Similar Documents at Perry |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20083B7881991-09-20020 September 1991 Ohio Edison Co Interrogatories to NRC Staff.* Requests That NRC Answer Separately & Fully in Writing,Each Listed Interrogatory within 30 Days.W/Certificate of Svc.Related Correspondence ML20059H4141990-08-31031 August 1990 Licensee Response to Ohio Citizens for Responsible Energy, Inc Interrogatories & Request for Production of Documents.* W/Certificate of Svc & Svc List.Related Correspondence ML20056B1811990-08-0808 August 1990 Interrogatories & Request for Production of Documents.* Requests That Util Answer Interrogatories & Request for Production of Documents No Later than 900831.Certificate of Svc Encl.Related Correspondence ML20137J0871986-01-17017 January 1986 Response Opposing Ocre Offer to Withdraw Proposed Contentions B-1,B-2,B-3 & B-5.Condition to Limit Single Loop Operation to 50% of Rated Thermal Power Unacceptable. Certificate of Svc Encl ML20100H1921985-04-0101 April 1985 Updated Response to Interrogatories Re Issue 16 Concerning Diesel Generator Reliability.Documents Relevant to Issue, Which May Be Used in cross-examination or Offered as Exhibits,Listed.Related Correspondence ML20114B7081985-01-25025 January 1985 Supplementary Response to Ohio Citzens for Responsible Energy 10th,11th & 12th Sets of Interrogatories to Applicants Re Issue 16.Certificate of Svc Encl.Related Correspondence ML20114A5421985-01-22022 January 1985 Updated Response to Applicant Second Set of Interrogatories Re Issue 8.Certificate of Svc Encl.Related Correspondence ML20113F2521985-01-22022 January 1985 Answers to 850107 Fourteenth Set of Interrogatories Re Issue 16.Supporting Documentation & Certificate of Svc Encl. Related Correspondence ML20112C9171985-01-0707 January 1985 Fourteenth Set of Interrogatories,Pertaining to Issue 16 Re Tdi Diesel Generators & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20101M4441984-12-28028 December 1984 Second Voluntary Answers to Portion of Ohio Citizens for Responsible Energy 840730 Thirteenth Set of Interrogatories. Prof Qualifications of Gm Fuls & Jd Richardson & Certificate of Svc Encl.Related Correspondence ML20099C6591984-11-16016 November 1984 Voluntary Answers to Portion of Ohio Citizens for Responsible Energy late-filed Thirteenth Set of Interrogatories Re Issue 8.Prof Qualifications of Rj Schmehl & Certificate of Svc Encl.Related Correspondence ML20094E5171984-07-30030 July 1984 Thirteenth Set of Interrogatories Pertaining to Issue 8 Re Hydrogen Control.Interrogatories Concern Generation,Release & Combustion of Hydrogen Gas in Degraded Core Accident. Certificate of Svc Encl.Related Correspondence ML20140C3561984-06-15015 June 1984 Amended & Supplemental Answers to Sunflower Alliance First Round Discovery Requests & Second Set of Interrogatories Re Issue 1.Certificate of Svc Encl.Related Correspondence ML20091P9241984-06-11011 June 1984 Answer to Ohio Citizens for Responsible Energy Twelfth Set of Interrogatories to Applicant Re Issue 16.Certificate of Svc Encl.Related Correspondence ML20084P0751984-05-14014 May 1984 Twelfth Set of Interrogatories on Issue 16 Re Diesel Generator Reliability.Certificate of Svc Encl.Related Correspondence ML20084P0791984-05-14014 May 1984 Response to Applicant 840309 Interrogatories & Request for Production of Documents (Fifth Set).Certificate of Svc Encl. Related Correspondence ML20087C6901984-03-0909 March 1984 Interrogatories & Request for Production of Documents to Ohio Citizens for Responsible Energy Re Reliability of Transamerica Delaval Standby Diesel Generators.W/Certificate of Svc.Related Correspondence ML20087C2701984-03-0808 March 1984 Answer to Ohio Citizens for Responsible Energy Eleventh Set of Interrogatories to Applicant Re Issue 16.Certificate of Svc Encl.Related Correspondence ML20086T3691984-02-29029 February 1984 Supplemental