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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20028B2101982-11-26026 November 1982 Response to Interrogatory 26 & Revised Interrogatory 47. Certificate of Svc Encl ML20028B3051982-11-22022 November 1982 Revised Interrogatory 47.Svc List Encl ML20066E9521982-11-0404 November 1982 Responses to 821020 Revised Interrogatories.Certificate of Svc Encl ML20065T3991982-10-27027 October 1982 Objections to 821020 Revised Interrogatories.Certificate of Svc Encl.Related Correspondence ML20069J7761982-10-20020 October 1982 Revised Interrogatories & Requests for Production of Documents ML20063B2711982-08-23023 August 1982 Response to Interrogatories & Requests for Production of Documents.Certificate of Svc Encl ML20058D5881982-07-23023 July 1982 Responses to Interrogatories Served on Callaway Court Administrative Judges & Emergency Mgt Coordinator. Certificate of Svc Encl ML20055A2681982-07-15015 July 1982 Interrogatories & Request for Production of Documents.Notice of Appearance & Certificate of Svc Encl ML20055B1301982-07-13013 July 1982 Interrogatories & Requests for Production of Documents. Certificate of Svc Encl ML20054H5201982-06-16016 June 1982 Correction to Interrogatory 13 of Interrogatories & Requests for Production of Documents,Set 1,directed to State of Mo PSC & State of Mo.Certificate of Svc Encl.Related Correspondence ML20054H6011982-06-15015 June 1982 Interrogatories & Requests for Production of Documents, Set 1,to State of Mo PSC & State of Mo.Certificate of Svc Encl ML20054G4601982-06-14014 June 1982 Interrogatories & Requests for Production of Documents,Set 1,to Callaway County Court Administrative Judges & Callaway County Emergency Mgt Coordinator.Certificate of Svc Encl. Related Correspondence ML20005C0531981-11-0909 November 1981 Suppl to Response to Applicant First Set of Interrogatories on Joint Intervenors Contention 2.Results of Tritium Injections in Mice Supplied.Certificate of Svc Encl.Related Correspondence ML20010H5691981-09-17017 September 1981 Supplemental Response to Util Interrogatories & Requests for Document Production (Set 2) Directed to Joint Intervenors Re Contention 1.Certificate of Svc Encl.Related Correspondence ML20010H5761981-09-17017 September 1981 Response to Util Interrogatories & Requests for Document Production (Set 2) Directed to Joint Intervenors Re Contention 2.Certificate of Svc Encl.Related Correspondence ML20010G5131981-09-10010 September 1981 Supplemental Response to NRC Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20010G5111981-09-10010 September 1981 Response to Applicant Interrogatories & Requests for Document Production (Set 2) Directed to Joint Intervenors on Contention 1.Certificate of Svc Encl.Related Correspondence ML20010G5091981-09-10010 September 1981 Supplemental Response to Applicant Interrogatories & Requests for Document Production (Set 1) Directed to Joint Intervenors.Certificate of Svc Encl.Related Correspondence ML20005B9251981-09-0101 September 1981 Response to NRC First Set of Interrogatories Directed to Commonwealth of Ma.Certificate of Svc Encl.Related Correspondence ML20010B2771981-08-12012 August 1981 Second Set of Interrogatories Directed to Applicant Re Substandard Reinforced Concrete Const (Embedded Plates, Cracks in Concrete,Honeycombing,Concrete Cover) & Substandard Piping.Related Correspondence ML20010B3791981-08-12012 August 1981 Second Request for Production of Documents Directed to Applicant.Related Correspondence ML20010B1261981-08-10010 August 1981 Interrogatories & Requests for Document Production (Set 2) Directed to Joint Intervenors Re Contention 2.Related Correspondence ML20010B2811981-08-10010 August 1981 Interrogatories & Requests for Production of Documents (Set 2) Directed to Joint Intervenors on Contention 1.Certificate of Svc Encl.Related Correspondence ML20010B3561981-08-10010 August 1981 Second Set of Interrogatories Directed to Nrc.Certificate of Svc Encl.Related Correspondence ML20009C9121981-07-16016 July 1981 Response to Util Interrogatories & Request for Document Production (Set 1) Directed to Joint Intervenors on Contention 2.Certificate of Svc Encl ML20009C9101981-07-16016 