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Category:AFFIDAVITS
MONTHYEARML20125B3021985-06-0606 June 1985 Affidavit of G Laroche Re Environ Conditions of Site,Berm Const & Site Stabilization.Prof Qualifications,Se Turk Notice of Appearance & Certificate of Svc Encl ML20071D5431983-03-0303 March 1983 Affidavit of J Foy Opposing Applicant Motion for Summary Disposition or for Continuance Pending Discovery.No Documents Produced Re Prairie Alliance 830128 Request. Certificate of Svc Encl.Related Correspondence ML20028E3861982-12-13013 December 1982 Affidavit of Wh Bruggeman.Ge Does Not Expect to Abandon Nuclear Business & Will Continue to Furnish Support & Expertise to BWR Owners.Fuel Svc Needs Will Be Served & Hardware Design Mods Will Be Made.Certificate of Svc Encl ML20023D0351982-07-26026 July 1982 Affidavit of at Howard Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities ML20023D0341982-07-26026 July 1982 Affidavit of SL Marello Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities ML20054E6501982-06-0404 June 1982 Affidavit of Wc Gerstner Re Quality Rept Sys Functions. Confidentiality of Quality Repts Is Key to Effectiveness of Sys.Disclosure of Previously Submitted Repts Would Destroy Sys.Certificate of Svc Encl 1985-06-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARU-602875, Comment Supporting Proposed Rule 10CFR50 Re Proposed Rule for Financial Assurance Requirements for Decommissioning Nuclear Power Reactors1997-11-21021 November 1997 Comment Supporting Proposed Rule 10CFR50 Re Proposed Rule for Financial Assurance Requirements for Decommissioning Nuclear Power Reactors U-602719, Comment Supporting Proposed Communication;Gl 97-XX, Assurance of Sufficient Net Positive Suction Head for ECCS & Containment Heat Removal Pumps1997-03-20020 March 1997 Comment Supporting Proposed Communication;Gl 97-XX, Assurance of Sufficient Net Positive Suction Head for ECCS & Containment Heat Removal Pumps ML20136F2841997-03-11011 March 1997 Memorandum & Order (Terminating Proceeding).* Grants Southwestern Electric Cooperative 970311 Motion to Terminate Proceeding & Dismisses 970228 Petition for Leave to Intervene.W/Certificate of Svc.Served on 970311 ML20136F3281997-03-0707 March 1997 Establishment of Atomic Safety & Licensing Board.* Board Being Established in Following Proceeding to Rule on Petitions for Leave to Intervene And/Or Requests for Hearings.Certificate of Svc Encl.Served on 970307 ML20136F3561997-02-28028 February 1997 Petition for Leave to Intervene of Southwestern Electric Cooperative,Inc.* Requests That Commission Grant Petition for Leave to Intervene & Grant Other Relief as Commission Deems Appropriate.W/Certificate of Svc U-602603, Comments on Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors1996-06-21021 June 1996 Comments on Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors U-602559, Comments on Proposed Rule 10CFR20 Re Unauthorized Use of Licensed Radioactive Matl.Proposes Changes to Wording of Pr1996-02-27027 February 1996 Comments on Proposed Rule 10CFR20 Re Unauthorized Use of Licensed Radioactive Matl.Proposes Changes to Wording of Pr U-602408, Comment Supporting NUMARC Comments on Proposed Rule 10CFR50 Re Plant Shutdown & Low Power Operations.Requests Addl Period for Public Comment Be Made Available1995-02-0101 February 1995 Comment Supporting NUMARC Comments on Proposed Rule 10CFR50 Re Plant Shutdown & Low Power Operations.Requests Addl Period for Public Comment Be Made Available ML20071N4861994-07-21021 July 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Changing 10CFR50 & 73 for Frequency W/Which Licensee Conduct Independent Reviews & Audits of Safeguards Contingency Plan & Security Program from Every 12 Months to Every 24 Months ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process U-601930, Comment Opposing Draft Rev 1 to NUREG-1022, Event Reporting Sys - 