Answers to Interrogatories on Issues 6,8 & 15. Certificate of Svc Encl.Related Correspondence ML20080N2461984-02-21021 February 1984 Order Extending Time Until 840228 for Commission to Act to Review 831115 Director'S Decision ML20080N8191984-02-17017 February 1984 Eleventh Set of Interrogatories on Issue 16 Re Diesel Generators.Certificate of Svc Encl.Related Correspondence ML20080J7761984-02-0808 February 1984 Answers to Ohio Citizens for Responsible Energy Tenth Set of Interrogatories Re Issue 16.Certificate of Svc Encl ML20086L2651984-02-0303 February 1984 Motion to Reopen Discovery on Issue 1 Re Emergency Planning. Certificate of Svc Encl.Related Correspondence ML20082P2621983-12-0505 December 1983 Supplemental Discovery Response Consisting of Status Rept: Planning for Accident at Perry Nuclear Plant, by Perry Legal Defense Fund.Certificate of Svc Encl.Related Correspondence ML20072E5521983-06-21021 June 1983 Supplemental Response to Third Set of Interrogatories. Certificate of Svc Encl ML20072E5421983-06-21021 June 1983 Responses to Fourth Set of Interrogatories & Request for Production of Documents.Related Correspondence ML20071H1241983-05-19019 May 1983 Update to Util 830205 Answer to Interrogatory 3 of Sunflower Alliance 811202 First Set of Interrogatories.All Three Counties Have Submitted Draft Plans to Ohio Disaster Svcs Agency.Svc List Encl.Related Correspondence ML20073B8001983-04-0808 April 1983 Fourth Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20072K0151983-03-18018 March 1983 Response to Third Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20069C1451983-03-14014 March 1983 Updated Response to Applicant 830308 Response to Interrogatory 9-1 in 830131 Ninth Set.Svc List Encl ML20069C3341983-03-14014 March 1983 Answer Opposing Oh Citizens for Responsible Energy 830223 Motion for Rewording of Issue 8 & Spec of Guidelines for Litigation.Motion Seeks to Frustrate & Further Delay Issue 8 Litigation.Certificate of Svc Encl ML20071E8531983-03-0808 March 1983 Answers to Interrogatories 9-1 Through 9-25 & 9-38 Through 9-52 Re Issues 13 & 15,from 830131 Ninth Set of Interrogatories.Prof Qualifications & Certificate of Svc Encl ML20071C7051983-03-0303 March 1983 Response to Relevant Portion of General Interrogatory 9-52. Svc List Encl ML20071C1491983-02-25025 February 1983 Answers to Interrogatories 9-26 Through 9-37 Re in-core Thermocouples (Issue 14).Interrogatory Portions Re core-exit Thermocouples Irrelevant & Will Not Be Answered.Certificate of Svc Encl ML20071B8841983-02-25025 February 1983 Answer to 830131 Interrogatories 9-26 Through 9-37 Re Issue 14 on in-core Thermocouples.Certificate of Svc Encl.Related Correspondence ML20070U7791983-02-0707 February 1983 Supplemental Response to Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20028G2451983-01-31031 January 1983 Third Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20070T2591983-01-31031 January 1983 Ninth Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML20070T1711983-01-31031 January 1983 Ninth Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20083J4081983-01-0606 January 1983 Tenth Set of Interrogatories on Diesel Generators. Certificate of Svc Encl ML20028C2931983-01-0303 January 1983 Supplemental Answers to Third Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl. Related Correspondence ML20070L4631982-12-28028 December 1982 Supplemental Response to Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl. Related Correspondence ML20079H3561982-12-13013 December 1982 Answers to Second Set of Interrogatories,Numbers 20,28 & 31. Certificate of Svc Encl ML20079H3511982-12-13013 December 1982 Answers to Eighth Set of Interrogatories.Certificate of Svc Encl ML20067B2631982-11-30030 November 1982 Resubmission of Sixth Set of Interrogatories & Motion Requesting Presiding Officer to Require NRC Answers. Certificate of Svc Encl.Related Correspondence