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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference ML20059D2071993-08-24024 August 1993 Intervenor Exhibit I-MFP-193,consisting of Review of LER 1-90-015-00,re Docket 50-275,dtd 910118 ML20059D2241993-08-24024 August 1993 Intervenor Exhibit I-MFP-220,consisting of Protest of Util ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 IR 05000275/19920261993-08-24024 August 1993 Intervenor Exhibit I-MFP-118,consisting of Notice of Violation & Insp Rept Re Docket 50-275/92-26 & 50-323/93-26,dtd 921113 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 IR 05000275/19920131993-08-24024 August 1993 Intervenor Exhibit I-MFP-140,consisting of 920416,mgt Meeting Repts 50-275/92-13 & 50-323/92-13 IR 05000275/19910061993-08-24024 August 1993 Intervenor Exhibit I-MFP-71,consisting of Rept of EC W/Util Mgt,Re Rept Numbers 50-275/91-06 & 50-323/91-06,dtd 910411 IR 05000275/19930111993-08-24024 August 1993 Intervenor Exhibit I-MFP-26,consisting of Re Insp Repts 50-275/93-11 & 50-323/93-11 1999-09-20
[Table view] Category:SUBPOENAS
MONTHYEARML20081D7711983-10-26026 October 1983 Application for Subpoena to Compel Production of Evidence by Applicant at Hearing Commencing on 831031.List of Documents to Be Produced Encl ML20081D7761983-10-26026 October 1983 Application for Subpoena to Compel Production of Evidence by Idvp at Hearing Commencing on 831031.List of Documents to Be Produced Encl ML20078G0241983-10-0606 October 1983 Application for Subpoena for G Apostolakis for 831011 Deposition & Production of Documents ML20080J2461983-09-20020 September 1983 Application for Subpoena to Require J Roesset to Appear for 830929-30 Deposition.Proposed Subpoena Encl ML20072K7771983-07-0101 July 1983 Application for Issuance of Subpoena Directing Vh Tennyson to Testify at 830719 Hearings.Proposed Subpoena & Certificate of Svc Encl ML20040A9251982-01-12012 January 1982 Request for Issuance of Subpoena Duces Tecum to JW Eldridge of FEMA to Bring State of CA Nuclear Power Plant Emergency Response Plan & Santa Barbara County Emergency Response Plan.Proposed Subpoena & Certificate of Svc Encl ML19282B1511979-01-30030 January 1979 Requests Issuance of Subpoena to C Hall for Testimony Re Seismic Issues.Proposed Subpoena & Certificate of Svc Encl ML19282B1161979-01-26026 January 1979 Forwards Proposed Subpoenas for M Trifunac & E Luco as Per ALAB-519.Certificate of Svc Encl 1983-09-20
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) -Docket Nos. 50-275 0.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
)
)
GOVERNOR'S APPLICATION FOR SUBPOENA '
DIRECTED TO APPLICANT Governor Deukmejian hereby respectfully applies to the Atomic Safety and Licensing Appeal Board, pursuant to 10 C.F.R.
section 2.720, for a subpoena to compel production of evidence by applicant Pacific Gas & Electric Company ("PG&E") at the hearing commencing on October 31, 1983.
The evidence documents sought to be produced is attached hereto. Each request is either for a document that is explicitly referred to or relied upon in the applicant's prefiled direct testimony, or is for the doc ~umentation that forms the basis for a portion of such testimony. Each requested document or document category is accompanied by a citation to the portion of~the applicant's direct testimony that refers to or is based upon the
! document.
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F311010330 831024 PDR ADOCK 05000275 o PM
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eo v'
The relevancy of the documents requested lies in PG&E's reliance upon them in its direct testimony.
DATED: OCTOBER 26, 1983 Respectfully submitted, JOHN K. VAN DE KAMP, Attorney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General SUSAN L. DURBIN, PETER H. KAUFMAN, Deputy Attorneys General By $ [ML
- SUSAN L. DURBIN Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 Telephone: (213) 736-2105 4
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1 UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD l
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.
(Diablo Canyon Nuclear Power
) 50-323 0.L.
)
Plant, Units 1 and 2) )
)
)
SUBPOENA FOR PRODUCTION e OF EVIDENCE TO THE CUSTODIAN OF RECORDS, PACIFIC GAS & ELECTRIC COMPANY YOU ARE HEREBY COMMANDED to produce, on October 31, 1983, at 1:00 p.m., at the San Luis Bay Inn, Avila Beach, California, for inspection and copying by counsel for Governor Deukmejian, the documents listed or described on the attached Exhibit A.
