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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20076N4991994-10-31031 October 1994 Gulf States Utilities Co Second Supplemental Response to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* W/Certificate of Svc ML20078D3291994-10-28028 October 1994 Gulf States Utilities Company Second Supplemental Response to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories,Dtd 940908.* W/Certificate of Svc ML20080A2971994-10-13013 October 1994 Gulf States Utilities Company Supplemental Responses to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* W/Certificate of Svc.Related Correspondence ML20024J3161994-09-30030 September 1994 NRC Staff Response to Licensee Request for Production of Documents.* NRC Unaware of Document That Relate to Scope & Criteria for NRC Review of Operation of Facility When Holder of OL Filed for Bankruptcy Protection.W/Certificate of Svc ML20073H2701994-09-22022 September 1994 Gsu Objections to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* Objects to Identified Interrogatories & Cajun General Instruction B.W/ Certificate of Svc.Related Correspondence ML20073H2631994-09-20020 September 1994 Gulf States Util Company Responses to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* Related Correspondence ML20072Q5061994-09-0606 September 1994 Gulf State Utilities Company Objections to Cajun Electric Cooperative,Inc. Interrogatories,Dtd 940822.* Gsu Objects to General Instruction B of Cajun Requests for Production of Document.W/Certificate of Svc.Related Correspondence ML20072Q4881994-09-0202 September 1994 Gsu Co Responses to Interrogatories Dtd 940822.* Informs That Responses Subj to Objections Filed by Util Dtd 940906. Related Correspondence ML20072P2201994-08-26026 August 1994 Gulf States Utilities Co First Request for Production of Documents to NRC Executive Director of Operations.* Requests Production of Documents as Listed.W/Certificate of Svc. Related Correspondence ML20072P2051994-08-26026 August 1994 Gulf States Utilities Co First Set of Interrogatories & Request for Production of Documents to Cajun Electric Power Cooperative,Inc.* Requests Production of Listed Documents. W/Certificate of Svc.Related Correspondence ML20093N2701984-07-24024 July 1984 Answers to First Set of Interrogatories & Response to Request for Production of Documents.Certificate of Svc Encl. Related Correspondence ML20091L0861984-06-0505 June 1984 First Set of Interrogatories & Request for Production of Documents to State of La & Joint Intervenors on Safety Contentions 1 & 2.Svc List Encl.Related Correspondence ML20081C3411984-03-13013 March 1984 Proposed Emergency Planning Contentions 1-12,identifying Major Flaws in Emergency Plan.Certificate of Svc Encl ML20032A1381981-10-26026 October 1981 Response to State of La Petitions to Intervene & Request for Hearing.State Should Be Required to Designate Whether Participation Requested as State,As Full Party or as Both. Request for Hearing Premature.Certificate of Svc Encl ML19276F5601979-03-13013 March 1979 NRC Response to Utils First Set of Interrogatories;In Particular,Interrogatories 2,12,13,19-26,29-31,36,37,39-54, 63,65,69,70,73,74-76,78,81-95,97 & 99 ML19276F5611979-03-13013 March 1979 NRC Response to Utils Third Set of Interrogatories;In Particular,Interrogatories 178,179,182-184,194,195,199-201, 207,216,221,225,228 & 230 ML19276F5621979-03-13013 March 1979 NRC Response to Utils Fourth Set of Interrogatories;In Particular,Interrogatories 262 & 263 ML19282C3621979-02-23023 February 1979 Greene County,Nys Interrogatories to NRC Re NUREG-0512. Answers Requested on or Before 790309.Certificate of Svc Encl ML19259B3631979-01-0505 January 1979 County Survival Committees Further Responses to NRC Interrogatories.Believes SER to Be Deficient Re non-military Traffic,Population Related to Water Supply, Radioactive Matls & Conditions of Government Agencies ML20147F1911978-10-0202 October 1978 Interrogatories to Greene County,Towns of Catskill & Athens & Villages of Catskill & Athens Contentions.Contention States That Possible Consequences of Blasting in Vicinity of Cementon Site Not Well Evaluated ML20147F1791978-10-0202 October 1978 Interrogatories to Columbia County Survival Committee. Petition Contends Greene County Site for Nuclear Plant Unsuitable for Listed Reasons & That Applicant PSAR Inadequately Considered Site Susceptability to Quakes ML20147F1691978-10-0202 October 1978 Interrogatories to Columbia County.Contention Stipulates There Is Insufficient Evaluation of Effects of Quarrying & Placement of Earth on