ML20067A1131982-11-29029 November 1982 Updated Response to Oh Citizens for Responsible Energy 820928 Interrogatory 4-2.Svc List Encl.Related Correspondence ML20069L8321982-11-15015 November 1982 Response to Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20069L8391982-11-12012 November 1982 Update to 820625 Answers to Second Set of Interrogatories. Svc List Encl.Related Correspondence ML20028A3181982-11-12012 November 1982 Eighth Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML20027D4661982-11-0101 November 1982 Supplemental Response to First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl. Related Correspondence 1991-09-20
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212J1581999-09-30030 September 1999 Order Approving Transfer of License & Conforming Agreement. Orders That License Transfer Approved,Subj to Listed Conditions ML20205D4901999-02-22022 February 1999 Transcript of 990222 Informal Public Hearing on 10CFR2.206 Petition in Rockville,Md.Pp 1-105.Supporting Documentation Encl ML20198D9711998-11-0909 November 1998 Petition Per 10CFR2.206 Requesting That Facility Be Immediately Shut Down & OL Be Suspended or Modified Until Such Time That Facility Design & Licensing Bases Properly Updated to Permit Operation with Failed Fuel Assemblies ML20155F4561998-08-26026 August 1998 Demand for Info Re False Info Allegedly Provided by Wh Clark to Two NRC Licensees.Nrc Considering Whether Individual Should Be Prohibited from Working in NRC-licensed Activities for Period of 5 Yrs ML20236V5261998-07-20020 July 1998 Computer Access & Operating Agreement Between Cleveland Electric Illuminating Co & NRC PY-CEI-NRR-2284, Comment Opposing Proposed Generic Communication, Lab Testing of Nuclear-Grade Activated Charcoal1998-05-21021 May 1998 Comment Opposing Proposed Generic Communication, Lab Testing of Nuclear-Grade Activated Charcoal ML20216B5111998-04-0909 April 1998 Order Imposing Civil Monetary Penalty.Denies Request for Remission of Violation C,Ea 97-430 & Orders Licensee to Pay Civil Penalty in Amount of $50,000 within Next 30 Days PY-CEI-NRR-2269, Comment on Proposed Rule 10CFR50.NRC Should Demonstrate That Not Only Is Code Process Flawed,But That Proposed Change Justified from Cost Versus Safety Protective1998-04-0303 April 1998 Comment on Proposed Rule 10CFR50.NRC Should Demonstrate That Not Only Is Code Process Flawed,But That Proposed Change Justified from Cost Versus Safety Protective ML20217J0661998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Dqe, Inc & Allegheny Power System,Inc ML20216G3821998-03-11011 March 1998 Order Approving Application Re Merger Agreement Between Duquesne Light Co & Allegheny Power Systems,Inc ML20198P9311997-11-0707 November 1997 Comments of American Municipal Power-Ohio,Inc.NRC Should Require Allegheny Power Sys,Inc to Affirm That Capco Antitrust License Conditions Will Be Followed ML20134L3401997-01-22022 January 1997 Resolution 96-R-85, Resolution Supporting Merger of Centerior Energy Corp & Ohio Edison Under New Holding Co Called Firstenergy ML20133B6941996-12-18018 December 1996 Submits Ordinance 850-96 Re Approval of Merger of Centerior & Oh Edison Into Firstenergy ML20135F4731996-12-0606 December 1996 Memorandum & Order CLI-96-13.* Commission Reverses & Vacates ASLB LBP-95-17 Which Granted Motion for Summary Disposition Submitted by Ocre & Hiatt.W/Certificate of Svc.Served on 961206 ML20132A8461996-12-0202 December 1996 Resolution 20-1996 Supporting Merger of Ohio Edison & Centerior Corp Under New Holding Company Called Firstenergy ML20134M6191996-10-28028 October 1996 Proclamation of Support by City of Sandusky,Oh Re Merger of Ohio Edison and Centerior Energy Corp ML20112J8281996-06-18018 June 1996 Licensee Reply Brief on Review of Licensing Board Decision LBP-95-17.* W/Certificate of Svc ML20112D8721996-05-29029 May 1996 Intervenor Brief in Support of Commission Affirmation of LBP-95-17.