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| | issue date = 04/15/1981 | | | issue date = 04/15/1981 |
| | title = Request for Production of Listed Documents.Related Correspondence | | | title = Request for Production of Listed Documents.Related Correspondence |
| | author name = CHONIN N | | | author name = Chonin N |
| | author affiliation = CHONIN,N., ONCAVAGE, M. | | | author affiliation = CHONIN,N., ONCAVAGE, M. |
| | addressee name = | | | addressee name = |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML19351A6891989-12-0404 December 1989 Intervenors Supplemental Response to Licensee Discovery Requests,Interrogatory I.(A-B).* W/Supporting Info & Certificate of Svc.Related Correspondence ML20247F1011989-09-0808 September 1989 Intervenors Response to Licensee Followup Discovery Request to Ctr for Nuclear Responsibility & J Lorion.* Intervenors Believe That Unit 4 plant-specific Surveillance Data Only Credible Data.W/Certificate of Svc.Related Correspondence ML20246J6971989-08-29029 August 1989 NRC Staff Response to Ctr for Nuclear Responsibility & J Lorion First Set of Discovery Requests to NRC Staff.* Bj Elliot Unexecuted Affidavit Encl.Related Correspondence ML20246J2751989-08-28028 August 1989 Licensee Response to Intervenors First Set of Discovery Requests to Licensee.* W/Certificate of Svc.Related Correspondence ML20246B9511989-08-16016 August 1989 Licensee Followup Discovery Request to Ctr for Nuclear Responsibility & J Lorion.* W/Certificate of Svc.Related Correspondence ML20245F8111989-08-0808 August 1989 Intervenors Responses to Licensee First Set of Discovery Requests to Ctr for Nuclear Responsibility & J Lorion.* Certificate of Svc Encl.Related Correspondence ML20245F7651989-08-0707 August 1989 Intervenors First Set of Discovery Requests to NRC Staff.* W/Certificate of Svc.Related Correspondence ML20245F7891989-08-0707 August 1989 Intervenors First Set of Discovery Requests to Licensee.* Interrogatories & Documents Specific to Contentions 2 & 3 Requested,Per 10CFR2.740(b) & 2.741.Certificate of Svc Encl. Related Correspondence ML20245J6021989-06-21021 June 1989 Licensee First Set of Discovery Requests to Ctr for Nuclear Responsibility & J Lorion.* W/Certificate of Svc.Related Correspondence ML20137L8791985-11-27027 November 1985 Response to Licensee Interrogatories to Ctr for Nuclear Responsibility & J Lorion.General Interrogatories Answered for Each Contention Provided.Certificate of Svc Encl. Related Correspondence ML20137L9621985-11-27027 November 1985 Response to Licensee Interrogatories to Ctr for Nuclear Responsibilities & J Lorion.Addl Info Will Be Provided When Continuing Obligation Comes to Intervenor Attention. Certificate of Svc Encl.Related Correspondence ML20138L6451985-10-28028 October 1985 First Set of Interrogatories,Requesting All Documents,Books, Repts & Papers Intended for Use in Conducting cross- Examination of Witnesses Testifying on Contention 3.W/ Certificate of Svc.Related Correspondence ML20138L8951985-10-28028 October 1985 First Set of Interrogatories to Ctr for Nuclear Responsibility & J Lorion Re Spent Fuel Pool Expansion. Certificate of Svc Encl.Related Correspondence ML20106D2111985-02-0606 February 1985 First Discovery Request That NRC Provide Documents Listed in Encl App a Re Evaluation of Reactor Vessel Matls Data for Plant Reactor Vessels.Certificate of Svc Encl.Related Correspondence ML20090C2961984-07-10010 July 1984 Response to Interrogatories.Certificate of Svc Encl.Related Correspondence ML20091C9251984-05-29029 May 1984 Interrogatories on Contentions B & D.Certificate of Svc Encl.Related Correspondence ML20079N2181984-01-26026 January 1984 Discovery Request for Documents Listed on Encl App A.W/O App.Certificate of Svc Encl ML20079P8381984-01-26026 January 1984 Discovery Request as Part of Amended Petition to Intervene. Encl App a Inadvertently Omitted from Original Discovery Request.Certificate of Svc Encl ML17340B1291981-04-22022 April 1981 Response to Intervenor MP Oncavage 810414 & 15 Requests for Production of Documents.Licensee Will Provide Documents Except in Response to Requests 3 & 5.Certificate of Svc Encl ML17340B1401981-04-15015 April 1981 Request for Production of Listed Documents.Related Correspondence ML17340B1381981-04-15015 April 1981 Request for Production of Listed Documents.Related Correspondence ML17340B0341981-04-14014 April 1981 Request for Production of Listed Documents from Licensee. Certificate of Svc Encl.Related Correspondence