ML20072K061

Certification of Negotiations Re Efforts to Resolve Objections to Applicant 830131 Interrogatories

ML20072K061
Person / Time
Site:	Harris
Issue date:	03/21/1983
From:	Eddleman W EDDLEMAN, W.
To:
Shared Package
ML20072K057	List: ML20072K053 ML20072K061
References
ISSUANCES-OL, NUDOCS 8303300353
Download: ML20072K061 (2)

Text

B UNITED STATES OF AMER'ICA March 21, 1983 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of

) Dockets 50 400 OL CAROBINA POWER AND LIGHT CO. et al. ) 50-401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 and 2) )

)

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CERTIFICATION OF NEGOTIATIONS Vells Eddleman hereby affirms that he has made the following efforts to resolve objections to Apolicants' interrogatories dated 1-31-83, which are to be answered today under the Board's 3-10 Order:

1. I contacted Samantha Flynn, counsel for CP&L, and we have made arrangements for production of documents in 3 sets: ones I give CP&L a copy of to keep; ones I will .and to CP&L (ordinarily for 24 to h8 hourn, althoughI'mlet$1ngthemhave the first. set for a week);

and ones I will take more t$ne to produce a cony for'CP81 of, due to oE ES@ the need to prepare a copy from which my work product has been deleted.

88 no l Flynn voiced no objection to my deleting my work product from docunents.

U (conversation of 3-17-83 after about a week of try'nc to catch each other) j o i

Qg 2. I contacted John O'Neill, counsel for CP&L, ioneerning 88 oo ny objections to the genera? interrogatories. We acreed that neither 8 .

CP&L nor I will provide each other with conies of docunents from URC,

@@o mm but will instead identify the docunent and nages and identifier nunber which will enable the other party to order the docunent from NRC. _

Likewise, where I rely on a document originating from Annlicants, or they rely on a document originating from me, we agree to simply identify the document and pa,ges thereof sufficiently to find it. - We agree to consult informally whenever informetion suno11ed per the above identi-

.e 2-fication agreenent appears insufficient.

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3. I raised with O'Neill ny objection to oroviding the names of any persons who I may have consulted in answering interrogetories. .

On that, we reached an impasse. O'Neill believes Apolicants have an unconditional right to this information in order to possibly call such person (s) as witnesses. I continue to believe, as set forth obtain in ny cojections, that Apolicants have no unconditionr.1 right to such persons' identity, and that the conditions under uhich they night have such right are very narrowly linited by a showing (that the information and exoertise on the subject involved are not otherwise available to have not nade and .

them) which they probably cannot make. Therefore, I make the objections as stated in ny resuonse to Anulicants ' general interrogatories.

h. I agreed to consult with O'Neill on March 21 re any other in this set objections I may have to specific interrogatorie ; having only received t'he Board's 3-10-83 order on March 16, this is about as pronptly as I could resnond, since I was testifying the norning of March 17th in another case. Any such objections which are not resolved then will be noted in my resconses to Applicants' First Set of Interrogatories.

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