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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 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 ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] Category:PLEADINGS
MONTHYEARML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20205A9201999-03-26026 March 1999 Motion for Approval of Protective Order.* Orange County,With Support of CP&L & Nrc,Requests Board Approval of Encl Protective Order.With Certificate of Svc ML20204E5341999-03-17017 March 1999 Orange County Second Motion for Extension of Time to File Proposed Protective Order.* Licensing Board Granted Motion to Extend Deadline for Filing Proposed Protective Order Until 990304.With Certificate of Svc ML20207L4041999-03-16016 March 1999 NRC Staff Answer to Orange County Motion to Relocate Prehearing Conference.* NRC Has No Objections to Relocating Prehearing Conference,Time or Place.With Certificate of Svc ML20204C9721999-03-15015 March 1999 Applicant Response to Bcoc Motion to Relocate Prehearing Conference.* Applicant Requests That Prehearing Conference Be Held in Hillsborough,Nc.Location Available to Hold Prehearing Conference on 990513.With Certificate of Svc ML20207K1391999-03-0909 March 1999 Orange County Motion to Relocate Prehearing Conference.* Requests Licensing Board Relocate Prehearing Conference Scheduled for 990511 to Site in Area of Shearon Harris Npp. with Certificate of Svc ML20127M4091992-10-0202 October 1992 CP&L Response to Appeal to NRC Commissioners of NRC Staff Denial of Nirs Petitions for Immediate Enforcement Action of 920721 & 0812.* Commission Should Affirm NRR Denial of Nirs Petitions.Certificate of Svc Encl ML20213A0091987-01-28028 January 1987 NRC Staff Response to Intervenor Application for Stay of ALAB-856.* Motion Should Be Denied Since Coalition for Alternatives to Shearon Harris Lacks Standing to File Motion & 10CFR2.788 Criteria Not Met.Certificate of Svc Encl ML20212R6431987-01-27027 January 1987 NRC Staff Motion for Extension of Time.* Motion for Extension Until 870128 to File Response to Intervenors Motion for Stay of ALAB-856.Certificate of Svc Encl ML20212R6861987-01-27027 January 1987 Licensees Answer to Conservation Council of North Carolina/ Eddleman Motion for Stay.* Motion Should Be Summarily Denied.Certificate of Svc Encl ML20209A7191987-01-27027 January 1987 NRC Staff Motion for Extension of Time.* One Day Extension of Time Until 870128 to File Response to Intervenors Motion for Stay of ALAB-856 Requested.Granted for ASLB on 870128.W/ Certificate of Svc ML20207N6051987-01-10010 January 1987 Conservation Council of North Carolina,Wells Eddleman,Pro Se & Coalition for Alternatives to Shearon Harris Motion to Stay Effectiveness of Licensing of Shearon Harris Nuclear Power Plant.* W/Certificate of Svc ML20207M0191987-01-0808 January 1987 Motion to Continue Commission decision-making Re Licensing of Shearon Harris Nuclear Power Plant.* Requests NRC Refrain from Issuing Full Power OL Until Criteria Assuring Safe Operation Met.Certificate of Svc Encl ML20214A5171986-11-17017 November 1986 Response Opposing State of Nc Atty General 861028 Motion Re Applicant Request for Exemption from Portion of 10CFR50, App E & Part IV.F.1.Certificate of Svc Encl ML20197C8511986-11-0303 November 1986 Response to Atty General of State of Nc 861028 Motion to Dismiss,As Moot,Util 860304 Request for Exemption from 10CFR50,App E Requirement for Full Participation Exercise 1 Yr Prior to Full Power License.W/Certificate of Svc ML20215M2281986-10-28028 October 1986 Motion for Inquiry Into Feasibility of Applicant 860304 Request for Exemption from Requirement That full-scale Emergency Preparedness Exercise Be Conducted within 1 Yr Prior to Issuance of Ol.Certificate of Svc Encl ML20215G7061986-10-17017 October 1986 Response Opposing W Eddleman & Coalition for Alternatives to Shearon Harris 861006 Brief Requesting Hearing on Util Request for Exemption from Performing full-scale Emergency Exercise,Per Commission 860912 Order.W/Certificate of Svc ML20215J6121986-10-17017 October 1986 W Eddlemen & Coalition for Alternatives to Shearon Harris Petition,Per 10CFR2.206 