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Category:Legal-Interrogatories and Response
MONTHYEARML0501203612005-01-0404 January 2005 Letter from Mark J. Wetterhahn to Diane Curran Enclosing Duke Energy Corporation'S Fourth Supplemental Response to Blue Ridge Environmental Defense League'S First Set of Discovery Requests to Duke Regarding Bredl Security Contention 5 ML0433501372004-11-19019 November 2004 Duke Energy Corporation'S Second Supplemental Response to Blue Ridge Environmental Defense League'S First Set of Interrogatories on Bredl Security Contention 5 ML0432404862004-11-19019 November 2004 Catawba - NRC Staff'S Second Supplemental Response to the Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff Regarding Security Plan Submittal ML0433103352004-11-17017 November 2004 Letter from Mark J. Wetterhahn to Diane Curran Attaching an Updated Index of Documents Responsive to Bredl Security Discovery Requests ML0432001142004-11-0202 November 2004 Duke Energy Corporation'S First Supplemental Response to Blue Ridge Environmental Defense League'S First Set of Interrogatories on Bredl Security Contention 5 ML0430003892004-10-22022 October 2004 Catawba - NRC Staff'S Supplemental Response to the Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff Regarding Security Plan Submittal ML0428200922004-10-0505 October 2004 NRC Staff'S Response to the Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff Regarding Security Plan Submittal ML0427800972004-09-24024 September 2004 Duke Energy Corporation'S Objections to Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to Duke Energy Corporation Regarding Security Plan Submittal ML0427306022004-09-24024 September 2004 Catawba - NRC Staff'S Objections to Bredl'S Second Set of Discovery Requests to NRC Staff Regarding Security Contention 5 ML0426600152004-09-20020 September 2004 Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff Regarding Security Plan Submittal ML0419404662004-07-0202 July 2004 Status of Duke Energy Corporation Responses and Objections to Blue Ridge Environmental Defense League'S Interrogatories and Document Production Requests on Security Contention 5 ML0419404652004-07-0202 July 2004 Duke Energy Corporation'S Response to Blue Ridge Environmental Defense League'S First Document Production Request on Bredl Security Contention 5 ML0419404682004-07-0202 July 2004 Duke Energy Corporation'S Response to the NRC Staff'S First Set of Interrogatories and Request for Production of Documents to Duke Energy Corporation on the Admitted Security Contention ML0419404852004-06-29029 June 2004 Duke Energy Corporation'S Third Supplemental Response to Blue Ridge Environmental Defense League'S First Discovery Request ML0417603382004-06-23023 June 2004 Catawba - NRC Staff'S Objections to Bredl'S First Set of Discovery Requests to NRC Staff Regarding Security Plan Submittal and Request for Protective Order ML0417601422004-06-23023 June 2004 Catawba - NRC Staff'S Response to the Blue Ridge Environmental Defense League'S Request for a Need to Know Determination ML0417504182004-06-21021 June 2004 Catawba - Addendum to NRC Staff'S First Set of Interrogatories and Request for Production of Documents to the Blue Ridge Environmental Defense League on Security Contention 5 ML0417503962004-06-21021 June 2004 Catawba - NRC Staff'S First Set of Interrogatories and Request for Production of Documents to Duke Energy Corporation on Admitted Security Contention ML0416805232004-06-0808 June 2004 Blue Ridge Environmental Defense League'S Response to NRC Staff'S Second Set of Interrogatories and Request for Production of Documents ML0416805182004-06-0808 June 2004 Blue Ridge Environmental Defense League'S Response to Duke Energy Corporation'S Second Set of Interrogatories and Requests for Production of Documents ML0416100672004-06-0404 June 2004 NRC Staff Third Supplemental Response to Bredl'S First Discovery Request ML0416203782004-06-0303 June 2004 Duke Energy Corporation'S First Supplemental Response to Blue Ridge Environmental Defense League'S Second Discovery Request ML0413303672004-05-11011 May 2004 Catawba - NRC Staff Second Supplemental Response to Bredl'S First Discovery Request ML0413202212004-05-10010 May 2004 Catawba - NRC Staff Response to the Blue Ridge Environmental Defense League'S Second Set of Discovery Requests ML0414005142004-05-10010 May 2004 Duke Energy Corporation'S Response to Blue Ridge Environmental Defense League'S Second Discovery Request ML0413303642004-05-0505 May 2004 Duke Energy Corporation'S First Supplemental Response to Blue Ridge Environmental Defense League'S First Discovery Request ML0412600262004-04-30030 April 2004 Catawba - NRC Staff'S (1) Objections to the Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff and (2) Request for Protective Order ML0412603522004-04-26026 April 2004 Duke Energy Corporation'S Second Set of Interrogatories and Requests for Production of Documents Directed to Blue Ridge Environmental Defense League ML0412603442004-04-26026 April 2004 Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to Duke Energy Corporation ML0412603392004-04-26026 April 2004 Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff ML0411906402004-04-26026 April 2004 Catawba - NRC Staff'S Second Set of Interrogatories and Request for Production of Documents to the Blue Ridge Environmental Defense League and NRC Staff'S Notice of Deposition ML0412000232004-04-22022 April 2004 Blue Ridge Environmental Defense League'S First Supplemental Response to NRC Staff'S First Set of Interrogatories and Request for Production of Documents ML0411005292004-04-14014 April 2004 Catawba - Certificate of Service for NRC Staff'S Response to the Blue Ridge Environmental Defense League'S First Set of Discovery Requests to NRC Staff and NRC Staff Brief in Response to the Aslb'S April 8, 2004 Order ML0411005212004-04-14014 April 2004 Catawba - NRC Staff Brief in Response to the Aslb'S April 8, 2004 Order ML0411005262004-04-14014 April 2004 Catawba - NRC Staff'S Response to the Blue Ridge Environmental Defense League'S First Set of Discovery Requests to NRC Staff ML0411005272004-04-14014 April 2004 Orr, Palla Shoop and Shih-Liang Wu ML0411205212004-04-14014 April 2004 Blue Ridge Environmental Defense League'S Response to Duke Energy Corporation'S First Set of Interrogatories and Requests for Production of Documents ML0411205252004-04-14014 April 2004 Blue Ridge Environmental Defense League'S Response to NRC Staff'S First Set of Interrogatories and Request for Production of Documents ML0411300692004-04-14014 April 2004 Duke Energy Corporation'S Response to the NRC Staff'S First Set of Interrogatories and Request for Production of Documents to Duke Energy Corporation ML0411303922004-04-14014 April 2004 Duke Energy Corporation'S Response to Blue Ridge Environmental Defense League'S First Discovery Request ML0410001142004-04-0202 April 2004 Duke Energy Corporation'S Objections to Blue Ridge Environmental Defense League'S First Discovery Request ML0409602572004-04-0202 April 2004 League'S First Set of Discovery Requests to NRC Staff ML0411205272004-03-31031 March 2004 Blue Ridge Environmental Defense League'S First Set of Discovery Requests Directed to Duke Energy Corporation ML0410704432004-03-31031 March 2004 NRC Staff'S First Set of Interrogatories and Request for Production of Documents to Duke Energy Corporation ML0409801972004-03-31031 March 2004 Blue Ridge Environmental Defense League'S First Set of Discovery Requests to NRC Staff ML0409801882004-03-31031 March 2004 Duke Energy Corporation'S First Set of Interrogatories and Requests for Production of Documents Directed to Blue Ridge Environmental Defense League ML0409200232004-03-31031 March 2004 Catawba - NRC Staff'S First Set of Interrogatories and Request for Production of Documents to the Blue Ridge Environmental Defense League ML0210803372002-04-11011 April 2002 First Response of Duke Energy Corporation to the Nuclear Information and Resource Service'S Interrogatories, Requests for Admission and Requests for Production to Duke Energy ML0210803512002-04-0808 April 2002 Letter from David A. Repka to ASLBP Forwarding a Written Recounting of the Remaining Discovery Disputes Involving the Nuclear Information and Resource Service ML0210701452002-04-0505 April 2002 Duke Energy Corporation'S First Set of Interrogatories, Requests for Admission, and Document Production Requests to the Nuclear Information and Resource Service 2005-01-04
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June 4,2004 RAS 7899 UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC June 7,2004 (1252PM)
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRETARY In the Matter of RULEMAKINGS AND
) ADJUDICATIONS STAFF 1
DUKE ENERGY CORPORATION j Docket Nos. 50-413-OLA
) 50-414-OLA
)
(Catawba Nuclear Station )
Units 1 and 2) )
NRC STAFF THIRD SUPPLEMENTAL RESPONSE TO BREDL'S FIRST DISCOVERY REQUEST On April 14,2004, the staff of the Nuclear Regulatory Commission (Staff), filed a response to Blue Ridge Environmental Defense League's First Set of Discovery directed to the NRC Staff (BREDL's First Discovery Request), filed March 31,2004. The NRC Staff (Staff) filed its objections to BREDL's Request on April 12, 2004. The Staff hereby reiterates and renews each of its objections to BREDL's Request set forth in the Staff's Objection. Without waiving any previously made objections to BREDL's first discovery request, the Staff hereby files this supplemental response to BREDL's First Discovery Request.
