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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] Category:PLEADINGS
MONTHYEARML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20205A9201999-03-26026 March 1999 Motion for Approval of Protective Order.* Orange County,With Support of CP&L & Nrc,Requests Board Approval of Encl Protective Order.With Certificate of Svc ML20204E5341999-03-17017 March 1999 Orange County Second Motion for Extension of Time to File Proposed Protective Order.* Licensing Board Granted Motion to Extend Deadline for Filing Proposed Protective Order Until 990304.With Certificate of Svc ML20207L4041999-03-16016 March 1999 NRC Staff Answer to Orange County Motion to Relocate Prehearing Conference.* NRC Has No Objections to Relocating Prehearing Conference,Time or Place.With Certificate of Svc ML20204C9721999-03-15015 March 1999 Applicant Response to Bcoc Motion to Relocate Prehearing Conference.* Applicant Requests That Prehearing Conference Be Held in Hillsborough,Nc.Location Available to Hold Prehearing Conference on 990513.With Certificate of Svc ML20207K1391999-03-0909 March 1999 Orange County Motion to Relocate Prehearing Conference.* Requests Licensing Board Relocate Prehearing Conference Scheduled for 990511 to Site in Area of Shearon Harris Npp. with Certificate of Svc ML20127M4091992-10-0202 October 1992 CP&L Response to Appeal to NRC Commissioners of NRC Staff Denial of Nirs Petitions for Immediate Enforcement Action of 920721 & 0812.* Commission Should Affirm NRR Denial of Nirs Petitions.Certificate of Svc Encl ML20213A0091987-01-28028 January 1987 NRC Staff Response to Intervenor Application for Stay of ALAB-856.* Motion Should Be Denied Since Coalition for Alternatives to Shearon Harris Lacks Standing to File Motion & 10CFR2.788 Criteria Not Met.Certificate of Svc Encl ML20212R6431987-01-27027 January 1987 NRC Staff Motion for Extension of Time.* Motion for Extension Until 870128 to File Response to Intervenors Motion for Stay of ALAB-856.Certificate of Svc Encl ML20212R6861987-01-27027 January 1987 Licensees Answer to Conservation Council of North Carolina/ Eddleman Motion for Stay.* Motion Should Be Summarily Denied.Certificate of Svc Encl ML20209A7191987-01-27027 January 1987 NRC Staff Motion for Extension of Time.* One Day Extension of Time Until 870128 to File Response to Intervenors Motion for Stay of ALAB-856 Requested.Granted for ASLB on 870128.W/ Certificate of Svc ML20207N6051987-01-10010 January 1987 Conservation Council of North Carolina,Wells Eddleman,Pro Se & Coalition for Alternatives to Shearon Harris Motion to Stay Effectiveness of Licensing of Shearon Harris Nuclear Power Plant.* W/Certificate of Svc ML20207M0191987-01-0808 January 1987 Motion to Continue Commission decision-making Re Licensing of Shearon Harris Nuclear Power Plant.* Requests NRC Refrain from Issuing Full Power OL Until Criteria Assuring Safe Operation Met.Certificate of Svc Encl ML20214A5171986-11-17017 November 1986 Response Opposing State of Nc Atty General 861028 Motion Re Applicant Request for Exemption from Portion of 10CFR50, App E & Part IV.F.1.Certificate of Svc Encl ML20197C8511986-11-0303 November 1986 Response to Atty General of State of Nc 861028 Motion to Dismiss,As Moot,Util 860304 Request for Exemption from 10CFR50,App E Requirement for Full Participation Exercise 1 Yr Prior to Full Power License.W/Certificate of Svc ML20215M2281986-10-28028 October 1986 Motion for Inquiry Into Feasibility of Applicant 860304 Request for Exemption from Requirement That full-scale Emergency Preparedness Exercise Be Conducted within 1 Yr Prior to Issuance of Ol.Certificate of Svc Encl ML20215G7061986-10-17017 October 1986 Response Opposing W Eddleman & Coalition for Alternatives to Shearon Harris 861006 Brief Requesting Hearing on Util Request for Exemption from Performing full-scale Emergency Exercise,Per Commission 860912 Order.W/Certificate of Svc ML20215J6121986-10-17017 October 1986 W Eddlemen & Coalition for Alternatives