Stability of Subterranean Formations ML20147F1481978-10-0202 October 1978 Response to Intervenor SA Brand & Mid-Hudson Nuclear Opponents.Contention That Seismic Design of Proposed Facility Inadequate Unproven.Ground Acceleration Associated W/Proposed Safe Shutdown Underestimated ML20147F1591978-10-0202 October 1978 Interrogatories to Cementon Civic Assoc Contentions That Staff & Applicant Failed to Fully Assess Geological Data & Evaluations Sufficiently to Determine Site Geological Stability Re Operation of Three Cement Plants ML20147F4211978-09-29029 September 1978 Interrogatories & Request for Production of Documents from AL Reuter & Columbia County Survival Committee ML20147F4141978-09-29029 September 1978 Interrogatories & Request for Production of Documents from Lehigh Portland Cement Co ML20147F4091978-09-29029 September 1978 Interrogatories & Request for Production of Documents from Greene County Et Al ML20147F4021978-09-29029 September 1978 Interrogatories & Request for Production of Documents from Columbia County ML20147F3881978-09-29029 September 1978 Interrogatories & Request for Production of Documents from Citizens to Preserve Hudson Valley ML20147F3841978-09-29029 September 1978 Interrogatories & Request for Production of Documents from Cementon Civic Assoc ML20147F3761978-09-29029 September 1978 Interrogatories & Request for Production of Documents from SA Brand & Mid-Hudson Nuclear Opponents ML20204B7791978-09-0808 September 1978 Interrogatories & Request for Production of Documents from Lehigh Portland Cement Co.Certificate of Svc Encl 1994-09-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20205D4901999-02-22022 February 1999 Transcript of 990222 Informal Public Hearing on 10CFR2.206 Petition in Rockville,Md.Pp 1-105.Supporting Documentation Encl ML20197H8661998-12-0202 December 1998 Exemption from Requirements of 10CFR70.24(a) Re Criticality Accident Requirements ML20155E1631998-09-25025 September 1998 Petition Per 10CFR2.206 Requesting That Plant Be Immediately Shut Down & OL Suspended or Modified Until Such Time That Facility Design & Licensing Bases Properly Updated to Permit Operation with Failed Fuel Assemblies ML20202F0081997-11-28028 November 1997 Order Approving Transfer of License for River Bend Station, Unit 1 ML20211P2771997-10-15015 October 1997 Application of RR Mabey,Chapter 11 Trustee for Cajun Electric Power Cooperative,Inc,For Transfer & Amend of License ML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements RBG-42925, Comment on Draft Reg Guide DG-5007, Perimeter Instrusion Alarm Sys. Word Splices Should Be Changed to Terminations1996-05-29029 May 1996 Comment on Draft Reg Guide DG-5007, Perimeter Instrusion Alarm Sys. Word Splices Should Be Changed to Terminations ML20097D8631996-02-0909 February 1996 Suppl to Withdrawal of Contention & Motion for Termination of Hearing of RR Mabey,Chapter 11 Trustee for Util.* W/Certificate of Svc ML20100D2221996-01-25025 January 1996 Withdrawal of Contention & Motion for Termination of Hearing of RR Mabey,Chapter 11 Trustee for Cajun Electric Cooperative,Inc.* W/Certificate of Svc ML20096G4991996-01-16016 January 1996 Joint Motion to Suspend Procedural Schedule.* Requests That Procedural Schedule in Proceeding Be Suspended,Pending Action by Bankruptcy Court at Following Scheduled Hearing on 960122.W/Certificate of Svc ML20113G0751995-10-26026 October 1995 Transcript of Interview of J Fisicaro on 951026 in St Francisville,La ML20093G3461995-10-10010 October 1995 Joint Motion to Extend Hearing Date & Scheduling Order.* Trustee & Gsu Request That Prehearing Schedule & Hearing Schedule Be Revised So That All Depositions Be Completed by 960623.W/Certificate of Svc ML20113G0631995-07-27027 July 1995 Transcript of Interview of J Mcgaha on 950727 in St Francisville,La ML20113G0601995-07-21021 July 1995 Transcript of Interview of CR Maxson on 950721 in St Francisville,La ML20113G0421995-07-20020 July 1995 Transcript of Interview of Dn Lorfing on 950720 in St Francisville,La ML20113G0371995-07-19019 July 1995 Transcript of Interview of as Soni on 950719 in St Francisville,La ML20086P6501995-07-17017 July 1995 Joint Motion to Extend Hearing Date & Amend Scheduling Order.