ML17339A6301980-02-11011 February 1980 Supplemental Responses to MP Oncavage 791027 Interrogatories & Requests for Documents,Per ASLB 800124 Order.Includes Info Re Safety Retrofitting or Backfitting & New Technologies Re Coal Project.W/Affidavit & Certificate of Svc ML17339A6271980-02-0505 February 1980 Answers to Interrogatories Per ASLB 800122 Order.Nrc Safety Evaluation & Eia Are Deficient Due to NRC Reliance on Licensee.Prepared Steam Generator Repair Rept.Certificate of Svc & Licensee Complaint Encl ML17339A4461979-12-17017 December 1979 Answers to NRC Interrogatories & Request for Production of Documents.Confirms a Bowen,W Goldberg,R Anderson, D Bridenbaugh,Kz Morgan & AR Tamplin as Witnesses.Considers Safety Evaluation & Eia to Be Deficient ML17339A4511979-12-17017 December 1979 Responses to Intervenor MP Oncavage 791027 Interrogatories & Request for Production of Documents,Per ASLB 791115 Order. Objects to Majority of Questions as Irrelevancy & Immateriality.Certificate of Svc & Affidavit Encl ML17339A3321979-11-0707 November 1979 Responses to Intervenor MP Oncavage 791027 Interrogatories & Request for Production of Documents.Objects to Majority of Questions.Aslb 790927 Order Rejected All Issues Re Steam Generator Repairs.Certificates of Svc Encl ML17339A3341979-10-27027 October 1979 Interrogatories & Request for Production of Documents Directed to Licensee.Includes Questions on Licensee Preparedness to Protect Public & Environ in Event of Steam Generator Failure.Certificate of Svc Encl 1989-09-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEAR3F0999-05, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines1999-09-14014 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines L-99-201, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments1999-09-0707 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments ML20206H4441999-05-0303 May 1999 Comment Opposing Proposed Rules 10CFR170 & 10CFR171 Re Rev of Fy 1999 Fee Schedules ML20205J0461999-04-0101 April 1999 Comment Supporting Proposed Draft Std Review Plan on Foreign Ownership,Control & Domination.Util Supports Approach Set Forth in SRP Toward Reviewing Whether Applicant for NRC License Owned by Foreign Corp.Endorses NEI Comments ML20205B3771999-03-16016 March 1999 Comment Opposing PRM 50-64 Re Liability of Joint Owners of Npps.Util Endorses Comments of NEI & Urges Commission to Deny Petition for Rulemaking ML17355A2511999-03-0909 March 1999 Comment Supporting Amend to Policy & Procedure for NRC Enforcement Actions Re Treatment of Severity Level IV Violations at Power Reactors.Util Also Endorses Comments of NEI on Revs L-98-306, Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP1998-12-10010 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP L-98-272, Comment on Draft Reg Guide DG-4005, Preparation of Suppl Environ Repts for Applications to Renew Nuclear Power Plant Operating Licenses1998-10-28028 October 1998 Comment on Draft Reg Guide DG-4005, Preparation of Suppl Environ Repts for Applications to Renew Nuclear Power Plant Operating Licenses L-98-252, Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule1998-10-0606 October 1998 Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule L-98-248, Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement1998-10-0505 October 1998 Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement ML17354A8741998-03-27027 March 1998 Comment Opposing Proposed Generic Communication,Lab Testing of nuclear-grade Activated Charcoal (M97978) ML17354B1061998-02-26026 February 1998 Submits Listed Requests for NRC EA Per 10CFR2.206 to Modify OLs for All FPL NPPs Until Licensee Can Demonstrate Open Communication Channels Exist Between NRC & Licensee.Also Requests EA to Address Alleged Discriminatory Practices ML20217M0751997-08-13013 August 1997 Licensee Response to Supplemental 10CFR2.206 Petitions Filed by Tj Saporito & National Litigation Consultants.Petition Provides No Basis for Extraordinary Relief Requested. Petition Should Be Denied.W/Certificate of Svc ML20217J4321997-08-0707 August 1997 Memorandum & Order.* Grants Staff Petition for Review & Reverses Presiding Officer Decision Requiring Staff to Issue Tetrick SRO License.Order Disapproved by Commissioner Diaz. W/Certificate of Svc.Served on 970807 ML20148P8461997-06-25025 June 1997 Memorandum & Order (Determination of Remand Question).