to Shearon Harris Petition,Per 10CFR2.206 to Revoke,Suspend or Modify Cp. Certificate of Svc Encl ML20203N9191986-10-14014 October 1986 Response Opposing Coalition for Alternatives to Shearon Harris/Eddleman 860731 Request for Hearing on Util Request for Exemption from Requirement to Conduct Full Participation Exercise.Certificate of Svc Encl ML20210V1571986-10-0606 October 1986 Answer in Opposition to Coalition for Alternatives to Shearon Harris,W Eddleman & Conservation Council of North Carolina 860915 Motion to Reopen Record.Related Info & Certificate of Svc Encl ML20210S9871986-10-0606 October 1986 Brief Opposing Applicant 860304 & 0710 Requests for Exemption from 10CFR50,App E Requirement to Conduct Full Participation Exercise of Emergency Mgt Plan within 1 Yr Prior to Operation.W/Certification of Svc ML20214S0831986-09-25025 September 1986 Applicant Answer Opposing 860915 Coalition for Alternatives to Shearon Harris (Cash) Motion to Reopen Record.Motion Opposed Since Cash Not Party in OL Proceeding.Certificate of Svc Encl ML20214R0531986-09-24024 September 1986 Response Opposing Eddleman/Coalition for Alternatives to Shearon Harris 860919 Request for Extension of Time to Respond to Commission 860912 Order.W/Certificate of Svc ML20214R3681986-09-23023 September 1986 Response Opposing Coalition for Alternatives to Shearon Harris/Eddleman Request for 2-wk Extension to Respond to Commission 860912 Order Re Exemption from Requirements of 10CFR50,App E.W/Certificate of Svc ML20214Q9531986-09-19019 September 1986 Requests Extension of Time Until 2 Wks from 860929 Deadline to Respond to 860912 Order Requiring Analysis of 10CFR50.12 Specific Exemptions ML20210D9001986-09-15015 September 1986 Motion to Reopen Record,Per 10CFR2.734,asserting That Commission Unable to Determine Reasonableness of Assurance That Plant Can Operate W/O Endangering Public Health & Safety.Certificate of Svc & Insp Rept 50-400/85-48 Encl ML20203M0021986-08-28028 August 1986 Response Opposing Coalition for Alternatives to Shearon Harris/Eddleman 860731 Joint Petition for Hearing on Exemption Request Re Full Participation Emergency Preparedness Exercise.W/Certificate of Svc ML18004A4681986-08-15015 August 1986 Response to Coalition for Alternatives to Shearon Harris 860702 Show Cause Petition Re Emergency Planning Requirements,Filed Per 10CFR2.206.Petition Should Be Denied Due to Lack of Basis for Action.Certificate of Svc Encl ML20205F3591986-08-15015 August 1986 Response to Coalition for Alternatives to Shearon Harris 860702 2.206 Petition to Show Cause Re Emergency Planning Requirements,P Miriello Allegations & Welding Insps.Show Cause Order Unwarranted.W/Certificate of Svc ML20205F4131986-08-14014 August 1986 Answer Opposing Intervenor 860730 Petition for Review of Aslab 860711 Memorandum & Order Denying Two Requests for Relief.Petition Lacks Important Procedural Issue.Certificate of Svc Encl ML20205F2251986-08-14014 August 1986 Answer Opposing Coalition for Alternatives to Shearon Harris & W Eddleman 860730 Petition for Commission Review Per 10CFR2.786.W/Certificate of Svc ML20203K1511986-07-30030 July 1986 Petition for Commission Review of Aslab 860711 Memorandum & Order Denying Coalition for Alternative to Shearon Harris 860609 Petition to Intervene.Certificate of Svc & Svc List Encl ML20212A6071986-07-25025 July 1986 Response to ASLAP 860708 Order Requiring Licensee to Update Re Emergency Plan.Chatham County Resolution Does Not Resolve Issues Re Adequacy of Plan.Resolution False. Certificate of Svc Encl ML20207J8281986-07-24024 July 1986 Response Opposing W Eddleman 860403 Request for Hearing on Util Request for Exemption from Emergency Preparedness Exercise Requirement.W/Certificate of Svc ML20211Q5221986-07-23023 July 1986 Answer Opposing Coalition for Alternatives to Shearon Harris 860721 Motion for 10-day Extension to File Brief Supporting 860721 Notice of Appeal & Request for Review of Aslab 860711 Memorandum & Order.W/Certificate of Svc ML20207E4231986-07-18018 July 1986 