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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217N7201998-03-31031 March 1998 Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.55a,inservice Inspection & Inservice Testing of Nuclear Power Plant Components ML20203J9661998-02-27027 February 1998 Comment on GL 98-XX, Yr 2000 Readiness of Computer Sys at Npps ML18067A6301997-07-0707 July 1997 Comment Supporting NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Charges,Tests or Experiments). DD-97-15, Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request1997-06-18018 June 1997 Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request ML20115H7061996-06-0404 June 1996 Submits Addl Info to Support Petition for Rulemaking PRM-72-3 Re Amend to SAR ML18065A0761995-09-13013 September 1995 Comment on Draft Rg DG-1043 Re Proposed Rev 2 to Rg 1.149. New Malfunction Tests Required by Revised Rg Can Be Tested at Required 25% Per Year & Reported in Next 4-yr Testing Rept W/O Rev to Test Plan ML20086D9031995-06-29029 June 1995 Comments on Proposed Generic Ltr Re Process for Changes to Security Plans W/O Prior NRC Approval.Proposed GL Also Avoids Unnecessary Expense for Requirements That Provide No Benefit ML18064A8201995-06-27027 June 1995 Comment on Proposed GL Re Relocation of Pressure Temperature Limit Curves & Low Temperature Overpressure Protection Sys Limits.Supports Issuance of Ltr ML20085E6541995-06-13013 June 1995 Comment Re Draft NUREG/BR-0199, Responsiveness to Public. Expresses Concern on Dry Cask Storage W/Exemption Given to VSC-24 Cask & Procedures for Unloading & Transport at Plant ML18064A7681995-05-26026 May 1995 Comment on Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves. ML20073M0621994-09-29029 September 1994 Comment Opposing Proposed Rule 10CFR72 Re Addition of NUHOMS 52B Dry Casks to List of Approved Spent Fuel Storage Casks. Objects to Proposed Rule Because of Substantial Differences Between Fuel Rods & Assemblies at Different Plant ML20056E5101993-08-11011 August 1993 Comment Opposing Proposed Rule 10CFR20 Re Radiological Criteria for Decommissioning ML20012G5301993-02-26026 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Suggests That NRC Conduct Formal Hearing ML20012G5311993-02-24024 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5331993-02-23023 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5341993-02-23023 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5321993-02-23023 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5231993-02-20020 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20012G5251993-02-15015 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20128L9531993-02-10010 February 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127E8851993-01-15015 January 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127E8631993-01-14014 January 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127F0561993-01-0808 January 1993 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116N9171992-11-12012 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116K9591992-11-0909 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Concerns Noted ML20116L4651992-11-0606 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L0501992-11-0303 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Concerns Noted ML20116K7851992-11-0303 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L1811992-11-0202 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L2051992-11-0202 November 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L3341992-10-30030 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Waste Can Not Be Stored Safely.Doe Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20116L2881992-10-26026 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L1311992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Waste Cannot Be Stored Safely.Doe Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20116L2841992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20116L2681992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Waste Can Not Be Stored Safely.Doe Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20116K9861992-10-22022 October 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule.Deadly Waste Cannot Be Stored Safely.Doe Stated Will Not Be Liable for Wastes If Interim Site Not Built by 1998 ML20127E1371992-09-16016 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4721992-09-14014 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4081992-09-14014 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4011992-09-14014 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A3981992-09-11011 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D6611992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A3831992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4521992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D6241992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D9421992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D6331992-09-0909 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A4111992-09-0808 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20106A3671992-09-0808 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D7191992-09-0606 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule 1998-03-31