DATED: , 1983 THOMAS S. MOORE, Chairman Atomic Safety & Licensing Appeal Board I
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,s EXHIBIT A DOCUMENTS TO BE PRODUCED BY PG&E DOCUMENT DESCRIPTION CITATION IN PG&E'S DIRECT PREFILED TESTIMONY PG&E Panel 1 PG&E Panel 1 Testimony
- 1. The in-depth Page 3, line 7 reviews and analyses to assure compliance with licensing criteria
- 2. The study or studies on Page 14, lines 16-18 which PG&E relies for its judgment that none of the findings of the ITP or'IDVP would have resulted in the failure of any structure or system to perform its intended safety function
- 3. Documentation setting forth Page 17 line 3 to the scope, procedures, and page 18, line 24 results of the ITP's functional design reviews of non-seismic safety-related design activities
- 4. The basic criteria Page 17; 11 to 12; page 18 for each ITP review of the -
lines 3 and 15 non-seismic systems described in the testimony
- 5. The documentation by the Page 29, lines 21-23 Unit 2 Project Engineer of the inapplicability of Unit 1 findings
- 6. The documentation of the Page 30, lines 5-7 differences and applicability of Unit 1 review to Unit 2
- 7. The log of each ITP and Page 30, lines 14-21 IDVP finding and all the associated completion sheets for Unit 2.
1.
- 8. The guidelines and Page 32, lines 22-35 tolerances issued by the PG&E ,
, engineering Department, including i the documentation requirements PG&E Panel 2 PG&E Panel 2 Testimony
- 1. Documentation of all Page 71,-line 23 to analyses performed concerning page 72, line 6
, separation or uplift of the i containment foundation mat.
PG&E Panel 3 PG&E Panel 3 Testimony
- 1. Decumentation of the daily Page 37, lines 18-26 mean, maximum and minimum ocean temperatures at the site for June 1, 1983 to the present date, including hourly reports for all time periods wherein
, the ocean temperature exceeded 64*F.
- 2. All analysis of component Same cooling water supply temperatures (and length of time at peak temperatures) with two heat exchangers in operation, assuming a 70*F intake temperature, a LOCA, no off-site power available, and a failure of an auxiliary saltwater pump, all occurring together.
- 3. Documentation provided to Same PG&E by pump cooler suppliers ,
regarding peak acceptable component cooling water supply temperatures.
t
- 4. Documentation relied upon Same *
, to support the conclusion that if 64*F were used as the maximum ocean temperature for other accident analyses, the results of the analyses-would.
be bounded by analyses governed by a maximum. assumed ocean temperature of 70*F specified in the FSAR (page 5 of May 18, 1983 letter of Crane-to Eisenhut).
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- 2. -
.fo PG&E Panel 4 PG&E Panel 4 Testimony
- 1. Documentation of NRC's Page 3, -line 3 approval of Westinghouse's QA Program for all time ,
periods of Diablo Canyon design activities.
- 2. Documentation of the Page 13, lines 8-9 thirteen audits of Westinghouse design contract conducted by the NRC, and all responses thereto, by Westinghouse, including the description of all corrective action taken by Westinghouse.
! PG&E Panel 5 PG&E Panel 5 Testimony
- 1. Training aids used for Page 17, line 4 to the training personnel page 18, line 2 who perform quality-related activities, a well as the attendance records and reports resulting from such training.
- 2. The summary document Page 21, lines 5 to 7 listing the 100 findings and the corrective actions associated with each finding
- 3. The overall audit plan, Page 21, lines 19 to 21 including the definition of areas of activities to be audited annually, as separate and distinguished from areas to be covered by monitoring activities.
- 4. The summary document Page 23, lines 13 to 17 listing the 100 characteristics of governing procedures and over 400 pieces of evidence covered by the audits, and a description of the several findings _
f 3.
- 5. The discrepancy report Page 24, line 7 initiated regarding the use
, of Stress Intensification Factors.
- 6. The Project audit of the Page 24, lines 15 to 22 Unit 2 internal review of Unit 1 Verification Program results.
- 7. Documentation of the audits Page 25, lines 1 to 7 and quality monitoring activities regarding the process of reviewing as-built information and of determining conformance with the design analysis. ,
l PG&E Panel 6 PG&E Panel 6 Testimony
- 1. The lists of " design Page 45, line 16 to page elements" for the AFWS, the 46, line 11 K160-V AC system, and the CRVPS I
f l
4.
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