Response to Aslab 860708 Order to File Update to Re Chatham County,Nc Rescission of Prior Approval of Emergency Response Plan.Chatham County Endorsed Plan on 860707.W/Certificate of Svc ML20199L1671986-07-0808 July 1986 Suppl to 860624 Response to Conservation Council of North Carolina & Eddleman Request to Continue Stay Indefinitely.On 860707,Chatham County Adopted Resolution Which Endorses Emergency Plan.W/Certificate of Svc ML18019B0891986-07-0202 July 1986 Petition Requesting Institution of Proceedings Per 10CFR2.206,requiring Util to Respond to Show Cause Order Due to Failure to Meet Required Stds in Areas of Emergency Planning,Plant Safety,Security & Personnel Stress ML20206R8691986-06-30030 June 1986 Response Opposing Coalition for Alternatives to Shearon Harris (Cash) 860609 Petition for Leave to Intervene.Any Cash Participation Would Cause Delay in Proceedings.Petition Should Be Rejected as Untimely Filed ML20206P6641986-06-25025 June 1986 Response to Coalition for Alternatives to Shearon Harris & W Eddleman 860428 Motion for Stay of Immediate Effectiveness of Final ASLB Decision.Motion Should Be Denied.Certificate of Svc Encl ML20206J3641986-06-24024 June 1986 Response Opposing Conservation Council of North Carolina & W Eddleman 860609 Motion to Stay All Power Operations Per ASLB 860428 Final Decision.Motion Fails to Show Single Significant Safety Issue.W/Certificate of Svc ML20206J2051986-06-24024 June 1986 Response to Intervenors Conservative Council of North Carolina & W Eddleman Request to Continue Stay Indefinitely. Certificate of Svc & Svc List Encl ML20211D8641986-06-0909 June 1986 Requests to Continue Temporary Automatic Stay of ASLB Authorization of Full Power Operations Indefinitely.Low Power Operations Should Be Stayed Until NRC Completes Immediate Effectiveness Review & Encl Comments Resolved ML20199E4441986-06-0909 June 1986 Request to Indefinitely Continue Temporary Automatic Stay as to ASLB Authorization of Full Power Operations Until Commission Resolves Issue Raised in Encl Comments on Immediate Effectiveness Review ML20205T4001986-06-0909 June 1986 Appeal from Final Licensing Board Decision to Grant Ol.Board Erred in Determining That Widespread Drug Abuse Had No Effect on Const,In Accepting Applicant Nighttime Alert & Notification Plans & in Rendering Final Decision 1999-07-21
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DOCKETED UNITED STATES OF AMERICA M#
NUCLEAR REGULATORY COMMISSION 8faguag fjh)$983
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
' ;W '
Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of
) Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )
Units i and 2) )
)
Wells Eddleman's Motion Concerning DORDR Information As detailed in the additional DORDR contentions filed herewith, and the other contentions based solely on CP&L's "DCRDR" and NUREG-0737 Rev.1, the earliest of which I saw is 12-14-82, the information in CP&L's so-called "DCRDR" is inadequate to evaluate control room design.
The report itself has a. body of iv+1h pages, and the arpendices, e.g.,
give only 2 of some 35 HERSs referred to in it. However, the "DCRDR" l appendix KA lists a huge amount of information in the nossession of CP&L which has not been provided to me, or to other intervenors.
Now here 's a Catch-22: I can get that information by discovery on my contention 132, but NRC rules won't let me formulats a contention i
based on information which must later be obtained by discovery.
Therefore, I join w* th Dr. Wilson 's not$ nn ("Resoc nse" dated Jan 6 '83) that late-filing of contentions not be considered to apply to those based -
on specific HEDs, HERS, DER file, and othor records listed in said Anpendix.
CP&L has conceded that the DCRDR is a document not available to intervenors nrior to the deadline for submitted contentions in this case.
l 8301130068 830108 PDR ADOCK 05000400 <
0 PDR DS 0] __-
And the failure to include and sucoly inf ormation is clearly CP&L's and their contractor Essex Corocration's, not nine..