to Revoke,Suspend or Modify Cp. Certificate of Svc Encl ML20203N9191986-10-14014 October 1986 Response Opposing Coalition for Alternatives to Shearon Harris/Eddleman 860731 Request for Hearing on Util Request for Exemption from Requirement to Conduct Full Participation Exercise.Certificate of Svc Encl ML20210V1571986-10-0606 October 1986 Answer in Opposition to Coalition for Alternatives to Shearon Harris,W Eddleman & Conservation Council of North Carolina 860915 Motion to Reopen Record.Related Info & Certificate of Svc Encl ML20210S9871986-10-0606 October 1986 Brief Opposing Applicant 860304 & 0710 Requests for Exemption from 10CFR50,App E Requirement to Conduct Full Participation Exercise of Emergency Mgt Plan within 1 Yr Prior to Operation.W/Certification of Svc ML20214S0831986-09-25025 September 1986 Applicant Answer Opposing 860915 Coalition for Alternatives to Shearon Harris (Cash) Motion to Reopen Record.Motion Opposed Since Cash Not Party in OL Proceeding.Certificate of Svc Encl ML20214R0531986-09-24024 September 1986 Response Opposing Eddleman/Coalition for Alternatives to Shearon Harris 860919 Request for Extension of Time to Respond to Commission 860912 Order.W/Certificate of Svc ML20214R3681986-09-23023 September 1986 Response Opposing Coalition for Alternatives to Shearon Harris/Eddleman Request for 2-wk Extension to Respond to Commission 860912 Order Re Exemption from Requirements of 10CFR50,App E.W/Certificate of Svc ML20214Q9531986-09-19019 September 1986 Requests Extension of Time Until 2 Wks from 860929 Deadline to Respond to 860912 Order Requiring Analysis of 10CFR50.12 Specific Exemptions ML20210D9001986-09-15015 September 1986 Motion to Reopen Record,Per 10CFR2.734,asserting That Commission Unable to Determine Reasonableness of Assurance That Plant Can Operate W/O Endangering Public Health & Safety.Certificate of Svc & Insp Rept 50-400/85-48 Encl ML20203M0021986-08-28028 August 1986 Response Opposing Coalition for Alternatives to Shearon Harris/Eddleman 860731 Joint Petition for Hearing on Exemption Request Re Full Participation Emergency Preparedness Exercise.W/Certificate of Svc ML18004A4681986-08-15015 August 1986 Response to Coalition for Alternatives to Shearon Harris 860702 Show Cause Petition Re Emergency Planning Requirements,Filed Per 10CFR2.206.Petition Should Be Denied Due to Lack of Basis for Action.Certificate of Svc Encl ML20205F3591986-08-15015 August 1986 Response to Coalition for Alternatives to Shearon Harris 860702 2.206 Petition to Show Cause Re Emergency Planning Requirements,P Miriello Allegations & Welding Insps.Show Cause Order Unwarranted.W/Certificate of Svc ML20205F4131986-08-14014 August 1986 Answer Opposing Intervenor 860730 Petition for Review of Aslab 860711 Memorandum & Order Denying Two Requests for Relief.Petition Lacks Important Procedural Issue.Certificate of Svc Encl ML20205F2251986-08-14014 August 1986 Answer Opposing Coalition for Alternatives to Shearon Harris & W Eddleman 860730 Petition for Commission Review Per 10CFR2.786.W/Certificate of Svc ML20203K1511986-07-30030 July 1986 Petition for Commission Review of Aslab 860711 Memorandum & Order Denying Coalition for Alternative to Shearon Harris 860609 Petition to Intervene.Certificate of Svc & Svc List Encl ML20212A6071986-07-25025 July 1986 Response to ASLAP 860708 Order Requiring Licensee to Update Re Emergency Plan.Chatham County Resolution Does Not Resolve Issues Re Adequacy of Plan.Resolution False. Certificate of Svc Encl ML20207J8281986-07-24024 July 1986 Response Opposing W Eddleman 860403 Request for Hearing on Util Request for Exemption from Emergency Preparedness Exercise Requirement.W/Certificate of Svc ML20211Q5221986-07-23023 July 1986 Answer Opposing Coalition for Alternatives to Shearon Harris 860721 Motion for 10-day Extension to File Brief Supporting 860721 Notice of Appeal & Request for Review of Aslab 860711 Memorandum & Order.W/Certificate of Svc ML20207E4231986-07-18018 July 1986 Response to Aslab 860708 Order to File Update to Re Chatham County,Nc Rescission of Prior Approval of Emergency Response Plan.Chatham County Endorsed Plan on 860707.W/Certificate of Svc