ML19209B153
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| ML19209B153 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 08/24/1979 |
| From: | Kosik L KOSIK, L. S., MIAMI VALLEY POWER PROJECT |
| To: | |
| Shared Package | |
| ML19209B128 | List: |
| References | |
| NUDOCS 7910090251 | |
| Download: ML19209B153 (2) | |
Similar Documents at Zimmer | |
|---|---|
Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20071K7501982-07-29029 July 1982
[Table view]First Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML20058B7661982-07-23023 July 1982 First Request for Production of Documents.Certificate of Svc Encl ML20054K6271982-06-0707 June 1982 Interrogatory Re How Zirconium Oxide & Water Bound Electrolytes Catalyze Formation of Hydrogen from Water at Sufficiently High Temps ML20039E9611982-01-0505 January 1982 Objection to City of Mentor,Ky 811215 Formal Discovery Requests.Absurd to Request Formal Admissions from Nonparty. Informally,Interrogatories Have Been Answered. Certificate of Svc Encl.Related Correspondence ML20039E5881982-01-0404 January 1982 Responses to City of Mentor 811214 Interrogatories. Certificate of Svc Encl.Related Correspondence ML20039E9501981-12-31031 December 1981 Response to Requests for Admissions.Certificate of Svc Encl. Related Correspondence ML20039D7351981-12-30030 December 1981 Response to Zimmer Area Citizens-Zimmer Area Citizens of Ky 811215 Request for Admissions ML20039D7311981-12-30030 December 1981 Objections to Certain Zimmer Area Citizens-Zimmer Area Citizens of Ky 811215 Requests for Admissions.Certificate of Svc Encl ML20039E5791981-12-29029 December 1981 Response to City of Mentor Requests for Admissions.Related Correspondence ML20039D7371981-12-29029 December 1981 Response to City of Mentor 811214 Requests for Admissions. Certificate of Svc Encl ML20039C1841981-12-28028 December 1981 Objections to Formal Discovery Requests of ZAC-ZACK. Commonwealth of Ky Does Not Have Any Contentions in Proceeding,Thus Is Not Party.Certificate of Svc Encl ML20039C1881981-12-23023 December 1981 Objections to Listed 811204 Interrogatories.Discovery May Not Compel Party to Generate New Info.Each Party Has Responsibility to Do Own Pretrial Work.Protective Order Should Be Issued ML20039C1831981-12-23023 December 1981 Responses to ZAC-ZACK 811204 Interrogatories.Certificate of Svc Encl ML20039C1851981-12-22022 December 1981 Response to ZAC-ZACK Interrogatories.Certificate of Svc Encl ML20039B5671981-12-21021 December 1981 Requests for Admissions by Commonwealth of Ky ML20039B5291981-12-21021 December 1981 Requests for Admissions Directed to Applicant ML20039B5231981-12-21021 December 1981 Requests for Admissions Directed to Clermont County,Oh ML20039B1071981-12-14014 December 1981 Request for Admissions.Related Correspondence ML20039B1031981-12-14014 December 1981 Request for Admissions.Related Correspondence ML20039B0421981-12-14014 December 1981 Interrogatories Directed to Commonwealth of Ky.Related Correspondence ML20039B0301981-12-14014 December 1981 Interrogatories Directed to Applicant.Related Correspondence ML20038B9741981-12-0404 December 1981 Objections to Fankhauser 811125 Interrogatories 3 Through 11 & Response to Interrogatories 1,2 & 12.Certificate of Svc Encl.Related Correspondence ML20038B9721981-12-0404 December 1981 Responses to Fankhauser Interrogatories.Related Correspondence ML20039A1901981-12-0404 December 1981 Interrogatories Directed Towards Applicant.Certificate of Svc Encl ML19341A7951981-01-23023 January 1981 Response to NRC Second Second Set of Interrogatories Re S&W Evacuation Time Study.Prof Qualifications & Certificate of Svc Encl ML20003A1391981-01-20020 January 1981 Answers of Miami Valley Power Project to Applicant Seventh Set of Interrogatories Re Witnesses & Decommissioning Costs. Analysis of Decommissioning & Premature Shutdown Costs of Plants & Certification of Svc