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Category:AFFIDAVITS
MONTHYEARML20087L3301992-04-0202 April 1992 Affidavit of RW Cink Re Speakout Program ML20087L3491992-04-0202 April 1992 Affidavit of JW Hinson Re ATI Career Training Ctr ML20087L3561992-04-0202 April 1992 Affidavit of Wj Jump Re Tj Saporito 2.206 Petition ML20087L3651992-04-0202 April 1992 Affidavit of Rl Balcom Re Access Authorization Program ML20005G1451989-12-0505 December 1989 Affidavit of Financial Hardship.* Requests NRC to Provide Funds for Investigation & Correction of Errors at Plant Due to Listed Reasons,Including Corder State of Tx Unemployment Compensation Defunct ML20203E1941986-07-18018 July 1986 Affidavit of Jn Wilson Amending 860714 Affidavit Re Design of Nonconforming Structures to Withstand Hurricanes & Tornadoes.Certificate of Svc Encl.Related Correspondence ML20197J7401986-05-15015 May 1986 Supplemental Affidavit of LP Crocker Re Review of 860409 Amend 53 to Fsar,Including Changes to Chapter 13 Matl on Conduct of Operations.Changes Limited Primarily to Changes in Titles ML20141N9191986-03-14014 March 1986 Affidavit of LP Crocker Re Applicant Organization for Operation.Section of Forthcoming SER Encl.Supporting Documentation Encl.Related Correspondence ML20138B0331986-03-14014 March 1986 Affidavit of AO Hill Re Confidential Nature of Info Requested by Citizens Concerned About Nuclear Power,Inc in 860204 Second Set of Interrogatories ML20138A9021986-03-13013 March 1986 Affidavit of JW Briskin Re Author Former Deposition Concerning Quadrex Rept & Brown & Root Ability to Complete Facility,Attached to Citizens Concerned About Nuclear Power, Inc 860221 Motion.Certificate of Svc Encl ML20141N8531986-03-10010 March 1986 Affidavit of Je Geiger Addressing Issue F Re Ability of Util QA Program to Meet Requirements of App B to 10CFR50. Statement of Matl Facts as to Which No Genuine Issue to Be Heard & Certificate of Svc Encl ML20137X0791986-02-27027 February 1986 Affidavit of Jn Wilson,Concluding That Sum of Probabilities of Tornado or hurricane-borne Missile Damage Remains Below 1 X 10 -7 W/Consideration of Addl Pertinent Structures. Related Correspondence ML20153E8711986-02-21021 February 1986 Affidavit of Cg Robertson Re Lack of Util Licensing Engineer Presence at Briefing Given by Quadrex to Brown & Root Prior to Finalization & Submission of Quadrex Rept.Certificate of Svc Encl ML20214C8781986-02-17017 February 1986 Affidavit of RB Linderman Updating Info in Mar 1985 Affidavit Re Use of Probability Analyses to Determine Potential for Tornado Missiles Striking safety-related Structures.Certificate of Svc Encl.Related Correspondence ML20214C8671986-02-14014 February 1986 Affidavit of Jg Dewease on Util Progress on Preparations for Operation of Facilities Since 1982.Functions Mentioned in Organizational Description Provided in 1982 Addressed in Revised Organization.Related Correspondence ML20151T6111986-01-29029 January 1986 Affidavit of Jh Goldberg Re Meeting W/Ea Saltarelli to Discuss Desirability of Independent Review of Engineering Work on Nuclear Projects ML20138M6081985-12-12012 December 1985 Affidavit of L Stanley Re Encl Notes of 810102 Telcon W/ Jr Sumpter Concerning Util Desire for Review of Brown & Root Engineering.Certificate of Svc Encl ML20135A0231985-09-0404 September 1985 Affidavit of C Thrash Re Questions Concerning Preparation of Minutes of Mgt Committee 850427,0626,0723 & 24 Meetings ML20112B0401985-03-11011 March 1985 Affidavit of RB Linderman Re Category 1 Structures & Equipment Design to Withstand Hurricane Wind Loads, hurricane-induced Collapse of non-Category 1 Structures & hurricane-generated Missiles ML20112B0351985-03-0707 March 1985 Affidavit of DE Wolfe Re Adequacy of Operating Basis Wind for Facility in Light of Historical Data on Wind Speeds ML20107G7201985-02-22022 February 1985 Joint Affidavit of MR Wisenburg & Je Geiger Supplementing Info Contained in 841221 Rept on Const Qa/Qc Under New Contractors Per 840314 Partial Initial Decision & 841116 Fifth Prehearing Conference Order.Certificate of Svc Encl ML20076L6691983-09-13013 September 1983 Affidavit of Jl Wray in Response to State of Tx Notice of Deposition of Quadrex Corp on Written Interrogatories. Certificate of Svc Encl ML20053D2961982-05-28028 May 1982 Affidavit of Ws Jordan Listing Judge Ee Hill Actions Observed During Hearings.Certificate of Svc Encl ML20050D9361982-04-0202 April 1982 Affidavit of R Hagar Alleging That Judge E Hill Appeared to Be Asleep During Hearings on Wk of 820118-22.Request That Listed Statement Be Stricken from