[Table view] Category:PLEADINGS
MONTHYEARML20071N4031982-10-0505 October 1982 Motion for Indefinite Continuance of Proceeding.Need for Steam Generator Replacement Alleviated Due to Better than Expected Corrosion Performance of Steam Generator Tubes. Future Rate of Corrosion Unpredictable.W/Certificate of Svc ML20038C1621981-12-0808 December 1981 Response Opposing Christa-Maria 811204 Motion for Indefinite Extension of Time to Respond to Licensee & NRC Motions for Summary Dispostion.Time to Respond Already Extended & Contentions Insubstantial.Certificate of Svc Encl ML20140B4781981-08-31031 August 1981 Response to Aslab 810824 Order to Show Cause Why Appeal Should Not Be Dismissed as Untimely.Untimely Filing Due to Misunderstanding Re Computation of Commission Time Limits for Appeal Filings ML20010D1381981-08-17017 August 1981 Brief,In Form of Pleading,On Appeal from ASLB 810721 Order Denying Petition for Hearing Re 810309 Order Confirming Licensee Actions to Upgrade Facility Performance.Certificate of Svc Encl ML18046A7511981-05-28028 May 1981 Reply Supporting Util Workers' Union of America & Mi Util Workers Council 810331 Request for Hearing on Overtime Restrictions Imposed by NRC 810309 Order.Requested Hearing Would Not Involve Labor/Mgt Dispute.Proof of Svc Encl ML19343D1661981-03-31031 March 1981 Requests Hearing on Commission 810309 Order.Restrictions on Overtime Were Imposed W/O Consulting Union Which Is Collective Bargaining Agent for Operating,Maint & Const Employees.Commission Stds Are Not as Restrictive ML18046A2561980-12-0101 December 1980 Response to NRC 801107 Requests for Admissions.Admits That Two Manual Containment Isolation Valves in Containment Bldg Penetration 4a Were Found Locked Open on 790911.Certificate of Svc Encl ML18045A7771980-10-0606 October 1980 Motion to Compel More Specific Answers from NRC to Second Round of Interrogatories 1 Through 4.Requested Info Needed in Detail in Order to Determine If Discretion Abused. Certificate of Svc Encl.Related Correspondence ML18045A3831980-07-18018 July 1980 Response in Opposition to NRC 800703 Motion for Protective Order Re CPC 800221 Interrogatories & Requests for Production of Documents.Relief Not Warranted Per ALAB-594. W/Certificate of Svc ML18045A2531980-06-13013 June 1980 Supplemental Motion to Compel NRC Response to 800225 Interrogatories 2 Through 5,13 Through 15 & 17.Matl Not Privileged,Relevant or Necessary to Decision.Certificate of Svc Encl ML18045A2241980-05-14014 May 1980 Motion to Compel NRC to Produce Documents Requested in Util Interrogatories 2,3,4,5,12,13,14,15 & 17.Util Will Review NRC Objections Re Other Matls.Certificate of Svc Encl. Related Correspondence ML19290D5851980-01-29029 January 1980 Answers to 800117 Notice of Hearing.Noncompliance Item 1 of 791109 Notice of Violation Miscategorized.Civil Penalties Imposed Per 791220 Order Abused Discretion Entrusted to NRC Per Atomic Energy Act ML18043A8131979-05-30030 May 1979 Consumers Power Opposition to Great Lakes Energy Alliance 790509 Prehearing Conference Statement,Amended Contentions & Request for Financial Assistance.Certificate of Svc Encl ML19263E8691979-05-0707 May 1979 States Key Issues for Consideration at 790509 Prehearing Conference.Nrc Should Provide Funds to Intervenor So Latter May Exercise Legal Rights & Assist ASLB in Finding of Facts. Certificate of Svc Encl ML19269D9241979-05-0404 May 1979 Applicant Answer Opposing Great Lakes Energy Alliance 790420 Response.Response Does Not Cure Defects Found in Earlier Submission.Alliance Petition to Intervene Should Be Denied. Certificate of Svc Encl ML19289E9631979-04-20020 April 1979 Responds to Nrc,Consumers Power Co & ASLB Re Intervention in Hearings on Steam Generator Replacement.Supporting Documentation & Certificate of Svc Encl ML19282C3811979-02-27027 February 1979 Great Lakes Energy Alliance Petition to Intervene & Statement of Contentions.W/Attached Article on Pipe Corrosion ML19331A3741974-11-0101 November 1974 Response to Saginaw Intervenors' Motion for Discovery in Aid of Oral Argument.Discusses Saginaw Intervenors' Procedural Deficiencies.Requests That Motion Be Denied.Certificate of Svc Encl ML19331A3791974-10-0909 October 1974 Memorandum Opposing Saginaw Intervenors' 740930 Petition to Reopen Record &/Or for Reconsideration of Initial Decision. Petition Untimely & Issues Raised Are Insignificant to Plant Safety & Should Be Denied.Proof of Svc Encl 1982-10-05
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Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE
.. ~).
