Similar Documents at Byron |
---|
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
[Table view] Category:SUBPOENAS
MONTHYEARML20073T0511983-05-0606 May 1983 Application for Issuance of Encl Unsigned Subpoenas Directing Attendance & Testimony of I Souders & J Ogsbury at ASLB 830523 Session in Rockford,Il.Certificate of Svc Encl ML20070M0781983-01-0707 January 1983 Application for Subpoena Duces Tecum Directing P Stomfay- Stitz to Appear on 830119 in Chicago,Il for Deposition Re Design,Const & Future Operation of Plant.Certificate of Svc Encl ML20028A3391982-11-15015 November 1982 Application for Subpoena Directing Executive Director of Operations to Appear for Deposition Re Rockford League of Women Voters Contentions 63,53,54 & 77 & Use of Term Important to Safety. Draft Subpoena Encl ML20028A0651982-11-11011 November 1982 Application for Subpoenas Directed to Gc Minor,Rb Hubbard, DG Bridenbaugh,Bj Wood & B Johnson Re Design,Const & Future Operation of Plant.Certificate of Svc Encl 1983-05-06
[Table view] |
Text
_
w*' Dattd: November 11, 1982 ir 00LKETED UNITED STATES OF AMERICA USNP.C NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSIN3*8E)ANfl 15 - P1 :08 rrm CFSECREMM*
In the Matter of ) t[gpcc & SERVICE
) BHAllCH COMMONWEALTH EDISON COMPANY ) Docket Nos.-50-454-OL
) 50-455-OL (Byron Nuclear Power Station )
Units 1 and 2) )
)
COMMONWEALTH EDISON COMPANY'S APPLICATION FOR SUBPOENAS Pursuant to 10 CFR S2.720, Commonwealth Edison Company (Edison) hereby requests that the Licensing Board issue subpoenas duces tecum directing the following persons to appear and give their depositions before a certified court reporter at the offices of Isham, Lincoln & Beale, Three First National Plaza, Chicago, Illinois 60602, be-ginning at 9:30 A.M. local time, November 29, 1982, and thereafter until said depositions have been completed, and to bring with them the documents described in Attachment A hereto:
Messrs. Gregory C. Minor, Richard B. Hubbard and Dale G. Bridenbaugh, all of MHB Technical Associates, Inc.,
Professor Bernie J. Wood of Northwestern University, and Mrs. Betty Johnson of the Rockford League of Women Voters (League).
The purpose of the depositions is to inquire of each deponent as to his or her knowledge regarding the
.g7 8211160370 821111 PDR ADOCK 05000454 O
PDR
]$h}.
7 design, construction and future operation of the Byron v
Nuclear Power Station and into such other matters which are directly relevant to' issues now before the Licensing Board in this proceeding.
As grounds-for its application, Edison states the following:
- 1. In its Answers to Edison's First Round of Interrogatories, dated July 6, 1982, the League identifies Messrs. Minor, Hubbard and/or Bridenbaugh as possible witnesses with respect to matters raised by the League contentions. In addition, in its Answers to the NRC Staff's Amended First Set of Interrogatories, dated October 15, 1982, the League identifies Messrs. Minor, Hubbard and Bridenbaugh as having contributed to the preparation of the Answers.
- 2. The League indicates in its Answers to NRC Staff's Amended First Set of Interrogatories that material for answers to interrogatories related to League Contentions 39 and 109 is being prepared by Professor Bernie Wood, Locy Hall, 1847 Sheridan Road, Evanston, Illinois 60201.
- 3. In its Answers to Commonwealth Edison Com-pany's Amended Second Round of Interrogatories, the League identifies Mrs. Betty Johnson as one of the individuals who participated in the preparation of the Answers. In addition, in its Answers to the NRC Staff's Amended First Set of Interrogatories, the League states that Mrs. Betty Johnson substantially contributed to the preparation of the Answers.
Finally, Mrs. Johnson verified the truthfulness of both the League's Answers to the NRC Staff's Amended First Set of
. . ~ __ .._ _ _ - . .
Interrogatories, and the League's Answers to Edison's Amended Second Round of Interrogatories.
- 4. This Board is authorized to issue a subpoena duces tecum in aid of discovery directed to third parties.
Pacific Gas & Electric Co. (Stanislaus Nuclear Project, Unit 1), ALAB-550, 9 NRC 683 (1979).
