Response to ASLB 840810 Order Establishing 840820 as Date to Identify Witnesses & to Make Witnesses Available for Depositions within 2 Wks.Addl Time Requested.Certificate of Svc Encl| ML20095H333 |
| Person / Time |
|---|
| Site: |
Hope Creek  |
|---|
| Issue date: |
08/20/1984 |
|---|
| From: |
Remis S, Shapiro R
NEW JERSEY, STATE OF |
|---|
| To: |
|
|---|
| References |
|---|
| OL, NUDOCS 8408280447 |
| Download: ML20095H333 (4) |
|
|
|---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998
Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr
LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998
Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation
ML18106A8731998-09-15015 September 1998
Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki
ML18106A8811998-09-15015 September 1998
Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG
LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998
Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991
LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998
Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis
ML18102B4361997-07-0707 July 1997
Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst
ML20132A8961996-12-0606 December 1996
Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry
ML20084H9251995-06-0202 June 1995
Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs
ML20080G8321995-02-0606 February 1995
Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary
ML20077L8631995-01-0303 January 1995
Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities
ML20056G4121993-08-31031 August 1993
Comment Supporting Proposed Rule 10CFR2 Re Review of 2.206 Process
ML20126F2721992-12-21021 December 1992
Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys
ML20095B2411992-04-10010 April 1992
Comment on Draft NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us
ML20072T2421991-04-11011 April 1991
Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams
ML20246H8141989-07-0505 July 1989
Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components
ML20235T1861989-02-24024 February 1989
Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule
ML20195H0331988-11-21021 November 1988
Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing
ML20153F9681988-08-17017 August 1988
Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged
ML20247N7531988-07-28028 July 1988
Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons
ML20154G1421988-04-20020 April 1988
Comment Opposing Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization Program.Nrc Should Establish Program Mutually Agreed Upon Between Union & Util,Per Hope Creek & Salem Programs
ML20154G4601988-04-18018 April 1988
Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility
ML18093A6331988-02-0101 February 1988
Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods
ML20207H6521986-07-21021 July 1986
Transcript of Commission 860721 Discussion/Possible Vote on Full Power OL for Facility in Washington,Dc.Pp 1-76. Supporting Documentation Encl
ML20203D9661986-07-21021 July 1986
Corrected Page 5 to 860721 Transcript Re Facility
ML20107A5261985-02-19019 February 1985
Joint Motion for Leave to Withdraw as Party to Proceeding & Dismissal of Admitted Contentions.Draft Order Approving Both Requests,Settlement Agreement & Certificate of Svc Encl
ML20114A6911985-01-23023 January 1985
Response Opposing Intervenor,Public Advocate of State of Ny Notice of Deposition & Motion for Protective Order. Certificate of Svc Encl.Related Correspondence
ML20113H7211985-01-22022 January 1985
Response Opposing Applicant Motion for Sanctions Re Discovery.Certificate of Svc Encl.Related Correspondence
ML20114B7361985-01-21021 January 1985
Applicant Response to Intervenor Third Set of Interrogatories & Request for Production of Documents Re Pipe Cracks.Related Correspondence
ML20113H7321985-01-21021 January 1985
Second Supplemental Response to Preliminary & First Sets of Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence
ML20113H9441985-01-18018 January 1985
Notice of H Sonn 850130 Deposition in Trenton,Nj.Concurrent Depositions of Listed Applicant Employees Requested.Related Correspondence
ML20113H9671985-01-18018 January 1985
Fourth Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence
ML20113H8091985-01-17017 January 1985
Response to Applicant 850114 Objections to Intervenor 850104 Third Set of Interrogatories & Request for Production of Documents & Motion for Protective Order.Certificate of Svc Encl.Related Correspondence
ML20112J2841985-01-15015 January 1985
Second Set of Interrogatories Requesting Production of Documents Re Listed Definitions & Instructions to Public Advocate.Certificate of Svc Encl.Related Correspondence
ML20112G4171985-01-14014 January 1985
Applicant Objections to Intervenor 850107 Third Set of Interrogatories & Request for Production of Documents to Applicants & Motion for Protective Order.Certificate of Svc Encl.Related Correspondence
ML20112G3921985-01-14014 January 1985
Motion That ASLB Impose Sanction of Dismissal of Contentions Due to Intervenor Failure to Respond to ASLB 841121 Order to Show Cause Why OL Proceeding Should Not Be Dismissed. Related Correspondence
ML20112D8631985-01-10010 January 1985
Response Opposing Intervenor 850107 Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence
ML20112C0001985-01-0707 January 1985
Joint Motion for Issuance of Protective Order Re Personnel Info.Draft Protective Order,Unexecuted Affidavit & Certificate of Svc Encl.Related Correspondence
ML20112C9651985-01-0707 January 1985
Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor 841213 Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence
ML20101Q6111985-01-0404 January 1985
Third Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence
ML20101Q7911985-01-0404 January 1985
Intervenors Supplemental Response to Applicants Preliminary & First Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence
ML20101P9441984-12-31031 December 1984
Response to Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence
ML20101L1861984-12-28028 December 1984
Motion to Correct 841224 Record.Applicants Never Agreed to Discovery & Trial Preparation Schedule.Certificate of Svc Encl
ML20101M5731984-12-28028 December 1984
Response to Applicant Objections to Intervenor 841213 Second Set of Interrogatories & Request for Production.Document Request & Motion for Protective Order Should Be Denied. W/Certificate of Svc.Related Correspondence
ML20101E8381984-12-21021 December 1984
Objections to State of Nj Second Set of Interrogatories & Request for Production of Documents & Motion for Protective Order.Disclosure Will Constitute Unwarranted Invasion of Privacy.Related Correspondence
ML20101E7821984-12-21021 December 1984
Notice of Appearance in Proceeding.Certificate of Svc Encl
ML20101E8511984-12-20020 December 1984
Affidavit of RM Nelson Re Info Requested by State of Nj 841213 Second Set of Interrogatories & Request for Production of Documents.Personnel Files Maintained in Confidence.Related Correspondence
ML20101A1651984-12-13013 December 1984
Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence
ML20108E1161984-12-10010 December 1984
Response to ASLB 841121 Order Directing Public Advocate to Show Cause Re Dismissal of Contentions.State of Nj Safety & Environ Concerns Essential.Prehearing & Hearing Schedule Rerequested.Certificate of Svc Encl
ML20099E7201984-11-23023 November 1984
Notice of Appearance in Proceeding
1998-09-15
[Table view]
Category:OTHER LEGAL DOCUMENT
MONTHYEARML20113H9441985-01-18018 January 1985
Notice of H Sonn 850130 Deposition in Trenton,Nj.Concurrent Depositions of Listed Applicant Employees Requested.Related Correspondence
ML20101E7821984-12-21021 December 1984
Notice of Appearance in Proceeding.Certificate of Svc Encl
ML20099E7201984-11-23023 November 1984
Notice of Appearance in Proceeding
ML20095H3361984-08-23023 August 1984
Notice of Appearance in Proceeding
ML20095H3331984-08-20020 August 1984
Response to ASLB 840810 Order Establishing 840820 as Date to Identify Witnesses & to Make Witnesses Available for Depositions within 2 Wks.Addl Time Requested.Certificate of Svc Encl
ML20092P7711984-06-29029 June 1984
Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl
ML20080G1301984-02-0909 February 1984
Notice of Jh Rodriguez 840222 Deposition in Newark,Nj Re Contentions 1,2 & 3.Certificate of Svc Encl.Related Correspondence
ML20083J3971984-01-0303 January 1984
Certifies Svc of Applicant Preliminary Set of Initial Interrogatories & Request for Production of Documents to Public Advocate & State of DE on 840103
ML20080M1311983-09-29029 September 1983
Notice of Appearance in Proceeding.Certificate of Svc Encl
ML20040B7681982-01-14014 January 1982
Forwards Addl Matls Subsequent to 820106-08 Prehearing Conference,Including Minutes of 641021 Meeting W/Bnl,Acrs 710810 Summary of 136th Meeting on 710805-07 & Wa Lochstet Statement of Position
1985-01-18
[Table view] |
Text
,
-: m m- w %- m un
- s. . s, ;n . .
- -. , 4' ' :- - ,
. a c. 4 , , n t.
. ie .A. . w-. .m , . -
w - * '
a
,, 4 -
^
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board 34 js) 23 m:22 ,
- g. . (Ef?[
IN THE MATTER OF
'PUBLIC SERVICE ELECTRIC
'M $NE AND GAS CO. , 'et al. -
Docket No. 50-354-OL
, (Hope Creek Generating Station, 1
Unit 1{ :
INTERVENOR'S RESPONSE TO THE ATOMIC SAFETY AND LICENSING BOARD'S ORDER OF AUGUST 10, 1984 The Public Advocate is submitting the following information in response
_ . _ to the Atomic Safety and Licensing Board's August 10, 1984, order. In that order, the Board states:
. "The Public Advocate of New Jersey will be given to and including August 20, 1984, to identify its witnesses and to make them reasonably available for depositions within two weeks thereafter."
j$dc [ if In response to this'~ order, the Public Advocate has' made arrangements
~
', to use.the expert services of MHB Technical Associates loc'ated at 1723 C ' Hamilton Avenue,' Suite E, San Jose, California 95125. Spe'ifically, c the Public Advocate plans to hall as an expert witness Dale Bridenbaugliof MHB Technical Associates on the first contention regarding pipe cracks; p- :
e -_ . 9.:,3 w Dale Bridenbaugh and Richard Hubbard of MHB Technical Associates on
, the contention regarding management competence; and Richard Hubbard
.u and Gregory Minor-of MHB Technical Associates on the contention re--
s _f7.n s ,
,garding environmental qualifications. -
[ ~-
,'] ~ ~' y s
8408200447 840820 ' \
PDR ADOCK 05000354 C PDR
_ - - - . - - - - - - - - _ _ - - - - - . - - - _ - - - - - . - - - - - - - - - _ - - ------- - - - - - --- J
pp % G 7 %
w); ;
a$
% A..O.p e. . a v. $dAf.%".