ML20199L1671986-07-0808 July 1986 Suppl to 860624 Response to Conservation Council of North Carolina & Eddleman Request to Continue Stay Indefinitely.On 860707,Chatham County Adopted Resolution Which Endorses Emergency Plan.W/Certificate of Svc ML18019B0891986-07-0202 July 1986 Petition Requesting Institution of Proceedings Per 10CFR2.206,requiring Util to Respond to Show Cause Order Due to Failure to Meet Required Stds in Areas of Emergency Planning,Plant Safety,Security & Personnel Stress ML20206R8691986-06-30030 June 1986 Response Opposing Coalition for Alternatives to Shearon Harris (Cash) 860609 Petition for Leave to Intervene.Any Cash Participation Would Cause Delay in Proceedings.Petition Should Be Rejected as Untimely Filed ML20206P6641986-06-25025 June 1986 Response to Coalition for Alternatives to Shearon Harris & W Eddleman 860428 Motion for Stay of Immediate Effectiveness of Final ASLB Decision.Motion Should Be Denied.Certificate of Svc Encl ML20206J3641986-06-24024 June 1986 Response Opposing Conservation Council of North Carolina & W Eddleman 860609 Motion to Stay All Power Operations Per ASLB 860428 Final Decision.Motion Fails to Show Single Significant Safety Issue.W/Certificate of Svc ML20206J2051986-06-24024 June 1986 Response to Intervenors Conservative Council of North Carolina & W Eddleman Request to Continue Stay Indefinitely. Certificate of Svc & Svc List Encl ML20211D8641986-06-0909 June 1986 Requests to Continue Temporary Automatic Stay of ASLB Authorization of Full Power Operations Indefinitely.Low Power Operations Should Be Stayed Until NRC Completes Immediate Effectiveness Review & Encl Comments Resolved ML20199E4441986-06-0909 June 1986 Request to Indefinitely Continue Temporary Automatic Stay as to ASLB Authorization of Full Power Operations Until Commission Resolves Issue Raised in Encl Comments on Immediate Effectiveness Review ML20205T4001986-06-0909 June 1986 Appeal from Final Licensing Board Decision to Grant Ol.Board Erred in Determining That Widespread Drug Abuse Had No Effect on Const,In Accepting Applicant Nighttime Alert & Notification Plans & in Rendering Final Decision 1999-07-21
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RELuc.D< 1 "Gi4DENf May 9,1984 UNITED STATES OF AMERICA 00}g}[0 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSINWARD14 A10:28 In the Matter of ) CFFEOTTjQ-l-000/ETtigg
)
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL
)
(Shearon Harris Nuclear Power Plant, )
Units 1 & 2) ) ,
APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF EDDLEMAN CONTENTION 132C(II) t I. INTRODUCTION Carolina Power & Light Company and North Carolina Eastern Municipal Power t
Agency (" Applicants") hereby move the Atomic Safety and Licensing Board, pursuant to l 10 C.F.R. S 2.749, for Summary. Disposition in Applicants' favor of Wells Eddleman's Contention 132C(II). As grounds for their motion, Applicants assert that there is no genuine issue of material fact to be heard with respect to Contention 132C(II), and that Applicants are entitled to a decision in their favor on this contention as a matter of law.
This motion is supported by :
- 1. " Applicants' Memorandum of Law in Support of Motions for Summary .
Disposition on Intervenor Eddleman's Contention 64(f), 75, 80, 'and 83/84," dated September 1,1983;
- 2. " Applicants' Statement of Material Facts as to Which There is No Genuine Issue
-t to be Heard on Wells Eddleman's Contention 132C(II)"; ,
- 3. " Affidavit of Robert W. Prunty, Jr."
8405140555 840509 PDR ADOCK 05000400 e-Q O PDR ; ) ,
, - . - - - ,-.-- - ,- . , . , , - --,--,,,--.y. , . , - . r -~ . _ - - - - , , - . - -
r o
- H. PROCEDURAL BACKGROUND The Applicants' " Human Factors Design Evaluation Report of the Shearon Harris Unit 1 Control Room," (hereinafter "DCRDR") was first issued January 23,1983.1 In his
" Motion Concerning DCRDR Information," dated January 8,1983, Mr. Eddleman proposed his original contentions on the DCRDR. These contentions were based on the recently promulgated Supplement I to NUREG-0737, Requirements for Emergency Response Capability (December 1982) which Applicants had not yet had an opportunity to address.