* Concludes That Presiding Officer Reaffirms Determination That Response of Rl Tetrick to Question 63 of Exam to Be SRO Was Incorrect.W/Certificate of Svc.Served on 970626 ML17354A5521997-06-18018 June 1997 Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems. ML20141F5441997-06-13013 June 1997 NRC Staff Response to Presiding Officer Memorandum & Order (Questions Relevant to Remand).* Staff Submits That Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam Should Be Denied ML20141F5711997-06-13013 June 1997 Supplemental Affidavit of B Hughes & Ta Peebles.* Affidavit Re Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam.W/Certificate of Svc ML17354A5181997-05-27027 May 1997 Licensee Response to 10CFR2.206 Petition Filed by Tj Saporito & National Litigation Consultants.Petition Should Be Denied,Based on Listed Info.W/Certificate of Svc ML20148G6531997-05-27027 May 1997 Notice.* Forwards Documents Received & Read by Author from Rl Tetrick on 970317 W/O Being Served as Required Under Procedural Rules.W/Certificate of Svc.Served on 970527 ML20148G7071997-05-27027 May 1997 Memorandum & Order (Questions Relevant to Remand).* Rl Tetrick May Respond to Questions W/Filing Served Pursuant to Procedural Regulations W/Notarized Statement to Be Received by 970617.Certificate of Svc Encl.Served on 970527 ML20148G7501997-05-20020 May 1997 Memorandum & Order CLI-97-05.* Staff May Withhold Issuance of SRO License to Rl Tetrick Pending Further Order of Commission.W/Certificate of Svc.Served on 970520 ML17354A5631997-05-17017 May 1997 Second Suppl to 970423 Petition Requesting Enforcement Against Listed Util Employees by Imposing Civil Penalties, Restricting Employees from Licensed Activities & Revoking Unescorted Access ML20141C7331997-05-16016 May 1997 Order Extending Until 970616,time within Which Commission May Rule on NRC Staff 970416 Petition for Review of Presiding Officer Initial Decision.W/Certificate of Svc. Served on 970516 ML17354A5611997-05-11011 May 1997 Suppl to 970423 Petition Requesting Enforcement Action Against Util Former Executive Vice President,Site Vice President & Maint Superintendent by Imposing Civil Monetary Penalty ML20138J2331997-05-0202 May 1997 Affidavit.* Affidavit of B Hughes Re Denial of Application for SRO License for Rl Tetrick.W/Certificate of Svc ML20138J2271997-05-0202 May 1997 NRC Staff Response to Questions Posed in Commission Order of 970425.* Staff Respectfully Submits That Commission Should Undertake Review of Presiding Officer Decisions in Proceedings LBP-97-2 & LBP-97-6 ML20138J2241997-05-0202 May 1997 Line (Providing Omitted Citation).* Informs That Submitted Citation Inadvertently Omitted from Response to Questions Posed in Commission Order of 970425.W/Certificate of Svc ML20138J2401997-04-25025 April 1997 Scheduling Order.* Staff Instructed to File W/Commission,By COB 970502,response to Tetrick Argument Re Question 63 & Discussion of Legal Significance of Consistent Staff Practices.W/Certificate of Svc.Served on 970425 ML17354A5651997-04-23023 April 1997 Requests That NRC Take EA to Modify,Suspend or Revoke FPL Operating Licenses for All Four Nuclear Reactors Until Licensee Can Sufficiently Demonstrate to NRC & Public That Employees Encouraged to Freely Raise Safety Concerns ML20137X5921997-04-16016 April 1997 NRC Staff Petition for Commission Review of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Undertake Review of Presiding Officer Decisions in Proceeding.W/Certificate of Svc ML20137X5511997-04-11011 April 1997 NRC Request for Issuance of Order Staying Effectiveness of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Stay Effectiveness of Decision in Subj Proceeding.W/Certificate of Svc ML20137R3531997-03-27027 March 1997 Correct Copy of Memorandum & Order (Denial of Reconsideration,Stay).* Denies NRC Staff Motion for Reconsideration.W/Certificate of Svc.Served on 970327 ML20137F5551997-03-25025 March 1997 NRC Staff Response to Memorandum & Order of 970321.* Presiding Officer Should Grant Staff 970310 Motion for Reconsideration.W/Certificate of Svc ML20137F8251997-03-21021 March 1997 Memorandum & Order (Grant of Housekeeping Stay).* Orders That Effect of Initial Decision Postponed Until Close of Business on 970326.W/Certificate of Svc.Served on 970321 ML20137F5081997-03-17017 March 1997 NRC Staff Motion for Issuance of Stay.* Requests That Presiding Officer Deny NRC Staff Request for Issuance of Stay in Matter of Issuance of SRO License ML20137F5371997-03-17017 March 1997 NRC Staff Motion for Reconsideration in Matter of Rl Tetrick.