ML20084C417

Response to T Baxter Alleging That Notice of Disposition Does Not Comply w/10CFR2.740a & Motion for Leave to Take Depositions Re Safety Contentions.Aslb Moved to Allow Disposition of Eddleman 65.Related Correspondence

ML20084C417
Person / Time
Site:	Harris
Issue date:	04/24/1984
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
References
82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8404270259
Download: ML20084C417 (2)

Text

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'Poo April 2k,1984 Y

UNITED STATES OF AMERICK '

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';nry NUCLEAR BEGULATOBY COMMISSION

'84 APR 27 A10:53 BEFORE THE A_TOMIC SAFETY AND LICENSING BOARD LFFKE 0: SECn j, Glenn O. Bright 00CMETING A SEPylti Dr. James H. Carpenter "H James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Unit 1) ) ASLBP No. 82-h68-01

) OL Wells Eddleman's Response to Baxter Letter of k-18 and Motion for Leave to Take Depositions Wells Eddleman hereby responds to the letter of Applicants' attorney Tom Baxter dated 4-18-84:1.He alleges the notice does not comply with 10 CPR 2.7h0a, but cites no provision thereof not comolied with. The notice was served on the parties and on the persons named at the address CP&L had supplied.

2. The cosition that depositions based on information delivered after March 15, 1984, because (due to Auplicants' delaying tactics) the information was not delivered until after that date is a classic' Catch-22, makes no sense and should have no force.

Information uncovered in the Response served March 23 and in documents

,8$ produced pursuant to it (mostly from the documents) is the basis for me n.

noticing these depositions, o{

m8 3. Baxter's 3d point is a rehash of #2, responded to above.

Ex no Therefore, in Applicants' " tradition" of changing their positions, I think RQ it appropriate to file the motion below:

N< MOTION

$a: Due to the discrenancies and problems outlined in discovery docu-ESo ments received from ^pplicants, after the March 15 cutoff date for discovery in this proceeding on safety contentions, Wells Eddleman

.F.

hereby moves the Board to allow depositions of the persons named in the notice of depositions hi filed in this docket on 9 April 198h and other eersons whose names or identification or info reasonably identifying same (e.g. concrete inspector on pour (number)) was received after 4-9-84 In sunnort hereof I noint out the contradiction between Anolicants' discovery response that no nours were identified as difficult prior to placement, and the infox on the nreplacement renort ICBXWhh]4001 which says "an esnecially diff'icult placement" ov' words to that effect.

There are also numerous field changes, PW's and rebard i

discrepancies and deviations in numbers of the reports uroduced; some are referred to repeatedly. Numerous orocedures, changes and so on have not been produced. Therefore these denositions might reasonably be delayed until such documents are produced and I and/or my exnert(s) have time to examine them.

It is the oninion of my consulting expert that a pour with surface honeycombing or voids is very likely to have internal honeycombing and/or voids. Since only visual inspection was used on the Harris base mat pour that had surface indications, this indicates a potentially serious problem. It should not be dismissed lightly. Depositions, as this Board has noted, are a more efficient way to obtain information.

As an example of the information that needs followup, pour ICBXW290001 had a concrete test with two criteria, one of which was average of a 3 consecutive samples not below minimum strength. This criterion was violated; but the second criterion, no sample more than 500 psi below minimum strength, was also violated with a 4105 psi test with 5000 required. This appears to not have been followed up at all by CP&L.

I therefore move the N

Eddleman 65 to investigate problems found unon discovery so far. Board , to allow i