ML20077J076
| ML20077J076 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/08/1983 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20077J062 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8308120229 | |
| Download: ML20077J076 (2) | |
Text
{{#Wiki_filter:~ l ,2 l OCLMET!s ' U%E UNITED STATES OF AMERICA ES D NUCLEAR BEGULATORY COMMISSION e CFFILi CF 'E ut - 00CKE-TING & 5b' A',; BEFORE THE ATOMIC SAFETY AND LICENSING BOARD BRM Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of J Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50-401 OL (Shearon Harris Nuclear Power Plant, ) Units 1 and 2) ) ) Certificate' of Negotiations concerning Auplicants' 5-27-83 resnonse/ objections to Interrogatories on Eddleman 60Fand 67 including Interrogs G8 & G9,
- Please note: Applicants have agreed that interrogatories G8 and G9 in certain other sets of.Eddleman interrogatories can be decided on the basis of the filing-here.
Tineliness objections to the use of these arguments with respect 'to other contentions are not to follow from a timeliness objection to this (attached) motion to compel. Each timeliness objection has to stand on its own and I have not agreed to annly timeliness objections diat may be made on this set of interrogatories to any others, or to the issue of anpropriateness of interrogatories G8 of G9 for any other' set of interrogatories. The G8 and G9 discussed in the attached motion are thos e of hw22-83.by ne. Applicants' resnon.ce was served May 27, 1983 On June 1, 1983, Applicants ' counsel O'Neill and I began negotiations on the answers and objections. I ao notified the Board by card (per 3/10/83 order and oral order 6f Judge Kelley. ) 8308120229 830805 PDR ADOCK 05000400 0 PDR
l - It was my understanding then that Annlicants would supplement their resnonses to certain interrogatories and clarify others; however, I cannot locate any such supplement /resnonse, except as noted: The interrogatories to get supnlemental responses were 64-1(a), 64-2(a),(b), (c)(supplement received, letters from CnP&L and GE to NRC re withdrawal of IF-300 cask from wet shipment service), 6h-3(c)(as to method of calculation), 6h-h(c)(reference only received) (e) (oral supplement that answer to 1(a) has not been changed); 64-6(d)(e)(f)(g)(h)(Applicants have not resnonded in writing ut the oral answer is they don't know the answer to any of these) 64-9(e)tno firn connitnent to supplement; 67-h(a )(1) and (ii) to answer those questions snecifically (there was just one answer for (a)); (b) and (d), CP&L did not want to s unply the don.uments but was going to answer in that fashion. In addition we agreed that 64-7(a) was nhrased wrongly and would have to be re-asked in a later set. It is my understanding (I have notes to this effect) that we also agreed to continue negotiating until (1) these updates were sunn11ed and (2) I got time to look up the legal references in the objections to G8 and G9, which I did not accent. (Applicants' counsel later informed me he did not recall this and did not now agree to it -- I'll let them address that.) In a ddition to discussions of information in intornal settlement negotiations (which I do not recall dianging any of the above), I discussed the G8 and G9 matter with O'Neill first on 7-27 and then in more detail on 7-29-83 We were unable to reach agreement on those or any other objectiens (e.g. to 67-2 and3 which were discussed on June 1). Except as noted above, we cane t to no agreements throughout this series of discussions. The attached motion to compel is therefore due August 8. fj 4 #'* l I affirm the above is true to the best of my knowledge & belief.3 =}}