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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M1851999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept from Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Requal Pass Dates JPN-99-035, Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 11999-10-15015 October 1999 Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 1 JPN-99-034, Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping1999-10-13013 October 1999 Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping JPN-99-033, Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon1999-10-0808 October 1999 Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon JPN-99-030, Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days1999-09-29029 September 1999 Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days JPN-99-032, Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request1999-09-29029 September 1999 Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request ML20212F8341999-09-22022 September 1999 Forwards Insp Rept 50-333/99-07 on 990718-0828.No Violations Noted JAFP-99-0262, Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl1999-09-16016 September 1999 Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl ML20212A8341999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics ML20212A6951999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics 05000333/LER-1998-015, Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete1999-09-0808 September 1999 Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete ML20211N4301999-09-0808 September 1999 Discusses Proposed Meeting to Discuss Kaowool Fire Barriers. Staff Requesting That Affected Licensees Take Issue on Voluntary Initative & Propose Approach for Resolving Issues JAFP-99-0258, Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld1999-09-0808 September 1999 Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld JPN-99-028, Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity1999-08-30030 August 1999 Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity JAFP-99-0247, Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 41999-08-26026 August 1999 Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 4 JAFP-99-0245, Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 19991999-08-19019 August 1999 Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 1999 ML20210U2621999-08-12012 August 1999 Forwards Insp Rept 50-333/99-06 on 990601-0717.No Violations Noted JPN-99-025, Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams1999-08-0505 August 1999 Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams JPN-99-026, Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds1999-08-0505 August 1999 Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds ML20216D9421999-07-28028 July 1999 Forwards Safety Evaluation Granting Requests for Relief from Requirements of ASME Code,Section XI for Second 10-year ISI Interval for James a FitzPatrick NPP JAFP-99-0229, Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1)1999-07-22022 July 1999 Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1) JAFP-99-0228, Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal1999-07-21021 July 1999 Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal ML20210A7001999-07-16016 July 1999 Forwards Request for Addl Info to Supplement Response Provided for GL 97-05, Steam Generator Tube Insp Techniques JAFP-99-0208, Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl1999-07-14014 July 1999 Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl ML20209D5511999-07-0606 July 1999 Informs That as Result of NRC Review of Licensee Response to GL 92-01,rev 1,suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2 ML20210C9031999-06-30030 June 1999 Summarizes Impact of Changes & Errors in Methodology Used by GE to Demonstrate Compliance with ECCS Requirements of 10CFR50.46.Summary of Changes & Errors Provided in Attached Table JPN-99-021, Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend1999-06-22022 June 1999 Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend JPN-99-020, Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept1999-06-21021 June 1999 Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept ML20196G2981999-06-18018 June 1999 Forwards Insp Rept 50-333/99-04 on 990412 to 0529.Violations Being Treated as non-cited Violations ML20212J0541999-06-17017 June 1999 Responds to Requesting That NRC Staff ...Allow BWR Plants Identified to Defer Weld Overlay Exams Until March 2001 or Until Completion of NRC Staff Review & Approval of Proposed Generic Rept,Whichever Comes First