Record Revealed Inability to Control Bias Favoring Nuclear Power.W/Certificate of Svc ML19323D3351980-04-11011 April 1980 Affidavit Stating Progress of Settlement Negotiations Initiated in Aug 1979.Thirty-day Extension Will Assist in Reaching Reasonable Agreement.Certificate of Svc Encl ML19305E1301980-04-10010 April 1980 Affidavit Responding to Public Utils Board of City of Brownsville,Tx Allegation That Brownsville Has Been Excluded from Discussions Re Interconnection.Clarifies Statement Made at 800327 Meeting.Certificate of Svc Encl ML19305E1511980-04-10010 April 1980 Affidavit Stating That Central & South West Corp,Houston Lighting & Power Co & Tx Utils Co Sys Have Reached Agreement in Principle Re Interconnection Disputes.Agreement May Form Basis for Discussions W/Other Parties.W/Certificate of Svc ML19309H6481980-04-10010 April 1980 Affidavit Stating That 30-day Extension Will Be of Substantial Assistance in Efforts Made for Attaining Settlement.Progress in Negotiations Has Already Been Achieved.Certificate of Svc Encl ML19305C7771980-03-27027 March 1980 Affidavit of Re Roundtree,General Manager of Brownsville Public Utils Board Re Agreement Among Tx Ious for Const of Two Dc Interstate Ties of 500 MW & 250 Mw. Brownsville Prepared to Enter Settlement Negotiations ML19309F8031980-03-27027 March 1980 Affidavit Re Settlement Negotiations.Public Utils Board of City of Brownsville,Tx Is Prepared to Enter Negotiations Provided That Electric Industry Benefits Should Flow to All Segments.Supporting Documentation & Certificate of Svc Encl ML19257D6181980-01-22022 January 1980 Affidavit Re Inadvertent Opening of Sealed Documents by Jm Cutchin.No Documents Read ML19257D6171980-01-22022 January 1980 Affidavit Re Inadvertent Opening of Sealed Documents by Jm Cutchin.No Documents Read ML19257D6211980-01-22022 January 1980 Affidavit Re Inadvertent Opening of Sealed Documents by Jm Cutchin.No Documents Read ML19257D6121980-01-22022 January 1980 Affidavit Re Inadvertent Opening of Sealed Documents by Jm Cutchin.No Documents Read ML19257D6231980-01-22022 January 1980 Affidavit Re Inadvertent Opening of Sealed Documents by Jm Cutchin.No Documents Read ML19256F4981979-09-14014 September 1979 Affidavit by General Manager of Public Utils Board of City of Brownsville.Ack That 790502 Responses to Houston Lighting & Power First Set of Interrogatories & 790626 Supplemental Responses to Same Discovery Have Been Reviewed ML19256F5141979-09-14014 September 1979 Affidavit by Associate General Manager of Public Utils Board,Brownsville,Tx.Ack That 790502 Responses to Houston Lighting & Power First Set of Interrogatories & 790626 Supplemental Responses to Same Discovery Have Been Received 1992-04-02
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20206H2221999-05-0404 May 1999 Exemption from Requirements of 10CFR50.60 That Would Allow STP Nuclear Operating Co to Apply ASME Code Case N-514 for Determining Plant Cold Overpressurization Mitigation Sys Pressure Setpoint.Commission Grants Exemption ML20195C7541998-11-0505 November 1998 Order Approving Application Re Proposed Corporate Merger of Central & South West Corp & American Electric Power Co,Inc.Commission Approves Application Re Merger Agreement Between Csw & Aep ML20155H5511998-11-0202 November 1998 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR ML20195E1481998-10-0202 October 1998 Confirmatory Order Modifying Licenses NPF-76 & NPF-80 Effective Immediately.Order Confirms Licensee Commitment, as Stated in Ltrs & 0604,to Complete Implementation of Thermo-Lag 330-1 Fire Barriers ML20248K5051998-06-0909 June 1998 Confirmatory Order Modifying License (Effective Immediately).Answer for Request for Hearing Shall Not Stay Immediate Effectiveness of Order NOC-AE-000109, Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI ML20137U3531997-04-0808 April 1997 Order Approving Application Re Formation of Operating Company & Transfer of Operating Authority ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20094Q4581995-08-31031 August 1995 Exemption from Certain Requirements of 10CFR50,App J to Allow Performance of Required Periodic Type C Tests During Power Operation TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20085L8531995-06-14014 June 1995 Exemption from Certain Requirements of 10CFR73.55 Re Issuance,Storage & Retrieval of Badges for Personnel Granted Unescorted Access to Protected Areas,Per Util 950327 Application to Implement Geometry Biometric Sys ML20085L5021995-06-0909 June 1995 Exemption Granting One Time Exemption to Permit Schedular Extension of One Cycle