Encl.Related Correspondence ML19339B0221980-10-28028 October 1980 Response to NRC 801010 Interrogatories Re S&W Study on Population Evacuation.Study Is Subj to Revision Due to Development of NRC Position & State & Local Emergency Plans. W/Certificate of Svc.Related Correspondence ML19262A9791979-11-27027 November 1979 Response to Intervenor Miami Valley Power Project Interrogatories Re Contention 13,concerning Delay in Fuel Loading Date.Certificate of Svc Encl ML19262A9641979-11-21021 November 1979 Seventh Set of Interrogatories Re Intervenor Contention 13. Certificate of Svc Encl ML19253C7101979-11-0808 November 1979 Interrogatories Re Contention 13.Certificate of Svc Encl ML19209B2111979-09-11011 September 1979 Responses to Miami Valley Power Project Interrogatories Re Contention 17.Contains Affirmation That Test at Const Technology Labs Was Designed to Qualify Fire Barrier Capability of Kaowool Matl Only.Certificate of Svc Encl ML19209B1581979-08-24024 August 1979 Interrogatories Directed to Applicant Re Contention 17. Includes Questions Re Layers & Thickness of Kaowool Covering Cable Trays,Heat Generated by Cables,Tests Performed on Fire Safety & Other Related Matters.W/Certificate of Svc ML19209B1531979-08-24024 August 1979 First Set of Interrogatories Directed to Nrc.Includes Questions Re Fires Occurring within Cable Trays, Identification of Plants Where Such Occurrences Took Place & Procedures Applied to Prevent Similar Fires ML19249D5441979-08-24024 August 1979 Sixth Set of Interrogatories to Intervenor Miami Valley Project.Certificate of Svc Encl ML19225A6041979-06-15015 June 1979 Cincinnati Gas & Electric Further Responses to Miami Valley Power Project Third Set of Interrogatories.Affidavit & Certificate of Svc Encl ML19256B4451979-05-30030 May 1979 Miami Valley Power Project Answers to Certain of NRC Interrogatories.Affidavit & Certificate of Svc Encl ML19269E4281979-05-14014 May 1979 Applicant Responses to Intervenor Miami Valley Power Project Third Set of Interrogatories.Affidavit & Certificate of Svc Encl ML19241A9441979-05-0909 May 1979 Intervenor Miami Valley Power Project Answers to NRC 790420 Interrogatories ML19241A9571979-05-0909 May 1979 Intervenor Miami Valley Power Project Answer to Cincinnati Gas & Electric 790420 Fifth Set of Interrogatories ML19289F0291979-03-19019 March 1979 Second Set of Interrogatories Submitted to Applicant. Certificate of Svc Encl ML19289E9231979-03-13013 March 1979 Submits Supplementary Answers to Applicant'S Second Set of Interrogatories.Affidavit Encl ML19289E8541979-03-0808 March 1979 Serves Fourth Set of Interrogatories on Miami Valley Power Project.Certificate of Svc Encl ML19273B4851979-03-0202 March 1979 Intervenor Miami Valley Power Project'S First Set of Interrogatories to Applicant.Queries Concern Reed Rept,Const Costs,Decommissioning Expenditures & Projected Capacity Factor.Certificate of Svc Encl ML19261A2791978-12-19019 December 1978 Applicant'S Second Set of Interrogatories Propounded to Intervenor Miami Valley Power Project Pertaining to Contentions as Admitted as Issues by ASLB 760319 Order. Certificate of Svc Encl 1982-07-29 Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS MONTHYEARML20056E5101993-08-11011 August 1993
[Table view]Comment Opposing Proposed Rule 10CFR20 Re Radiological Criteria for Decommissioning ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal IR 05000358/19820101986-06-24024 June 1986 Applicant Exhibit A-49,consisting of Forwarding Partially Withheld Safety Insp Rept 50-358/82-10 on 820607- 0818 (Ref 10CFR2.790) & Notice of Violation ML20129A3751985-05-16016 May 1985 Order Revoking CPPR-88,based on Util 840127 Plan to Convert Facility to Coal Fuel ML20133N3621985-03-14014 March 1985 Unexecuted Amend 3 Terminating Indemnity Agreement B-85 ML20094C3571984-08-0202 August 1984 Transmittal of Info Re Util 840320 Motion for Withdrawal of OL Application.Fuel