JPN-99-019, Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant1999-06-15015 June 1999 Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant ML20196L1451999-06-0707 June 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization,Div of Licensing Project Mgt Created.Ss Bajwa Will Be Section Chief for Ja Fitzpatrick & Indian Point NPPs JPN-99-018, Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1)1999-06-0101 June 1999 Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1) ML20207D9191999-05-27027 May 1999 Informs That on 990521 NRC Staff Held Planning Meeting to Identify Insp Activities at Facility Over Next Six Months JAFP-99-0171, Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr1999-05-20020 May 1999 Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr JPN-99-016, Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl1999-05-19019 May 1999 Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl ML20207A6751999-05-17017 May 1999 Forwards RAI Re 960626 Submittal & Suppl Related to IPEEEs for Plant.Licensee Committed to Revise Plant Fire IPEEE to Reflect Issues Associated with EPRI Fire PRA Implementation Guide within 120 Days of Issues Resolution JAFP-99-0168, Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls1999-05-13013 May 1999 Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls ML20206N0721999-05-11011 May 1999 Forwards Insp Rept 50-333/99-03 on 990301-0411.Four Violations of NRC Requirements Occurred & Being Treated as non-cited Violations,Consistent with App C of Enforcement Policy JAFP-99-0160, Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 41999-04-30030 April 1999 Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 4 ML20206C8551999-04-27027 April 1999 Informs That Util 990406 Submittal, Licensing Rept for Reracking of Ja FitzPatrick Spent Fuel Pool,Rev 7, Will Be Marked as Proprietary & Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) ML20205T1141999-04-22022 April 1999 Provides Comments from Technical Review of Draft Info Notice Re Unanticipated Reactor Water Draindown at Quad Cities Nuclear Power Station,Unit 2,ANO,Unit 2 & JAFNPP JPN-99-012, Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached1999-04-16016 April 1999 Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached ML20205P4641999-04-15015 April 1999 Forwards for Review & Comment Draft Info Notice That Describes Unanticipated Reactor Water Draindown at Quad Cities Nuclear Power Station Unit 2,Arkansas Nuclear One Unit 2 & Ja Fitzpatrick NPP ML20205P1991999-04-0909 April 1999 Discusses 990224 PPR & Forwards Plant Issues Matrix & Insp Plan.Advises of Planned Insp Effort Resulting from Plant PPR Review JAFP-99-0129, Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick1999-04-0909 April 1999 Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick JAFP-99-0127, Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld1999-04-0808 April 1999 Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld JAFP-99-0124, Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) ML20205M8941999-04-0707 April 1999 Forwards Rev 21 to App C of JAFNPP Emergency Plan & Rev 1 to EAP-32, Recovery Support Group Manager JAFP-99-0125, Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARJPN-99-035, Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 11999-10-15015 October 1999 Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 1 JPN-99-034, Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping1999-10-13013 October 1999 Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping JPN-99-033, Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon1999-10-0808 October 1999 Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon JPN-99-030, Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days1999-09-29029 September 1999 Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days JPN-99-032, Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request1999-09-29029 September 1999 Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request JAFP-99-0262, Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl1999-09-16016 September 1999 Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl JAFP-99-0258, Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld1999-09-0808 September 1999 Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld 05000333/LER-1998-015, Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete1999-09-0808 September 1999 Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete JPN-99-028, Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity1999-08-30030 August 1999 Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity JAFP-99-0247, Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 