July 1981 Response to NRC Interrogatories & Request for Production of Documents Directed to Joint Intervenors on Contention 2. Certificate of Svc Encl.Related Correspondence ML20009B3181981-07-10010 July 1981 Answers to Joint Intervenors' First Set of Interrogatories Directed to Util.Affidavit Encl.Related Correspondence ML20009B3091981-07-10010 July 1981 Response to Util Interrogatories & Request for Document Production (Set 1) Directed to Joint Intervenors on Contention 1.Certificate of Svc Encl.Related Correspondence ML20005A4221981-06-23023 June 1981 Objections to Joint Intervenors' First Set of Interrogatories.Interrogatories Are Overly Broad & Seek Info Which Is Irrelevant to Issues.Certificate of Svc Encl ML20005A4281981-06-22022 June 1981 Objections to Interrogatories & Request for Production of Documents.Only Names of Experts Expected to Testify at Trial & Those Retained or Specially Employed Are Discoverable. Certificate of Svc Encl.Related Correspondence ML20004D3791981-06-0404 June 1981 First Request for Production of Documents Re Embeds,Concrete Cracks,Honeycombing,Concrete Cover & Substandard Piping, Directed to Applicant ML19346A1761981-06-0303 June 1981 Request for Production of Documents Directed to Nrc.Related Correspondence ML19346A2111981-06-0303 June 1981 First Set of Interrogatories Directed to NRC Re Substd Reinforced Concrete.Related Correspondence ML20004D3801981-06-0202 June 1981 First Set of Interrogatories Directed to Util Re Std Reinforced Concrete Const,Embedded Plates,Concrete Cracks & Honeycombing.Certificate of Svc Encl.Related Correspondence ML20004D0881981-05-30030 May 1981 Response to Applicant 810526 Interrogatories & Requests Re Contention 1 on Ltrs of Agreement W/Local Agencies. Certificate of Svc Encl.Related Correspondence ML20004C5971981-05-26026 May 1981 Interrogatories & Requests for Document Production,Set 1,to Joint Intervenors on Contention 1 Re Embedded Plates, Concrete Cracks,Honeycombing,Concrete Coverage & Piping ML20004C6021981-05-26026 May 1981 Interrogatories & Requests for Document Production,Set 1 to Joint Intervenors on Contention 2 Re Radioactive Pollutants Released from Facility Into Mo River ML20004C6051981-05-26026 May 1981 Interrogatories & Requests for Production of Documents,Set 1,re Contentions 1-3 on Emergency Plans & Allocation of Responsibilities for Offsite Emergency Planning Between State & Local Organizations.Certificate of Svc Encl ML20008G2291981-05-0606 May 1981 Response to Intervenor J Reed Document Production Request. Current Draft of Facility Radiological Emergency Response Plan Encl.W/O Encl.W/Certificate of Svc ML19345G5721981-03-24024 March 1981 Request for Current Radiological Emergency Response Plan.To Wait for Final Plan to Be Formalized Would Impose Hardship on Intervenor.Plan Required to Determine If Plan Meshes W/ Surrounding Local Plans.Certificate of Svc Encl 1982-08-23
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212K8711999-09-30030 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Elimination of Requirements for Noncombustible Fire Barriers Penetration Seal Matls ULNRC-04117, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines 10CFR50.72 & 50.731999-09-22022 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines 10CFR50.72 & 50.73 ML20217M2091998-03-19019 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds Amended Requirements. NRC Justification for Avoiding Backfit Analysis,Nonstantial.Backfit Analysis,As Required by Law as Mandatory for Proposed Rule Changes ML20217J9691997-10-16016 October 1997 Order Approving Application Re Corporate Merger Agreement Between Union Electric Co & Cipsco,Inc to Form Holding Company.Commission Ordered to Approve Subj Application ML20148N0511997-06-19019 June 1997 Comment Opposing Proposed NRC Bulletin 96-001,Suppl 1, CR Insertion Problems ML20140G1691997-06-0606 June 1997 Requests Extension of Comment Period Expiration Date from 970619 to 970719,for Comments on Control Rod Insertion Problems ML20077E9041994-12-0202 December 1994 Comment Supporting Proposed Rule 10CFR50 Re TS Improvements. Advises That PSA Portion of Fourth Criterion Should Be Clarified to Include Only Those Equipment