ML20217D566

NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence

ML20217D566
Person / Time
Site:	Harris
Issue date:	10/12/1999
From:	Uttal S NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#499-20889 99-762-02-LA, LA, NUDOCS 9910180017
Download: ML20217D566 (6)

Text

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RElATED CORRESPONDENCE 00CMETED

}d$ USMPC i

9 OC' 13 All :17 October 12,1999 RU UNITED STATES OF AMERICA ADA , -

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

) Docket No. 50-400-LA CAROLINA POWER & LIGHT )

COMPANY ) ASLBP No. 99-762-02-LA

)

(Shearon Harris Nuclear Power Plant) )

)

NRC STAFF'S FIRST SUPPLEMENTAL RESPONSE TO ORANGE COUNTY'S FIRST SET OF DISCOVERY REOUESTS TO NRC STAFF The Nuclear Regulatory Commission staff (Staff) hereby files this supplement to Staf; responses to Orange County's First Set of Discovery Requests to NRC Staff, filed September 20,1999.

A. GENERALINTERROGATORIES GENERAL INTERROGATORY NO. 2. For each admitted l Orange County contention, give the name, address, l profession, employer, area of professional expertise, and educational and scientific experience of each person whom the NRC Staff expects to provide sworn affidavits and declarations in the written filing for the Subpart K proceeding )

described _in the Board's July 29,1999, Memorandum and j Order and the general subject matter on which each person is expected to provide sworn affidavits and dec!reations for the written filing. For purposes of answering this interrogatory, the educational and scientific experience of expected affiants and declarants may be provided by a resume of the person attached to the response.

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l The Staff supplements its response to Orange County's First Set of Discovery Requests by providing the following additional person who is likely to provide a swom affidavit or declaration in the' written filing for the subpart K proceeding: ,

l Christopher Gratton Reactor Systems Engineer Plant Systems Branch, Division of Systems Jafety & Analysis Office of Nuclear Reactor Regulation General subject matter: Coatention 3 A resume is annexed hereto. The Staff reserves the right to amend this answer as discovery continues.

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GENERAL INTERROGATORY NO. 3. For each admitted Orange County contention, identify each expert on whom the NRC Staff intends to rely on in its written filing ,

for the Subpart K proceeding described in the Board's July l

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29,1999 Memorandum and Order, the general subject matter on which each expen is expecied to provide swom affidavits and declarations for the written filing, the qualifications of each expert whom the NRC Staff expects to provide sworn 1 affidavits and declarations for the written filing, a list of all  !

publications authored by the expert within the preceding ten  ;

years, and a listing of any other cases in which the expert has '

testified as an expert at a trial, hearing or by deposition within the preceding four years.

The Staff supplements its response to Orange County's First Set of Discovery Requests by providing the following name:

Christopher Gratton -

Publications within 10 years: none Testimony within 4 years: none .

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j 3-L The Staff reserves the right to amend this answer as discovery continues.

R pectfully sub 'tted, l

1 f l Vb j Susan L. Uttal 1 Counsel for NRC staff

', Dated at Rockville, Maryland this 12* day of October 1999

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J Christopher Gratton Reactor Systems Engineer Education M.B.A. University of Maryland,1992 B.S., Engineering, University of Maryland,1980 Emolovment U.S. Nuclear Regulatory Commission, Reactor Systems Engineer,1992 - present Performs safety evaluations of reactor license applications, technical specifications, and topical reports for various balanet.Of-plant systems including wet spent fuel storage facilities.

Performed risk assessments and safety evaluations regarding the adequacy of spent fuel storage issues as part of the Spent Fuel Storage Pool Action Plan.

U.S. Nuclear Regulatory Commission, Operator Licensing Examiner,1987 - 1992 Qualified operator licensing examiner for boiling water, test and research reactors. Developed aad administered licensing examinations to candidates applying for certification. Examinations included written, cral, and performance based tests administered on plan simulators. Toples included physics, reactor system and auxiliary system design and operation, emergency operating and offsite accident response procedures.

Norfolk Naval Shipyard, Assistant Chief Test Engineer,1980 - 1987 Responsible for the overall safety of the nuclear power plar'. aboard submarines undergoing overhaul. Qualified Shift Test Engineer (STE) for reactors designed by Westinghouse and General Electric. Responsible for setting electrical and mechanical isolations, changing plant conditions to support maint3 nance and testing, and directing post maintenance tes'.s.

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3 DOCKETED US"RC UNITED STATES OF AMERICA W DCT 13 All :17 NUCLEAR REGULATORY COMMISSION l OF BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

%u g In the Matter of ) 3

)

CAROLINA POWER & LIGHT COMPANY ) Docket No. 50-400-LA

) ASLBP No. 99-762-02-LA (Shearon Harris Nuclear Power Plant) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of"NRC STAFF'S FIRST SUPPLEMENTAL RESPONSE TO ORANGE COUNTY'S FIRST SET OF DISCOVERY REQUESTS TO NRC STAFF' in the above captioned proceeding have been served on the following through deposit in the Nuclear Regulatory Commission's intemal mail system or as indicated by an asterisk, by first-class mail and by electronic mail (e-Mail) transmission where indicated this 12th day of October,1999:

G. Paul Bollwerk,III, Chairman Frederick J. Shon Administrative Judge Administrative Judge

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Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop: T 3F-23 Mail Stop: T-3F-23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 (E-mail: GPB@NRC. GOV) (E-mail: FJS@NRC. GOV)

Dr. Peter S. Lam Office of the Secretary Administrative Judge A'ITN: Rulemaking and Adjudications Atomic Safety and Licensing Board Staff Mail Stop: T 3F-23 Mail Stop: O 16-C-1  ;

U.S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission j Washington, DC 20555-0001 Washington, DC 20555-0001

.< (E-mail: PSL@NRC. GOV) (E-mail: HEARINGDOCKET l

@NRC. GOV) i i

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. Office of the Commission Appellate . James M. Cutchin, V Adjudication Atomic Safety and Licensing Board Mail Stop: O 16-C-1 Mail Stop: T 3F-23

- U.S. Nuclear Regulatory Comnussion U.S. Nuclear Regulatory Comminion Washington, DC 20555-0001 Washington, DC 20555 (E-mail: JMC3@NRC. GOV) 1 Diane Curran, Esq.* _

John H. O'Neill, Jr.*

- Harmon, Curran, Spielberg William R. Hollaway*

& Eisenberg, L.L.P. Counsel for Licensee 1726 M Street, N.W., Suite 600 Shaw Pittman Potts & Trowbridge

-Washington, DC 20025 2300 "N" Street, N.W.

(E-mail: dcurren@harmoncurran.com) .. Washington, DC 20037-1128 (E-mail: john _o'neill@shawpittman.com, william.hollaway @ shawpittman.com)

Steven Carr*

Legal Department Carolina Power & Light Co.

411 Fayetteville Street Mall P.O. Box 1551- CPB 13A2 Raleigh, Nonh Carolina 27602 (E-mail: steven.carr@cplc.com)

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Susan L Uttal Counsel for NRC Staff I