If in the alternative the Board decides to acoly the late-filing criteria to such contenticns, I argue (based solely on that assunption) that under 10 CFR s.71h(a)(1) there is good cause for failure to file on tine, because Apolicants withheld the information necessary to formulate the contentions, and are still withholding it so far; further, the NUnEG-0737 Rev.1 and other basis did not exist 5-14-82; There are no other means to protect my interest in this matter since no other party has more rights dhan I do to file contentions based on deficiencies in the DCRDR and the control room's conpliance with NRC rules, and intervenors file contentions as a matter of right.
Staff review is no substitute for this right, nor for litigation.
See ALAB-298, Perry, 2 NFC 730 at 736-7 (1975). Control rooms datang design and nrocedures, and energency planning concerns tied to the control roon and accurate renorting of plant data, are too comnlex to allow a a simple judgment by the Staff as to whether the Anplicants meet NRC licensing requirements. Perry, sunra, ibid.
Given the scarse nature of what CP&L has file d so far re DCRDR and the qualifications of its control room reviewers ~, it is clear that litigation of U11s issue can help in developing a sound record.
l I have training in systens and can ask good questions on these points.
l But the basic help to the record is getting the information before l the Board. The Board acknowledges the control rcon is an important issue, and has adnitted my contention 132 thereon.
As shown above, no other oarty can represent my interests in this unless they have ri Ehts I don't. Annlicants are clearly adverse
! to my interests in this matter, ad shown e.g. by their slowness to file even the thin documentation they have re control roon design review.
(Sco MacDuffic CP&L letter to Denton NRC 7 Dec '82 sLying CP&L was 1
filing this now, theuch it had been revised last in Sant 1981,
~
to " expedite" this case. ) Staff, as noted above, car.not recrosent my interests under the test of Perry.
This matter of additional contentions re control roon design will not broaden the issues much, if at all, since a control roon contention is already adnitted. Indeed, contentions based on later revealed documents nay focus and narrow the control roon issues to be heard. Moreover, we are 20 months f ron hearing now, according to NRC 's new Harris licensing schedule of December 1982, so the admission of such contentions cannot act to delay the oroceeding significantly.
Finally, such contentions should be allowed because to do otherzwise wonid encourage anolicants in this and ether licensing proceedings to withhold information from intervenors in the hope of preventing them from f"aning contentions uoon inoortant safety and environmental concerns, such as the adequacy of control room design for accident conditions (public health and safety) and for providing data for emergency resoonse (ditto).
Written this 8th day of Ja nary 1983 71@ ~
Wells Eddleman Attached: contentions based solely on new information voceived on &
after dxx December 14, 1982 re contrb1 room design. Note that CP&L distribution of the document is spread over 10 days. The LPDR in Raleigh did not have the DCRDR document as late as 12-22-82 according to my search and to the ref erence librarian, I . Hickman.
y Additional contentions of Wells Eddleman based onbCRDR"I got 12-14 82 1323 The deisign of the Harris Unit 1 control room does not connly with the requirements of NUREG-0737, revision 1, dated 12-17-82, particularly the Safety Parameter Display System (SPDS) requirement.
BASIS: the Detailed Control Room Design Review and its recow.nendations o prepared by Essex Corp. for CP&L in 1980-81, including the details thereing of CP&L/"Ebasco 's control room design for Harris 1, e.g.
Figure 1, p.10, make no reference to the SPDS and show no SPDS e 'uiument nor location for same. Thus, it is clear the SPDS isn't in the design as of 1980 by Ebasco, nor in the design as being updated in accord with the Essex DCRDR of 1981. .
~
132C Ann 14. cants have not established that the Essex Corp review team had the appronriate nultidisciolinary qualifications requ! red drx section 5.1.b.(1) by NUREG-0737, Rev.1 of 12-1k7-82 and the ability to use accented human engineering principles, whizkxix in the DCRDR.
BASIS: the 12-7-82 dated docunent CP&L styles a DCRDR , section 1.1 (p.1) makes no reference to any established (or other) hunan engineering princioles used in this review. Nor does the rest of Section 1. -
1.2's conolete Section im2nznnmihahnamihm description of the teamb qualifications is as follows: "The evaluation team was connosed of six Essex Corooration l , employees permanently located in Raleigh and two CP&L employees. The Raleigh Essex starff were human factors specialists made up of two research scientist and four research associates. CP&L uersonnel functioned as contract administrators, onerat*ons suecialists, niant i liaison, and evaluation nrocess expeditors." This says nothing of the CD&L nennle 's qualifications, if any, and does not address the question of anpropriate multidisciplinary qualifications excent to say that all the Essex peonle are " human factors snecialists". This says nothing of their snecific cualification's oft multidisciolinary knowledge or abilities. Nothing further on this is in the "DCRDR".