. o c%ws
- - ->* ~ .c -.t;+ f-w +ta
?.
,u
. :c idz
+ ~.
,. ,, c.--
.% ?9 l
' ~
r se
. - %,. i \' ~
. . In addition, the Public Mvocate is presently in the process of obtaining a netallurgist to testify on the contention regarding pipe cracks. We have attempted to contact Professor Robert N. Anderson of San Jose State University, San Jose, Califo.nia , for these purposes, but he has .
- Pbeen unavailable to date. .In light, of his present unavailability, our Depahnt has not yet been able to .fimlive the arrangenents with Professor Anderson. Under these circt h.s, it is not possible to identfy him with certainty at this tims as a witness. However, as soon as the intervenor is' able to discuss the matter with Professor Anderson, we will notify the Board'and the parties of his status.
At this tine, the Public Advocate does not foresee the need for other expert witnesses in this proceeding. Ibwever, in the event that we are advised by our present expert witnesses that other testimony would assist
-the Board in assessing our contentions in a fair and appropriate manner, we will advise the Board, the' parties and the applicant of tha' identity.of these witnesses forthwith.
4
-With respect to the precise timing of the depositions of the inter-venor's witnesses, the Public Advocate respectfully requests that this
~' +- q. 3y 3 our petiti[on ,,. ~ .
~ '
~ Board corisider for additichal tine within~ which'to make '
' expert witnesses available for depositions, sttich is being filed '~
r .
. ~_e - .- ,
contemporaneously in this matter.
a , ;; ,
w Respectfully sutmitted, L u -. u; c. .i.-
Dated: August 20, 1984
~ y -
PUBLIC ADVOCATE
. STATE OF "W JERSEY
- w. ..
- m. ..
p-RICHARD E. SFAPIRO "
i 9 ;",t,. 7k s .e : D.txtdOR, DIVISION OF PUBLIC IhMCST ADVOCJCI n ...
., s SUSAN C. REMIS
_____ _______-R-______-__-_________JK%@@M T@WiS7 TW%W[G H@R&N6%
.m ,-
. --..~ . ~ . - - - -
n UNITED STATES OF AMERICA NUCLEAR REGULATORY CO3DIISSION n ,, g ..
~ Vstid" Before the Atomic Safety and Licensing Board
, , 84 ASO 23 M1:22 PUBLIC SERVICE ELECTRIC :
AND GAS COMPANY (HOPE Docket No.,503540L. CREEK '
GENERATING STATION) : Q'ghpH 'sEP t r SR;.EH 3..
CERTIFICATE OF SERVICE I hereby certify that copics of "Intervenor's Reiponse to the Atomic Safety and Licensing Board's Order of August 10,1984," dated August 20, 1984, in the abovecaptioned matter, have been served upon the following by deposit in the United States mail on this 20th day of August,1984:
Marshall E. Miller, Esquire Chairman Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Peter A. Morris
. Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DC 20555 Dr. David R. Schink
' Atomic Safety and Licensing Board i U. S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Panel
.- U. S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DC 20555 Docketing and Service Section Office of, the Secretary
. . a-U.S. ' Nuclear Regulatory Commission ,
_ Washington, DC 20555 A
4%
FJs,/iig :ys.g+ r,.. ;& y .
o k.'- ( = .
t f . ..
,~ : y . -
Lee Scott Dewey, Esquire Office of the Executive Legal Director U. S. Nuclear Regulatory Commission .
Washington, DC 20555 Richird Fryling, .Jr. , Esquire '
Associate General Counsel Public Service' Electric & Gas Company 2-P.. O." Box 570 *(TSE) '
Newark, NJ 07101 Troy'B. Conner,:Jr. , Esquire Conner & Wetterhahn 1747 Pennsylvania Avenue, N.W.
Washington, DC 20006 Carol Delaney, Esquire Deputy Attorney General Department of Justice State Office Building - 8th Floor 820 North French Street Wilmington, Delaware 19801 4
- v _,
4 b-__,,-a ~c~ %'.
~
,_ Susan C. Remis Assistant Deputy Public Advocate Dated: August 20, 1984 x . . .
., r. .
b -
9 Y
" 4+
.% .E
. .w-
, vet 7 ilDe + a+<3 %'*
l g _
i s
~
- T Q ;:.d . ^-- ' ~
,Q '4 s ,- - . 1,
1,