Removed from Site,Steam Supply Sys Modified & CRD Mechanisms Removed.Certificate of Svc Encl ML20087H7881984-03-20020 March 1984 Motion Requesting Issuance of Order Authorizing Withdrawal of Application.Plant Will Be Used as Part of New Fossil fuel-fired Electric Generating Plant.Certificate of Svc Encl ML20087N2281984-03-0101 March 1984 Endorsement 25 to Nelia Policy NF-249 ML20079F8181984-01-16016 January 1984 Response Opposing Miami Valley Power Project 831231 Proposed Issues & Support for Contentions Re Qa.Issues Not Specific or Litigable.Certificate of Svc Encl ML20083J5321983-12-31031 December 1983 Proposed Issues & Prospective Witnesses Supporting Miami Valley Power Project Proposed Contentions Re Qa,Character & Competence.Certificate of Svc Encl ML20079H6901983-12-14014 December 1983 Petition Per 10CFR2.206 to Defer Judgment or Decision on Proposed Course of Action for Completion of Facility Until Suppl Created for Record of J Keppler 831215 Briefing.W/O Encls ML20082P8501983-12-0606 December 1983 Response Opposing City of Mentor 831115 Memorandum in Support of NRC 831031 Motion to Defer Rulings on Miami Valley Power Project Motion to Reopen Record.Motion W/O Merit.Certificate of Svc Encl.Related Correspondence ML20082M5791983-12-0202 December 1983 Response Opposing Applicant 831115 Answer to NRC 831031 Motion to Defer Ruling on Petition for Reconsideration & Motion for Leave to File Addl Evidence Prior to 831215 Conference of Counsel.Certificate of Svc Encl ML20082L0991983-11-30030 November 1983 Memorandum in Support of City of Mentor Motion to Further Defer Rulings Until Completion of Investigation Into Matl False Statements by NRC & Applicants.Certificate of Svc Encl ML20082D6991983-11-15015 November 1983 Memorandum in Support of NRC Motion to Defer Rulings on Miami Valley Power Project Motion to Reopen & City of Mentor Motion to Further Defer Rulings Until Completion of Investigation.Certificate of Svc Encl ML20081M7951983-11-15015 November 1983 Answer Opposing NRC Motion to Defer Rulings on Miami Valley Power Project (MVPP) 831003 Motion to Reopen Record.Decision Should Not Be Deferred to Await Completion of Investigation. Certificate of Svc Encl ML20085K7841983-10-18018 October 1983 Answer Opposing Miami Valley Power Project 831003 Petition for Reconsideration of ASLB 830915 Memorandum & Order Denying Project Motion to Reopen Record to Admit Eight Late Filed Contentions on Qa.Certificate of Svc Encl ML20078K5621983-10-13013 October 1983 Memorandum in Support of Miami Valley Power Project (MVPP) Petition for Reconsideration of ASLB 830915 Order.Mvpp Urges ASLB to Address Stds for Reopening Record.Issues Should Be Included to Ensure Complete Record.Certificate of Svc Encl ML20078F9641983-10-0606 October 1983 Notification to Commission of Miami Valley Power Project Misrepresentation in 831003 Motion for Reconsideration of ASLB 830915 Order.No Util Counsel Communicated W/Govt Accountability Project.Certificate of Svc Encl ML20078F8891983-10-0606 October 1983 Notice of Jh Laverty Employment W/Conner & Wetterhahn,Pc. Laverty Will Not Participate in Matters Leading to OL Issuance Due to Previous Employment W/Commissioner Roberts. Certificate of Svc Encl ML20078F8751983-10-0606 October 1983 Notice of Jh Laverty Employment W/Conner & Wetterhahn,Pc. Previous Employment W/Commissioner Roberts Eliminates Any Contribution to Zimmer Case ML20080P0771983-10-0303 October 1983 Motion for Extension to File Appeal Until 10 Days After Svc of ASLB Decision on Miami Valley Power Project Petition for Reconsideration.Certificate of Svc Encl ML20080P0141983-10-0303 October 1983 Petition for Reconsideration of ASLB 830915 Order Denying Miami Valley Power Project Motion to Reopen Record for Admission of Eight Proposed Contentions.Addl Info Provided Since Original Decision.Certificate of Svc Encl ML20080P0481983-09-26026 September 1983 Affidavit of T Devine