ML20063A445
| ML20063A445 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/17/1982 |
| From: | Eddleman W AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8208240341 | |
| Download: ML20063A445 (4) | |
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C-00f;KETED August 17, 1982 USHRC USA-URC Dockets 50-L'00 Q
Before the Atonic Safety & Licensing Board
$MO$6E20. A9 50 D
b 0FFICE OF 3ECRt W'Y
^
J Wells Eddlenan's responsed to " Applicants ' nosition DOCKEfm3 & SU:vtCE on service of documents to intervenors" of August 10 BRANCH h
p I can't take seriously CP&L's attennt not to serve copies
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.kp of the documents they originate.
All it does is waste time and create inconvenience.
NRC Staff has been coonerative in Q <4
'providing copies of what they originate, but their summaries like y
are so brief as to be substanceless, xxgr "we met CP&L and
@g talked about hydrology and feel their nositions are nostiv 10K".
letlW (A ghco4c pu) w9 telis snwaf eKr$fS, tM* 4A} 0V'shdk/ sh Sf hC.,
v6) A Cov4-f Even if Apulicants' claims of cooperation are taken at face
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value, it took an hour or so of talking to CP&L, and four weeks,
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$ to get copies of h anendments to their FSAR and ER.
(Copies of 1, V4 CP&Lis misleading cover letter, and my response which fills in 6 A _ ':s some of the more important omissions from it, are attached.)
4.
Such time delays are not conducivez to pronpt responses from A
y) intervenors, yet how can one respond to a document unless one v
(hasit?
CP&L's attempts to place anendments directly in the local M 38 public document rooms actually d to confusion uhen they do not tm i update the main FSAR or ER index, throw out the sheets showing s
what pages have been replaced (the "out and uitch" sheets) and white-8 out the marks showing where only a few words have been changed,
%Q L thus forcing one to read whole pages to see if CP&L's clain that C gsuch changes are uninportant is true (if so uninportant, why nake I
0 pppca# ytfeance 4b %scoby Wks" 6 Mf OW M g
$ ]2'"$0h (t(es -11ase kcumeh
- H& Mtast O %fL%?Nh W$ry 3p f
W.b Intervenors must serve CP&L with document's intervenors originate.
Lu
$yINRC Staff is serving all of us with what they originate.
I see no
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reason for CP&L not to do the sane, to avoid the above problems
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and in fairness to the other parties.
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8208240341 820817 f
DR ADOCK 05000 cf)O
s.
Carolina Power & Iight Com 'N
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POST OFFICE BOX 1551 g ASD 20 49:51 Raleigh, North Carolina 27602 OFFIc-LEGAL DEPARTMENT 00cghg{gyLgra;<s Wriur's Direct Dial Number (919)836 7707 BaANCH Telecopier (919) 836 7678 August 9, 1982 Mr. Wells Eddleman 718-A Iredell Street Durham, North Carolina 27705
Dear Mr. Eddleman:
At the special prehearing conference in the Shearon Harris operating license proceeding on July 13-14, 1982, you requested that CP&L furnish you with copies of Amendments 1, 2 and 3 to the Harris Final Safety Analysis Report (FSAR) and Amendmant 1 to the Harris Environmental Report (ER); and you offered to pay CP&L's cost of providing you with such documents.
CP&L has agreed to furnish you with copies of those documents at CP&L's cost.
l I advised you by telephone on August 6, 1982 that the cost to CP&L of providing you with the documents would be $270.00 and you requested me to send them to you.
Enclosed are copies of FSAR Amendments 1, 2 and 3 and;ER Amendment 1.
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Please make your check in the ainount of $270.00 payable to t
Carolina Power & Light Company and send it to my attention.
Sincerely,
/
00
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Tee rm e-<
m Samantha Francis Flynn Associate General Counsel SFF/dlt Enclosures
Tiumntha Frar:cis iicnn Associa.te General Counccl CP&L
Dear-'S5mantha Francis Flynn,
Enclos-ed is my. check for 3270.00 to Carolina Power E Light Co. for Sbearon Habris' FSAR amendmentis 1 through 3 and.ER ameridment'. l_
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Tour letter omits some aspects of this exchange that'I note here:
(1) On_ July 1h,1982 I had asked you to determine the costs-of FSAR Amendnents 1 thrcugh 3 and IR Amendments 1 through 3 I. did not give a " blank check" aErcement to nay any such costs, but rather asked you to deternine CP&L's costs and contact ne the next. week, which you said would be enough tine to find the
. cost informatien, you believed.
