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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20149E4541994-05-13013 May 1994
Licensee First Set of Interrogatories & Request for Production of Documents to Eco.* W/Certificate of Svc. Related Correspondence
ML19290E0461980-02-15015 February 1980
Supplemental Response to NRC 800124 Answers to Friends of the Earth First Set of Interrogatories.Describes Controlled Filtered Venting Sys.Summary of Past TMI Safety Improvements,Affidavit & Certificate of Svc Encl
ML19305B0231980-02-0101 February 1980
Response to NRC Interrogatories,Complying W/Aslb 800122 Order Re NRC Motion to Compel Friends of the Earth Answers. Includes Statements Re long-term Mods,Facility Mgt Competence & Nonlicensed Personnel.Certificate of Svc Encl
ML19260E0921980-01-31031 January 1980
Suppl to Licensee 791204 Answers,Set 3,to CA Energy Commission 791115 First Set of Interrogatories.Rc Jones Will Sponsor Ba Karrasch Testimony Re Areas of Transient Analyses.Prof Qualifications & Affidavit Encl
ML19257C3701980-01-17017 January 1980
Responses by CA Energy Commission (CEC) to Licensee Second Set of Interrogatories.Lewis Will Testify Re ASLB Questions CEC 1-2 & 1-10 & Re Natural Circulation Cooling Sys. Affidavits of Mann,Minor & Bridenbaugh & Proof of Svc Encl
ML19257C4251980-01-17017 January 1980
Answers,Set 1,to CA Energy Commission Second Set of Interrogatories.Includes Info Re Feedwater Transients,Most Severe Over Cooling Events & Atypical Welding Matls Used in Reactor Pressure Vessel.Affidavit Encl
ML19257C4291980-01-17017 January 1980
Answers,Set 2,to CA Energy Commission Second Set of Interrogatories.Contains Info Re Feedwater Transients Reactor Trip,Most Severe Overcooling Events & Mgt of Technical Personnel.Affidavit Encl
ML19257C3571980-01-17017 January 1980
Suppls to CA Energy Commission (CEC) Responses to NRC First & Second Sets of Interrogatories.Dg Brodembaigm Will Testify in Support of CEC Admitted Issues.B Mann May Be Called as Witness.Affidavit Encl
ML19257C3061980-01-17017 January 1980
Responses to CA Energy Commission 791221 Second Set of Interrogatories.Includes Info Re Increased Reactor Trips & Initiation of Auxiliary Feedwater in Feedwater Transients. Affidavits,Notice of Appearance & Certificate of Svc Encl
ML19257C4301980-01-16016 January 1980
Answers,Set 3,to CA Energy Commission Second Set of Interrogatories.Contains Info Re Transients That May Result in Reactor Coolant Pressure Reduction & Transients That May Result in Turning Off Main Coolant Pumps.Affidavit Encl
ML20125E3641980-01-14014 January 1980
Responds to G Hursh & R Castro Second Set of NRC Interrogatories.Reiterates Objection to Interrogatory 22. Info Re Interrogatory 24 Is Confidential.Certificate of Svc Encl
ML19291C5001980-01-0707 January 1980
Answers to Licensee First Set of Interrogatories.Alleges That Inability to Operate Certain Equipment Automatically Contributed to TMI-2 Accident.Objects to Remaining Questions
ML19290C0651979-12-17017 December 1979
First Set of Interrogatories.Requests Info Re Former Nonlicensed operators,NUREG-0578 Application,Reactor Trips Occurring Due to Commission 790507 Order & Feedwater Transients Since 1975.Cert of Svc Encl
ML19260C4251979-12-17017 December 1979
Second Set of Interrogatiories.Requests Further Info Re Responses to NRC Interrogatories 2,7,20 & 21 of NRC First Set of Interrogatories
ML19260C4211979-12-17017 December 1979
Second Set of Interrogatories.Requests Clarification of Responses to Interrogatories 2,4 & 5 of NRC First Set of Interrogatories
ML19260C4261979-12-17017 December 1979
Second Set of Interrogatories.Requests Further Info Re Intervenor Contentions Re NRC 790507 Order,Facility Personnel Competence & Adequacy of Emergency Instructions. Certificate of Svc Encl
ML19290C0561979-12-17017 December 1979