* Commission Should Affirm Licensing Board Decision.W/Certificate of Svc ML20108D9571996-05-0303 May 1996 CEI Response to City of Cleveland 2.206 Petition.Nrc Should Deny Petition ML20108B7571996-04-26026 April 1996 Licensee Brief on Review of Licensing Board Decision LBP-95-17.* Recommends That Commission Reverse Board Memorandum & Order Issued 951004.W/Certificate of Svc & Svc List PY-CEI-NRR-2034, Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matl1996-03-11011 March 1996 Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matl ML20097B8721996-01-23023 January 1996 Petition of City of Cleveland,Oh for Expedited Issuance of Nov,Enforcement of License Conditions & Imposition of Appropriate Fines,Per 10CFR2.201,2.202,2.205 & 2.206 ML20097B8911996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement or in Alternative,For Severance of Issue & Expedited Hearing Procedures ML20101B5841996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement Or,In Alternative,For Severance of Issue & Expedited Hearing Procedures.W/Certificate of Svc ML20096E2471996-01-0303 January 1996 Comment on PRM 50-64 Re Stockpiling Ki for Use as Thyroid Protectant in Event of Nuclear Accident.Supports Distribution of Ki to Public ML20094N1951995-11-17017 November 1995 Oh Edison Application for License Transfer in Connection W/ Sale & Related Transactions ML20094M5941995-11-15015 November 1995 Intervenors Answer to Licensees Petition for Review.* Intervenor Conclude That Commission Should Not Review Board Decision.W/Certificate of Svc ML20094J9141995-11-0707 November 1995 Petition for Review.* Submits That Commission Review of Board Decision Appropriate Under 10CFR2.786. W/Certificate of Svc & Svc List ML20093N9491995-10-23023 October 1995 Licensee Request for Extension of Time to File Petition for Review.* Requests That Commission Grant Extension Until 951107 of Deadline for Filing Petition for Review. W/Certificate of Svc ML20065L3571994-04-0505 April 1994 Intervenors Answer to NRC Staff Response to Intervenors Motion for Summary Disposition & Licensees Cross Motion for Summary Disposition.* Urges Board to Deny Licensee Cross Motion.W/Certificate of Svc ML20064N9201994-03-21021 March 1994 Affidavit of RW Schrauder in Support of Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition. W/Svc List ML20064N6341994-03-21021 March 1994 Affidavit of RW Schrauder in Support of Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition.W/Certificate of Svc ML20064N6081994-03-21021 March 1994 Licensee Cross Motion for Summary Disposition & Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Motion for Summary Disposition.* Moves for Decision in Licensee Favor on Ocre Contention ML20063L4621994-02-0707 February 1994 Motion for Summary Disposition.* Intervenors Request That Board Grant Summary Disposition Favorably & Issue Declaratory Relief by Finding Challenged Portion of Amend 45 to Be in Violation of Aea.W/Certificate of Svc ML20058P4451993-12-13013 December 1993 Licensee Answer to Ohio Citizens for Responsible Energy,Inc & SL Hiatt Supplemental Petition for Leave to Intervene.* W/Certificate of Svc ML20059L9391993-11-12012 November 1993 Petitioners Supplemental Petition for Leave to Intervene.* Court Held That NRC May Not Eliminate Public Participation on Matl Issue in Interest of Making Process More Efficient. W/Certificate of Svc ML20059B1421993-10-19019 October 1993 Order.* Petitioners Shall File Supplemental Petition in Accordance W/Schedule in 931018 Order.W/Certificate of Svc. Served on 931020 ML20059B1761993-10-18018 October 1993 Order.* Informs That for Each Contention,Petitioners Shall Comply Fully W/Requirements of 10CFR2.714(b)(2)(i),(ii) & (III) & Their Filing Should Address Requirements Set Forth in Regulations.W/Certificate of Svc.Served on 931019 ML20059B0701993-10-12012 October 1993 Motion to Defer Consideration of Remanded Issue.