ML20197H364
| ML20197H364 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/14/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8406180399 | |
| Download: ML20197H364 (4) | |
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DMED corn:E Si'C. Nom 2-UNITED STATES OF AMERICA
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June
, 1984 NUCLEAR REGULATORY COMMISSION BEFORE THE A'!OMIC SAFETY AND LICENSING BOARD
- 1gg Glenn O. Eri Dr. James H.ght OR;.NDi Carpenter b
Y James L. Kelley, Chairman O
In the Matter of
)
Docket 50-40 OL CAB 0 LINA POWER AND LIGHT CO. et al.
Harris Nuclear Power Plant, ar
)
ASLBP No. 82-h68-01
)
OL Motion to Connel Discovery fron NRC Staff re Joint Contention I As noted in the nrehearing conference early in May, Staff and Joint Intervenors were negotiating over Staff's objections and answer,s re Joint Contention I (Managenent Incanability).
Because of no further progress on the natters below, this notion is now filed, ten days from the 30 nay breakdown of negotiations (as described in the acco manying certificate of negotiations) counting the fcet that June 9 is a SaturdF7 He interrogatory 17, answers to interrogatories 2 thru 4 adnd to 15 say or innly analysis has been done, but none is given.
We are entitled to know what analysis has been done (what AISI has been
.,gg done).
- t a.
,$O Re #22, the answer does not annear consistent with answersk to 8
'S 2 thru 4 above.
$2c t
c)u Re #21, we think the answer is Yes and the Staff should either 4
88 7
say so or give a better exnlanation of the " answer" nrovided.
-og En.o Re #141, the answer given does not say which reports other than the SALPs relate to nanagement, though the question is ask d We think we are entitled to an answer.
e.
95 0
9
-2 Re #1h4, we believe the answer is Yes and that Staff alnost nust know sone answer to this question beyond that nrovided elsneuhere.
Since we contend CP&L nanagenen
= inadequate, it is surely relevant to know who or what the Staff believes is inadequate nuclear management.
Re #145 answer, the question enconpasses who the Staff member (s) are (is) who conducted these interviews, and identification of documents f
concerning the interviews.
Fron the answer it is not clear if all the followups are identified in the answer; they should be.
Re #147 answer, no docunents are identified, though the interro-gatory asks for identification of all documents =e the agenda of each such neeting.
Re #149, we believe that the nanagenent of the Zimmer nlant, that of GPU Nuclear, etc., come within at least the scone of nart (bb) of this question.
Staff is being evasive about relevant information.
In the 1979 renand hearings, a poll of 9egion II insnectors was brought into the hearings, re CP&L nanagement adequacy.
The sane sort of noll would be relevant herre, especially if there are inspe ctors who think CP&L nanagenent is not, or may not be, adequate to assure the safe operation of the Harris niant.
Re #150, we nay be wrong, but we find it hard to believe that N90 Staff has nade no studies or the weaknesses or strengths of nanagement of nuclear utilities or niants.
We find it hand to believe also that no analysis or study of CP&L managenent has been done, in light of the questions that have been raised about CP&L nanagenent in the past, e.g. 1979 renand hearings.
If Staff has a working definition of good nanagement (e.g. as in resnonse to #143 that Staff agreed 5/31/8k.
to nake) then it should_be something Staff can articulate.
Re #151, if the Staff has since nulled information related to tr.is interrogatory together, we believe they are reouired to supply it.
c ~'
Concerning #152, we believe this is a dodge of the question, l
which is directed to the Staff, not just to Region II.
We suggest asking Ed Reis of OELD who was Staff counsel in the 1979 renand, or checking with OELD personnel.
Concerning #153, it is not clear whether the neonle referred to have been asked this question.
We think they should be asked.
The answer is surely relevant to nanagement canability of CP&L.
Concerning #154, we nay be wrong, but we find it hard to believe that NRC Staff does not analyze the events renorted in LERs, or has no documents beyond the LERs themselves which relate to their analysis of renortable accidents, problens, etc.
We are quite willing to have this answered just for CP&L's nlants if that is an easier way to answer it.
Concerning #156, we are not sure the Staff is familinr with the statenents in the 1979 renand case to the effect that the oroblems at Brunswick were basically taken care of.
We think they should take interest in these nuestions if they have not already.
We think we are entitled to an answer if and when the Staff does.
Re #156 objection, we think the connarative nerfornance of other nuclear utilities is releavant.
Diftto re #157 objection.
We want to know in #157 if any other utility has innvouerly disnosed of low level radioactive waste in the way X CP&L did, or a similar way.
Surely it-is relevant if CP&L has connitted nistakes no othew licensee.
has,' which are outstandingly bad and/or only discovered by luck, not l'icensee or NRC diligence.
\\
$[htereobjectionto revised interrogatory #1: We aren't pressing for an answer _to #1, but if Staff's "eviewers.do understand the. subject matter they are reviewing, then the objections. to '1h3..
157 'as noted above don't make much sense, and answers could be gi n
For Joint Intervenors, ie is 'ddlenan
June 11, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE A'10MIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of
)
Docket 50 400 OL CAROLINA POWER AND LIGHT CO. et al.
)
ar Harris Nuclear Power Plant,
)
ASLBP No. 82-h68-01
)
OL Certificate of Negotiations Charles Barth of NRC Staff and Wells Eddlenan for Joint
.Intervenors conducted infornal negotiations, with ninimal progress, ending in an annarent breakdown on 30 May 1984 However, on 31 May the Staff agreed to supply additional information related to Interrogatory 143, which was accepted for Joint Intervenors.
If additional orogress results before the notion,
' to compel is filed, it will be noted.
I affirn the above is true.
f 11 June 1984
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