ML20083H551

Response to Summary Disposition on Eddleman Contention 132 Re Safety Parameter Display Sys.Certificate of Svc Encl

ML20083H551
Person / Time
Site:	Harris
Issue date:	01/03/1984
From:	Eddleman W EDDLEMAN, W.
To:	Bright G, Carpenter J, Kelley J Atomic Safety and Licensing Board Panel
Shared Package
ML20083H553	List: ML20083H551 ML20083H571
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8401090335
Download: ML20083H551 (2)

Text

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7 UNITED STATES OF AMERICA 2'

Jan3,0gjp NUCLEAR REGULATORY COMMISSION

'84 JAN -6 P3:12 BEFOREDr. Glenn THE O. Bri ATOMIC James Carpenter SAFETY H.ght AND LICE MAHcs James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Units 1 and 2) ) ASLFP No. 82-1468-01

) OL ,

Wells Eddleman's Resnonne to Summary Disposition '

on Eddleman 132 As contention 132 is written, I have no available response to Applicants and Staff. But I didn't get a chance to complete my planned 2d round of discovery (the fall '83 was not a 2d round, it was 1st round to Staff per agreement with Staff counsel in May '83),

and the RVLIS doesn't meet my concerns (as I stated on discovery to Applicants). While my analysis is still incomplete, having only 2 channels l raises an obvious question: what if the two disagree? htat useful info does RVLIS provide then? Staff responded (as usual) in the form of another i

motion for summary disposition, with no exnediting. I would request the

Board to make its oral order re Joint II and 37B permanent on the staff, i.e. that where their " response" to a motion for sumnary dispotition is n88 effectively another notion for summary disposition, they file it early o u, o (i.e. at or near the date for motions for summary dispotition) so I can 5o n respond. Also, I note that my second set of interrogatories on Eddleman mz oo 65 is forthcoming (to Staff and Applicants) as I have ureviously advised ok g attorney Baxter for Applicants. In agreeing to allow discovery to start

$$o early on certain contentions, I never have agreed to expedite my own work on contentions (e.g. 141, 65, 132) fortheconvenienceofAnplicants./

~fb

UNITED STATES OF AMEHICA XUOLFAE REGUIATORY C0! MISSION In the matter of CAROLIKA POWEP k LIGHT Co. Et al. ) Docket 50-h00 Shearon Harris Nuclear Power Plant. Units 1 and 2 1 0.L.

. CERTIFICATE 0F SERVICE WE's New Contentions re SDDS I hereby certify that copies of __ _

and of W.E. Stesnonse to Summarr Disnosit'en nn W m ==n 'M HAVE been served this 3 day of January 1981,bydepositin the US Mail, first-class pos: age prepaid, upon all parties whose  :

names are listed below, except those whose nanes are parked with an asterisk, for whom service was acconplished by Judges Ja tes Kelley, Glenn Bright and James Carpenter (1 egy each)

Atomic Safety and Licensing Board US Nuclear Megulatory Commission Washin6ton DC 20555 George F. Trowbridge (attorney for Applicants)

Shaw, Pittman,.Potts & Trowbridge R.uthanne G. Miller -

1800 M St. NW ASLB Panel WashinEton, DC 20036 USNRC Washington DC 2C55 5

~

Office of the Executive Legal Director Phv111s Lotchin, Ph.D.

Attn Docke ts 50-400/401 0.L. 10B Bridle Run USNRC Chanel Hill

' NC 2751h l

Washington DC 20555 Dan Read Docketing and Service Section (3x) CEA?UE/FL?

Attn Docke ts 50-h00/h01 0.L. .

Office of the Secretary Maleigh,r/c7 NC waveross 27606

~

""' Li"d* "* Littl*

l Eas.$$natonDC20555 Governor's Waste Mgt. Bd.

John Runkle - 513. Albemarle B3ds.-

325 N. salisbutw St.

Granville Rd Raleigh, NC 27611 Chapel Hill Nc 2751L. Bradier W. Jones Robert Gruber USNRC Region II

'Travi s Payne Exec. Director 101 Marietta St.

Edelstein & Payne Public Staff Atlanta GA 30303 Dnex 12601 Box 991 Raleigh NC 27605 Raleigh NC 37602 Richard Wilson, M.D. Certified by T-729 Hunter St.

Apex NC 27502

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