ML20087J453

Supplemental Document Listing on Discovery.Related Correspondence

ML20087J453
Person / Time
Site:	Harris
Issue date:	03/13/1984
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
References
CON-DSB-52, CON-DSD-52 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8403220222
Download: ML20087J453 (2)

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pg . . 4DgED CORRESPONDENCE

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C0CKETEr served by hand to CD&L r, UNITED STATES OF AMERICAM (when they come by my wc home to nick un S.S.

NUCLEAR REGULATORY C0gIggIpf A10 b * '

Ssne"i do cQLws 3-lq U tD :F Muim BEFORE THE ATOMIC SAFETY ANDGLICENSINGRBOARD

, Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Units 1 ani 2) ) ASLBP No. 82-1468-01

) OL Document Listing on Discovery (supulemental listing)

Pursuant to conversations with Apolicants' counsel O'Neill and Hollar, Wells Eddleman provides the followinF list of documents in his possession. Under the Anril 1983 agreenent between Eddleman and O'Neill,

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only docunents which are not (1) NRC documents or (2) in CP&L's possession, need be produced on discovery.

132(c)(2): NUREG/CR 1276 (Parts I and II): Handbook of Hunan Reliability Analysis with E,:phasis on Nuclear Dower Plant Applications NUREG-0801 "Draf t : For. Con ~.ent" re 0C909 innlementation Joint I: A fast review of the working " management" file shows that it contains the E-2 sub Idd4 (CP&L General Rate case) "Jacobstein Report" investi Eating the CP&L Brunswick nuclear plant, and some Exhibits thereto, e.g. ARJ 7. I believe all Jacobstein's exhibits are in file I nossess, Other than that and drafts of the Joint Interrenors' interrogatovies to CP&L, the documents are all CP&L-originated, or URC-originated, excent:

CP&L SEC Form 10-K for yesr ended 12-31-1980; Charlotto Observe" p.1C of 2-19-8 NRC Imno es Observer,3: Feb 19,19h3 (Larbest pp Fine)Ever and A ainst CP&L; Raleigh News &

6A Recor$FineDronosedForCPIL.

I will lend these to Dale Hollar today for conying, along with the ".c.9.

Box" on Joint 7 and two itens re 15AA and Joint I received this weekend, the summary of the OTA report " Nuclear Power in an Age of Uncertainty" and the report "Is the Peaceful Atom a Good Investment".

I have also referred Applicants' counsel to the references of my

original contention 3 and other, contentions superseded by Joint I. At the request of Applicants' counsel Sanantha Flynn, I an =eviewing Eddleman 3 to try to specify the references more in detail. This contention is at pages31-145 of my 5-17-82 4 (contentions) supplement to petition to intervene.

(see separate undate re Joint Intervenors' info'in makinc Joint I 1 l and its precursors,~ also).

! B403220222 840713 PDR ADCCK 09C00400 g

pago two March 13, 198h Listing of W.E. documents for CP&L (supolemental listing)

Joint 3 (al has highly specific references, (b) is same info base l j as (a). (c) refers to a lack of information.

(d) has a highly specific reference to Jacobstein's renort we l Brunswick (5-lh-82 at 33). Page 3h (middle), C.E. Murphy meno is from #egion II construction branch, NDC. I believe it is in an appendix to UCS's " Browns Ferry: the Degulatory Failure" which is probably somethere in my files but not readily found today.

the IEEE renort I refer to, I believe is a renort not made nublicly available. You could check with IEEE about it. I don't have a cony to my knowledge.

Further Jacobstein references are on p.35, for nart (a).

(e) also on n.35, references Jacobstein specifically. I haven't located the Brunswick internal nemon referred to on that page, and may never have had a cony, though I have seen one. CP&L admitted I

being the only offsite LLRW releaser, see resnonses to interrogatories on Eddleman 67.

(f) on page 36, line h, shoulmd read "of" inability torespond, not "if".

l I don't have transcript. references to the 1979 remands handy, but I recall J.A. Jones vehemently denying that CP&L would ever onerate a ulant in an unsafe manner (nuclear plants). Dr. Leeds' questioning of CP&L cones.toward j the end of the hearing as I recall. There's a lot about the watentight l

doors and their alarms in Cantrell's vrefiled,'nostibly his exhibits, and l

in the transcript.

(g) reference to E-2 sub h16 is to 'oublic hearing at Wilmington NC.

l I believe CP&L has a transcript of that case. Shackelford's nhone is now-

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l 919-762-6121; address is sane. I don't have the date or cite to the renorter.

(h) references given. (H2) is based on n-ws reports,' my meno*ies' of information, end does not list documents. (I) the nav cut.is a news recort.

I'm not sure what date, urobably raleigh N&O. CP&L'7h'-75 nay cuts, 50 100 4

raemand see Jones testimony and cross etc. " rove 9ent Progran" of 1982 (did not exist when contention, file 8) Brunswick connare w/ I earrings innrove-l mt progran" of 197h-75. P.h5 should come between h2 and 43 i

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