By subsequent agreement of the parties and the Board, it was decided that a supplement to the DCRDR which Applicants intended to file on June 1,1983, would serve as the
" trigger" for amended, revised or reasserted contentions on the DCRDR. See Memorandum and Order (Ruling on Cost Saving Contentions, Discovery Disputes, and Scheduling Matters), dated May 27,1983, at 25. On July 2,1983, Mr. Eddleman filed his
" Response to 1983 Updated DCRDR Including Revised and New Contentions" which contained seven numbered contentions on the DCRCR. i i
Contention 132C(II), alleging that the DCRDR failed to comply with NUREG-0737, Supplement' 1, in several respects, contained seven different subparts. In its !
Memorandum and Order (Ruling on Wells Eddleman's Proposed Contentions Concerning Detailed Control Room Design Review (DCRDR), Richard Wilson's Motion to Withdraw Contentions, and the Conservation Council of North Carolina's Motion to Withdraw '
r Coittentions), dated October 6,1983 (" October 6 Order") the Board rejected all Eddleman Contentions on the DCRDR including all subparts of Eddleman Contention 132C(II) except subpart 4 on the layout of the Shearon Harris Nuclear Power Plant (SHNPP) control room. !
t i Eddleman 132C(II) as admitted states as follows: i With respect to layout [of the control room], [ Applicants 3 proposal arranges control and display cabinets such that they ;
l A copy was provided to the Board by letter dated January 21,1983.
block or impede the view of some others (See figure 2, page 12, where view of/from panels 8,9,10 and 11 is obscured by numbers 12,13,14 and 15 from numbers 6, 7, and 1, 2, 3, 4 and 5.
Numbers 6 and 7 are hidden from operators by 1 and 2 (as well as 3, 4 and 5). Numbers 16 and 17, the incore instrumentation and nuclear instrumentation system are almost totally behind the two blocks 1 through 5 and 6-7 with respect to the radiation :
monitoring equipment panels 12 through 15, the 8-11 block (start-up and generator) and the 1-5 block's sections 1 through 4 and possibly 5. Operator inability to see, read accurately, or integrete the information on these panels can imperil public safety in an accident.
During discovery on this contention, Applicants served two sets of interrogatories on Mr. Eddleman. " Interrogatories and Request for Production of Documents to Wells Eddleman Concerning Eddleman Contentions 9,11, and 132C(II)" (January 24, 1984);
" Interrogatories and Request for Production of Documents on Wells Eddleman's k Contention 132C(II) (Second Set)" (March 15, 1984). Mr. Eddleman filed his responses on ;
March 7 and on ' April 12 respectively.
Mr. Eddleman filed and served his " General Interrogatories and Interrogatories on Contentions 9,11, 41, 45,116,~ and 132CII to Applicants Carolina Power & Light el aj."
on March 26,1984. Applicants responded to these interrogatories on April 17,1984.
Discovery has now been completed on this contention and has failed to reveal any basis for the allegations or factualinformation that cells into issue any material facts.
III. ARGUMENT
, A. Standards for Summary Disposition I The general standards by which motions for Summary Disposition are judged are set forth in " Applicants' Memorandum of Law in Support of Motions for Summary Disposition I on Intervenor Eddleman's Contentions 64(f),75,80 and 83/84," dated September 1,1983, which is incorporated herein by reference.
B. There Is No Genuine Issue Of Material Fact As To Eddlemen 132C(II) i r
f t
Pursuant to the Board's October 6 Order, of the numerous issues raised by Mr. Eddleman concerning Applicants' DCRDR, only one narrow contention remains.
Eddleman Contention 132C(II) alleges that the layout of the SHNPP control room is such that public safety might be imperilled during an accident due to the inability of the control room operators to read and " integrate" information contained on various control i room panels. It is true that certain panels could be obscured from the view of a control !
room operator, if he were to locate himself across the room from the panels in question, [
in the vicinity of or behind other control room panels. Affidavit of Robert W. Prunty, Jr.