41999-08-26026 August 1999 Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 4 JAFP-99-0245, Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 19991999-08-19019 August 1999 Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 1999 JPN-99-025, Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams1999-08-0505 August 1999 Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams JPN-99-026, Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds1999-08-0505 August 1999 Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds JAFP-99-0229, Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1)1999-07-22022 July 1999 Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1) JAFP-99-0228, Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal1999-07-21021 July 1999 Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal JAFP-99-0208, Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl1999-07-14014 July 1999 Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl ML20210C9031999-06-30030 June 1999 Summarizes Impact of Changes & Errors in Methodology Used by GE to Demonstrate Compliance with ECCS Requirements of 10CFR50.46.Summary of Changes & Errors Provided in Attached Table JPN-99-021, Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend1999-06-22022 June 1999 Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend JPN-99-020, Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept1999-06-21021 June 1999 Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept JPN-99-019, Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant1999-06-15015 June 1999 Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant JPN-99-018, Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1)1999-06-0101 June 1999 Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1) JAFP-99-0171, Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr1999-05-20020 May 1999 Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr JPN-99-016, Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl1999-05-19019 May 1999 Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl JAFP-99-0168, Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls1999-05-13013 May 1999 Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls JAFP-99-0160, Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 41999-04-30030 April 1999 Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 4 ML20205T1141999-04-22022 April 1999 Provides Comments from Technical Review of Draft Info Notice Re Unanticipated Reactor Water Draindown at Quad Cities Nuclear Power Station,Unit 2,ANO,Unit 2 & JAFNPP JPN-99-012, Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached1999-04-16016 April 1999 Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached JAFP-99-0129, Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick1999-04-0909 April 1999 Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick JAFP-99-0127, Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld1999-04-0808 April 1999 Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld JAFP-99-0124, Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) JAFP-99-0125, Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) ML20205M8941999-04-0707 April 1999 Forwards Rev 21 to App C of JAFNPP Emergency Plan & Rev 1 to EAP-32, Recovery Support Group Manager JPN-99-011, Forwards Application for Amend to License DPR-59,removing Position Title of General Manager from Sections & Will Delegate Responsibilities to Another Staff Member,In Writing1999-04-0505 April 1999 Forwards Application for Amend to License DPR-59,removing Position Title of General Manager from Sections & Will Delegate Responsibilities to Another Staff Member,In Writing ML20205G4111999-03-31031 March 1999 Forwards Rev 7 to JAFNPP EP App J & Rev 6,pages 7 & 8 to EAP-5.3 05000333/LER-1999-001, Forwards LER 99-001-01 Re Incorrect EDG line-up During Fire Placing Plant in Outside Design Basis.Suppl Contains Results of Completed Root Cause Evaluations & Subsequent Corrective Actions Taken.Rept Contains No Commitments1999-03-31031 March 1999 Forwards LER 99-001-01 Re Incorrect EDG line-up During Fire Placing Plant in Outside Design Basis.Suppl Contains Results of Completed Root Cause Evaluations & Subsequent Corrective Actions Taken.Rept Contains No Commitments JPN-99-008, Forwards Application for Amend to License DPR-59,converting CTS to Be Consistent with Improved Std TS in NUREG-1433, Rev 1.Synopsis of LAR for Conversion to Its,Pending Lars, List of Subsections,Scope of Changes & Commitments,Encl1999-03-31031 March 1999 Forwards Application for Amend to License DPR-59,converting CTS to Be Consistent