WHEREFORE, Commonwealth Edison Company respect-fully requests that this Board issue subpoenas duces tecum to Mr. Gregory C. Minor, to appear at 9:30 A.M. on November 29, 1982, to Mr. Richard B. Hubbard, to appear at 9:30 A.M.
on November 30, 1982, to Mr. Dale G. Bridenbaugh, to appear at 9:30 A.M. on December 1, 1982, to Professor Bernie Wood, to appear at 9:30 A.M. on December 2, 1982, and to Mrs.
Betty Johnson, to appear at 9:30 A.M. on December 3, 1982, at the offices of Isham, Lincoln & Beale, Three First National Plaza, Chicago, Illinois 60602, for the purpose of taking their depositions upon oral examination before a court reporter, certified in the State of Illinois, and to provide by November 22, 1982, for inspection and/or copying by Edison the documents described in Attachment A hereto.
Dated: November 11, 1982 Respectfully submitted, l
- _ =
/ Alan P. Tielawski Michael I. Miller One of the Attorneys for Alan P. Bielawski Commonwealth Edison Company ISHAM, LINCOLN & BEALE Three First National Plaza Chicago, Illinois 60602 (312) 558-7500
e ATTACHMENT A TO SUBPOENA DUCES TECUM You are hereby directed to make available, seg-regated by category, on :Tovember 29, 1982, in the offices of Isham, Lincoln & Beale for inspection and/or copying by same, counsel of record for Applicant, Commonwealth Edison Company, the following documents:
Category 1 All documents provided to you by the Rockford League of Women Voters (" League") in connection with any review or analysis performed by you or any member of your firm of Commonwealth Edison Company's Byron Nuclear Power Station (" Byron Station").
Category 2 All documents consulted or reviewed by you or any member of your firm in connection with any review or analysis performed by you or any member of your firm of the Byron Station and which you believe to contain information directly relevant to the safety of the design, construction or operation of the Byron Station.
Category 3 All documents written, dictated, authored, co-authored, or to which you contributed information or ideas of any kind which directly relate or
p refer to the Byron Station, or whien discuss, analyze or refer to safety-related considerations which you believe are applicable to the Byron station.
Category 4 All documents provided by you or any member of your. firm to the League in connection with any consultation you have engaged in with the League which in any way relate to the Byron Station.
For purposes of this subpoena, the term document shall include any information recorded in any permanent or semi-permanent form. This subpoena requires you to produce the original, or a copy if the original is not in your possession or under your control; together with any and all non-identical copies. A non-identical copy is any copy which differs from the original by way of addition or l deletion, including without limit handwritten or other t
notations added to the document before or after copying.
J
- , .c - - . , . - . . . - - , _ , , ,, - - , . . . - -
i l
CERTIFICATE OF SERVICE i
The undersigned, one of the attorneys for Common-wealth Edison Company, certifies that on this date he filed two copies (plus the original) of the attached pleading with the Secretary of the Nuclear Regulatory Commission and served a copy of the same on each of the persons at the addresses shown on the' attached service list in the manner indicated.
Date: November 11, 1982
- ~
Ala W Bi lawski l
l
SERVICE LIST t
i COMMONWEALTH EDISON COMPANY -- Byron Station Docket Nos. 50-454 and 50-455 Mr. Ivan W. Smith
- Atomic Safety and Licensing Administrative Judge and Chairman Appeal Board Panel A'tomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Attn: Chief, Docketing and Dr. Richard F. Cole Service Section Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Myron M. Cherry, Esq. 1907 Stratford Lane Rockford, Illinois 61107 Cherry & Flynn Three First National Plaza ** Ms. Diane Chavez Suite 3700 SAFE Chicago, Illinois 60602 326 North Avon Street Rockford, Illinois 61103
- Atomic Safety and Licensing Board Panel
- Dr. Bruce von Zellen U.S. Nuclear Regulatory Commission Department of Biological Sciences Washington, D.C. 20555 Northern Illinois University DeKalb, Illinois 60115
- Chief Hearing Counsel Office of the Executive -
Legal Director , Isham, Lincoln & Beale U.S. Nuclear Regulatory Commission Suite 840 Washington, D.C. 20555 1120 Connecticut Ave., N.W.
Washington, D.C. 20036
- Dr. A Dixon Callihan Union Carbide Corporation
P.O. Box Y Jane Whicher Oak Ridge, Tennessee 37830 BPI Suite 1300
- Mr . Steven C. Goldberg 109 N. Dearborn Ms. Mitzi A. Young Chicago, IL 60602 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Via U.S. Mail
.