First Set of Interrogatories.Requests Info Re Procedure Used to Determine Competency & Fitness of Licensees,Training, Personnel Requirements,Control Room design,post-licensing Review & Outstanding long-term Generic Issues
ML20125C4381979-12-17017 December 1979
First Set of Interrogatories Directed to Nrc.Adopts CA Energy Commission & Friends of the Earth 791115 & 1217 First Sets of Interrogatories Directed to NRC
ML20125C4571979-12-17017 December 1979
First Set of Interrogatories Directed to Licensee.Adopts CA Energy Commission & Friends of the Earth 791115 & 1217 First Sets of Interrogatories Directed to Licensee
ML19211A2531979-12-11011 December 1979
Responses to CA Energy Commission 791115 First Set of Interrogatories.Includes Listing of All Documents Related to TMI-2 & to Effects of Accident on B&W Plants.Affidavits,Prof Qualifications & Certificate of Svc Encl
ML19257A0711979-12-0707 December 1979
Answers to NRC First Set of Interrogatories.Includes Info Re NUREG-0560 & NUREG-0578 Asserting That Operation of B&W NSSS Results in Frequency Rate for Feedwater Transients Greater than Other NSSS Designs.Certificate of Svc Encl
ML19257A2491979-12-0404 December 1979
Response to First Set of Interrogatories,Questions 11-30. Provides Info About Procedures for Plant Emergency Re Feedwater Transients,Control Room Design & Operator Training & Performance.Supporting Documentation Encl
ML19257A2481979-12-0404 December 1979
Response to First Set of Interrogatories,Questions 1-10. Describes Proposed or Implememted Changes in Facility Design,Equipment & Operating Proceedures Resulting from TMI Incident.Affidavit of RA Dieterich Encl
ML19257A2501979-12-0404 December 1979
Response to First Set of Interrogatories.Provides Info Re Plant Transient Conditions Requiring Use of Natural Circulation for Core Cooling.Lists Witnesses to Be Called in Proceeding.Affidavit of DC Holt Encl
ML19290B8011979-12-0404 December 1979
First Set of Interrogatories.Seeks Info on Contentions 22,25,30,32 & 34
ML19290B7641979-11-15015 November 1979
Intervenor CA Energy Commission First Set of Interrogatories & Request for Documents.Seeks Info Re Small Break Analysis, Plant Transient Conditions & Safety Precautions Taken in Light of TMI
ML19260B4171979-11-0909 November 1979
First Set of Interrogatories Directed to CA Energy Commission (Cec).Questions Meaning of Mechanics of Facility, Basic Reactor Physics, Overpressurization Protection & Other Terms Used in CEC Queries
ML19260B4271979-11-0909 November 1979
First Set of Interrogatories Directed to Friends of the Earth.Requests Reasons & Bases Re Allegations of Util Failure to Take Procedures Assuring Facility Mgt Competence
ML19260B4091979-11-0909 November 1979
First Set of Interrogatories,Directed to G Hursh & R Castro. Requests Bases for Allegations That Steam Generator Design Results in Unsafe Faciliity
1994-05-13
[Table view]
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20149E4541994-05-13013 May 1994
Licensee First Set of Interrogatories & Request for Production of Documents to Eco.* W/Certificate of Svc. Related Correspondence
ML20058P3701993-12-16016 December 1993
Memorandum & Order (Telcon 931209).* Smud Unopposed Motion Granted.W/Certificate of Svc.Served on 931217
ML20058P4161993-12-15015 December 1993
Licensee Petition for Review of Second Prehearing Conference Order & Motion for Directed Certification.* Advises That Commission Accept Review & Grant Directed Certification of Board Rulings.W/Certificate of Svc
ML20058E0471993-11-30030 November 1993
Second Prehearing Conference Order (Proposed Contentions; Summary Disposition).* Environmental & Resources Conservation Organization Bases 1,5,11,13,2 & 14 Accepted for Litigation.W/Certificate of Svc.Served on 931201
ML20058E0361993-11-30030 November 1993
Transcript Corrections (Second Prehearing conference,930921- 22).* Board Adopts Listed Corrections.W/Certificate of Svc. Served on 931201
ML20058D6481993-11-19019 November 1993