(2) Irr the week fellowing, you did contact me, and.eaid CP&L's cost of all 6 amendnents would be 42!t0.00 delivered, and that.. this; would. include.. the "put. and piteb? sheets that tell where' this-infornation goes in the PSAR. and ER.;. I asked if you had that broken down by cost for each amendment. You had that data in hand, and we discussed y getting only FSAR amendments 1 through 3 and n amendment' 1 fron C?&L, since I had been able to obtain ER anendmentss 2 and 3 elsewhere at a lower cost.
You were flexible and agreed to urovide FSAR amendments 1 through 3 and ER amendnent 1 at a cost of ^pl80.00 which you stated was CP&L's cost based 'on the infornation xx you had in hand. I asked you 'to send a bill for that annunt along with the informat" on, which was to be delivered by Unite.d 'a-cel Service.
'You had als o checked, at nw recuest, the cost to zerox (photo 9 copy) the-amendnents instead-of printing then. You renorted that that cost was higher, includin5 labor of "$7 an hour or whatever the neonle that do tha t make"..
Under those considerat'ons ue agreed en the price of $180.00 and delivery as stated abo.ve.. -
(3) On August 6, 1982 you.did telenhene me, and stated that
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due to errors in the information on cost from CP&L's other ceonle, the urice for FSAR amendments 1 through 3 and "R anendnent 1, including "nostaSe" (i.e. delivery charges) would be $270.00.
I was rather surorised, but agreed to pay that price.
.I no.te here that I have no idea wha.t it actually cost CP&L to "roduce this rr.terial.-
I have taken" your word for it.
I have aleo taken
.your word for the increase in cost and the error involved.
I recall your saying that labor charSes had been omitted from the $180.00 price.
(14) my notes on thct conversation do not natch your statenents in your phone call of August 9, but I do not think that is worth l
rehashing and make this note only so you do not think I have deliberately onitted this matter.
My objective has been to get this inf ormat'.on.
I now have it in hand and cresune it is conclete although I have not been able to inspect it in any detail.
That is because of g inability te lif t th $.n6s.
The tons of the amendments do show the "put and nitch" sheets and ther a*e bound l
as conolete sets.
/
p f
4
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UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION In the matter of CAROLI!'A P0'ilER & LIGHT CO. Et al. )
Dockets $0-h00 Shearon Harris Nuclear Power Plant, Units 1 and 2
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and 50lth01 0.L.
CERTIFICATE 0F SERVICE I hereby certify that copies of bM/6t+ tap f58&t5e g[/C
$e ser+ a of docamots A o%Ers" 00seh a on pat HAVE been served this f h day of
[t(4Dd 198h, by deposit in S
J y
h6d the US Mail, first-class postnge prepaid, upon all parties whose W6 names are listed below, except those whose names are parked with b
an asterisk, for whom service was acconnlished by k
S@4
\\ eW Judges James Kelley, Glenn B=ight and James Ca y nter (1 cony each) 6:PA)MAtomic Safety and Licensing Board Washington DC 20$$$ y Commission US Nuclear Regulator George F. Trowbridge (attorney for Anplicants)
Shaw, Pittman, Potts & Trowbridge 1800 M St. NW Washington, DC 20036 Office of the Executive Legal Director Phyllis Lotchin, Ph.D.
Attn Docke ts 50-400/401 Q?L.
108 Bridle Run Washingt~on DC-20555 NC 2751h USNRC Chanel Hill Dan Read Docketing and Service Section -nm CHAUGE/ELP Attn Dockets 50-400/401 0.L.
Box 524 Office of the Secretary Chapel Hill NC 2751h USNRC Washington DC x 20$$$
Pat & Slater Newman CANP John Runkle 2309 Weynouth Court CCNC Raleigh NC 27612 307 Granville Rd Chapel Hill Nc 27514 Travixs Payne Edelstein & Payne Ra e ITC 27605 g
Richard Wilson, M.D.
Certified by g#sezw 729 Hunter St.
Apex NC 27502
.