* Requests That Prehearing Schedule & Hearing Schedule Be Revised.W/Certificate of Svc ML20086K7511995-07-0707 July 1995 Exemption Granted from Requirements of 10CFR73.55(d)(5) Re Returning of Picture Badges Upon Exit from Protected Area of Individuals Not Employed by Licensee ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20113G0671995-06-16016 June 1995 Transcript of Interview of Wj Fountain on 950616 in St Francisville,La ML20113G0541995-06-15015 June 1995 Transcript of Interview of Jc Maher on 950615 in St Francisville,La ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20085K9481995-06-0808 June 1995 Order Approving Transfers & Notice of Issuance of License Amends.Authorizes Gsu to Operate & Hold 70% Ownership Share in Plant ML20085M4891995-06-0808 June 1995 Order Approving Transfer of License to Entergy Corp & Entergy Operation,Inc & Notice of Issuance of License Amend ML20083M7811995-05-10010 May 1995 Submits Request for Reevaluation of Cities of Benton,Conway, North Little Rock,Osceola,Prescott & West Memphis,Arkansas & Farmers Electric Cooperative Corp on Anti-Trust Issues ML20080G8241995-02-0606 February 1995 Cajun Electric Power Cooperative,Inc Answer in Opposition to NRC Staff Response in Support of Gsu Motion for Summary Disposition.* Requests That Aslp Find Staff Response Inadequate.W/Certificate of Svc ML20078C7131995-01-23023 January 1995 Cajun Electric Power Cooperative,Inc Answer in Opposition to Gulf State Utilities Company Motion for Summary Disposition.W/Certificate of Svc ML20078C7821995-01-23023 January 1995 Cajun Electric Power Cooperative,Inc Concise Statement of Matl Facts to Which Genuine Issue Exists Accompanying & Supporting Answer to Gulf State Utilities Company Motion for Summary Disposition.W/Certificate of Svc ML20078C7261995-01-19019 January 1995 Affidavit of WT Ullrich on Behalf of Cajun Electric Power Cooperative,Inc.* Affidavit Re Past Performance of & Future Decommission Plans of Plant ML20078C7441995-01-19019 January 1995 Affidavit of Jm Griffin on Behalf of Cajun Electric Power Cooperative,Inc.* Affidavit Re Past Performance of & Future Decommission Plans for Plant ML20078C7861995-01-0909 January 1995 Gulf States Util Co Statement of Undisputed Facts in Support of Motion for Summary Disposition.* Util Intends to Safely Operate Plant within Requirements of Operating License ML20082H2341995-01-0909 January 1995 Gulf States Utilities Co Motion for Summary Disposition.* W/Certificate of Svc ML20077C0911994-11-17017 November 1994 Gsu Co Answer to Cajun Electric Power Cooperative 941107 Motion to Compel.* Requests Denial of Cajun Electric Power 941107 Motion for Reasons as Stated.W/Certificate of Svc ML20076N3141994-11-0707 November 1994 Util Motion to Compel Responses to follow-up Discovery Requests & Answer to Motion for Protective Order.* Util Requests That ASLB Issue Order Against Gsu/Eoi Re Discovery Responses.W/Certificate of Svc ML20076N4991994-10-31031 October 1994 Gulf States Utilities Co Second Supplemental Response to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* W/Certificate of Svc ML20078C9751994-10-28028 October 1994 Gsu Objections to Cajun Electric Power Cooperative,Inc Followup Discovery Requests & Motion for Protective Order.* Cajun Electric Power Discovery Requests Relate to Matters Outside Proper Scope.W/Certificate of Svc ML20078D3291994-10-28028 October 1994 Gulf States Utilities Company Second Supplemental Response to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories,Dtd 940908.* W/Certificate of Svc ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20080A2971994-10-13013 October 1994 Gulf States Utilities Company Supplemental Responses to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* W/Certificate of Svc.Related Correspondence ML20024J3081994-10-0303 October 1994 Cajun Electric Power Cooperative,Inc Motion to Compel Responses to Interrogatories & Production of Documents.* Requests Board to Issue Order Against Gsu Compelling Production of Listed Items.W/Certificate of Svc ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20073H2071994-09-30030 September 1994 Answer of Util to Motion to Compel Production & Provide for Addl Info Discovery.* Informs That Motion Should Be Denied. W/Certificate of Svc ML20024J3161994-09-30030 September 1994 NRC Staff Response to Licensee Request for Production of Documents.* NRC Unaware of Document That Relate to Scope & Criteria for NRC Review of Operation of Facility When Holder of OL Filed for Bankruptcy Protection.W/Certificate of Svc ML20073H0931994-09-29029 September 1994 Gulf States Utils Co Motion to Compel Answers to Interrogatories & Document Production Requests & for Other Relief*. Requests That Board Grant Util Addl Time to Conduct follow-up Discovery Based on Responses.W/Certificate of Svc ML20073H2301994-09-26026 September 1994 Notice of Appearance.