- ("Prunty Affidavit") at 3-4. This, however, is not a design flaw which will in any way hamper the operators in responding to emergency operating procedures. In fact the control room layout was finalized only after extensive human factors analysis to assure protection of public safety during both routine and emergency situation operation.
Prunty Affidavit at 2; see also NUREG-0737, Supplement 1, at 10 ("The objective of the r I
control room design review is to ' improve the ability of nuclear power plant control room ;
operators to prevent accidents or cope with accidents if they occur by improving information provided to them'(from NUREG-0660, Item I.D.1).") {
it is inevitable that regardless of the configuration of a control room, some scenario could be postulated whereby a control room operator could locate himself where he would not be able to view some of the control panels. However, the public safety will ,
remain protected by other design features of the control room. That is one purpose of the human factors analysis performed in the DCRDR: to configure the control room in i
such a way as to best protect public safety given physical and mental limitations of !
human control room operators. NUREG-0737, Supplement 1 at 10. Mr. Eddleman has not challenged the methodology which led to the layout of the SHNPP control room.
NUREG-0737, Supplement 1, requires that a qualified multidisciplinary review team (S 5.1.b.(i)) prepare a review program incorporating accepted human engineering !
principles. From April 1980 to January 1981, a review team consisting of CP&L, Ebasco l
Services, Inc., Westinghouse Corporation, and Essex Corporation performed a comprehensive human factors review of the SHNPP control room. Prunty Affidavit at
- 2. Appendix D of the Applicants' DCRDR (attached to the Prunty Affidavit as Exhibit 2) contains the Recommended Control Room Equipment Arrangement. That report used three primary positions for control operators whereby close proximity to Reactor Controls, Emergency Safeguards, and Emergency Power controls and displays and optimum viewing angles for all panels other than the Main Control Board are maintained. Prunty Affidavit at 2-3; DCRDR, Appendix D at 8-11. These three operating positions are indicated on Exhibit 3 to the Prunty Affidavit. Changes that were effected as a result of the review included bringing panels 1 through 5, panels 12 through 15, and panels 8 through 11 closer to operator positions. Prunty Affidavit at 3.
These changes significantly reduced signal densities and error rate probabilities.
DCRDR, Appendix D at 10.
The contention postulates that the view of certain control panels is obscured when or if an operator is located in various positions around the control room primarily away ;
from the Main Control Board. Mr. Eddleman picks three positions in the control room where he asserts an operator would have his view of some control panels blocked by others. See " Wells Eddleman's Response to Applicants' Interrogatories Concerning Contentions 9,11, and 132(c)(2)" at Response 132(c)(2)-1(a)("The contention does not say the operator is at the desk. Rather, it refers to the fact that an operator standing, e.g.
by one of panels 1 through 5 . . . has a view of panel 10 . . . blocked (apparently) by panels 12 through 15.") i Specifically, the contention alleges first, that panels 12 through 15 block the view of panels 8 through 11 from an operator standing at panels 1 through 5 and 6 and 7, or vice versa. Second, it is asserted that Panels 6 and 7 are blocked by panels 1 through 5 f from the view of an operator who is presumably located near the Main Control Board.
Finally, the contention states that an operator standing near panels 1 through 5,12 through 15, or 8 through 11 could have his view blocked of panels 16 and 17. ,
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A Note, however, in only onetof these three' scenarios (#2) is the postulated operator
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F ,'. position even close to one of the DCRDR primary positions at the Main Control Board.
L
- y While SHNPP. is[ operating, there will be at all times a minumum of two licensed g ,.
y , operators - a reactor operator and a senior operator -in the control room.10 C.F.R. S
) 50.54(h(()(i) and (iii). It is anticipated that much of the time, Applicants will have two
!.- s reactor,'oierators, one senior operator, and one shift foreman in the control room. l e
Prunty Affidavit 5t 3. 'Of the operators on duty in the control room, one must be at the i controls at all timp 10 C.'F'R. S 50.54(mX2Xiii). Accordingly, it is anticipated that one wv of the operators will work at the, opt::ator desk much of the time. Prunty Affidavit at 3.