Items Important to risk-significant Sequences as Defined in GL 88-20,App 2 ML20071L1951994-07-21021 July 1994 Comment on Proposed Rule 10CFR26 Re Changes to fitness-for-duty Requirements.Urges NRC to Revise Scope of 10CFR26 to Limit Random Drug & Alcohol Testing to Only Workers Who Have Unescorted Access to Vital Areas at NPP ML20065D3851994-03-22022 March 1994 Comment on Draft NUREG-1022, Event Reporting Systems, 10CFR50.72 & 50.73 ML20113H4281992-07-23023 July 1992 Comment Commending Proposed Suppl One to GL 83-28 4.2.3 & 4.2.4 Closing All GL 83-28 Actions for Callaway But Staff Conclusion Should Be Expanded ML20101P4091992-06-26026 June 1992 Comment Supporting low-level Radwaste After Treatment to Reduce Volume & Represents Safest,Most Cost Effective Solution ML20091F9501991-12-0202 December 1991 Submits Comments Opposing Draft NUREG-1022, Event Reporting Sys,10CFR50.72 & 50.73. Licensee Feels That Changes to Intial NUREG-1022 Increases Util Expenses W/O Improving Public Health & Safety ML20058D2741990-10-15015 October 1990 Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20058N9891990-08-0101 August 1990 Comment Re Proposed Rules 10CFR20,30,40 & 70, Notifications of Incidents. Language of Rule Should Be Clarified by Referring to Applicable Reporting Requirements of 10CFR50.72 & 73 for Commercial Nuclear Power Reactors ML20063Q1771990-07-0606 July 1990 Comment on Petition for Rulemaking PRM-50-55 Re Revs to Fsar.Revs Should Be Driven by Circumstances Rather than by Arbitrary Time Schedule ML20235V9301989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint Programs for Nuclear Power Plants.Endorses NUMARC Comments.Major Concern Is Lack of Demonstrated Need for Rule Since Most Utils Already Have Effective Maint Programs ML20235T7901989-02-20020 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Establishment of Programs for Operators to Earn Degress Would Be Expensive ML20235T7011989-02-17017 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Which Require Degrees of Senior Operators & Shift Supervisors.Both Alternatives Would Contribute to Lower Morale Among Reactor Operators ML20195J3191988-11-25025 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Policy of Yearly Testing & Testing for Cause,Backed Up by Training for Drug Prevention Supported ML20195E8561988-10-28028 October 1988 Comment Supporting Proposed Rule 10CFR50 Re Renewal of Licenses ML20133B7711985-08-0202 August 1985 Response to 850705 Petitioner Response in Opposition to Util Request That Show Cause Order Not Be Issued.Util Actions Demonstrate Dedication to QA & Safe Plant Operation. Certificate of Svc Encl ML20128K2111985-07-0505 July 1985 Response Opposing Util Request That Show Cause Order Not Be Issued.Requests NRC Independent Investigation & Suspension or Revocation of OL During Period of Investigation ML20129H7511985-06-0606 June 1985 Response to Missouri Coalition for Environ & K Drey 850325 Show Cause Petition Requesting Suspension or Revocation of OL Due to Questionable QC Inspector Certification.Denial of Petition Recommended.Certificate of Svc Encl ML20129H7741985-06-0505 June 1985 Affidavit of DF Schnell Re Issues Raised in Missouri Coalition for Environ & K Drey Petition to Show Cause Requesting Suspension or Revocation of Ol.Root Causes of Questionable QC Certifications Addressed ML20100F4301985-03-25025 March 1985 Show Cause Petition Requesting Suspension or Revocation of License NPF-30,due to Failure to Comply W/Qa Regulations & Guidelines Re Proper Training of QA Personnel ML20092H1141984-06-22022 June 1984 Answer Opposing Petitioners 840613 Instant Motion for Order Setting Aside or Staying Permit for Ol.Certificate of Svc Encl ML20197H4321984-06-13013 June 1984 Motion for Commission Order Setting Aside Low Power Testing Permit Granted on 840611,or in Alternative,Stay to Permit & Prohibit Taking of Any Action.Certificate of Svc Encl ML20091R6401984-06-13013 June 1984 Request That Commission Enter Order Setting Aside Low Power Testing Permit Allegedly Granted on or About 840611,due to Joint Intervenors 840418 Motion for Leave to File Supplemental Contention ML20084G1791984-05-0303 May 1984 Affidavit of Cw Mueller Re Financial Integrity