly and honestly responded to questions to the best of his ability. While the Manager feels that there may be room for differences ofopinion concerning thejudgments that he made regarding the MYAPS SBLOCA analysis, there is no justification for attacking the Manager's honesty, integrity and credibility. The issues surrounding the application of RELAP5YA to Maine Yankee Atomic Power Station
("MYAPS") were well known and based on institutional decisions. Therefore, the Manager does not understand why the focus of the Demand is on two individual.
The Manager believes that the conclusions reached by DE&S are supported by the evidence gathered by the Commission during its investigations of the matters discussed in the Demand, including sworn interviews given by the Manager. Therefore, while reserving the right to respond in more detail at some appropriate time in the future if such a response is requested or necessary, the Manager does not think a further response is needed at this time.
3 It is the Manager's opinion that the analysis described in YAEC-1868 provided a valid and conservative SBLOCA analysis for MYAPS.
2
x-
- o. .
Based on the record before the Commission, which, as determined by DE&S, does not support a conclusion of careless disregard, the Manager requests a letter from the Commission declaring that he did not disregard NRC requirements. The Manager respectfully submits that equity
- warrants the granting of this request because of the personal hardship the Manager has suffered or may sufTer due to the issuance of the Demand. The Manager respectfully requests that such a letter be placed in the Public Document Room as soon as practicable as a conclusion to the Manager's direct involvement in this matter.
. Respectfully submitted, BAKER & BOTTS, L.L.P.
9 By:
Mark R. Robeck Texas Bar No. 16990040 1600 San Jacinto Center 98 San Jacinto Boulevard Austin, Texas 78701 ,
l Phone:(512) 322-2500 Fax:(512) 322-2501 Michael P. Lennon, Jr. .
Texas Bar No. 00787895 3000 One Shell Plaza 910 Louisiana )
Houston, Texas 77002 Phone:(713) 229-1234 Fax:(713) 229-1522 ATTORNEYS FOR THE LOCA GROUP MANAGER 3-