* Undersigned Attys Enter Appearances in Proceeding.W/Certificate of Svc ML20073H2701994-09-22022 September 1994 Gsu Objections to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* Objects to Identified Interrogatories & Cajun General Instruction B.W/ Certificate of Svc.Related Correspondence ML20073H2121994-09-21021 September 1994 Gulf States Util Co Responses to Cajun First Request for Production of Documents Dtd 940822.W/Certificate of Svc. Related Correspondence ML20073H2631994-09-20020 September 1994 Gulf States Util Company Responses to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* Related Correspondence ML20072Q5061994-09-0606 September 1994 Gulf State Utilities Company Objections to Cajun Electric Cooperative,Inc. Interrogatories,Dtd 940822.* Gsu Objects to General Instruction B of Cajun Requests for Production of Document.W/Certificate of Svc.Related Correspondence ML20072Q4881994-09-0202 September 1994 Gsu Co Responses to Interrogatories Dtd 940822.* Informs That Responses Subj to Objections Filed by Util Dtd 940906. Related Correspondence 1999-02-22
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY'AND LICENSING BOARD In the Matter of POWER AUTHORITY OF THE STATE OF NEW YORK' Docket No. 50-549 (GreeneCountyNuclearPowerPlant)
)
NRC STAFF INTERROGATORIES TO THE CEMENTON CIVIC ASSOCIATION Pursuant to 10 CFR S 2.740 of the Commission's Rules of Practice, the NRC Staff hereby requests that the Cementon Civic Association (Inter-venor) answer separately and fully in writing under oath or affirmation the interrogatories set forth below.
Insofar as any answer is based on information other than the personal knowledge of the individual subscribing to the answers, the source of such information shall be disclosed. When the source of the information is another individual, such disclosure is to be in the form of che indi-vidual's name, address, and relationship with the Intervenor, if any.
Where the source of information is a writing of some kind, it shall be identified.
The interrogatories set forth below are to be considered the Intervenor's continuing obligation. Accordingly, if, after the Intervenor has answered these interrogatories, additional information comes to its attention with respect to one or more of the answers, the answers should be amended to provide such additional information.
1[r/cI10 OlF m
- Cementon Civic Association Contention I C. U C.
The Petitioner contends that the Staff and Applicant have failed to fully assess the geological data and evaluation sufficiently to determine the site's geological stability, particularly with regard to the extensive quarrying operations of the three local and contiguous cement plants.
1-1 a.
Upon what person or persons do you rely to substantiate your case on the above contention?
b.
Provide the addresses and educational and professional qualifications of any person named in your response to
- a. above.
c.
Identify which of the above persons you intend to call as witnesses on this contention in this proceeding.
d.
Identify which of those persons identified in c. above you anticipate will appear voluntarily and which under subpoena.
e.
Identify each document upon which this contention is based.
1-2 a.
Is it your contention that the geological data assessed by the Staff is incomplete? In your response to this interrogatory address both the sufficiency of the data used by the Staff with regard to the Cementon site's l
geological stability in general as well as the geolo-gical stability as affected by quarrying.
b.
If your answer to Interrogatory 1-2a is yes identify the data which was not considered by the Staff.
U The wording of this contents-conforms to the wo iing accepted by the Atomic Safety and Lic^...
Board in its Memorandum and Order dated February 14, 1977, at.'.
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c.
Indicate the deficiencies (aside from that noted in
- b. above) in the Staff's evaluation of the site's geological ' stability.
d.
Indicate how the specific deficiencies noted in your response to c. above and the data noted in your response to b. above could impact the Staff's con-clusion regarding the stability of the Greene County site.
1-3 To the extent that Intervenor's case on this contention will rely on cross-examination of witnesses presented by other parties to this proceeding, identify any material to be relied upon during such cross-examination.
1-4 Identify all documentary or other material which you' intend to offer as exhibits on this contention in'this proceeding.
Respectfully submitted, 11, Henry J. McG1rren Counsel for NRC Staff Dated at Bethesda, Maryland this 2nd day of October,1978 J
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