10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting1992-01-30030 January 1992 Comment Opposing Draft Rev 1 to NUREG-1022, Event Reporting Sys - 10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting JSP-860-90, Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty1990-10-30030 October 1990 Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty ML20043F9941990-06-0606 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55, Coordinating Revs of FSAR W/Refueling Cycles.Approval of Rulemaking Change Would Provide for More Logical & Timely Basis for Incorporating Plant Procedure Changes in Future U-601249, Comment Supporting Proposed Rule 10CFR50 Re Nuclear Plant License Renewal (NUREG-1317)1988-10-21021 October 1988 Comment Supporting Proposed Rule 10CFR50 Re Nuclear Plant License Renewal (NUREG-1317) ML20204J3461988-10-20020 October 1988 Order Imposing Civil Monetory Penalty in Amount of $75,000. Violation a Occurred as Stated.For Violation C,Violation Most Appropriately Classified at Severity Level IV & Should Be Removed as Violation Supporting Civil Penalty ML20205Q9141988-10-20020 October 1988 Comment Opposing Proposed Rule 10CFR26 Re Commission Statement on Fitness for Duty of Nuclear Power Personnel. Commission Requested to Reconsider Efforts Prior to Issuing Final Rule ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons ML20196C5481988-06-0707 June 1988 Comment Supporting Proposed Rule 10CFR50 Re leak-before-break (LBB) Technology.Believes That Extension of LBB Technology to Performance Requirements for Emergency Core Cooling Sys Appropriate U-601050, Advises That Util Endorses BWR Owners Group 870820 Comments on Draft NUREG-1150, Reactor Risk Ref Document1987-09-30030 September 1987 Advises That Util Endorses BWR Owners Group 870820 Comments on Draft NUREG-1150, Reactor Risk Ref Document ML20206J2131987-04-10010 April 1987 Transcript of 870410 Public Meeting,Discussion/Possible Vote in Washington,Dc Re Full Power OL for Plant.Pp 1-73. Supporting Documentation Encl ML20135H3381985-09-11011 September 1985 Order Revoking CPPR-138 ML20133N7801985-08-0707 August 1985 Unexecuted Indemnity Agreement B-91 ML20129A8351985-07-11011 July 1985 Memorandum & Order Terminating Proceeding Per 850517 Motion on Grounds of Mootness.Requests ASLB Authorize NRR to Rescind CPPR-138.Served on 850712 ML20126F1611985-06-13013 June 1985 Memorandum & Order Directing Any Party Wishing to Examine Photographs to File Request W/Aslb by 850701.Photographs Deal w/850611 Memorandum & Order Requesting Addl Info on Unit 2 Excavation.Served on 850614 ML20126A0141985-06-11011 June 1985 Memorandum & Order Requiring NRC to Provide ASLB & Parties W/Photographs,Maps & Accompanying Explanations Referred to in G Laroche 850606 Affidavit Re Evacuation.Served on 850612 ML20126C3271985-06-11011 June 1985 Order Directing NRC Provide ASLB W/Photographs,Maps & Accompanying Explanations Referred to in 850606 Affidavit of Germain Laroche Addressing Environ Conditions of Excavation Site.Served on 850612 ML20125B3021985-06-0606 June 1985 Affidavit of G Laroche Re Environ Conditions of Site,Berm Const & Site Stabilization.Prof Qualifications,Se Turk Notice of Appearance & Certificate of Svc Encl ML20125B2631985-06-0606 June 1985 Response to Applicant 850517 Motion to Terminate Proceeding. No Opposition Offered,Subj to Two Listed Site Redress Conditions.G Laroche Affidavit Encl ML20128P7311985-06-0303 June 1985 Notice of Filing of Answer to Applicant Motion to Terminate Proceeding ML20128P7401985-05-29029 May 1985 Response to Applicant Motion to Terminate Proceeding.No Objections Offered.Method Applicant Proposed for Remediating Unit 2 Excavation Area Questioned.Certificate of Svc Encl ML20127G1901985-05-17017 May 1985 Motion to Terminate Proceeding,Due to 831018 Cancellation of Unit & 850409 Withdrawal of Application for OL & Request for Rescission of CPPR-138.All Stabilization Work Described in FSAR