Exemption from Requirements of 10CFR140.11(a)(4) to Extent That Primary Financial Protection in Stated Amount Shall Be Maintained
ML20058E0151993-11-14014 November 1993
Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down
ML20057G2181993-10-14014 October 1993
Proposed Transcript Corrections.* Submits Listed Transcript Corrections for 930921 & 22 Prehearing Conference. W/Certificate of Svc
ML20058M8951993-10-0505 October 1993
Order (Proposed Transcript Corrections).* Util Submitted Proposed Transcript Corrections for 930921-22 Prehearing Conference.Other Parties May Submit Proposed Corrections by 931015.W/Certificate of Svc.Served on 931005
ML20058M8581993-10-0101 October 1993
Licensee Motion to Correct Transcript of Prehearing Conference.* Requests That Licensing Board Direct Correction of Prehearing Conference Trancript in Manner Described Above.Certification of Svc& Svc List Encl
ML20057D1021993-09-27027 September 1993
Eco Answer in Opposition to Smud Motion for Summary Disposition of Eco Original Loop Contention.* Urges Board Either to Deny Motion or to Defer Consideration of Smud Motion to Conclusion of Proceeding.W/Certificate of Svc
ML20057D0861993-09-27027 September 1993
NRC Staff Response in Support of Licensee Motion for Summary Disposition of Eco Original Loop Contention.* Summary Disposition Should Be Granted.Certificate of Svc Encl
ML20057D1891993-09-27027 September 1993
Exemption from Training rule,10CFR50.120 Requirements to Establish,Implement & Maintain Training Program,Using Sys Approach to Training,For Categories of Personnel Listed in 10CFR50.120.Exemption Effective 931122
ML20057D1351993-09-27027 September 1993
Eco Concise Statement of Material Facts as to Which There Exists Genuine Issue to Be Heard.* Eco Original LOOP Contention Continues to Present Justifiable & Matl Issues Requiring Denial of Smud Motion.Certificate of Svc Encl
ML20057D0451993-09-24024 September 1993
Notice of Hearing.* Notifies That Hearing Will Be Conducted in Matter of Proposed Decommissioning of Plant.W/Certificate of Svc.Served on 930924
ML20057D0441993-09-23023 September 1993
Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc
ML20057C0851993-09-22022 September 1993
Transcript of 930922 Hearing in Bethesda,Md Re Facility.Pp 387-579
ML20057B9611993-09-21021 September 1993
Transcript of 930921 Hearing in Bethesda,Md.Pp 181-386
ML20057B0091993-09-10010 September 1993
Memorandum & Order CLI-93-19.* Informs That Further Questions of Board Re Effect of Commission Holding in Issues Concerning CLI-93-3 & CLI-93-12 Should Be Certified to NRC, Per 10CFR2.718(i).W/Certificate of Svc.Served on 930910
ML20057B0101993-09-0707 September 1993
Licensee Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard (Environ & Resources Conservation Organization Original Loop Contention).* Advises That Contention No Longer Matl Issue.W/Certificate of Svc
ML20057B0051993-09-0707 September 1993
Licensee Motion for Summary Disposition of Environ & Resources Conservation Organization Original Loop Contention.* Advises That Contention Presents No Genuine Issue of Matl Fact to Be Heard & Should Be Dismissed
ML20057A1721993-08-31031 August 1993
Notice of Prehearing Conference.* Notifies of 930921 Prehearing Conference in Bethesda,Md to Discuss Proposed Decommissioning of Plant.W/Certificate of Svc.Served on 930901
ML20046C5241993-08-0202 August 1993
NRC Staff Response to Eco Contentions on Staff Ea,Finding of No Significant Impact & Se.* W/Certificate of Svc & Notice of Appearance
ML20045G9611993-07-12012 July 1993
Environ & Resources Conservation Organization Contentions on Staff Environ Assessment Findings of No Significant Impact & Safety Evaluation.* Urges ASLB to Admit Foregoing Contention Per 10CFR2.714(b)(2).W/Certificate of Svc
ML20044F8041993-05-26026 May 1993
Memorandum & Order CLI-93-12.* Util Motion for Reconsideration of CLI-93-03 Denied.W/Certificate of Svc. Served on 930526
