ML20024B113
| ML20024B113 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/27/1983 |
| From: | Matthews B HARTSVILLE GROUP |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20024B114 | List: |
| References | |
| ISSUANCES-OLA, NUDOCS 8307050231 | |
| Download: ML20024B113 (8) | |
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board, JUll 301983 > j) c',\\
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In the Matter of
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CAROLINA POWER & LIGHT COMPANY)
Docket No. 50-261 OLA N
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(H.B. Robinson Steam Electric )
June 27, 1983 Plant, Unit 2)
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RESPONSES OF THE HARTSVILLE GROUP TO NRC STAFF INTERROGATORIES AND REQUESTS FOR DOCUMENTS The Hartsville Group hereby responds to the Interrogatories and Requests for Documents of the NRC Staff.
The Hartsville Group would note generally with respect to the requests for information and documents and the responses thereto that most of the information and material requested herein is in the possession of or under the control of either the Applicant or the Staff.
Hartsville recognizes and respects its obligation to make known to the other parties everything of which it has knowledge.
At this stage of the proceeding, however, little such information has been provided to the Intervenor.
Intervenor has undertaken to meet its obligations in this proceeding by serving detailed interrogatories and requests for production on both the Appli-l cant and the Staff.
No responses to those filings have been due and none have been received by The Hartsville Group.
l The Hartsville Group has endeavored to carry out its obli-gations in this matter.
However, those efforts have been l
hampered by difficulties with the Local Public Document Room.
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First, the hours of the LpDR are severely limited.
The Hartsville Memorial Library, site of the LPDR, is only open the following hours:
M-W-F 9 am - 6 pm T - Th 9 am - 9 pm Sat 10 am - 3 pm Sun 12 n.- 5 pm B.A. Matthews, Authorized Representative for The Hartsville Group, and Dr. John:Ruoff, who has been assisting The Hartsville Group, are both employed full-time.
Of necessity, work on this proceeding is done nights and weekends.
That is made almost impossible by the severely limited hours at the LPDR.
Moreover, the information available to The Hartsville Group in the LPDR is extremely limited.
The "O File," which contains most of the information relative to contentions 1(a) and 1(b),
only goes back through 1981.
Further, no library known to The Hartsville Group and open to the public contains either the most recent NUREG series or any significant portion of the NUREG/CR series.
We are doing our best with what is available to us.
1-1 a-d.
The Hartsville Group cannot provide the names of potential witnesses until discovery responses from Staff and the Applicants have been received.
1-2 See the response to 1-1.
1-3 The Hartsville Group does not have all of the material needed to respond to this question until discovery requests
have been answered by the Staff and the Applicant.
From the very limited materials available to it in the LPDR, The Hartsville Group will rely upon, but not limit itself to, the following:
1.
5/12/81, Stello to CP & L, EA-81-46 2.
4/14/81, O'Reilly to CP & L, re:
Inspection Report Nos. (IRN) : 50-324/81-07; 50-325/81-07; 50-261/81-11 3.
2/23/81, O'Reilly to CP & L, re: IRN 50-261/81-03 4.
3/10/81, Lewis to CP & L, re: IRN: 50-261/81-05 5.
1/13/81, Lewis to CP & L, re: IRN: 50-261/80-30 6.
7/22/81, Lewis to CP & L, re: IRN: 50-261/81-19 7.
6/10/81, Lewis to CP & L, re: IRN: 50-261/81-15 8.
5/11/81, Lewis to CP & L, re: IRN: 50-261/81-12 9.
5/12/81, Lewis to CP & L, re: IRN: 50-261/81-10 10.
12/1/81, DeYoung to CP & L, re: EA 82-07 11.
10/13/81, Lewis to CP & L, re: 50-261/81-27 12.
9/24/81, Lewis to CP & L, re: 50-261/81-26 13.
8/11/81, Lewis to CP & L, re: IRN: 50-261/81-20 14.
4/1/82, Cantrell to CP & L, re: IRN: 50-261/82-07 15.
3/30/82, Lewis to CP & L, re: IRN: 50-261/82-08 16.
3/16/82, Cantrell to CP & L, re: IRN: 50-261/82-04 17.
2/3/82, Lewis to CP & L, re: IRN: 50-261/81-36 18.
1/7/82, Lewis to CP & L, re: IRN: 50-261/81-35 19.
11/24/81, Lewis to CP & L, re: IRN: 50-261/81-31 20.
1/5/82, Utley to DeYoung, re:
EA 82-07 21, 6/24/82, O'Reilly to CP & L, re:
IRN 50-261/82-03 22.
6/9/82, Lewis to CP & L, re: IRN 50-261/82-16 23.
4/22/82, Long to CP & L, re: IRN 50-261/82-11 24.
8/27/82, Starkey to DeYoung, Re:
IRN 82-20 25.
10/25/82, Lewis (?) to CP & L, Re; IRN 50-261/82-35 26.
10/1/82,
?
to CP & L, re:
50-261/82-32 27.
9/22/82, Lewis to CP & L, re: IRN: 50-261/82-31 28.
10/22/82, Starkey to O'Reilly, re:
IRN 82-31 29.
9/8/82, Lewis to CP & L, re: IRN 50=251/82-27 30.
4/5/83, Lewis to Utley, re:
IRN 50-261/82-33 31.
5/12/81, Stello to CP & L, re: EA 81-46
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32, 4/14/81, O'Reilly to CP & L, re: Enforcement Meeting 33.
12/23/82, Lewis (?) to CP & L, re: IRN: 50-261/82-37 34.