GENERAL DOCUMENT PRODUCTION REQUESTS GENERAL REQUEST NO. 2: All documents in your possession, custody or control relevant to each BREDL admitted contention, and to the extent possible, segregated by contention and separatedfrom already produced documents.
STAFF RESPONSE: The staff provides the following additional documents in responseto General Request No. 2. The following documents are publicly available at the locations listed. By providing documents in response to this request or any other portion of BREDL's Request, the Staff is not conceding that any of the answers or documents provided are material to the admitted contentions.
The Staff reserves the right to object to the introduction of any of these documents at hearing on the grounds that they are immaterial, irrelevant or outside the scope of the proceeding. Documents denoted by an asterisk (*) have already been provided to BREDL.
- 1. RAls on SRXB, Radiological Consequences, Environmental Impacts, July 25,2003 (ADAMS ML032060316).
- 2. RAls on Quality Assurance, August 13,2003 (ADAMS ML032250422).
- 3. Framatome responds to Aug 13 RAI. Provides FramatomeANP Fuel Sector Quality Management Manual, October 1,2003 (ADAMS ML032890405)
- 4. Duke responds to all July 25 RAls (non-proprietary), November 4, 2003 (ADAMS ML033210345).
- 5. RAls on environmental and consequences reviews, November 21,2003 (ADAMS ML033250530).
- 6. RAI on RV materials and dose consequences, December 16,2003 (ADAMS ML033500408).
- 7. RAI requesting copy of QA document, December 24,2003 (ADAMS ML033580008).
- 8. Two RAls on Radiological Consequences, February 4,2004 (ADAMS ML040350005).
- 9. Duke responds to RAI on SFP criticality issues, March 9,2004 (ADAMS ML040760831)*
- 10. Duke letter on burn-up limit commitment, March 31,2004 (ADAMS ML040980602).*
- 11. NRG Safety Evaluation, April 5,2004 (ADAMS ML040970046).*
- 12. Duke letter on W Next Generation Fuel, April 16, 2004 (ADAMS ML041130422).*
- 13. ACRS Letter from May 6 Full Committee Meeting, May 7,2004 (ADAMS ML041320159 & ML041340427).
- 14. Duke letter on Clarifications RE: NGF fuel, May 13,2004 (ADAMS ML041410479).
- 15. Staff RAI I I on NGF Fuel, May 19,2004 (ADAMS ML041400201).*
- 16. Response io RAls 6,7; 3,4, 6,28,29 (NP), July 27,2001 (ADAMS ML012140093).
- 17. SE for LEU version of COPERNIC topical BAW-10231, April 18, 2002 (ADAMS ML020070158).
- 18. Draft SE on COPERNIC topical report, November 21,2003 (ADAMS ML033290099).
- 19. NP version of DPC-NE-1005, August 6,2001 (ADAMS MLOl2270096).
- 20. Response to 23 RAls, Sept 12,2002 (ADAMS ML022660041).
21 Response to RAI 8, fission chambers, Nov 12,2002 (ADAMS ML023330443).
- 22. Startup Physics Testing Program, June 26,2003 (ADAMS ML031840379).