t_ _
5 132C CP&L's "DCRDR" and control roon design fail to connly with hUREG-0737, Revision 1, sections 5.1(b)(ii),(iii)m(iv), 5.1(c) and 5.1(d) in at least the follouing ways:
(1) no function and task analysis was nerforned in the DCRDR, which itself states (p. iii, iten f) "The procedures for SENPP-1 have not been developed; "
... Section 2.0, u.x 3, begins with this: "2.1 For a olant under construction, such as SENPP-1, certain control roon and equipnent carameters cannot be evaluated. These paranetors include such elements as noise, light, control board components yot to be acquired, and procedures yet to be written."
By contrast, NUMxBO-0737 Rev 15.1.b. (ii) requires the use of function and task analysis that had been used as the basis for develoning ener-gency operating prodedures technical guidelines and nlant soecific emergency onerating procedures. Yet CP&L's "DCRDR" sec 6.3 n.13 states, (end of part (b)) "None of the problems mentioned in naraF"a,h 6.2b were identified from t hese task flows". No other part of the"DCRDR" states that such func tion and task analysis was used to identify problems.
(2) No connarison of the disclay and control room requirenents of NRC with any inventory is in the"DCRDR". Sec. 2.1 quoted above says this hasnot been done.
(3) the "DCRDR" does not address the usefulness of audible alcrm systems, information recording and recall capability at all. With respect to layout, the proposal arranges control and display cabinets such that they block or impede view of some others. (See Fig. 2, p.12, whero view of/ from panels 8,9,10&11 is obscured by #s 12,13,14 and 15 fron #'s 6,7, and 1,2,3,4 and 5. #6 and 7 are hidden f*on onerators by 1 and 2 (as well as nT 3,4 and 5) #'s 16 and 17, the incore instrunentation and inanrn nuclear instrumentat'en sveten ave alnost totally behind the 2 blocks 1 thwu 5 and 6-7 with ' respect to the
. . . 6 radiation nonitor equienent panels 12 thru 15, the 8-11 block (startup and generator) and the 1-5 block's sections i thru 4 and nossibly 5. Operator inability to see, read accurately, or integrate the info on these panels can im eril rublic safety jpef8ent.
The "D0903" does not nrovide the HERS (snecifications) for lighting and visual alarms, though section 2 3 says there are 17 of them (p.3): P.h is Missing from the cony of the "DC9DR" I have to make these contentions fron, but Appendix G, the HERS for emergency procqdures (and for procedures), the only ones given in the"DCRDR",
are mainly typesetting and format guides and do not explain how accepted human factors principles are incoroorated into them.
This is a basis for presun'.ng the other 15 h9?S are likewise deficient in explaining t;he accepted human factors principles involved in them.
Without seeing them it is silly to ask me to nredict this, so more ,
contentions may follow if the other 15 HERS are produced by CP&L.
(4) the "DCRDR" f ails to select doisign imurovements that will correct discrepancies that are significant in hunan engineering terns.
E.g. section 3 2(f) and (g), p.5, provide that concerns were evaluated using the Harris si nulator checklists, as deened applicable to SHUPP-1, but were referred to engineering or startuo personnel if not resolved.
At p. 6 (3 3 c) a total of 143 HED recorts are noted, 25 of which 30 became HERSs and 42 of which were judged inaoplicable since they refer to the simulator. That leaves 88 unaddressed. In all of this and throughout the "DCRDR" there is no indication of how significance of human engineering concerns re the control roon were determined, or if they were, or how the troposals will corr,ect the discrenancies.
Referral to startup, or nnking a recommendation, is not enough; and there are 88 HED renorts (not listed or described further in the "DCRDR")that seem to have fallen through the cracks.
(5) the "DCRDR" does not verify that each selected design improvenent will nrovide the necessan correction, as m19m-0737
Rev.1 5.1(d) requires. Indeed, the repor$ by Essex has ao its fir,st result, quoted above (1, suura, ref. section 2.1,n 3) that this' has not and cannot be done for several inportant areas.