* Requests That Licensing Board Defer Consideration of Remanded Issue Pending Outcome of Commission Review of 2.206 Process.W/ Certificate of Svc ML20058M8761993-09-30030 September 1993 Memorandum & Order CLI-93-21.* Appeal for Hearing Re Amend to Plant OL Denied.W/Certificate of Svc.Served on 930930 ML20057C0461993-09-21021 September 1993 Supplemental Director'S Decision DD-93-15 Involving 920929 Request for Certain Actions to Be Taken Re Proposed Construction of Interim onsite,low-level Radioactive Waste Facility at Plant.Request Denied ML20056C8951993-07-19019 July 1993 Order Extending Time within Which Commission May Rule on Petitions for Review of LBP-92-32.W/Certificate of Svc. Served on 930720 ML20045B5661993-06-0707 June 1993 Comment Re Proposed Generic Communication on Mod of TS Administrative Control Requirements for Emergency & Security Plans,As Published in Fr on 930401 (58FR17293).Believes Concept of Technical Review Not Addressed by STS ML20044E2781993-05-13013 May 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re VEPCO Petition to Change Frequency of Emergency Planning Exercise from Annual to Biennial ML20127A6171993-01-0606 January 1993 Order.* Time within Which Commission May Rule on Petitions for Review of Board Order LBP-92-32,dtd 921118,extended Until 930208.W/Certificate of Svc.Served on 930106 ML20126D5171992-12-23023 December 1992 City of Brook Park Answer to Petitions for Review.* Opposes Applicants 921208 Petitions for Review Based on Fact That ASLB Decision in proceeding,LBP-92-32,adequately Addressed Issues Raised in Petitions.W/Certificate of Svc ML20126F6501992-12-23023 December 1992 Answer of City of Cleveland,Oh,Intervenor,In Opposition to Petitions for Review of 921118 Decision of Aslb.* Petitioners Petitions for Review Should Be Denied. Certificate of Svc Encl ML20126D5801992-12-23023 December 1992 NRC Staff Answer in Response to Petitions for Review Filed by Oh Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & City of Cleveland.* W/Certificate of Svc ML20126D5781992-12-23023 December 1992 Answer of American Municipal Power-OH,Inc in Opposition to Petitions for Review of Oh Edison Co & Cleveland Electric Illuminating Co/Toledo Edison Co.* W/Certificate of Svc ML20126D5461992-12-23023 December 1992 Answer of Cleveland Electric Illuminating Co & Toledo Edison Co to Limited Petition for Review of City of Cleveland,Oh of 921118 Decision of Aslb.* Commission Should Deny City of Cleveland Petition.W/Certificate of Svc 1999-09-30
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T2 !!5 22 A9:18 March 17, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Bcard In the Matter of )
)
THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, et al. ) 50-441
)
(Perry Nuclear Power Plant, ) n.
Units 1 and 2) ) x CD g2-k ! s er :
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/*~) l APPLICANTS ' ANSWERS TO SI u n ,, ,
E-OHIO CITIZENS FOR RESPONSIBLE ENERGY -
g,.j,nl'[g FIRST SET OF INTERROGATORIES O, er
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Applicants for their answers to First Set of Interrogr-i}]~[ssccT \(6' tories of Ohio Citizens for Responsible Energy, dated January 30, 1982, state as follows:
Copies of all documents and resumes to be supplied with Applicants' answers will be sent to the interim representative for Ohio Citizens for Responsible Energy, Ms. Sue Hiatt, under separate cover (documents and resumes are listed in Appendix to Applicants' answers).
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{DRADOCK 05000440 PDR
1-1 In its response to IE Bulletin No. 81-03, Applicant states that Applicant's " investigations have determined that neither Mytilus sp. nor Corbicula sp. are present in Lake Erie in the local environment of the plant." Please describe both the methodologies 2.nd extent to which those investigations were conducted. When were those investiga-tions conducted?