ML20045D1871993-05-10010 May 1993
Erratum.* Informs That Correct Ref for Footnote 34 on Page 22 of Commission Memoranudm & order,CLI-93-03,dtd 930303 Is 57 Fed Reg 20,718 (920514).W/Certificate of Svc.Served on 930610
ML20035G3321993-04-21021 April 1993
NRC Staff Response to Eco Contention Re Loss of Offsite Power.* Advises That Eco Contention & Bases Must Be Rejected in Entirety.W/Certificate of Svc
ML20035F5841993-04-13013 April 1993
Licensee Response to Eco Proposed Loop Contentions.* Util Opposes Eco Proposed Contentions on LOOP Because Contentions Vague & Confusing & Lack Factual & Legal Bases.W/Certificate of Svc & Svc List
ML20035E0031993-04-12012 April 1993
NRC Staff Response to Eco Contentions Re Funding of Decommissioning.* All Bases Eco Decommissioning Funding Contention & Contention Should Be Rejected.W/Certificate of Svc
ML20035B5391993-03-26026 March 1993
NRC Staff Support of Licensee Motion for Reconsideration.* Decommissioning Funding Plan Cannot Be Deemed Adequate Until Listed Issues Resolved.W/Certificate of Svc
ML20035B5711993-03-26026 March 1993
Environ & Resources Conservation Organization Answer in Opposition to Licensee Motion for Reconsideration.* W/Certificate of Svc
ML20035B5441993-03-22022 March 1993
Environ & Resources Conservation Organization Contention on Licensee Proposed Decommissioning Funding Plan.* Environ & Resources Conservation Organization Contends That Licensee Decommissioning Plan Inadequate.W/Certificate of Svc
ML20034H8441993-03-12012 March 1993
NRC Staff Opposition to Environ & Resources Conservation Organization Petition for Reconsideration.* Staff Opposes Petition W/Respect to Reconsideration of Paragraph 2.W/ Certificate of Svc
ML20034H7991993-03-12012 March 1993
Order.* Orders That Any Response to Smud Petition,From Either NRC or Environ & Resources Conservation Organization, Shall Be Filed by 930326.W/Certificate of Svc.Served on 930312
ML20034H8661993-03-10010 March 1993
Licensee Motion for Reconsideration.* Licensee Requests Commission Reconsider Grant of Discretionary Intervention to Environmental & Resources Conservation Organization. W/Certificate of Svc
ML20034G7151993-03-0909 March 1993
Licensee Response to Eco Petition for Reconsideration.* Eco 930305 Petition Should Be Denied in Toto.Certificate of Svc Encl
ML20034G6841993-03-0505 March 1993
Environmental & Resources Conservation Organization Petition for Reconsideration.* Urges Commission to Reconsider & Amend 930303 Decommissioning Order.W/Certificate of Svc
ML20128D4951993-01-28028 January 1993
Notice of Appointment of Adjudicatory Employee.* W/Certificate of Svc.Served on 930129
ML20127D5091992-09-11011 September 1992
Environ & Resources Conservation Organization Brief in Support of Appeal from LBP-92-23.* Certificate of Svc Encl
ML20127D4711992-09-0808 September 1992
Notice of Appeal.* Gives Notice of Appeal from Order of Board (Served 910821),denying Environ & Resources Conservation Organization Petition for Intervention & Request for Hearings & Termination of Proceedings
ML20141M5981992-08-20020 August 1992
Prehearing Conference Order (Terminating Proceeding).* Petition for Leave to Intervene & Request for Prior Hearing of Petitioner, ,denied & Proceeding Terminated. W/Certificate of Svc.Served on 920821
ML20141M5881992-08-17017 August 1992
NRC Staff Response in Support of Licensee Motions to Strike Improper Argument in Environmental & Resources Conservation Organization (Eco) Filings.* Further Argument by Eco Unauthorized.Certificate of Svc Encl
ML20029B5991991-03-0404 March 1991
Environ Conservation Organization Reply to 910215 Order.* ASLB Should Limit Any Rulings Based on Current State of Record to Rulings Which Presume That Petitioner & Members Have Standing Under Atomic Energy Act.W/Certificate of Svc
ML20029B6701991-02-22022 February 1991