with Improved Std TS in NUREG-1433, Rev 1.Synopsis of LAR for Conversion to Its,Pending Lars, List of Subsections,Scope of Changes & Commitments,Encl JPN-99-010, Transmits Revised Exemption Request from Some of Requirements of 10CFR50,App R.Exemption Would Permit Use of CS for Rc Makeup to Achieve Safe Shutdown in Fire Area XI at JAFNPP1999-03-31031 March 1999 Transmits Revised Exemption Request from Some of Requirements of 10CFR50,App R.Exemption Would Permit Use of CS for Rc Makeup to Achieve Safe Shutdown in Fire Area XI at JAFNPP JAFP-99-0114, Requests That License OP-11037,for Bs Brooks,Be re-issued Without Restriction for Corrective Lenses.Nrc Form 369,encl. Without Encl1999-03-29029 March 1999 Requests That License OP-11037,for Bs Brooks,Be re-issued Without Restriction for Corrective Lenses.Nrc Form 369,encl. Without Encl JAFP-99-0112, Informs of Util Determination That Listed Individuals No Longer Need to Maintain Operating License for Ja FitzPatrick Nuclear Plant.Termination of Listed Licenses,Requested1999-03-29029 March 1999 Informs of Util Determination That Listed Individuals No Longer Need to Maintain Operating License for Ja FitzPatrick Nuclear Plant.Termination of Listed Licenses,Requested JAFP-99-0097, Forwards JAFNPP Referenced Simulation Facility Four Year Performance Testing Rept, Containing Description of Performance Testing Completed During Past Four Years & Description of Testing Scheduled During Next Four Years1999-03-17017 March 1999 Forwards JAFNPP Referenced Simulation Facility Four Year Performance Testing Rept, Containing Description of Performance Testing Completed During Past Four Years & Description of Testing Scheduled During Next Four Years ML20204B6241999-03-17017 March 1999 Forwards Plant Referenced Simulation Facility Four Year Performance Testing Rept, Per 10CFR55.45(b)ii 05000333/LER-1999-003, Forwards LER 99-003-00,per 10CFR50.73(a)(2)(i)(B).One New Commitment Is Contained in Rept1999-03-16016 March 1999 Forwards LER 99-003-00,per 10CFR50.73(a)(2)(i)(B).One New Commitment Is Contained in Rept ML20204C7371999-03-15015 March 1999 Forwards Revised EP Coversheets for Sections to Vol 1 & Rev 26,Vol 3 to EPIP SAP-10, Meteorological Monitoring Sys Surveillance JAFP-99-0085, Submits in-vessel Visual Insp Summary Rept for RFO 13 for Ja FitzPatrick Nuclear Power Plant.All Relevant Indications Recorded During Insp Were Satisfactorily Dispositioned IAW Util Internal C/A Tracking Sys & Were Found Acceptable1999-03-0808 March 1999 Submits in-vessel Visual Insp Summary Rept for RFO 13 for Ja FitzPatrick Nuclear Power Plant.All Relevant Indications Recorded During Insp Were Satisfactorily Dispositioned IAW Util Internal C/A Tracking Sys & Were Found Acceptable ML20207J3201999-03-0505 March 1999 Forwards Form NRC-369,requesting That Restriction for Corrective Lenses Be Placed on Current License SOP-10089-3, for Ks Allen.Encl Withheld Per 10CFR2.790(a)(6).Without Encl JAFP-99-0073, Submits Annual Rept on SRV Challenges & Failures,Per Plant TS 6.9.A.2.b.No Challenges to SRVs from Automatic Control Circuits or from RCS Pressure Transients,Occurred.Ltr Contains No New Commitments1999-02-26026 February 1999 Submits Annual Rept on SRV Challenges & Failures,Per Plant TS 6.9.A.2.b.No Challenges to SRVs from Automatic Control Circuits or from RCS Pressure Transients,Occurred.Ltr Contains No New Commitments JAFP-99-0071, Forwards Semi-Annual Radioactive Effluent Release Rept for Period of 980701-1231. Format Used for Effluent Data Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 41999-02-25025 February 1999 Forwards Semi-Annual Radioactive Effluent Release Rept for Period of 980701-1231. Format Used for Effluent Data Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 4 JAFP-99-0068, Forwards Form NRC-5 Equivalent Records of All Individuals Monitored at JAFNPP from 980101-1231 on Electronic Media, Per 10CFR20.2206(b) & App a of NRC Reg Guide 8.7, Instruction for Recording & Reporting..1999-02-22022 February 1999 Forwards Form NRC-5 Equivalent Records of All Individuals Monitored at JAFNPP from 980101-1231 on Electronic Media, Per 10CFR20.2206(b) & App a of NRC Reg Guide 8.7, Instruction for Recording & Reporting.. JAFP-99-0019, Informs of Licensee Intent to Upgrade ERDS at Ja FitzPatrick in Preparation for Year 2000 (Y2K) Readiness,Per GL 98-01. Encl Contains Brief Summary of Proposed Changes to ERDS1999-01-25025 January 1999 Informs of Licensee Intent to Upgrade ERDS at Ja FitzPatrick in Preparation for Year 2000 (Y2K) Readiness,Per GL 98-01. Encl Contains Brief Summary of Proposed Changes to ERDS JAFP-99-0012, Documents Util Position Re Methodology for LPRM Calibr During Reactor Operation Using Traversing In-core Probe Sys1999-01-18018 January 1999 Documents Util Position Re Methodology for LPRM Calibr During Reactor Operation Using Traversing In-core Probe Sys 1999-09-08