for Preformance of App J ML20083A9941994-12-21021 December 1994 Response to Demand for Info (Dfi),Motion for Retraction of DFI & Alternatively,Request for Hearing ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20092C4031993-11-15015 November 1993 Partially Deleted Response of Hl&P to Demand for Info ML20092C3911993-11-15015 November 1993 Partially Deleted Response of Rl Balcom to Demand for Info ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ST-HL-AE-4428, Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans1993-05-0404 May 1993 Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans ML20092C5921992-07-28028 July 1992 Partially Deleted Transcript of 920728 Interview W/Dp Hall in Bay City,Tx.Pp 1-59 ML20092C6211992-07-28028 July 1992 Transcript of 920728 Investigative Interview of JW Hinson in Bay City,Tx.Pp 1-171 ML20092C6301992-07-28028 July 1992 Partially Deleted Transcript of 920728 Interview of Wg Isereau in Bay City,Tx.Pp 1-57 ST-HL-AE-4162, Comment Supporting Proposed Rules 10CFR20 & 50 Re Reducing Regulatory Burden on Nuclear Licenses1992-07-22022 July 1992 Comment Supporting Proposed Rules 10CFR20 & 50 Re Reducing Regulatory Burden on Nuclear Licenses ST-HL-AE-4146, Comment Supporting Draft Reg Guide DG-1021, Selection, Design,Qualification,Testing & Reliability of EDG Units Used as Class 1E Onsite Electric Power Sys at Nuclear Power Plants1992-07-0606 July 1992 Comment Supporting Draft Reg Guide DG-1021, Selection, Design,Qualification,Testing & Reliability of EDG Units Used as Class 1E Onsite Electric Power Sys at Nuclear Power Plants ST-HL-AE-4145, Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Rule1992-07-0606 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Rule ML20101K1131992-06-29029 June 1992 Motion for Leave to Suppl Motion to Modify or Quash Subpoenas & Supplemental Info.* OI Policy Unfair & Violative of Subpoenaed Individuals Statutory Rights & Goes Beyond Investigatory Authority.W/Certificate of Svc ML20101G2041992-06-18018 June 1992 Motion to Modify or Quash Subpoenas.* Requests Mod of Subpoenas Due to Manner in Which Ofc of Investigations Seeks to Enforce Is Unreasonable & Fails to Protect Statutory Rights of Subpoenaed Individuals.W/Certificate of Svc ML20087L3491992-04-0202 April 1992 Affidavit of JW Hinson Re ATI Career Training Ctr ML20087L3651992-04-0202 April 1992 Affidavit of Rl Balcom Re Access Authorization Program ML20087L3561992-04-0202 April 1992 Affidavit of Wj Jump Re Tj Saporito 2.206 Petition ML20087L3301992-04-0202 April 1992 Affidavit of RW Cink Re Speakout Program ML20116F2671992-02-19019 February 1992 Requests NRC to Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility ML20094E9511992-02-10010 February 1992 Requests That NRC Initiate Swift & Effective Actions to Cause Licensee to Immediately Revoke All Escorted Access to Facility & to Adequately Train All Util Employees in Use of Rev 3 to Work Process Program ML20086J4611991-11-21021 November 1991 Exemption Extending Completion Date of Emergency Preparedness Program (EPP) to Allow for Evaluation of Enhanced EPP After Four Months of Implementation ML20066C5041990-09-24024 September 1990 Comment on Proposed Rule 10CFR26 Re NRC Fitness for Duty Program.Urges NRC Examine Rept Filed by Bay City,Tx Woman Who Was Fired from Clerical Position at Nuclear Power Plant Due to Faulty Drug Test Administered by Util ML20029C1511990-03-0909 March 1990 Partially Withheld Subpoena Directing Unname Receipient to Appear Before NRC to Testify Re Alleged Nuclear Safety Concerns ML20087H7261990-02-0808 February 1990 Partially Deleted Order (CLI-90-01) Denying Stay of Enforcement of Administrative Subpoena,Issued by NRC Staff on 891201,until NRC Has Responded to Request Under FOIA for All Records Re Concerns Re Plant from June 1986 to Present CLI-90-01, Order CLI-90-01.* Denies J Corder Motion for Protective Order Staying Enforcement of NRC 891201 Subpoena on Basis That No Reason Exists to Delay Corder Compliance W/Subpoena. W/Certificate of Svc.Served on 900209.Re-served on 9002121990-02-0808 February 1990 Order CLI-90-01.* Denies J Corder Motion for Protective Order Staying Enforcement of NRC 891201 Subpoena on Basis That No Reason Exists to Delay Corder Compliance W/Subpoena. W/Certificate of Svc.Served on 900209.Re-served on 900212 ML20006A0281990-01-0808 January 1990 J Corder Response to NRC Staff Motion to Modify Subpoena & Motion for Protective Order.