132 D The "DCRDR" for SHNPP utterly f ails to conply with the requirenants of.NUREG-0737 Rev.1 with respect to Harris Unit 2.
The design of the Harris 2 control roon does not connly with the requivamenta of that document.
$ ASIS: OP&L's "DCRDR"a_ddresses unit #1 only. No nontion of a
unit 2 is nado in it. CP&L has not sunnlied a DCRDR f or Unit 2 yet.
However, NURFG-0737 Rev.1, section 5.2f provides that for anplications with an SSER dated after June ,1983, Control Roon Design Review will be required prior to licensing. According to N90s 12-28-82
" Schedule Change Milestones for Shearon Harris Unit 1", the SSER for Unit 1 was scheduled for Jan 9,1988h, now is slated for 4-2-8h, a 3 month klippage. Both these dates are beyond June 1983, and Unit 2 cannot be finished har6mm before Unit 1. No schedule of Unit 2 SSER has yet been provided by NRC, but it nurt be af ter Unit l's.
Although energency n1anning contentions are deferred, I think
, it nrudent to file the following emergency plan contentions now also's ,
l l based on NUREG-0737, Rev. 1 of 12-17-82:
Contention 142: CP&Ls meteorological monitoring a t SHNPP is unable to accurately represent noteorological conditions within 10 miles of the plant.
BASIS : Wind patterns, patterns of raitr, snow and othe r nrocinitation j differ considerably between SHEPD and neavby sites, e.g. NC State U and Raleigh-Durhan airport, where meteorological data is taken regularly.
l The SHNPP site is charadterized by highly variable vinds with a nearly 1
l circular wind rose and frequent chcnges of wind direction.
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< Contention 1h3; CP&L's Energency Ocerati.cns Facility, alternate EOF, EncrConey Oncrations Procedures (EOPs), Technical Sunnart Center (TS'C), Operational Support Contor 3(OSC) and required conmunications between and anong these are inadequate to nrotect the nublic health and safety adequately and do not conaly with the rea.uirements of NUREG-0737, REY. 1,12-17-82, particularly those of Table 1, and sections 7,6 and 8 thereof.
BASIS: These facilities'are either incomolete or unbuilt now, the connunication lines do not er.ist and have not been tested, and NRC has not assessed CP&L's compliance with HUREG-0737 Rev.1 as required prior to SENPP operation. .
Contention 1hk: CP&L's emergency and security norsonnel l'ovels do not neet the requirements of HUREG-0737, REY. 1, Table 2.
BASIS: The security plan isn't complete, and is unavailable for review until security exnerts have been qualified, which is being hold up by Applicants ' objections. The staffing le vols shown in the FSAR are insufficient to meet the requirements fo'r x one damaged and en one undamaged unit. -
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Wells Eddleman ,
i l written Jan 8 '83, sewved Jan 10 l
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UNITED STATES OF AME9ICA NUCIJAR REGUIATOPI C0!C4ISSION In the matter of CAROLIhA PO'.iER & LIGHT C0. Et al. ) Dockets 50-h00 Shear o~ n Harris Nuclear Power Plant, Units 1 and 2 ) and 50hh01 0 L.
CERTIFICATE 0F SERVICE I hereby certify that copies of W.E. notion concerninn DORDn info and additi.nnal contentions based solely nn decunents accuined en &
arter Ld-ut-on HAVE been served this 10thday of January 1981_, by deposit in the US Mail, first-class posth6c prepaid, upon all parties whose names are listed below, except those whose names are marked with an asterisk, for whom service was acconplished by Judges James Kelley, Glenn Bright and Janes Carpenter (1 cony each)
Atonic Safety and Licensing Board US Nuclear Regulatory Commission Washington DC 20555 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/k010?L. 108 Bridle Run USNRC Chanel Hill
~ NC 2751h Washington DC 20555 Dan 9ead Docketing and Service Section CEANGT/ELP l Attn Docke ts 50-h00/h01 0.L. Box 52h
, Office of the Secretary Chapel Hill NC 27514 l
USNRC Washington DC x 20555 Pat & Slater Newman CANP John Runkle 2309 Weynouth Court CCNC Raleigh NC 27612 307 Granville Rd .
Chapel Hill Nc 2751h Travias Payne Edelstein & Payne Box 126h3 Raleigh NC 27605 Richard Wilson, M.D. Certified by *erw 729 Hunter St. .
Apex NC 27502
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