Summarizing 830919 Discussion W/ C Weaver Re Summary of Interview in Torrey Pines Rept. Weaver Seriously Challenges Completeness of Interview Summary ML20080P0291983-09-26026 September 1983 Affidavit of D Jones for Govt Accountability Project Protesting Torrey Pines Rept Chapter on Cases Studies.Ref to Author Interviews Incomplete & Thus Inaccurate.Analysis of Whistleblower Missed Real Problem of Lack of Freedom ML20080P0671983-09-24024 September 1983 Affidavit of R Reiter for Govt Accountability Project Expressing Dissatisfaction of W/Summarized Interview in Torrey Pines Rept ML20080F2451983-09-13013 September 1983 Memorandum Supporting Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight Contentions. Torrey Pines Mgt Review & NRC Repts Confirm Project Substantially Correct on Qa.Certificate of Svc Encl ML20080E6921983-09-12012 September 1983 Answer Opposing Miami Valley Power Project 830826 Motion for Leave to Submit New Documents & for ASLB Review of Pending Investigations.Motion Unjustified Attempt to Bend Rules on Late Contentions.W/Certificate of Svc ML20080D2791983-08-26026 August 1983 Motion for Leave to Submit New Evidence in Support of 830603 Proposed Contentions & for ASLB Review of Significant Pending Investigations.Certificate of Svc Encl ML20080C7171983-08-25025 August 1983 Answer Opposing Miami Valley Power Project 830811 Motion for Leave to File Reply Brief to Util & NRC Answers to Project 830712 Motion to Compel Discovery.Project Had Opportunity to Brief Issue in Original Motion.Certificate of Svc Encl ML20076A6451983-08-15015 August 1983 Notice of Substitution of Counsel for Amicus Curiae Brief & Appearance Before Aslb.Certificate of Svc Encl ML20024E5591983-08-11011 August 1983 Motion for Leave to File Reply Brief to Applicant & NRC 830803 & 01,respectively,answers Opposing Miami Valley Power Project Motion to Compel Discovery.Assertion of Boundary on Discovery Should Be Briefed.Certificate of Svc Encl ML20024E3941983-08-0505 August 1983 Motion for Leave to File Reply Brief & for Clarification of Responsibility to Duplicate Previous Analysis & Evidentiary Submissions.Util Challenge Frivolous,Heavy on Chutzpah & Deficient on Common Sense.Certificate of Svc Encl ML20077L5161983-08-0303 August 1983 Response Opposing Miami Valley Power Project 830707 Reply Brief Supporting Project 830603 Motion to Reopen Record.Aslb Lacks Jurisdiction to Hear Motion to Reopen to Admit Eight late-filed Contentions.Certificate of Svc Encl ML20024D1381983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion for Protective Order to Withhold Identity of Persons Upon Whose Allegations Project Relied in Seeking to Reopen Record.Motion W/O Merit.Certificate of Svc Encl ML20024D1261983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion to Reopen Record for Admission of Eight QA Contentions. Motion Actually Is Untimely Appeal from Earlier ASLB Rulings.Relief Sought Contrary to Commission Orders ML20024D1171983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion to Defer Ruling on Review of ALAB-727 Pending Ruling on Motions to Reopen.No Justification Given to Delay Review for Unrelated Matters ML20080A2721983-07-21021 July 1983 Response to Applicant Motion for Leave to Respond to Miami Valley Power Project Reply Brief.Applicant Should Respond Only to Substance of Proposed Contentions Re QA Program Inadequacy.Certificate of Svc Encl ML20076L4691983-07-15015 July 1983 Motion for Leave to Respond by 830729 to Miami Valley Power Project (MVPP) Reply Brief Re Applicant Opposition to Eight QA Contentions.Mvpp Reply Distorts Record & Applicant Position.Certificate of Svc Encl ML20072N4501983-07-12012 July 1983 Reply Brief Supporting Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight Contentions on QA & Corporate Character & Competence & Motion to Compel Discovery on Contentions ML20072N4631983-07-12012 July 1983 Motion to Reopen Record