- 23. Duke response to CASMO RAI on DRWM, Dec 2,2003 (ADAMS ML032380584).
- 24. Draft SE to Duke, Feb 20,2004 (ADAMS ML040550384).
- 25. Letter replying to draft SE on CASMO-4/SIMULATE-3 MOX, March 9, 2004 (ADAMS ML040760899).
- 26. FANP Submits BAW-10238, Rev 1, MOX Fuel Design Report, May 30, 2003 (ADAMS ML031540668).
- 27. NRC RAls, October 8,2003 (ADAMS ML032870371 & ML033000363).
- 28. Framatome Acceptance of 5 Conditions, March 29,2004 (ADAMS ML040910284).
- 29. BAW-10239, Rev 0, Adv. Mark BW Mechanical Design, April 30, 2002 (ADAMS ML040770368).
- 30. Response to 04/07/03 RAls, May 9,2003 (ADAMS ML031330106).
- 31. SE on Cat FHA & WGD with AST, April 23,2002 (ADAMS ML021140431).
- 32. NRC Acceptance of Rev to Framatome QA Topical Report, May 15, 1998 (ADAMS ML040830529).
- 33. Meeting Notice, Forthcoming Meeting with Framatome ANP Regarding Use of Condition Statements in Topical Report Safety Evaluations, May 18, 2004 (ADAMS ML041380294).
- 34. N. Waeckel and J.P. Mardon, Electricite de France, Abstract, Behavior of M5v. Zr4 in Term of Ballooning and Flow Blockage, May 25-26, 2004. (Attached)
- 35. N oWaeckel, J.P. Mardon, L. Portier, and A. Lesbros, Presentation, Does M5TM balloon more than Zircaloy-4 under LOCA conditions?, Argonne SEGFSM LOCA Meeting, May 27, 2004. (Attached)
An updated version of the Staffs privilege log is attached.
Respectfully submitted, Counsel for NRC Staff Dated at Rockville, Maryland this 4thday of June, 2004.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
DUKE ENERGY CORPORATION ) Docket Nos. 50-413-OLA
) 50-414-OLA
)
(Catawba Nuclear Station )
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF THIRD SUPPLEMENTAL RESPONSE TO BREDLS FIRST DISCOVERY REQUEST in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class; or as indicated by an asterisk (*), by deposit in the Nuclear Regulatory Commissions internal mail system; and by e-mail as indicated by a double asterisk (**), this 4thday of June, 2004.
Ann Marshall Young, Chair * ** Office of the Secretary * **
Administrative Judge ATTN: Docketing and Service Atomic Safety and Licensing Board US. Nuclear Regulatory Commission Mail Stop: T-3F23 Mail Stop: 0 - 16C1 U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555-0001 (E-mail: HEARINGDOCKET@ nrc.gov)
(E-mail: AMY @ nrc.gov)
Office of Commission Appellate Anthony J. Baratta * ** Adjudication*
Administrative Judge Mail Stop: 0-16C1 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop: T-3F23 Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Atomic Safety and Licensing Board (E-mail: AJB5@nrc.gov) Adjudicatory File*
U S . Nuclear Regulatory Commission Thomas S. Elleman ** Mail Stop: T-3F23 Administrative Judge Washington, DC 20555 Atomic Safety and Licensing Board 5207 Creedmoor Rd. #IO1 Diane Curran, Esq. **
Raleigh, NC 27612 Harmon, Curran, Spielberg (E-mail: elleman @eos.ncsu.edu) & Eisenberg, L.L.P.
1726 M Street, N.W., Suite 600 Washington, DC 20036 (E-mail: dcurran @ harmoncurran.com)
Lisa F. Vaughn, Esq ** David A. Repka, Esq. **
Legal Department Anne W. Cottingham, Esq. **
Mail Code - PB05E Mark Wetterhahn, Esq. **
Duke Energy Corporation Winston & Strawn LLP 426 S. Church Street (EC11X) 1400 L Street, N.W.
Charlotte, NC 28201-1006 Washington, DC 20005-3502 (E-mail: IfVaughn@duke-energy.com) (E-mail: drepka @winston.com acotting @winston.com)
Counsel for NRC Staff