Completed.Certificate of Svc Encl ML20114D0281985-01-28028 January 1985 Notice of Filing of Joint Stipulation.Certificate of Svc Encl ML20114D0441985-01-28028 January 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20099D2701984-11-15015 November 1984 Third Supplemental Response to State of Il First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20099D2921984-11-15015 November 1984 Third Supplemental Response to State of Il Second Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20099D2561984-11-15015 November 1984 First Supplemental Response to Prairie Alliance First Round of Discovery.Certificate of Svc Encl.Related Correspondence ML20099C6261984-11-15015 November 1984 Supplemental Responses to Applicant Interrogatories Re Contentions 2 & 3.Certificate of Svc Encl.Related Correspondence ML20097G2291984-09-18018 September 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl. Related Correspondence ML20097G2071984-09-18018 September 1984 Notice of Change of Address & Telephone Number.Related Correspondence ML20098A3921984-09-11011 September 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20094P6621984-08-13013 August 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20090E5021984-06-28028 June 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20090E4831984-06-28028 June 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20092J8221984-06-22022 June 1984 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20091R9621984-05-31031 May 1984 Notice Forwarding NRC Region III Re Independent Design Review.Certificate of Svc Encl.Related Correspondence ML20090L2101984-05-22022 May 1984 Notice of Appearance of SL Johnson.Certificate of Svc Encl ML20087P8451984-04-0404 April 1984 Second Supplemental Response to State of Il First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20087P8201984-03-23023 March 1984 Second Supplemental Response to State of Il Second Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20086T9881984-03-0202 March 1984 Notice of Filing of Joint Stipulation in OL Hearing ML20080Q4241983-10-0606 October 1983 Notice of Appearance in Proceeding.Certificate of Svc Encl 1997-03-07
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i' EXHIBIT 2 UNITED STATES OF AMERICA NCLEAR REGULATORY COMMISSION IN THE MATTER OF )
ILLINOIS POWER COMPANY, )
SOYLAND POWER COOPERATIVE, INC. )
and WESTERN ILLINOIS POWER ) Docket No. 50-461 COOPERATIVE, INC. )
)
(Operating License for Clinton )
Power Station, Unit 1) )
STATE OF CALIFORNIA )
COUNTY OF AFFIDAVIT W. H. Bruggeman, being first duly sworn upon oath, deposes and says as follows:
- 1. I am Vice President and General Manager of the Nuclear Energy Business Operations of the General Electric Com-pany, 175 Curtner Avenue, San Jose, California 95125.
- 2. As Vice President and General Manager, I over-see and have direct responsibility for General Electric's Nuclear Business Operations.
- 3. General Electric Company has no expectations of abandoning the nuclear business. General Electric Company will continue to furnish support and expertise to Illinois Power Company and other owners of boiling water reactors.
l
- 4. General Electric Company is aggressively and i
diligently satisfying its obligations under existing nuclear 0$O$000k{1 PDR
e steam supply contracts, including its nuclear steam supply con-tract with Illinois Power Company for Clinton Power Station, Unit 1.
- 5. General Electric Company views the fuel and service needs of nuclear plants as sensible ' business oppor-tunities. General Electric Company will aggressively pursue those opportunities.
- 6. General Electric Company is not discontinuing hardware design modifications. General Electric Company ser-vices will be available in the future to Illinois Power Company to make hardware and other design modifications which may be required by present or future rules or regulations of the Nuclear Regulatory Commission.