of Util ML20084G1561984-05-0303 May 1984 Answer Opposing Coalition for Environ,Missourians for Safe Energy & Crawdad Alliance 840418 Motion for Leave to File Supplemental Contention Re Financial Qualifications of Util. Certificate of Svc Encl ML20084G1731984-05-0202 May 1984 Affidavit of DF Schnell Re Financial Stability of Util ML20083Q3671984-04-18018 April 1984 Supplemental Contention Re Applicant Financial Qualification to Construct & Operate Facility.Certificate of Svc Encl ML20083Q3521984-04-18018 April 1984 Motion for Leave to File Supplemental Contention Re Financial Qualification of Applicant to Construct & Operate Facility.Certificate of Svc Encl ML20083Q2601984-04-18018 April 1984 Notice of Appearance of LC Green & Withdrawal of KM Chackes as Counsel for Intervenors.Certificate of Svc Encl ML20082B4641983-11-15015 November 1983 Comments on Applicant & NRC Responses to Aslab 831020 Memorandum & Order Re Safety of Manually Welded Embedded Plates.Appointment of Independent Expert Requested. Certificate of Svc Encl ML20082A6631983-11-15015 November 1983 Comments on NRC & Applicant Responses to Aslab 831020 Order Requesting Addl Info.Responses Contain Nothing More than Description of Activities & Conclusion of No Safety Significance.Certificate of Svc Encl ML20078P7131983-11-0404 November 1983 Response to Aslab 831020 Memorandum & Order for Addl Info on Observation 4-1 of Integrated Design Insp Program Rept Re Original Design Floor Response Spectra.Spectra Have No Safety Significance.Certificate of Svc Encl ML20078P7251983-11-0303 November 1983 Affidavit of Ew Thomas Re Revised Design Response Spectra ML20081C3031983-10-27027 October 1983 Reply to Reed 831006 Proposed Findings of Fact & Conclusions of Law Re Contention 6.Findings Mischaracterized Fda Recommendation & Position of Applicant & State of Mo. Certificate of Svc Encl ML20078H1751983-10-12012 October 1983 Response to Joint Intervenors 830823 Petition for Reconsideration of ASLB 830914 Decision ALAB-740. Insufficient Showing Made to Justify Reopening Record. Certificate of Svc Encl ML20080Q4471983-10-0606 October 1983 Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20080M6381983-09-29029 September 1983 Motion for Extension to File,W/Commission,Petition for Review of Aslab 830914 Decision ALAB-740.Extension Should Be Granted Until 15 Days After Aslab Rules on Joint Intervenors 830923 Reconsideration Petition.Certificate of Svc Encl ML20078B4981983-09-23023 September 1983 Petition for Reconsideration of 830914 Decision ALAB-740 in Light of New Evidence Re Adequacy of Applicant QA Program. Many Items Remain Open in Integrated Design Insp Program Rept.Certificate of Svc Encl ML20078B8151983-09-23023 September 1983 Proposed Findings of Fact & Conclusions of Law in Form of Proposed Initial Decision ML20078B8201983-09-23023 September 1983 Proposed Corrections to 830913 Evidentiary Hearing Transcript.Certificate of Svc Encl ML20024E8211983-08-31031 August 1983 Comments on Applicant Response to Aslab 830815 Order Re Failure to Provide Safe SA-312 Piping & Adequate QA Program.Certificate of Svc Encl ML20080C7121983-08-24024 August 1983 Testimony of Re Linnemann in Response to Reed Contentions 6 & 16 Re Protective Actions Against Radioiodines & Messages W/Instructions for long-term Sheltering.Related Correspondence ML20080C7061983-08-24024 August 1983 Testimony of DF Paddleford in Response to Reed Contentions 6 & 16 Re Protective Actions Against Radioiodines & Messages W/Instructions for long-term Sheltering.Related Correspondence ML20080C6991983-08-24024 August 1983 Testimony of Ng Slaten in Response to Reed Contentions 6 & 16 Re Protective Actions Against Radioiodines & Messages W/Instructions for long-term Sheltering.Related Correspondence ML20080C7141983-08-24024 August 1983 Testimony of Kv Miller in Response to Reed Contention 6 Re Protective Actions Against Radioiodines.State of Mo Decided Not to Administer Potassium Iodide to General Public Based on Federal Guidance & Weighing of Advantages/Disadvantages 1999-09-30
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UNITED STATES OF AMERICA C JUM 2]i.901 > I NUCLEAR REGULATORY COMMISSION '
omce cf tMs Sec. /.
BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD G "ESS Y,s c'/ /
N u. .a w In the Matter of ) gjj .'.QQ UNION ELECTRIC COMPANY Docket No. STN 50-48370$,[
(Callaway Plant, Unit 1) ,
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M JOINT INTERVENORS' OBJECTIONS TO_ %: Y, INTERROGATORIES AND REQUESTS FOR PRODUCTION 'e ,e 8, Joint Intervenors make the following objections to Applicant's O,j rib Interroga and Requests for Document Production (Set No.1) on both Contentons 1 and 2, and NRC Staff Interrogatories and Request for Production of Documents.
- 1. Joint Intervenors object to identifying persons known to us to have first l hand knowledge of the basis for our contentions and persons who participate in providing answers to interrogatories. Applicant and the NRC Staff seek not only to know who our witnesses will be at the hearings in this matter, but also the names of all persons with whom Joint Intervenors have consulted in framing our contentions and answering i interrogatories. See, e_.g., Applicant's Interrogatories on Contention No.1, I A-1, I A-6(c), General Interrogatory A; Applicant's Interrogatories on Contention No. 2, p. 2 Y (first paragraph), A-1(c); NRC Staff Interrogatories 1(h)(a) and (b),13. Joint Intervenors l
recognize the need of the Applicant and Staff to know who our witnesses will be and t[
we fully intend to supply that information in due course when that has been determined.
Ilowever, the Applicant and Staff can have no legitimate need to know the identity of other persons, not witnesses, who have assisted and are assisting Joint Intervenors in
! this matter. That information is not relevant, and to identify such persons will only expose them to possible reprisals for their activities in support of Joint Intervenors.
Joint Intervenors must, therefore, object to identifying such persons in order to protect them from adverse employment actions in their present and prospective positions, and other possible reprisals. DSO}
S 81063ooo ft f,/o 6
Under the Federal Rules of Civil Procedure, upon which the NRC's discovery rules are modelled, only the names of experts who are expected to testify at trial and those who have been retained or specially employed are discoverable. The identity of experts who have been consulted informally in anticipation of trial is not discoverable.
- 2. Joint Intervenors object to Applicant's request for identification and production of correspondence and written records of telephone conversations or meetings between Kay Drey and any employee of the NRC. See, e& Applicant's Interrogatories on Contention No.1, I A-16. The grounds for this objection are simply that Kay Drey is not a party to this proceeding and her correspondence and records are not in the custody and control of Joint Intervenors.
Respectfully submitted, CHACKES AND HOARE
'L-Kenneth M. Chackes Attorneys for Joint Intervenors 314 North Broadvay St. Louis, MO 63102 314/241-7961 i
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UNITED STATES OF AMERICA ~ ,
lq ~~' -- NI# {5 NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD $5"YI$I h In the Matter of )
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UNION ELECTRIC COMPANY ) Docket No. STN 50-483-OL
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(Callaway Plant, Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of Jcint Intervenors' Objections to Interrogatories and Requests for Production have been served on the following by deposit in the United States mail this X)- day of June,1981.
Jemes P. Gleason, Esq., Chairman Atomic Safety and Licensing Board 513 Gilmoure Drive Silver Spring, MD 20901 Mr. Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regtilatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline Atomic Safety and Lacensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Thomas A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C. 20036 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 u Roy P. Lessy, Jr., Esq.
!; Cffice of the Executive Legal Director j U.S. Nuclear Regulatory Commission Washington, D.C. 20555 M Wh Kenneth M. Chackes CIIACKES AND HOARE
.