* Requests Protective Order Until NRC Makes Documents Available to Corder by FOIA or Directly.W/Certificate of Svc ML20005G1621989-12-31031 December 1989 Commands J Corder to Appear at Hilton Hotel in Lake Jackson,Tx on 891219 to Testify Before NRC Personnel Re Alleged Nuclear Safety Concerns Referred to in ML20005G0671989-12-27027 December 1989 NRC Staff Response to Motion to Modify Subpoena & Motion for Protective Order.* Request for Mod of Subpoena Re Place of Attendance Considered Moot in Light of Agreement Reached Between Bp Garde & NRC Counsel & Should Be Denied ML20005G1431989-12-11011 December 1989 Motion to Modify Subpoena & Motion for Protective Order.* Protective Order Requested on Basis That Subpoena Will Impose Undue Financial Hardship on J Corder ML20005G1451989-12-0505 December 1989 Affidavit of Financial Hardship.* Requests NRC to Provide Funds for Investigation & Correction of Errors at Plant Due to Listed Reasons,Including Corder State of Tx Unemployment Compensation Defunct ML20029C1491989-12-0101 December 1989 Partially Withheld Subpoena Directing Appearance to Testify Before NRC Re Alleged Nuclear Safety Concerns ST-HL-AE-3164, Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components1989-07-0505 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20205T7001988-11-0101 November 1988 Comment Supporting Proposed Rule 10CFR26 Re Initiation of Fitness for Duty Program at Facility.Need for Program Based on Presumption That Nuclear Power Activities Require That Personnel Be Free from Impairment of Illegal Drugs 1999-05-04
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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HOUSTON LIGHTING AND POWER
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Docket Nos. 50-498 COMPANY, F.T AL.
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50-499
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(South Texas Project, Units 1 & 2)
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SUPPLEMENTAL AFFIDAVIT OF LAWRENCE P. CROCKER Lawrence P. Crocker, being duly sworn, deposes and says:
1.
My name is Lawrence P.
Crocker.
I am employed by the Nuclear Regulatory Commission.
My business address is the Nuclear Regulatory Commission, Mail Stop 516, Washington, DC 20555.
Since a reorganization of the Office of Nuclear Reactor Regulation on November 24,
- 1985, I have been a Section Leader in the Facility Operations Branch of the Division of PWR Licensing -
A, Office of Nuclear Reactor Regulation.
Prior to the reorganization I 'was Section Leader of the Management Technology Section of the Licensee Qualifications Branch in the Division of Iluman Factors Safety, Office of l
Nuclear Reactor Regulation.
2.
On March 12, 1986, I executed an affidavit (filed March 14, j
1986) addressing the affidavit of Mr. Jerrold G. Dewease relating to the l
progress of IIL&P's preparations for operation of STP since 1982.
My affidavit included a copy of material regarding the organization and l
staffing for STP that was to be published as Chapter 13, Conduct of l
SM'*%ooESh8 l
G i
Operations, of the Staff's Safety Evaluation Report (SER) regarding the STP.
That SER was published in April 1986.
3.
On April 9,1986, the Applicant filed Amerdment 53 to the Final Safety Analysis Report for the STP, which included a number of changes to the Chapter 13 material on Conduct of Operations.
I have reviewed these changes to determine their impact on the Staff's SER.
4.
From my review, it appears that the changes are limited primarily to changes in titles, which in some cases also represent minor adjustments in relative positions within the organizational hierarchy.
There also have been some minor adjustments to the organization in terms of specialized groups added to some of the organizational elements.
In addition to these changes, planned staffing levels for plant operation have generally increased from the levels mentioned in the SER.
5.
These are the type of changes that normally occur as a plant gets closer to the fuel load date and the applicant becomes more aware of the actual needs to support safe plant operation.
The revisions noted above do not substantively effect my affidavit of March 12, 1986.
6.
The Staff plans to issue a Supplement to its SER in about August of 1986. At that time, revisions to the Chapter 13 material will be discussed in the Supplement.
When Staff review is complete for this SER
Supplement, a copy of the supplementary material will be furnished to the Board.
i l
9 w I Qck Lawrence P. Crocker Subscribed and sworn to before me this y of May,1986
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i Notary Public My commission expires:
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