for Admission of Eight Contentions on QA & Corporate Character & Competence.Aslab Has Jurisdiction Even If ASLB Lacks Jurisdiction to Reopen Record ML20072N4741983-07-12012 July 1983 Motion to Defer Ruling on Whether to Review ALAB-727 Until ASLB & Aslab Rule on Miami Valley Power Project 830603 & 0712 Motions to Reopen Record to Admit Contentions on QA & Character & Competence,Or Alternatively,To Reopen Record ML20072N4901983-07-12012 July 1983 Motion for Protective Order to Shield Identity of Affiants Providing Portion of Basis for Miami Valley Power Project Eight Proposed Contentions.Certificate of Svc Encl ML20072K7331983-07-0101 July 1983 Answer Opposing Miami Valley Power Project 830629 Motion for Leave to File Reply Brief to Util & NRC Answers to Project 830603 Motion to Reopen Record.No Purpose Would Be Served by Permitting Redundant Discussion.Certificate of Svc Encl ML20024B0591983-06-29029 June 1983 Motion for Leave to File Reply Brief,By 830706,to NRC & Util 830630 Answers to Miami Valley Power Project 830603 Motion to Reopen Record to Admit Eight Contentions on QA & Util Character & Competence.Certificate of Svc Encl ML20072F4481983-06-22022 June 1983 Memorandum Supporting Miami Valley Power Project 830602 Motion to Reopen Record to Admit Eight Contentions on QA & Lack of Corporate Character & Competence.Reopening Necessary to Foster Public Confidence in Nrc.W/Certificate of Svc ML20024A6661983-06-20020 June 1983 Response Opposing Motions to File Amicus Curiae Brief in Support of Miami Valley Power Project Motion to Reopen Record for Admission of Eight QA Contentions.Certificate of Svc Encl ML20024A6621983-06-20020 June 1983 Response Opposing Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight QA Contentions. Motion Untimely ML20076J1201983-06-16016 June 1983 Petition for Leave to File Amicus Curiae Brief Re Miami Valley Power Project Motion to Reopen Record to Admit Eight Contentions on QA & Character & Competence.Requests Extension of Time.Certificate of Svc Encl ML20076J1361983-06-16016 June 1983 Ohio Sierra Club Amicus Curiae Brief Supporting Miami Valley Power Project Motion to Reopen Record to Admit Eight Contentions.Contentions Provide Evidence That QA Problems Exist.Certificate of Svc Encl 1993-08-11 |
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DOCC LV. 50-358 (William H. Zi:nner Nuclear Station) -
IhTERVDOR MIN.II VAU.n* POER PPDJEC'S FIEST SET & INTERPCGATORIES 70 57.C STAST Interrenor Mia .i Valley Power Project (?.rJPP) hereby propounds the following interrogatories to h7f Sta.ff to be answered fully dr. writing under oath, within fourts (14) days after sen-ice hereof in accordance with the following instructions:
- 1. "rIscribe in detail" shall mean give all data, calculations and assunptions used in fonnalating the answer.
- 2. These interrogatcries request all imcwledge or infer =ation in the possessics of NPC Staff and/or SRC Staff's agents, rep esentatives ,ar.d unless.priveleged, attorneys.
11lu _us 7 9100 0 0 cl
- 1. Have fires ever occured within cable trays at any nuclear pow _r plant ubich has ever operated in the United States?
- 2. If the answer to interrogatory 1 is in the affi:n:ative, identify each such occurance by plant and date. Attach to your ansmrs investigation reports of each of these fires.
- 3. IR:at precautions have been taken at ZpS-1 to insure that similar fires will not occur there?
- 4. With regard to each fire identify in your answer to interrcgatory 2.
describe hcw the fire prctection at ZTS-1 differs fran that at the plam in cuestien.
- 5. Was Jan.es Creswell, an NRC inspector, ever involvec' I: any inspections of Zi;:rer cable tray fire insulation? If so, describe in detail the results of his inspections and provide all relevant dcenents.
Respectfully sub-itted, tY Cd<. 2 I.eah Kosik Attorney for MVp?
August 24, 1979
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