[Table view] Category:LEGAL/LAW FIRM TO NRC
MONTHYEARML20059H5541990-09-11011 September 1990 Forwards Endorsements 153,128 & 178 to Nelia Policies NF-170,NF-208 & NF-100 & Endorsements 136,115 & 159 to Maelu Policies MF-47,MF-77 & MF-29 ML18095A2541990-05-29029 May 1990 Forwards Endorsements 118-120 & 122-127 to Nelia Policy NF-208,Endorsements 105-107 & 109-114 to Maelu Policy MF-77 & Endorsements 13-14 to Certificates N-7/M-7 & N-47/M-47 ML20245D3421989-03-20020 March 1989 Forwards Listed Endorsements,Including Endorsements 14,163, 144,94,75,39 & 31 to Nelia Policies NF-295,NF-100,MAELU Policy MF-29,NELIA Policy NF-182,MAELU Policy MF-61,NELIA Policy NF-281 & Maelu Policy MF-112,respectively ML18093A8111988-04-28028 April 1988 Forwards Endorsements 102 & 103 to Nelia Policy NF-208, Endorsements 89 & 90 to Maelu Policy MF-77,Endorsements 100 & 101 to Nelia Policy NF-230 & Endorsements 84 & 85 to Maelu Policy MF-90 ML20207M8881986-12-30030 December 1986 Forwards Endorsement 7 to Nelia Certificates N-7 & N-47 & Maelu Certificates M-7 & M-47,Endorsements 96 & 152 to Nelia Policies NF-208 & NF-100,respectively & Endorsements 84 & 134 to Maelu Policies MF-77 & MF-29,respectively ML20210L2491986-03-24024 March 1986 Forwards Endorsements 78 & 79 to Maelu Policy MF-77, & Endorsements 90 & 91 to Nelia Policy NF-208 ML20210L1941986-03-18018 March 1986 Forwards Endorsement 89 to Nelia Policy NF-208 & Endorsement 77 to Maelu Policy MF-77 ML20117M8501985-05-10010 May 1985 Forwards Endorsement 85 to Nelia Policy NF-208 & Endorsement 73 to Maelu Policy MF-77 ML20113D1661985-04-0505 April 1985 Forwards Endorsement 82 to Nelia Policy NF-208 ML20099G3631984-11-21021 November 1984 Forwards Endorsement 80 to Nelia Policy NF-208 & Endorsement 69 to Maelu Policy MF-77 ML20106D5351984-10-19019 October 1984 Forwards Endorsements 78 & 79 to Nelia Policy NF-208 & Endorsements 67 & 68 to Maelu Policy MF-77 ML20090C4741984-07-0909 July 1984 Forwards Endorsements 65 & 66 to Maelu Policy MF-77 & Endorsements 76 & 77 to Nelia Policy NF-208 ML20091L6541984-05-30030 May 1984 Forwards Endorsement 75 to Nelia Policy NF-208 & Endorsement 64 to Maelu Policy MF-77 ML20080L2991983-09-26026 September 1983 Forwards Endorsements 56 & 57 to Maelu Policy MF-77 & Endorsements 66 & 67 to Nelia Policy NF-208 ML20077H8911983-07-20020 July 1983 Forwards Summons & Complaint Filed Against Util in Connection W/El Zeller & T Zeller Vs Pasny.Suit Arises Out of Traumatic Injury Sustained at Facility.Radiation Exposures Minimal ML20073H1901983-04-0707 April 1983 Forwards Endorsement 64 to Nelia Policy NF-208 ML19323C0231980-05-0707 May 1980 Notifies That Investigation Has Been Initiated Re Suit Brought by Ralph & Karen Dodge Against Util Concerning Allegations of Exposure & Injury from Radioactive Iodine ML20248E3661970-01-23023 January 1970 Forwards Amend 13 to Application for License,Containing cross-references Between PSAR & Suppls 1-11 1990-09-11
[Table view] |
Text
J un$
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JOHN E HARWARD Vice Resdent-Gorns L_
BURT C.PROOM,CPCU
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President July 20, 1983 Mr. Jerome Saltzman Assistant Director State and Licensee Relations Office of State Programs U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Abstract #104 Edward L. Zeller and Terry Zeller vs.
The Power Authority of the State of New York State of New York Supreme Court, County of Oswego Policy Nos. NF-208 and MF-77 D/O: January 19, 1982
Dear Mr. Salzman:
Enclosed find a copy of the Summons and Complaint filed against our policyholder, Power Authority of the State of New York, in connection with the captioned suit. It is my understanding that this suit arises out of a traumatic injury sustained at the PASNY nuclear facility and that the radiation exposures were minimal. It is not expected that any radiation injury could result from the minimal radiation exposure of the plaintiff, but he did receive a significant traumatic injury when a 650 lb. valve fell and fractured his lower right leg.
We have assigned the suit to defense counsel but have already undertaken measures to obtain the cooperation and participation of the conventional liability carrier of the policyholder and fully expect them to take an active role in the management of the future defense effort as well as participate in the expenses associated with this litigation.