- 7. General Electric Company recognizes that the opportunities for the sale of new nuclear steam supply systems are presently limited. General Electric Company is actively pursuing appropriate opportunities as such opportunities emerge.
Mmk W. W y eman Subscribed and Sworn to before ma this /3
1982.
b A Notary
- h. Public em My Commission Expires: *.
OFFICIAL SEAL RUTHE M giungyou NOTARY PUBLIC - CALIFORNIA r
EI NN_
' SANTA CLAR4 COUNTY
_ My comm. expires AFR 26,1905 m
a 95 2
i
. I
- o 1 EXHIBIT 3
~
Prairie Alliance I P.O. Box 2424 l Station A l Champaign, IL 6i820 l 5 January, 1983 Nr. Charles D. Fox IV Schiff Hardin & Waite 7200 Sears Tower Chicago, Illinois 60606
Dear Mr. Fox:
Thank you for your letter of 17 December, 1982, containing the affidavit of Mr. W.H. Bruggeman. We do not consider this affidavit sufficient for elimination of further consideration of Prairie Alliance's Contention VI, and have therefore requested a Motion to Compel produc-tion of certain documents relating to this contention. Given the recent acceptance of Contention VI, additional requests for information and documents will probably be necessary.
Thank you for your time.
Sincerely, Randall L. Plant cc: Mr. Richard Goddard Mr. Philip L. Wilman
CERTIFICATE OF SERVICE I hereby certify that an original and two con-formed copies of the foregoing document were served upon the following:
Secretary of the Commission United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch and that one copy of the foregoing document was served upon each of the following:
Hugh K. Clark, Esq., Chairman P.O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering Howard University
. 2300 Sixth Street, N.W.
Washington, D.C.
Dr. Oscar H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 .
Philip L. Willman Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, linois 60610 l Jean Foy l
511 W. Nevada Urbana, Illinois 61808 l
h 4
e
1 Prairie Alliance -
Box 2424 Station A Champaign, Illinois 61820 Herbert H. Livermore U.S. Nuclear Regulatory Commission RR 3, Box 229A Clinton, Illinois 61727 ,,
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appaal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 in each case by deposit in the United States Mail, postage prepaid on January 17, 1983.
/t A .
@N One of the Attorneys for Applicants Sheldon A. Zabel William Van Susteren Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000
~ ~ ~~
( .. . . , _ . _ . . .. - -
l l
UNITED STATES OF AMERICA
~
j NUCLEAR REGULATORY COMMISSION l l
IN THE MATTER OF )
ILLINOIS POWER COMPANY, )
SOYLAND POWER COOPERATIVE, INC. )
and WESTERN ILLINOIS POWER )
COOPERATIVE, INC. ) Docket No. 50-461 OL
)
(Operating License for Clinton )
Power Station, Unit 1) .)
NOTICE TO: Hugh K. Clark, Esq., Chairman P.O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering Howard University 2300 Sixth Street, N.W.
Washington, D.C. 20059 Dr. Oscar H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Philip L. Willman
' Assistant Attorney General l
Environmental Control Divinion 188 West Randolph Street Suite 2315 Chicago, Illinois 60610 Jean Foy 511 W. Nevada -
Urbana, Illinois 61808 O
'5......_........ - -- .
Prairie Alliance Box 2424 Station A Champaign, Illinois 61820 Herbert H. Livermore U.S. Nuclear Regulatory Commission Clinton Nuclear Power Station RR 3, Box 229A Clinton, Illinois 61727 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 PLEASE TAKE NOTICE that I have filed with the Secretary of the United States Nuclear Regulatory Commission MOTION FOR
SUMMARY
DISPOSITION OF PRAIRIE ALLIANCE CONTENTION VI in the above-captioned matter. A copy of this document is attached hereto and hereby served upon you.
VL 'Cl3 ] ' C' One of the Attor'neys for Applicants Sheldon A. Zabel Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 l
(312) 876-1000
! Dated: January 17, 1983
.