Response
The date, methodologies, and extent of the investigations cited in Applicants' response to IE Bulletin No. 81-03 are set forth and described in "Corbicula Reconnaissance Survsy At the Perry Nuclear Power Site, May 1981," prepared for The Cleveland Electric Illuminating Company by NUS Corporation, dated October 30, 1981 (hereinafter "Corbicula Reconnaissence Survey"). The Corbicula Reconnaissance Survey is supplied hetewith.
1-2 In the same response, Applicant states that six locations in the vicinity of the Perry plant were checked. Provide a map indicating those locations.
l
Response
A map identifying the six locations can be found on page 5 l
l (Figure 1) of the Corbicula Reconnaissance Survey.
l t
l l-3 Provide the results of CEI's most recent environmental monitoring program of aquatic life in the plant vicinity.
Response
The results of Applicants' most recent monitoring program of aquatic life in the Plant vicinity are described in the Corbicula Reconnaissance Survey.
j
1-4 Provide employment and educational and training histories for those persons employed by CEI to conduct said moni-toring program in 1-3 above.
Response
Resumes of the NUS Corporation employees that conducted the monitoring program are supplied herewith, 1-5 Does Applicant plan to develop appropriate preventative and corrective actions for dealing with corbicula before the clam is actually detected or will the Applicant wait until it arrives before acting? If the former, please provide the plans developed to date.
Response
Applicants intend to continue to monitor Lake Erie in the vicinity of Perry Nuclear Power Plant for the presence of Corbicula. If Corbicula are found in the vicinity of Perry Nuclear Power Plant, Applicants will implement an appropriate i
program of Plant inspection and corrective action. Such a program has not yet been developed, l
1-6 In the IE Bulletin No. 81-03 response, CEI also stated that "(t)he potential for intrusion by these organisms as a result of low level and high velocities at the point of intake, is minimal since Perry utilizes a subsurface intake structure in a standing body of water." Please explain this statement, providing both factual and empirical bases for this claim.
Response
The above referenced statement by Applicants was made in l
response to the NRC's request that Applicants evaluate "the l
l
1 potential for intrusion of the organisms into these systems due to low water level and high velocities in the intake structure expected during worst case conditions." See IE Bulletin No.
l 81-03, page 4. Applicants were informing the NRC that, to the extent an intrusion may be caused by low level and high velocities, the intake structure of Perry Nuclear Power Plant is not subject to such conditions. The Plant intake structure will be approximately twelve feet below the surface of Lake Erie, and will have an intake velocity of approximately 1.5 feet per second.
1-7 Toledo Edison's ("TE") response to that Bulletin stated that in May of 1981 inspections confirmed the " absence of clams and shell debris at the Davis-Besse Station." Page 2 of the Attachment. On page 3 of the attachment, it is stated that no fouling has been detected. From the response it appears that this was discerned from the work of one diver in Intake Bay No. 1: the diver found no shells in the bottom of the bay or its sides. Please describe all inspections utilized to search for corbicula notwithstanding that by the diver.
Response
The Toledo Edison response to Item 2 of IE Bulletin No.
81-03 does not state that the absence of clams or shell debris
! was discerned solely "on the work of one diver in Intake Bay No. 1." As the response expressly states, Toledo Edison found no evidence of clams during its routine maintenance on the Davis-Besse Nuclear Power Station raw water systems or during its inspections of the Station condenser and circulatin water canal.
t
Toledo Edison conducted subsequent investigations during the summer of 1981. As part of these investigations, the drained cooling tower basin and the length of the cooling canal were inspected for clams--none were found. In addition, extensive samplings were made in twenty locations along the southern shore of the Western Basin of Lake Erie. Corbicula were discovered only in the thermal plume areas of two coal-fired power plants with once-through condenser cooling systems. No Corbicula were found in the vicinity of the Davis-Besse Nuclear Power Station, which has a closed-cycle natural draft tower condenser cooling system, and hence no significant thermal plume. Inspections of the Davis-Besse Nuclear Power Station raw water systems were conducted in the fall of 1981 (see response to Interrogatory # l-8). No clams were discovered in such inspections. In October of 1981 accumulated sludge and dirt that had been removed from the Plant intake screenwells was inspected for Corbicula. No Corbicula were fo und .