Very truly yours, esz w 7C/t Y 8308120005 830720 PDR ADOCK 05000
[ 3 h. . E. Harward Vice President, Claims JEH/pbj g4 Enclosure iho Exchango Suite 245 /' 270 Forrnngton Avenue [Farrnogton. Connect <ut 06032 j'(203)677-7305 m Eng. Dept. (203) 677-7715 / TLX. th 643-0
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I T ATE OF, NEW YORK SUP)tEME COURT ; inder2Vo' COUNTY OF QSWEGO P]sirrti8 tiesignates q Oswego Coonty EDWARD L. ZELLER and TERRY ZELLER,, I' County as theplace of trial P1aLntiffa The ba. tis of the veatte is Plaintiffs' residence Plafatif scalast Summann POWER AUTHORITY OF THE STATE OF NEW YORK, ,
Plairiti5 te.titfes af
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RD (4, Seneca Hill, Box 76, o g,,,,, Oswego, New York
. . . . . . _l County of Oswego
- TO the abate Damed Defendant QQu522ltt2b1j i Suntut011th to snmr the een.plaiat to this action sne to ser.e a ecer of ysur answer, or,il (br tempislot is act served with thic sutomans, to serve a notice of bpptasence, on the PlaintiE's At cruer(s) wn.his 20 dart altar the service of this sumroons, esclusive of the dar of serviu (or within M days er the servict is complete if this summons is not personally defletted to you within the State ci New 1'crk): and la cass of your Isilure to appent et suawet, ludstuent will be taken agaiatt yea by delsult lot the reIid detaanded in the
~ cernplaict.
scred, May 31, 1983 Dad dson & O wara, P.C.
Defenotant's Address: . Attorney (s) for PlaiatiW
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Suite 1950 243 Lake street 99 Wa shington Avenue Elmira, New York 14901-31 Albany, New York 12210 - Tolephone: (607) 733-463
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TELECOPY TO GERALD COLDSTEIN - 2877 FROM GLORIA BALLIEN - ALBANY OFFICE - 6/13/83 t
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. stay to abe scal.:a je sto I2 years 41 ese and rcskke 4 er. 19 et %. EDWARD L. ZELLER and TERRY ZELLER,
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)GTATE OF NEW YORK l
SUPREME COURT : COUNTY OF OSijEGO EDWARD L. ZELLER and TERRY ZELLER, -
Plaintiffo, ,COMPLA INT
-ngainst- -
POWER AUTHORITY OF THE STATE OF NEW YORK, ?
Defendant.
The plaintiffs, Edward L. Zeller and Terry Zellcr, by their attorneys, D8vidson & O'Hara, P.C., complaining of the defendant herein, sh'w c to the' Court and allege:
- 1. The plaintiffs reside at RD d4, Seneca Hill, Box 76 Ouwego, New York. , ,
- 2. Upon information and belief, the defendant, Power Authority of the State of New York, is a p'ublic authority organized and existing under and pursuant to the provisions of th Public Authorities Law of the ' State of New Yo'rk.
- 3. Upon inf ormation and belief, at all tbnes hereinaf t-
! mentioned, the defendant, Pcuer Authority of the State of New Yor'.
was and still is the owner of the James Fitzpatrick Nuclear Power liPlant in Ocwego, New York, and mananes, maintains and controin
,. lsaid premises.
,' 4. Upon information and belief, prior to January 19, 111982, the Power Authority of the State of Mew York entered into c
..--..n contract with various contractors calJino for the performance of
~ s u ~ ,r e. e (
jiconstruction work at the James Pitzpatrick Power Plant in Osueco, 1
h New York. . -
i .
l 5. On or about January 10, 1982, the pJaintiff, Edward j
( l' L . Zeller, vac cinployed as a pipe fitter by CN F. lapp Company of l
i
-2 Meridan, Connecticut, and was 3 awfu11y on the premises of the James Fitzp'atrich power plant for the purpose of helping to install a check valve to a pipe in a dry well which was part of l the water eco3ing system surrounding the nuclear reactor at said plant. ,
l
- 6. O'n or about January 19, 1982, as the check valve vat '
being placed into position,' the hoistino cable broke causing the check valve to fa12 upon the plaintiff, Edward L. teller. .