Exemption from 10CFR50-54(q) Requirements Re Offsite Emergency Preparedness That Provides Reactor Shutdown & Changes Long Term Defueled Condition
ML20024F8321990-12-0505 December 1990
NRC Staff Response in Opposition to Petition to Intervene Filed by Environmental Conservation Organization on Proposed License Amend.Petition Should Be Denied Based on Listed Reasons.W/Certificate of Svc
ML20024F8311990-11-30030 November 1990
Licensee Answer to Environ Conservation Organization Petition.* Organization Seeks to Litigate Issues That Are Beyond NRC Jurisdiction & Scope of Proposed License Amend. Petition Should Be Denied.W/Certificate of Svc
ML20024F8301990-11-26026 November 1990
Order.* Motion for Extension of Time for 1 Wk to Respond to Environ Conservation Organization Petition for Leave to Intervene & Request for Hearing,Granted.Util Response Due on 901130.W/Certificate of Svc.Served on 901127
ML20024F9081990-11-16016 November 1990
Licensee Motion for Extension of Time.* Extension of Time of 1 Wk Beyond 901123 Deadline Requested,Based on Length of Petition/Request & Intervening Two Holidays.W/Certificate of Svc
ML20024F9051990-11-0808 November 1990
Environ Conservation Organization Comment on Proposed NSHC & Petition for Leave to Intervene & Request for Prior Hearing.* Other Remedies Sought Should Be Granted.Notice of Appearance & Certificate of Svc Encl
ML20058G9051990-10-23023 October 1990
Comment on Fr Notice Page 41280 to 41282 Re Smud Possession Only License Amend.Believes Termination of Plant OL Prior to End of Authorized Operating Term Will Have Significant Impact on Environ Sources Needed to Generate Power
1994-05-13
[Table view] |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
SACRAMENTO MUNICIPAL UTILITY Docket No. 50-312 (SP)
DISTRICT
)
(Rancho Seco Nuclear Generating Station)
)
FIRST SET OF NRC STAFF INTERROGATORIES TO THE CALIFORNIA ENERGY COMMISSION (CEC)
Pursuant to 10 CFR 6 2.740b, the following interrogatories are directed to CEC.V Each interrogatory, unless objected to, is to be answered separately and fully in writing, under oath or affinnation, by individuals having personal knowledge of the answers.
Section 2.740b requires interrogatories to be answered within 14 days of service.
Five days are added to this time when service is by mail pursuant to Section 2.710. Accordingly, responses to these interrogatories, which are served by mail on November 9,1979, are due to be filed on November 28, 1979.
Pursuant to Section 2.740(e), these interrogatories should be supplemented as required by the above-referenced rule.
If "NRC Staff Request to Produce Directed to the California Energy Commission -
(CEC)" is being served contemporaneously with these Staff interrogatories.
791 10
/
-2 Interrogatory 1 With regard to each of CEC's admitted issues,U provide the following information.
A.
Identify the individual (s), if any, whom CEC intends to present as witnesses in this proceeding on the subject matter of each of its issues.
The identification should include the individual's name, affiliation, and a summary of the educational and professional background of that individual.
B.
Provide a reasonable description of the substance of the testimony of any witness (es) that CEC intends to have testify with regard to each of its issues, including an identification of all documents that will be relied upon in that testimony.
C.
Following the substantive response to each of the subsequent interroga-tories posed by the Staff, identify all documents and studies relied upon by CEC in providing the answers to that interrogatory. The ider.tification should be specific to the portion of the document or study relied upon.
Studies shall include observations, calculations, literature and other types V
y By its " Order Ruling on Scope and Contentions" of October 5, 1979, the Atomic Safety and Licensing Board admitted CEC Issues 3-1, 3-2, 3-3, 5-1, and 5-2.