1-8 In its response to Item 4 of that Bulletin, TE states that an annual piping inspection program will be conducted beginning in the fall (Fall, 1981). Provide in detail the full substance of that program.
Response
Maintenance personnel of the Davis-Besse Nuclear Power Station inspect the Statioa raw water systems whenever the systems are down for repairs. Such inspections include
examinatf.on for the presence of any clams or shell debris. No clams or shell debris have been found in such inspections.
Similar inspections were conducted in the fire protection systen. and the containment air coolers during September and December, 1981, respectively. No clams or shell debris were discovered.
1-9 What is a "Ponar grab sampler"?
Response
A "Ponar grab sampler" is a raall dredge for collecting lake bottom sediment.
1-10 Describe CEI's current pl4ns (most recent) regarding chlorination at Perry. Note any variations from the ER-OL, if any.
Response
Applicants' current plans regarding chlorination at the Perry Nuclear Power Plant are described in Section 3.6.2 of the ER/OL.
1-11 What are the statutory limits placed upon CEI as to amount of chlorination allowable? Indicate the statutes, agency ruling, authority, etc. Does CEI anticipate appealing that limit or seeking an amended permit for a greater chlorine dosage? If so, explain why.
Response
The chlorine concentration of the final Perry Nuclear Power Plant discharge will not exceed the 12 vel established by
the Permit to Install issued by the Ohio Environmental Protection Agency on July 12, 1974. The Permit to Install and accompanying " Report on General Plans (Permit to Install and 4L1 Certification) For the Proposed Perry Nuclear Power Plant" are supplied herewith. Applicants have no plans to seek an amendment of the permissible concentration level established by the Permit to Install.
1-12 Please list all documents, reports, or other sources used or relied upon in the preparation of answers to the foregoing interrogatories.
Response
The following documents were relied upon in the prepara-tion of the foregoing responses:
- 1. Corbicula Reconnaissance Survey.
- 2. " Evaluation of the Asiatic Clam Corbicula Fluminea in the Western Basin of Lake Erie,"
prepared by Ms. Jennifer Scott-Wasilk, Mr. Gary G. Downing, and Mr. Jeffrey S. Lietzow of Toledo Edison (published in the 1981 Annual Environmental Operating Report For Davis-Besse Nuclear Power Station Unit No. 1).
- 3. Toledo Edison response to IE Bulletin No. 81-03, dated May 22, 1981.
- 4. Section 3.6.2 of the Perry Nuclear Power Plant ER/OL.
- 5. Ohio Environmental Protection Agency Permit to Install and accompanying " Report on General Plans (Permit to Install and 401 Certification)
For the Proposed Perry Nuclear Powei' Plant,"
dated July 12, 1974.
1-13 List all persons who assisted with the preparation of the previous interrogatories. For each person so listed, indicate that person's employer, his title / position / rank, and his occupational history.
Response
The following individuals assisted in the preparation of the foregoing tesponses:
i
- 1. Ms. Rebecca B. Coffey, Env..ronmentalist, Licensing and Permits, The Cleveland Electric Illuminating Company.
- 2. Mr. Richard A. Pender, Engineer, Mechanical Design, The Cleveland Electric Illuminating Company.
- 3. Mr. Ronald G. Wiley, Engineer, Licensing and Permits, The Cleveland Electric Illuminating Company.
~. -. ..
- 4. Mr. Raymond F. Zucker, Jr., Engineer, Chemical and Environmental, The Cleveland Electric Illuminating Company.
- 5. Ms. Jennifer Scott-Wasilk, Environmental Technologist,-Chemistry and Health Physics, Toledo Edison.
Resumes of these individuals are supplied herewith.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: r
' Jay E. Silberg Robert L. Willmore Counsel for Applicants 1800 M Street, N. W.
Washington, D.C. 20036 (202) 822-1000 DATED: March 17, 1982.
APPENDIX (Documents and Resumes Supplied Herewith to Ohio Citizens for Responsible Energy)
- 1. Corbicula Reconr.aissance Survey at the Perry Nuclear Power Plant Site, May 1981, dated October 30, 1981.