1
- 7. The aforesaid occurrence was caused by and due to th6 gross and wanton negligence of the defendant in the ownership, l
management, maintenance and control of the aforesaid premises and
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,- s its appurtenances and ly the gross and wanton _neolicence of the ?
defendant in failing to provide plaintif f with a safe place to _ _
work as required by law, in furnishing plaintiff with unreasonably dangerous, defective and unsafe construction equipment and in otherwise failing to prevent this occurrence.
- 8. The aforesaid occurrence was not caused by or due toL the carelessness or negligence of or od the part of the plaintiff, Edward L. Zellcr.
9 By reason of the negligence of the defendant, ll plaintiff, Edward L. 7.cIlcr , sustained severe physical and personc) e I linjuries, mental sufferino and has been inforned and believes that !
l:his injuries are permanent and that he will reouire treatments in l Ithe futuro.
- """".s 10. By reason of the negligence of the defendant, y [i plai n ti f f , Edward L. Zellor, became exposed to dangercus radiation
!.and sustained physical injuries und mental sufferino and has been_ . .
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informed and believes that these injuries are permanent and that he will require treatment in the future.
- 11. By reason of the negligence of the defendant, plaintiff, Edward L. Zeller, was obliged to and did e>: pend and incur large sums of money for medicines and medical and hospital care hnd treatment.
?
- 12. As a restilt,of the def endant's negligence, plaintiff Edward L. Zeller, has been damaged in the sinn of Two M3 liion Dolla.rs ($2,000,000.00).
FOR A SBCOND CAUSE OF ACTION
'fl.iB PLAINTIFF, EDWARD L. ZELLER, SHOWS TO THE COURT AMD ALLEGES:
- 13. Plaintiff, Edward L. Zeller, repeats, reiterates and realleges each and every allegation in those paragraphs designated "1" through *)l" as though fully set forth and repeated herein.
14 The aforesaid occurrence was caused by and due to
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the defendant's gross and wanton violation of provisions of the M: ,
Labor Law of the State of New York and regulatione promulgated
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thereunder and/or provisions of the Federal Occupational Benith land Safety Act and recrulations promulgated thereunder in that
_..___...~..__.. _
idefendant failed to furnish or erect or cauced to have furnished ior erected l
for the performance of plaintiff's labor, proper and l cafe hol,sts, bolte, cables, stayc, blocks, pulleys, braces, irons ind other devices and equipment so constructed, placed and
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loperatec as to gave plaintiff uroper protection.
By reason of the c'efencant's violation of these istatutory dutics, plaintiff, Edward L.
i 7.eller, sustainec severe jphysical i njuries and mental cuf ferinu and har been informed and I
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and believes that his ~ injuries .are perm:anent. ,
16 By reason of the defendant's violation of the statutory duties, plaintiff, Edward L. Zeller, became exposed to dangerous radiation and sustained physical injuries and ment-al suffering and has been informed and believen that these injuries are permanent.
17 By reason of the defendant's violation of these statutory duties, the plaintiff, Edward L. Ec11er, was obliged
, to and did cy. pend and incur large sums of money for modicines and medical and hospital care and treatment.
- 18. As a result of the defendant's violation of these statutory duties, plaintiff, Edward L. Zeller, has been damaged in the sum of Two Million Dollars (62,000,000.00).
FOR A TllIRD CAUSE OF ACTION, TJtE PIAINTIFF, EDWARD I., ZET.LER ,
SHOWS TO TFIE COURT AND ALLEGES:
- 19. Plaintiff, Edward L. Zeller, repeata, reiterates, and realleges cach and every allegation in those paragraphs .
designated "1" through "ll" and "14" through "17" as those fully iset forth and repeatad herein.
1 20.