* Requests That Presiding Officer Deny NRC Staff Request for Reconsideration ML20136F2981997-03-12012 March 1997 Memorandum & Order (Grant of Housekeeping Stay).* Informs That Initial Decision Issued by Presiding Officer on 970228 Postponed Until 970321 & Rl Tetrick May File Response by 970318.W/Certificate of Svc.Served on 970312 ML20136F2351997-03-10010 March 1997 NRC Staff Motion for Reconsideration Introduction.* Requests That Presiding Officer Reconsider Determination That Tetrick Passed Written Exam & Find,Instead,That Tetrick Failed Written Exam ML20136F3411997-03-10010 March 1997 NRC Staff Request for Issuance of Order Staying Effectiveness of Presiding Officers Initial Decision LBP-97-2.* Staff Submits That Presiding Officer Should Stay Effectiveness of Initial Decision.W/Certificate of Svc ML20136F2721997-03-0606 March 1997 Supplemental Affidavit of B Hughes.* Supports Staff Motion for Reconsideration of Presiding Officer Initial Decision of 970228.W/Certificate of Svc ML20138Q0191997-02-28028 February 1997 Initial Decision.* Concludes That Rl Tetrick Had Passing Score of 80% & Should Be Granted License as Sro. W/Certificate of Svc.Served on 970228 ML20134A6551997-01-23023 January 1997 Written Presentation of NRC Staff.* Staff Concludes That SE Turk Failed Written Exam & Did Not Establish Sufficient Cause to Change Grading of Answers to Listed Questions. Denial of Application for SRO License Should Be Sustained ML20134A6661997-01-23023 January 1997 Affidavit of B Hughes & Ta Peebles Re Denial of Application for SRO License.W/Certificate of Svc.Served on 970124 ML20129J5681996-10-23023 October 1996 Memorandum & Order (Error).* Informs of Incorrect Caption Identified in Order .W/Certificate of Svc.Served on 961023 ML20129D4981996-10-21021 October 1996 Memorandum & Order (Grant of Request for Hearing Scheduling).* Requests for Hearing Hereby Granted. W/Certificate of Svc.Served on 961021 ML20129D6681996-10-18018 October 1996 NRC Staff Answer to Rl Tetrick Request for Hearing.* Staff Does Not Oppose Request & Will Be Prepared to Submit Hearing File.W/Certificate of Svc & Notice of Appearance ML20129D4401996-10-0909 October 1996 Designating of Presiding Officer.* Pb Bloch Designated to Serve as Presiding Officer to Conduct Informal Adjudicatory Hearing in Proceeding of Rl Tetrick Re Denial of SRO License.W/Certificate of Svc.Served on 961010 ML17353A6311996-01-19019 January 1996 Decision & Remand Order Re FPL Discrimination Against RR Diaz-Robainas.FPL Ordered to Offer Reinstatement to RR Diaz-Robainas W/Comparable Pay & Benefits,To Pay Him Back Pay W/Interest & to Pay His Costs & Expenses Re Complaint ML17353A2471995-06-27027 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style. 1999-09-07
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UNITED S ATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of FLORIDA POWER AND LIGHT COMPANY (Turkey Point Nuclear Generating Units Nos.: 3 and 4)Docket Nos.: 50-250-SP 50-251-SP (Proposed Amendments to Facility Operating License to Permit Steam Generator Repairs)INTERVENOR MARK ONCAVAGE'S REQUEST TO PRODUCE DOCUMENTS'ROM THE'TAFF OF FLORIDA POWER AND'IGHT COMPANY Intervenor, by his undersigned attorney, in accordance wi'th the applicable rules of 10 CFR 2.740 and 2.741, requests the Staff to produce within thirty (30)days, at the office of the attorney for the Intervenor:
1.The reports of corrosion testing of low alloy steel such as the Turkey Point Steam Generator assemblies at Kure Beach, N.C..2.All memorandums, correspondence or other documents in the pos-session, custody or control of the Staff that outline the conclusions of Bernard Turovlin after the reports of corrosion testing of low alloy steel was performed at Kure Beach, North Carolina.3.The International Commission on Radiological Protection cost benefit methodology in publication 22.Copies of the instructions and demonstration in radiation protection principles, theory and practice, emergency planning, and the FPL radiological protection program.5.The comprehensive examination that will be give to personnel for authority to go unescorted in the radiation controlled area.6.The Intervenor has a substantial need for the documents and cannot obtain them elsewhere wihtout undue hardship., These documents support the Staff's Motion for Summary Disposition of Contention 2 and 6.Y ,DATED this 15th day of April, 1981.LAW OFFICES OF NEIL CHONIN, P.A.Counsel for Intevenor 1400 AmeriFirst Building 1 S.E.3rd Avenue Miami, FL 33131 BY:
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