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t E' . , Therefore, v:hile Mr. Eddleman hyppthesizes'tfiat the view of panels 8 through 11 may be obscured for an operator located 'al' panels 1 through-5, this is simply not a o , ,
norinsi position for even one of the control room operators; furthermore, if an operator s s 5 N,.
k ' ' were to be in this position, the other operator (s) would still have a commanding view of 3
panels 8 through 11 if needed. Prunty Affidavit at 4. The same analysis applies to the concern that the view of panels 16 and 17 may be otx3cuced from various postulated operator positions near panels 1 through 5, or 12 through 15, or 8 through 11. This is not n ws
, a typical paition where any of the operators would remain. IA at 4. Again, should an b[V "
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,OS6"ator find himself in such a position,'there wouM ' be one or more other operators in 4,a* 1- '
} y, th'e control room who would be able toyonitor,the equipment as necessary. IA
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scenario hypctkdied in Contention 132C(II) - an obscured view of
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[ 41 pQnels 6 and 7 - is clearly not 'd cone'ech ~since panel 7 (Condensate Booster Hydraulic
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Coupling) contains no controls or ', displays whatsoever on the front of the panel Id.,;
st l ,;DCRDR, Appendix D at 5 and 11. Panel 0 (Cooling T'o'wer and River Water Make-Up it Os Cfntrol) contains few controls an'd was\ evaluated as havinglninimal requirements for s i ,
even occasional monitoring. Prunty Affidavit at 4; DCRDR, ippendix D at 5 and 11. In 8 %,
fact, neither of these panels is safety related nor required to be operated in an accident l
scenario. Prunty Affidavit at 4.',8imilarly, panels 16 (Incore Instrumentation) and 17
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(Nuclear Instrumentation) require very little, if any, monitoring. M. There are even duplicate readouts of panel 17 on the Main Control Board. &
When questioned as to what specific information on these panels was necessary for i the operator, "to see, read accurately, or integrate," Mr. Eddleman was unable to come up with a factual answer. See Wells Eddleman's Response to Applicants Interrogatories [
re 9,11, and 132(cX2)," dated April 12, 1984 at Response 132(cX2)-1(b). Nor was Mr.
Eddleman able to be more specific on any of the panels he claimed were obscured from ;
view. When asked under what circumstances an operator was required to have an i unobstructed view of information on the panels he was concerned about, he responded, "This c' alls for more detailed analysis; read the contention for the basic info." Id.,at l Response 132(cX2)-1(bXii). I It should be noted that Applicants began assessing the control room design from a i
human factors perspective even before the Nuclear Regulatory Commission Staff issued j i
final guidance on the subject. A thorough and adequate human factors review, meeting i
all NRC requirements, has been performed on the SHNPP control room. Indeed, certain changes in the control room layout were made as a result of the human factors review.
Such changes contribute "to a significant reduction of risk and enhancement in the safety of operation." NUREG-0737 at 10. Thus, although some control panels may be obscured ,
from the view of an operator located in certain positions in the control room, this does ;
i not raise a safety issue: one panel (#7) has no displays; another (#17) has duplicate displays on the main control board; and two others (#6 and #16) require little to no monitoring. Panels 6 and 7, the only panels obscured from an operator positioned near the operator desk and/or Main Control Board are not safety related and are not required Most important, the operator positions to be operated in an accident scenario.
postulated by Mr. Eddleman for any of the control room panels to be obscured are not i i
typical operator positions, and even if one operator found himself in such a position, another operator would be in a position with an unobscured view.
0- Therefore, Applicants have demonstrated that there are no remaining issues of 1 material fact related to Eddleman Contention 132C(II). l
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/ -
IV. CONCLUSION ,
Based on the foregoing, Applicants respectfully request that tneir Motion for p
, Summary Disposition of Eddleman Contention l'J2C(II) be granted.
f, This the hday of 'hb.li8Y. v-
.- Respectfully submitted,
, -4 j, ~
Hill Carrow
' $_. Attorney o' Carolina Power & Light Compaiy
,. Post Office Box 1551
< ..- Raleigh, Nort.'t Carolina 2'Z602
, (919) 836-6839', -
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Attorneys for Applietmts:. f
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' Thomas A. Baxter
. " John H. O'Nelli, Jr. .. .
'F Shaw, PJttman, Potts & Trowbridge 1800 M 5troet, N.W. a
.r Waghington, D.C. 20036
, }' f/ .'. (20*.) 822-1000- ,
r
. A " Richard E. Jonea . "
. . "- [, ' ' Ssmantha Francis Flynn .
. > > J; Carolina Power & Light Company ' ~ , ,.
U ' ; Post Office Box 1551 .
,rRaleigh, Forth Carolina 27602
~ ' '(919) 836-6517 o, a a
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