Following said occurrence, the defendant, its agents,;
i jiservants or employees were crosqly and wantonly careless and l
l negligent in that the defendant, its agents, scIvants or employees l failed to properly attend to the plaintiff, Edward L. T.eller, and
..., _ failed to remove the plaintiff _from a dangerous radiation zonc j , ,*
iwithin a reasonable time after said occurrence.
l 21. By reason of the negligence of the defendant, its j _ _ _ . . ,
l lagen ts, servants or employees the plaintiff, Edward L. Zeiler, v [ sustained chvcical i nin-i a = ana
-nna' x
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9,. . 3 . ..g l
informed and believes that these injuries are permanent.
~
'22 By reason of the negligence of the defendant, its agents, servants or employees, the plaintiff, Edward L. Zeller, was obliged to and did expend and incur la'rge sums of money for medicines and medical and hospital care and treatment.
t
- 23. As a result of the negligence of the defendant, its agents, servants or employees, plaintiff, Edward L. Zeller, has been damaged in the sum of Two Million DoIIare ($2,000,000.00 FOR A POURTH CAUSE OF ACTION THE PLAINTIFF, TERRY ZELLER, SHOWS TO THE COURT AND ALLEGES:
- 24. Plaintiff, Terry Zeller, repeats, reiterates and realleges each and every allegation in those paragraphs designate "1" through "11", "14a through*"17" and "20" through "22" as' though fully set forth and repeated herein.
- 25. That prior to January 19, 1982, plaintiff, Terry Zeller, was and st1EL is the wife of plainti ff, Edward L. Zeller.
26 That by reason of the foregoing, plaintiff, Terry Zeller, has been deprived of the aid, companionship, company, society, comfort and services of her husband, Edward L. Zeller, has suffered loss of consortium having been deprived of the right: -
l and inthrests which has accrued by reason of her said marriage and her continuation of har said marriage relationship. All to I.
her damage in the sum of Two llundred Fifty Thousand Dollars (S250,000.00).
i WilEREFORE, plaintiff, Edward L. Zeller, demands judgment fagainstthedefendantinthesumofTwoMillionDollars I ($2,000,000.00) compensatory damngos and Two Million Dollars __ _ _ . , ._ _ . _ _.-. -
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. , ~
l P}aintiff, Edward L. Beller, dcmands judgment against the defenda: l in the sum of Two Million Dollars (02,000,000. 00) .compensa tory damages and. Two Million Dollars ($2,000,000.00) punitive damages on the second cause of action; plaintiff, Edward L. Zellor, demands judgment against? the defendant in the sum of Two Million Dollars ($2,000,000.00) compensatory damages and Two Million Dollars ($2,000,000.00) punitive damages on the third cause of action and plaintif f, Terry Zeller, demands judgment against the o
defendant in the sum of Two nundred Fifty Thousand Dollars
($250,000.00) compensatory damages and Two Million Dollars
($ 2,000,000. 00) punitive damages on the fourth cause of action together with the costs and disburcements of this action.
Dated: May 31, 1983 DAVIDSON &'O'MARA, P.C.
Attorneys for the plaintiffs Of fi ce & Post Office Address 243 Lake Street Elmira, New 1'ork 14901-310'2 Telephone: (607) 733-4635 l
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4 anonce of ewTav m As pa, 1-rear 19 Jar :-mase este mom = sass ia, wak I,,fesreuses) STATE OF NEW YORK :h.
%, ,f, SUPREME COURT: COUNTY OP OSWEGO i -
d.rp amored se she of)ks of de shit of de wshk mamsdseursmo J9 4
masse.
EDWARD L. 2ELLER and TERRY ZELLER, Yeaet. tx.
Plaintiffs,
- DAVIDSON & O'MARA, P. C. '
} Assansefsfer -against-
Defendant.
Anormy k
- WOTtcr. OF seTTLeue w *
. SUMHONS and COMPLAINT k :-rtaner saa marica ausse ardar ef ad4A de weh m a in.c ompy mer se prewiimap DAVIDSON & O'MARA. P. C.
=*--' te de. aran. ,
Auonneysfor P1aintiffs j
ens 4tf sAs /g4cs of de widh aawasJ Cairs. at 243 Lace'snes.T E1.MutA. NEW YORE en ne teld) 713-4433 l Ayof 12 at af.
i, Dared. __
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! DAVIDSON & O'MARA, P. C. d' " 'I *
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