In addition, on October 24, 1979, CEC filed its " Restate-ment of Issues of Concern and Request for Clarification of Ruling" resub-mitting CEC Issues 1-1 and 1-12.
The Staff has no objection to these latter issues as restated.
The Staff is also posing interrogatories with respect to them.
Although the Staff recognizes that interrogatory responses on the part of CEC with regard to issues not yet admitted to the proceeding are not legally required, the Staff is hopeful that CEC will respond to these interrogatories in an effort to expedite the proceeding.
\\b\\1 b52
of work, whether recorded in writing or not, which consist of an examination or analysis of a phenomenon.
D.
Following the substantive response to each of the subsequent inter-rogatories posed by the Staff, identify by name and affiliation each indi-vidual who has knowledge which served as the basis for the answer to that interrogatory.
Interrogatory 2 The following questions deal with CEC Issue 3-1.
A.
Describe the maning of " personnel" as it is used in this issue. The description should specify by job function, position title or some other means to the personnel at issue.
B.
Describe the meaning of the term " mechanics of the facility" as that term is used in this issue.
Include in your description an identification of all the " mechanics" which you contend should be adequately understood.
Provide your reasons.
C.
Describe the tenn " basic reactor physics" as it is used in this issue.
The description should include those elements which you contend should be adequately understood.
Provide your reasons.
15\\7 555
. D.
Describe the "other fundamental aspects of its operation" as that term is used in this issue.
ihe description should identify specifically each of the "other fundamental aspects" that are embraced by this tem and which you contend should be adequately understood.
For each of these identified
" fundamental aspects", please provide the reasons for your contention that an adequate understanding of them is necessary.
Interrogatory 3 The following questions deal with CEC Issue 3-2.
A.
Describe the meaning of the tem " personnel" as that tem is used in this issue. The description should specify by job function, position title or some other means the personnel at issue.
6.
Provide the reasons fi r your concern on this issue.
Interrogatory 4 The following questions deal with CEC Issue 3-3.
A.
Describe the meaning of the tem " plant personnel" as that tem is used in this issue. The des, intion should specify by job function, position title or some other means the personnel at issue.
B.
Define the term " emergency instructions" as that term is used in this issue.
1517 534
C.
Provide the reasons for your concern on this issue.
Interrogatory 5 The following questions deal with CEC Issue 5-1.
A.
Describe the " systems" which are referenced in this issue.
B.
Provide the reasons for your concern on this issue.
Interrogatory 6 The following questions deal with CEC Issue 5-2.
A.
Define the term "overpressurization protection" as that term is used in this issue.
Describe the events which you contend could lead to an overpres-surization of the containment building.
Identify the degree of overpressuriza-tion involved.
Provide your reasons which support the need for overpressure protection for the events identified.
B.
Provide the reasons for your concern on this issue.
Interrogatory 7 The following questions deal with CEC Issue 5-3a.
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. A.
Define the term "special features" as that tenn is used in this issue.
Does CEC contend that additional "special features" are required at the Rancho Seco facility.
If so, icentify those "special features" and the reasons for your claim that such additional features are necessary.
B.
Identify the term " instruments" as that term is used in this issue.
Does CEC contend that additional instruments are necessary at the Rancho Seco facility? If so, describe the additional instrumentation rec;3i vid and the reasona to support your claim that such instrumentation is necessary.
C.
Provide the reasons for your concern on this issue.
Interrogatory 8 The following questions deal with CEC Issue 1-1.
A.
Define the tenn " pressure and volume control sensitivities" as that term is used in this issue.
Identify the source of the sensitivities, their nature and rea:ons for occurrence.
B.
Identify the " safety systems" referenced in this issue.
C.
Provide the reasons for your concern on this issue.
Interrogatory 9 The vollow Qg questions deal with CEC Issue 1-12.
1517 336
A.
Identify the " safety systems' referenced in this issue.
B.
Provide the reasons for your concern on this issue.
Respectfully submitted, t
/
Richard K. Hoefling Counsel for NRC Staff Dated at Bethesda, Maryland this 9th day of November,1979.
1517 337
.