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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML18046A5731981-04-0909 April 1981 Response to NRC 810109 Third Set of Interrogatories Re Local Leak Test of Penetration 4.a,TP Neal Actions During Replacement & Testing of HEPA Filter in Penetration 4a. Certificate of Svc Encl ML18046A1801980-11-18018 November 1980 Third Round of Interrogatories Propounded to Nrc.Requests Info Re Items of Noncompliance,Imposition of Civil Penalties & Regulatory Authority.Certificate of Svc Encl ML18045A8041980-10-16016 October 1980 Response to NRC 800909 Second Round of Interrogatories & Requests for Production of Documents.Witnesses Not Yet Determined Due to Burden of Proof Falling on NRC Re All Issues Except Penalty.Documents & Certificate of Svc Encl ML18045A5411980-08-19019 August 1980 Second Round of Interrogatories Requesting Info on Criteria Used to Differentiate Between Single Incidents & Chains of Incidents,Continuing Violations,Witnesses & Bases of Item of Noncompliance.Certificate of Svc Encl ML18045A2821980-06-23023 June 1980 Response to NRC 800418 Interrogatories Re Civil Penalty Proceeding.Includes Info Re Sept 1979 Discovery of Two locked-open Manual Containment Isolation Valves & Associated Radiation Releases.Certificate of Svc & Documents Encl ML19322E1711980-02-21021 February 1980 First Round of Interrogatories & Request for Production of Documents Directed to Nrc.Requests Description of Basis Leading to Issuance of 791109 Notice of Violation & to Imposition of Civil Penalties 1981-04-09
[Table view] 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
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,1, 'If' e Nov IS'/ 19 s--o UNITED STA'J. -:.'::-; OF AMERICA NUCLL~:'\R REGUJ~_'\TORY COKMISSION BEFORE THE ADMINIS'rRli.TIVE LAW JUL:GE In the ~atter Of:
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(J"J CONSUMERS POWER COMPANY Docket No. 50-255 :::~ i~:*<
(?alisades Nuclear Power License No.. DPR-2 0 < ;:t;-r.,~
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--1 THIRD ROUND OF INTERROGATORIES TO BE ANSWERED ~ 0 z:
BY THE NUCLEAR REGULATORY COMMISSION ~
Consumers Power Compa_ny ("CPCo") hereby resuests
':.he Nuclear Reg:_:latory Cornmi~3sion ("NRC"), er the appropriate
~RC personnel, to answer separately and fully in writi~g, u 1der oc::th or 1
~1. :=: f irrna ti on, ec ch of the followins:; Interroga '.::o:c* -~,.:_~c::
within 30 days of service.
INSTRUCTIONS A~D DEFINITIONS Consumers incorporates by reference the instruct~~ns and definitions contained in "C~onsurner Power Company 1 s First Round of Interrogatories and Request for the Production of Documents by the Nuclear ReguL.ttory Commission", datcc~
Februar~* 21, 1980, as the ins~cuctions and definitio~s applicnble to the interr-:icjatoric~s set fc 1 :_ '_ h belov...
INTERROGATORIES
- 1. Identify each instance where the Director of Inspection and Enforcement (IE) determined that an NRC licensee committed an item of noncompliance, where the noncomplying condition continued for more than one day.
- 2. For each instanc~ identified in response to Interrogatory l above, state whether the Director of IE pro-
. posed the imposition of a civil penalty.
- 3. For each instance identified in response to Interrogatory 2 above, state whether the Director of IE pro-posed the imposition of a civil penalty for each day of non-compliance.
- 4. Identify each instance where the Director of IE proposed the imposition of a civil penalty for each day of a noncomplying condition whic~ continued for more than one day.
- 5. For each ~nstance identified irt response to Interrogatory 3 or 4 above, state the basis upon which the Di~ector proposed civil penalties for each day of the continuing noncompliance.
- 6. If the seriousness of the noncompliance was used, in whole or in part, as ~he basis for proposing civil penalties for each day of the continuing noncompliance iden-tified in response to Interrogatory 5( identify the factors or criteria considered by the Director in classifying the continuing noncompliance as serious in nature.
- 7. Identify the specific statutory and/or regulatory authority which confers the Director with the discretion to impose civil penalties for each day of a noncomplying con-dition on the basis that the Director has determined that the noncompliance is serious in nature.
- 8. Provide an explanation as to how the authority cited in response to Interrogatory 7 confers the Director with the discretion to impose civil penalties f6r continuing noncompliances which the Director determines are serious in nature.
DATED: November 18, 1980.
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" *.Alan P. '-BJ.elawskl'-
one of the Attorneys for Consumers PoweT Company 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 REGUL.:,TORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDG.E In the Matter Of:
CONSUMERS POWER COMPANY Docket No. 50-255 (Palisades Nuclear Power License No. DPR~20 Facility)
CERTIFICATE OF SERVICE I, Alan P. Bielawski,_ one of the attorneys for Consumers Power Company, certify that copies of "Consumers Powex Company's Third Round of Interrogatories To Be Answered By The Nuclear Regulatory Co:mmission" have been serveo in the above-captioned matter on the following by depositing same in United States mail~ postage prepaid, this 18th d~y of November, 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 ~egal Director Washington, D.C. 20555 Stephen G. Burns, Esq.
U.S. Nuclear Regulatory Commission Of £ice of Executive Legal Director Washington; D.C. 2055 . S
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 D.7.\TED: November 18, 1980. "/
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