In the Matter Of ) *-:J
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) Docket No. 50-255 ..o .**
~rm CONSUMERS POWER COMPANY ) (Civil Penalty) '. r::>
(Palisades Nuclear Power )
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Facility) )
CONSUMERS RESPONSE TO NRC STAFF'S Q
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REQUESTS FOR ADMISSIONS *SJ:)
DATED NOVEMBER 7, 1980 Consumers Power Company ("Consumers") submits the following responses to the NRC Staff's Request For Admissions By Consumers, dated November 7, 1980:
QUESTION
- 1. Does CPC admit that the two manual containment isolation valves in Containment Building Penetration 4a were found locked open on September 11, 1979?
RESPONSE
Yes.
QUESTION
- 2. Does CPC admit that Ted B. Jones found the valves locked open on September 11, 1979?
RESPONSE
Yes.
QUESTION
- 3. Does CPC admit that, when the valves were dis-covered locked open on September 11, 1979, the valves were locked open by virtue of a steel chain threaded through the spokes of the valve operating wheels, through the valve yoke, and joined by a padlock?
G-
RESPONSE
Yes.
QUESTION
- 4. Does CPC admit that, prior to September 11, 1980, the last local leak test of penetration 4.a occurred on March 20, 1978?
RESPONSE
No.
QUESTION
- 5. Does CPC admit that Document "A" is a true copy of a letter sent by R.B. DeWitt, CPC, to Victor Stello, Jr., NRC, on November 29, 1979, which letter concerns CPC's "Response to Notice of Violation"?
RESPONSE
The document appended as "Document 'A'" to the copy of "NRC Staff's Request For Admissions By Consumers Power Company", dated November 7, 1980, served upon Alan P. Bielawski is a true copy of the letter sent by R.B. DeWitt, CPCo, to Victor Stello, Jr., NRC, on November 29, 1979, concerning CPCo's "Response to Notice of Violation".
QUESTION
- 6. Does CPC admit that Document "B"- is a true copy of a letter sent by R.C. Youngdahl, CPC, to Victor Stello, Jr., NRC, on November 29, 1979, including revisions to page 7 of the letter, which letter concerns CPC's response to "Notice of Proposed Imposition of Civil Penalties"?
RESPONSE
Th_e document appended as "Document 'B'" to the copy of "NRC Staff's Request for Admissions By Consumers Power Company", dated November 7, 1980, served upon Alan P. Bielawski is a true copy of the letter sent by R.C. Youngdahl, CPCo, to
t.. ..J I
Victor Stello, Jr., NRC, on November 29, 1979, concerning CPCo's response to "Notice of Proposed Imposition of Civil Penalties" .. ~
QUESTION
- 7. Document "B" (letter to V. Stello from R.C.
Youngdahl, dated November 29, 1979) includes as "Exhibit 1 11 a table of days on which the Palisades facility was operated in other than a cold shutdown condition. Does CPC admit that the Palisades faci-lity was operated in other than a cold shutdown con-dition on all days during 1978 and 1979 which are marked by an "X" or "*" in the exhibit?
RESPONSE
Yes.
QUESTION
- 8. Does CPC admit tha,t Document "C" is a true copy of a letter sent by David P. Hoffman, CPC, to James G.
Keppler, NRC, on September 28, 1979, and its enclosure Licensee Event Report No.79-037?
RESPONSE
The document appended as "Document 'C'" to the copy of "NRC Staff's Request For Admissions By Consumers Power Company", dated November 7, 1980, served upon Alan P. Bielawski is a true copy of a letter sent by David P. Hoffman, CPCo, to James G. Keppler, NRC, on September 28, 1979, and its enclosure, Licensee Event Report No.79-037.
