ML20083C555

Response to Eddleman Interrogatory 15AA Re Mgt Performance. Info Sought Not Considered Relevant to Proceeding.Related Correspondence

ML20083C555
Person / Time
Site:	Harris
Issue date:	12/20/1983
From:	Hollar D CAROLINA POWER & LIGHT CO.
To:	Eddleman W EDDLEMAN, W.
Shared Package
ML20083C558	List: ML20083C555 ML20083C590
References
ISSUANCES-OL, NUDOCS 8312230182
Download: ML20083C555 (4)

Text

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4 .- - - ']{ USNRC December 20,1983 T53 DEC 22 A10:04 UNITED STATES OF AMERICA [0C Tfb'hk,%2 '

NUCLEAR REGULATORY COMMISSION BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY )

) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ) 50-401 OL Units 1 & 2) )

APPLICANTS' FURTHER INTERROGATORY RESPONSES ON EDDLEMAN CONTENTION 15AA As explained in the accompanying Applicants' Response to Motion to Compel Discovery of Applicants on Eddleman Contention 15AA, Applicants have withdrawn their objections to answering Interrogatories No. 15AA(2d)-18(m)(iv), 15AA(2d)-18(n),

15AA(2d)-19(d), 15AA(2d)-19(e) and 15AA(2d)-19(h) as it relates to 19(d) and (e).

Accordingly, answers to these Interrogatories are provided below. The provision of answers to these interrogatories is not to be deemed a representation that Applicants consider the information sought to be relevant to the issues to be heard in this proceeding.

INTERROGATORY NO.15AA(2d)-18(m). Does CP&L believe there are reasons for the poor performance of the Brunswick nuclear units it co-owns and operates that relate to . . . (iv) management . . .?

ANSWER: Applicants recognize that management, along with numerous other factors such as those mentioned in the other subparts of this Interrogatory, has had an impact on the performance of the Brunswick plant, as well as on other CP&L facilities and the entire CP&L system.

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e-INTERROGATORY NO.15AA(2d)-18(n) If answer to any part of (m) above is affirmative, please state for each such part, each reasons CP&L believes the matter inquired about in that part has contributed to lower or poor performance of the Brunswick nuclear units,in terms of capacity factor over their operating lifetimes?

ANSWER: Numerous interrelated factors, such as those mentioned in Interrogatory 15AA(2d)-18(m), may impact nuclear power plant performance. No single factor can be addressed independently of the other factors. CP&L further believes that its total system operations are the best measure of its management ability. In this regard,

-notwithstanding the Brunswick units' lower than average capacity factors, the Robinson unit and CP&L's fossil units have all achieved enviable performance records. CP&L has developed and irr.plemented a number of initiatives to improve the Brunswick performance over the past several years. In addition to improvements in systems and equipment via plant modifications, these efforts have involved enhancements to the Brunswick organization and strengthening of management capabilities where appropriate.

INTERROGATORY NO.15AA(2d)-19(d) Does CP&L dispute the ruling of the NC Utilities Commission in Docket E-2 sub 444 that CP&L management was at fault for the length of the Brunswick turbine outage?

- ANSWER: CP&L does net believe the North Carolina Utilities Commission's finding

.was supported by competent, material and substantial evidence.

INTERROGATORY NO.15AA(2d)-19(e) Does CP&L dispute the ruling of the NCUC in Docket E-2 sub 461 that CP&L was responsible for the failure to test the Brunswick plant as required by NRC, which failure led to an extended shutdown in the summer of 1982? ,

ANSWER: CP&L does not agree that the cost of the outage in question should have ,

been treated as other than a normal operation and maintenance expense. It does not dispute that it was responsible for not testing the unit or that th!s led to the shutdown.

INTERROGATORY NO.15AA(2d)-19(h). Please give all basis for your answers to (d),(e) . . ., stating which basis applies to each answer.

Interrogatory Nos.15AA(2d)-19(d) and 15AA(2d)-19(e) call for a legal analysis and conclusion. Applicants' answers are based upon their interpretation of Chapter 62 of the North Carolina GeneralStatutes.

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o Dated: December 20, 1983.

Submitted by:

? 2) i /

Dale E. Hollar, Esq.

Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 Attorneys for Applicants:

Thomas A.Baxter John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 e

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00CKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 13 DEC 22 A10:04 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD UFfiLE CF SEUC' In the Matter of ) /jNd

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLIN A EASTERN )

MUNICIPAL POWER AGENCY )

) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ) 50-401 OL Units 1 & 2) )

AFFIDAVIT OF B. M. WILLIAMS County of Wake )

)

State of North Carolina )

B. M. Williams, being duly sworn according to law, deposes and says that he is Director of Staff Services - Planning and Coordination Department of Carolina Power &

Light Company; that the answers to Interrogatories on Eddleman Contention 15AA contained in " Applicants' Further Interrogatory Responses on Eddleman Contention 15AA" are true and correct to the best of his information, knowledge and belief; and th'at the sources of his information are officers, employees, agents and contractors of f, ,evu ,,,,,

.;Cai4Hna.'Po,, w er & Light Company.

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d B. M. Williams

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,, .u.e * -. U ',% ,'c Sworn to and subscribed before me this ADti. day of December,1983.

SYhNotaryYPublic ,

My commission expires: M (,. / 9 ff U $'

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