Tennessee Valley Authority'S Submission of ExhibitsML022760126 |
Person / Time |
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Site: |
Browns Ferry, Watts Bar, Sequoyah |
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Issue date: |
09/30/2002 |
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From: |
Marquand B Tennessee Valley Authority, Winston & Strawn |
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To: |
Atomic Safety and Licensing Board Panel |
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Byrdsong A T |
References |
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+adjud/rulemjr200506, 50-259-CIVP, 50-260-CIVP, 50-296-CIVP, 50-327-CIVP, 50-328-CIVP, 50-390-CIVP, ASLBP 01-791-01-CIVP, EA-99-234, RAS 4891 |
Download: ML022760126 (4) |
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Category:Legal-Exhibit
MONTHYEARML15070A2992014-07-31031 July 2014 Official Exhibit - DTE000021-MA-CM01 - Excerpts from Draft NUREG-1437, Supplement 53, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 53 Regarding Sequoyah Nuclear Plant, Units 1 and 2 (ADAMS No. ML14 IR 05000327/20100042011-12-12012 December 2011 Official Exhibit - NYS000029-00-BD01 - NRC Integrated Inspection Report 05000327/2010004, 05000328/2010004, Sequoyah Nuclear Plant (Oct. 29, 2010) (Sequoyah IR) ML1110911672011-04-19019 April 2011 Declaration of Dr Arjun Makhijani in Support of Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Daiichi Nuclear Power Station Acc ML0924608012009-09-0303 September 2009 Petitioner'S Amended Contention 7 Regarding TVA Aquatic Study ML0329404722003-04-17017 April 2003 TVA - Joint Exhibit 66 - Rec'D 09/13/02: April 17, 2002, Joint Stipulation Between TVA and Staff ML0310000092003-03-0404 March 2003 Joint Exhibit List (TVA Exhibits), Volumes 1 - 6 ML0310000102003-03-0303 March 2003 Tennessee Valley Authority'S Exhibit List, Volumes 1 - 11 ML0229801002002-10-18018 October 2002 Tennessee Valley Authority'S Response in Support of the Admission of TVA Exhibit No. 75 ML0227601262002-09-30030 September 2002 Tennessee Valley Authority'S Submission of Exhibits ML0226601012002-09-20020 September 2002 TVA - NRC Staff Redacted Documents ML0329501412002-09-12012 September 2002 TVA - Licensee Exhibit 94 - Rec'D 09/12/02: Corporate Nuclear Employees' 1996 Surplus Notices (Redacted) ML0307801352002-09-12012 September 2002 TVA - Licensee Exhibit 149 - Rec'D 09/12/02: Vacancy Announcement 66-21 ML0307101442002-09-12012 September 2002 TVA - Licensee Exhibit 86 - Rec'D 09/12/02: Watts BAR Nuclear Plant, Fy 1997 Workforce Planning Documents and Employees' 1997 Retention Registers (Redacted and Substituted) ML0307101022002-09-12012 September 2002 TVA - Licensee Exhibit 95 - Rec'D 09/12/02: Corporate Nuclear Employees' 1996 Retention Registers (Redacted and Substituted) ML0309700782002-09-11011 September 2002 TVA - Staff Exhibit 147 - Rec'D 09/11/02: DOL Brief in Support of Respondents Motion for Summary Decision ML0307801202002-09-11011 September 2002 TVA - Licensee Exhibit 144 - Rec'D 09/11/02: Resume of Heyward R. Rogers ML0307801152002-09-11011 September 2002 TVA - Licensee Exhibit 142 - Rec'D 09/11/02: Resume of H. Keith Fogleman ML0308501032002-09-10010 September 2002 TVA - Licensee Exhibit 148 - Rec'D 09/10/02: Cd Recording of a December 9, 1992 Conversation Between Gary L. Fiser and Robert J. Beecken ML0307801102002-09-10010 September 2002 TVA - Licensee Exhibit 141 - Rec'D 09/10/02: Resume of SAM L. Harvey ML0307801032002-09-10010 September 2002 TVA - Licensee Exhibit 140 - Rec'D 09/10/02: Resume of David F. Goetcheus ML0306500122002-09-10010 September 2002 TVA - Licensee Exhibit 14 - Rec'D 09/10/02: June 17, 1996, SAM Harvey Franklin Planner Note ML0307801002002-09-0909 September 2002 TVA - Licensee Exhibit 139 - Rec'D 09/09/02: Resume of Mark J. Burzynski ML0307800982002-09-0909 September 2002 TVA - Licensee Exhibit 138 - Rec'D 09/09/02: Resume of Robert J. Beecken ML0225501012002-09-0606 September 2002 Tennessee Valley Authority (TVA) - NRC Staff Supplemental Document List ML0224002582002-08-22022 August 2002 Tennessee Valley Authority'S Fifth Supplemental Exhibit List ML0309700412002-07-13013 July 2002 TVA - Staff Exhibit 128 - Rec'D 09/13/02: TVA Nuclear Corporate 1996 Reorganization Impact on Headcount ML0307800452002-06-18018 June 2002 TVA - Licensee Exhibit 133 - Rec'D 06/18/02: Organizational Chart, August 1996, Chemistry Program Manager (Pwr), Chemistry Program Manager (BWR) ML0309700362002-06-17017 June 2002 TVA - Staff Exhibit 124 - Rec'D 06/17/02: Vacant Position Announcement for Manager, Radiological Control, Closing Date August 31, 1994 ML0309006902002-06-17017 June 2002 TVA - Staff Exhibit 53 - Rec'D 06/17/02: NRC OI Interview of Ronald O. Grover, December 18, 1998 ML0309004132002-06-17017 June 2002 TVA - Staff Exhibit 49 - Rec'D 06/17/02: TVA Oig Record of Interview of Ronald O. Grover, July 11, 1996 ML0306500152002-06-13013 June 2002 TVA - Licensee Exhibit 12 - Rec'D 06/13/02: January 11, 1994, Investigation Insert (Oig File No. 20-135) (Ee 75, 79-82) ML0307800412002-06-12012 June 2002 TVA - Licensee Exhibit 132 - Rec'D 06/12/02: Chart Entitled Decision 'To Post' or 'Not to Post' ML0307802342002-05-0707 May 2002 TVA - Joint Exhibit 55 - Rec'D 05/07/02: September 25, 1996 Landers TVA Oig Record of Interview ML0307802032002-05-0202 May 2002 TVA - Joint Exhibit 45 - Rec'D 05/02/02: September 20, 1999 Notice of Apparent Violation to Mcarthur ML0309102222002-05-0101 May 2002 TVA - Licensee Exhibit 24 - Rec'D 05/01/02: Selection Package for Vpa No. 6621 (Hh 1-198) ML0307900182002-04-30030 April 2002 TVA - Joint Exhibit 27 - Rec'D 04/30/02: Fiser Sequence of Events ML0309707202002-04-30030 April 2002 TVA - Staff Exhibit 168 - Rec'D 04/30/02: Compact Disc Recording of Gary L. Fiser (Tape a, Side A/Section II) ML0309707332002-04-30030 April 2002 TVA - Staff Exhibit 169 - Rec'D 04/30/02: Compact Disc Recording of Gary L. Fiser (Tape I, Side A/Sec II, III, IV) ML0307800042002-04-30030 April 2002 TVA - Licensee Exhibit 112 - Rec'D 04/30/02: Tva'S Memorandum on the Admissibility of Depositions ML0329501492002-04-25025 April 2002 TVA - Licensee Exhibit 73 - Rec'D 04/25/02: Significant Corrective Action Report (Scar) No. SQSCA920004 (Cg 1-82) ML0309702652002-04-25025 April 2002 TVA - Staff Exhibit 130 - Rec'D 04/25/02: Organizational Chart for Nuclear Operations, Operations Support, Radiology and Chemistry Control, February 13, 1995 ML0309201322002-04-25025 April 2002 TVA - Staff Exhibit 99 - Rec'D 04/25/02: Employee Action Reasons for Wilson C. Mcarthur ML0307103452002-04-25025 April 2002 TVA - Licensee Exhibit 62 - Rec'D 04/25/02: Operations Support'S Organizational Overview (Bi 1-229), Chapters 1 - 7 ML0307103422002-04-25025 April 2002 TVA - Licensee Exhibit 62 - Rec'D 04/25/02: Operations Support'S Organizational Overview (Bi 1-229), Agenda - Operations Support Business Plan for Fiscal Year 1997 ML0306500732002-04-24024 April 2002 TVA - Licensee Exhibit 48 - Rec'D 04/24/02: January 20, 1994, Investigative Insert (Oig File No. 2D-135 (Aj 297-33 ML0330101752002-04-17017 April 2002 TVA - Joint Exhibit 67 - Rec'D 09/13/02: April 23, 2002, Joint Stipulation Between TVA and Staff ML0309700772002-04-0404 April 2002 TVA - Staff Exhibit 162 - Rec'D 06/19/02: Declaration of G. Donald Hickman, April 4, 2002 ML0306501202002-03-22022 March 2002 TVA - Licensee Exhibit 61 - Rec'D 09/12/02: 1996 Vacancy Posting System Intent ML0217705702002-02-20020 February 2002 Position Description for Radiological and Chemistry Control Manager ML0217603452002-02-20020 February 2002 Department of Labor Brief in Support of Respondent'S Motion for Summary Decision 2014-07-31
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I r- s If,4 49W DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION October 1, 2002 (3:48PM)
ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF IN THE MATTER OF ) Docket Nos. 50-390-CivP;
) 50-327-CivP; 50-328-CivP; TENNESSEE VALLEY AUTHORITY ) 50-259-CivP; 50-260-CivP;
) 50-296-CivP
)
(Watts Bar Nuclear Plant, Unit 1; ) ASLBP No. 01-791-01-CivP Sequoyah Nuclear Plant, Units 1 & 2; )
Browns Ferry Nuclear Plant, ) EA 99-234 Units 1, 2 & 3) )
TENNESSEE VALLEY AUTHORITY'S SUBMISSION OF EXHIBITS Pursuant to the request of the Atomic Safety and Licensing Board (Board), Tennessee Valley Authority (TVA) has redacted TVA Exhibit Nos. 24, 39, 55, 56, 93, 94, 149, and Joint Exhibit Nos. 22 and 23. TVA is submitting the three official record copies to Judge Bechhoefer. Copies are also being sent to Judge Bechhoefer and Judge Young. The NRC Staff and Judge Cole indicated that they did not want a redacted copy.