QUESTION
- 9. Does CPC admit that Document "D" is a true copy of a letter sent by David P. Hoffman, CPC, to James G.
Keppler, NRC, on October 31, 1979 and its enclosure, Revision 1 to Licensee Event Report No.79-037?
RESPONSE
The document appended as "Document 'D'" to the copy of "NRC Staff's Request For Admissions By Consumers Power Company", dated November 7, 1980, served upon Alan P. Bielawski is a true copy of a letter sent by David P. Hoffman, CPCo, to James G. Keppler, NRC, on October 31, 1979 and its enclosure Revision 1 to Licensee Event Report No.79-037.
QUESTION
- 10. Does CPC admit that Document "E" is a true copy of CPC internal memorandum RAE 75-79, dated October 18, 1979, with its attachments?
RESPONSE
No, certain of the attachments to RAE 75-79 are not included in the copy of "Document 'E'" appended to "NRC Staff's Request For Admissions By Consumers Power Company", dated November 7, 1980 served upon Alan P. Bielawski.
QUESTION
- 11. Does CPC admit that the two manual isolation valves in Penetration 4.a were not listed on the containment integrity checklist (C.L.3.3) used between March 30, 1978, and September 11, 1979?
RESPONSE
Yes.
QUESTION
- 12. Does CPC admit that neither the* shift supervisor nor the plant health physicist signed off on Procedure H.P. 6.27 after HEPA filter replacement and testing were completed in Penetration 4.a on or about April 6, 1978?
RESPONSE
Yes, if by HP 6.27 the NRC Staff means to exclude any attached procedures or procedures incorporated by reference.
QUESTION
- 13. Does CPC admit that neither the shift supervisor nor the plant health physicist were notified upon completion of HEPA filter replacement and testing in Penetration 4.a on or about April 6, 1978?
RESPONSE
No.
QUESTION
- 14. Does CPC admit .that Thomas P. Neal, an employee of CPC, did not observe the replacement and testing of the HEPA filter in Penetration 4.a between April 4 and 7, 1978?
RESPONSE
No.
QUESTION
- 15. Does CPC admit that the containment integrity checklist (C.L.3.3) was completed for Penetration 4.a on April 1 or 2, 1978?
RESPONSE
Consumers neither admits nor denies question 15 on the grounds that this question, in its present form, is suscep-tible of a number of different interpretations.
QUESTION
- 16. Does CPC admit that the two manual containment isolation valves in penetration 4.a are located in a vital area as defined in 10 CFR 73.2(h)?
RESPONSE
Yes.
QUESTION
- 17. Does CPC admit that it controls access to the vital area within which the two manual containment isolation valves are located?
RESPONSE
Yes.
Respectfully submitted, Alan P. wski One of the Attorneys for Consumers Power Company DATED: December 1, 1980.
Michael I. Miller Paul M. Murphy ISHAM, LINCOLN & BEALE One First National Plaza Suite 4200 Chicago, Illinois 60603 (312) 558-7500
,;
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE In the Matter Of )
) Docket No. 50-255 CONSUMERS POWER COMPANY ) (Civil Penalty)
(Palisades Nuclear Power )
Facility) )
CERTIFICATE OF SERVICE I, Alan P. Bielawski, one of the attorneys for Consumers Power Company, certify that copies of "Consumers Response to NRC Staff's Requests For Admissions Dated November 7, 1980" have been served in the above-captioned matter on the following by depositing same in United States mail, postage prepaid, this 1st day of December, 1980:
Honorable Ivan W. Smith Administrative Law Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James P. Murray, Esq.
Director and Chief Counsel Rulemaking and Enforcement Division Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James Lieberman, Esq.
U.S. Nuclear Regulatory Commission Office of the Executive Legal Director Washington, D.C. 20555 Stephen G. Burns, Esq.
U.S. Nuclear Regulatory Commission Office of Executive Legal Director Washington, D.C. 20555
Docketing and Service Section Off ice of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board.Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judd L. Bacon, Esq.
Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 DATED: December 1, 1980.