1/7/83, Lewis to CP & L, re: IRN 50-261/82-41 35.
1/27/83, Lewis to CP & L, re:
IRN 50-261/82-33 36.
n.d., Utley to O'Reilly, re: IER 82-40 37.
11/1/82, Lewis to Utley, re: IRN 50-261/82-34 38.
12 / 29 ( ?) /82, O'Reilly to CP & L, re: IRN 50-261/82-43; 50-324/82-47; and 50-325/82-47 39.
11/2/82, Lewis to CP & L, re: IRN: 50-261/82-33 The Hartsville Group incorporates by reference each Inspection and Enforcement Report referenced in the above list and each Inspection and Enforcement Report upon which any EA listed above was taken.
The Hartsville Group further incorporates here the references cited in the body of Contentions 1(a) and 1(b).
Systematic Licensee Assessment Program, Licensee Assessments.
All other materials now known or thought to exist with regards to this contention, in both its parts, are believed to be in the possession of Applicants or Staff.
1-4 See response to 1-3.
1-5 Without the further documentation requested in its discovery requests of Applicants and Staff, The Hartsville Group lacks sufficient knowledge to answer this question.
1-6 The Hartsville Group, as explained above, lacks sufficient information at this stage of the proceedings to answer this interrogatory.
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As a general matter, however, The Hartsville Group maintains that any violation of NRC rules, regulations, requirements or procedures, including but not limited to violations of 10 CFR Part 50, App. B, go to the question of the character and competence of Carolina Power & Light Company to carry out the proposed steam generator repair in conformity with the requirements of the Atomic Energy Act.
2-1 through 2-5 Consistent with conversations with counsel for the NRC Staff indicating that Staff vould not respond to Interrogatories and Requests to Produce relating to Contention 2, The Hartsville Group will not respond to such Interrogatories or Requests for Documents either.
The contention is mooted by the Staff decision to conduct and Environmental Impact Statement.
3-1 At this point, The I:artsville Group has engaged no witnesses or consultants for Contention 3.
Hartsville is discussing such an engagement with the Energy Systems Research Group of Boston, MA.
Additional witnesses on this contention may be identified in the future, but have not been to date.
3-2 See the response to 3-1.
3-3 The Hartsville Group would note that it has requested
l i
to the information from both Staff and Applicants re at ng 4
issues raised in contention 3.
Information currently available to The Hartsville Group and upon which it will rely in presenting its case includes:
USNRC, Report to Congress on Abnormal Occurences, passim, 1.
but especially at July-September 1976, V. 1, No 4; V. 2, No. 3 ; V.
2, No. 4; V. 3, No. 1; V. 3, N. 2; i
Vol. 3, N. 4; V. 4, N.
1; V.
5, N. 2.
2.
USNRC, Steam Generator Status Report, Feb. 1982 3.
E.E. Utley to Harold Denton, Feb. 9, 1983, re: PTS 4.
S.A. Varga to E.E. Utley, Feb. 1, 1983,,re: PTS N.C. Utilities Commission, Public Staff, Analysis 5.
of Long Range Needs for Electric Generating Facilities in North Carolina, Public Staff Report 1983.
[Available from NC Public Staff, P.O. Box 991, Raleigh, NC 27602]
6.
Inside N.R.C., "NRC Staff Holds Off on Steam Generator Fixes as New Proble:hr Arise," July 12, 1982, pp. 6-7.
" Licensing Division Hands Utilities 7.
Package of Steam Generator Proposals," Aug. 23, 1982, pp. 10ff.
8.
O.S. Tatone and R.S. Pathania, " Steam Generator Tube Performance:
Experience with Water-Cooled Nuclear Power Reactors During 1980," Nuclear Safety, Jan-Feb 1983, pp. 75 ff.
9.
Nunzio J. Palladino to Hon. E.J. Markey, March 24, 1983, Staff Discussion of Points Raised in Rep. Markey's re:
10.
Ibid., March 21, 1983, re:
Response to Questions.
11.
USNRC, Staff Report by Division of Safety Technology, NRR, " Status of Recommendations Relating to Steam Generator Tube Rupture Events," Feb. 2, 1982.
12.
W.L. Server and H.W. Spaletta, " Evaluation of a Reactor Pressure Vessel Anneal Demonstration," Idaho National Engineering Laboratory, under DOE Grant No. DE-AC07-76IDO1570.
For USNRC.
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The Hartsville Group further incorporates by reference all studies, reports, etc. referenced in either the Supplement to its Petition to Intervene or the discussion during the Special Prehearing Conference.
3-4 See response to 3-3 above.
8-1 through 8-4 It is The Hartsville Group's contention that the information provided in the FSGRR is so woefully inadequate as a des-cription of the tomb for the steam generator assemblies that it cannot begin to address any matters related to those tombs without further information.
Extensive discovery questions have been propounded to the Applicants.
To date, we know no more than we are told in the FSGRR.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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CAROLINA POWER & LIGHT COMPANY)
Docket 50-261 OLA
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(H.B. Robinson Steam Electric )
June 27, 1983 Plant, Unit 2)
)
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AFFIDAVIT I, B.A. Matthews, do hereby affirm that I am the Autho-rized Representative of The Hartsville Group in this proceeding.
I have been responsible for answering the Interrogatories on all of The Hartsville Group's contentions.
Those responses are true and correct to the best of my knowledge and belief.
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Affirmed and subscribed to before me this M
- day of June 1982.
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NOTARY PUBLIC FOR SOUTH CAROLINA (L.S.)
My Commission Expires:
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