- 2. Ohio Environmental Protection Agency Permit to Install and accompanying " Report on General Plans (Permit to Install and 401 Certification) For the Proposed Perry Nuclear Power Plant," dated July 12, 1974.
- 3. Resumes in response to Interrogatory #1-4:
- a. Mr. Briant R. Oblad
- b. Mr. Robert L. Shema
- c. Mr. William R. Cody
- d. Mr. .
James H. Kennedy
- 4. Resumes in response to Interrogatory #1-13:
- a. Ms. Rebecca B. Coffey
- b. Mr. Richard A. Pender
- c. Mr. Ronald G. Wiley
- d. Mr. F.aymond F. Zucker
- e. Ms. Jennifer Scott-Wasilk
4 CLEVEIMO ELECTRIC ILLLMINATING COMPAFI CLEVELAID, OHIO Larry O. Becic , being duly sworn according to name law, deposes and says that he is General Supervising Engineer, Licensing and Fuel, of Cleveland Electric Illu=inating Co.
and that the facts set forth in the foregoing Applicants' Answers to Ohio Citizens for Responsible Energy (OCPI)
Interrogatories 1-6; 9-13 dated January 30, 1982, are true and correct to the best of his knowledge, infomation and belief.
Sworn to and subscribed tk before me this S day of mMcH, l962..
Sca td h, t M
() l VU JOSEPH C. SZWEJK0WSKI Notary Public. State of Ohio Caya. Cty
% Commuien Exp4res July 14, 1986 i
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TOLEDO EDISON COMPANY TOLEDO, OHIO Jennifer Scott Wasilk, being duly sworn according to law, name deposes and says that shet is an Environmental Technologist job title of Toledo Edison Company and that the f acts set forth in company the foregoing Applicants' Answers to Ohio Citizens for- .
Responsible Energy (OCRE) Interrogatories 1-7 and 1-8 dated January 30, 1982, are true and correct to the best of her knowledge, information and belief.
l 'A L 'n O'L] /, 6 /
Sworn to and subscribed before me this f h day
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, et al. ) 50-441
)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing
" Applicants' Answers to Ohio Citizens for Responsible Energy First Set of Interrogatories", were served by deposit in the U.S. Mail, first class,. postage prepaid, this 17th day of March, 1982, to all those on the attached Service List.
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Robert Li Willmore Dated: March 17, 1982.
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4 UNITED STATES OF AMEidCA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board In the Matter of )
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THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY Et Al.) 50-441
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- (Perry Nuclear Power Plant, )
Units 1 and 2) )
SERVICE LIST
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Pater B. Bloch, Chairman Ms. Sue Hiatt Atomic Safety and Licensing Board OCRE Interim Representative U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D.C. 20555 Mentor, Ohio 44060 Dr. Jerry R. Kline Daniel D. Wilt, Esquire Atomic Safety and Licensing Board Wegman, Hessler & Vanderburg U.S. Nuclear Regulatory Commission Suite 102 Washington, D.C. 20555 7301 Chippewa Road
- Brecksville, Ohio 44141 Mr. Frederick J. Shon Atomic Safety and Licensing Board Terry Lodge, Esquire U.S. Nuclear Regulatory Commission 915 Spitzer Building i Washington, D.C. 20555 Toledo, Ohio 43604 i
i Atomic Safety and Licensing Mr. Tod J. Kenney Board Panel 228 South College, Apt. A U.S. Nuclear Regulatory Commission Bowling Green, Ohio 43402 Washington, D.C. 20555 Donald T. E: one, Esquire Atomic Safety and Licensing Assistant Prosecuting Attorney Appeal Board Panel Lake County Administration Center j U.S. Nuclear Regulatory Commission 105 Center Street I
Washington, D.C. 20555 Painesville, Ohio 44077 l
! Docketing and Service Section John G. Cardinal, Esquire Office of the Secretary Prosecuting Attorney Nuclear Regul~atory Commission Ashtabula County Courthouse U.S. Jefferson, Ohio 44047 Washington, D.C. 20555 James H. Thessin, Esquire Office of the Executive l Legal Director l U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 l
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