In addition, pursuant to the Board's ruling, TVA has prepared summaries of TVA Exhibit Nos. 83-96, 109, and 110. TVA is submitting to Judge Bechhoefer the three official record copies of the summaries for inclusion in the record in the place of the business records which were originally offered into evidence during the hearing. Copies are also being sent to Judge Bechhoefer, Judge Young, Judge Cole, and the NRC Staff.
Finally, TVA tenders herewith into evidence TVA Exhibit 75, an extract from the Institute of Nuclear Power Operation's (INPO) written evaluation of TVA's Sequoyah Nuclear 1
T-empjal-- ;ecy-05'
-t Plant performed during the weeks of September 28 and October 5, 1992. On September 9, 2002, Robert J. Beecken, the former Sequoyah plant manager testified that he became critical of Fiser's management skills, in part, due to findings by INPO (See transcript page 4799, line 14; page 4800, line 3; page 4821, line 11; page 4822, line 2). During Mr. Beecken's cross-examination, counsel for NRC Staff asked questions which implied that INPO had not made any findings regarding the Chemistry program at Sequoyah (See Transcript page 4825, line 9; page 4828, line 20). TVA Exhibit 75 corrects any false impression that counsel's questions may have created since it shows that INPO in fact made the three findings discussed in the December 9, 1992, tape-recorded conversation Fiser had with Mr. Beecken (See Joint Exhibit 27 at 50-58; and TVA Exhibit 148). TVA is submitting herewith to Judge Bechhoefer 2
the three official record copies of TVA Exhibit 75. Copies are also being sent to Judge Bechhoefer, Judge Young, Judge Cole, and the NRC Staff.
Respectfully submitted, September 30, 2002 Maureen H. Dunn General Counsel Office of the General Counsel Tennessee Valley Authority Thomas F. Fine 400 West Summit Hill Drive Assistant General Counsel Knoxville, Tennessee 37902-1401 Facsimile 865-632-6718 John E. Slater Senior Litigation Attorney Brent R. Marquand Senior Litigation Attorn Telephone 865-632-4251 Of Counsel:
David A. Repka, Esq. Attorneys for Tennessee Valley Authority Winston & Strawn 1400 L Street, NW Washington, D.C. 20005 3
II CERTIFICATE OF SERVICE I hereby certify ihat copies of TVA's submission of exhibits has been served on the following persons by Overnight Messenger.
Administrative Judge Administrative Judge Charles Bechhoefer, Chairman Richard F. Cole U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Two White Flint North Two White Flint North 11545 Rockville Pike 11545 Rockville Pike Rockville, Maryland 20852-2738 Rockville, Maryland 20852-2738 e-mail address: cxb2@nrc.gov e-mail address: rfcl~nrc.gov Administrative Judge Dennis C. Dambly, Esq.
Ann Marshall Young Jennifer M. Euchner, Esq.
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Office of the General Counsel Two White Flint North One White Flint North 11545 Rockville Pike 11555 Rockville Pike Rockville, Maryland 20852-2738 Rockville, Maryland 20852-2738 e-mail address: amy~nrc.gov e-mail address: dcd~nrc.gov e-mail address: jme~nrc.gov Office of Commission Appellate Adjudication (w/o exhibits) Mr. William D. Travers (w/o exhibits)
U.S. Nuclear Regulatory Commission Executive Director of Operations One White Flint North U.S. Nuclear Regulatory Commission 11555 Rockville Pike One White Flint North Rockville, Maryland 20852-2738 11555 Rockville Pike Rockville, Maryland 20852-2738 This 30th day of September, 2002.
Attorney for Tennessee Val y Authority 4