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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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BAych;[,198h UNITED STATES OF AMERICA 'NC NUCLEAR BEGULATOBY COMMISSION 84 MR 12 All:25
,n . -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARDD'66 M Glenn O. Bright "U Dr. James H. Carpenter James L. Kelley, Chairman l
In the Ifatter of CAROLINA POWER AND LIGHT CO. et al. )
(Shearon Harris Nuclear Power Plant, )
Units 1 and 2) ) ASLFP No. 82-h68-01
) OL Wells Eddleman's Reply to Apolicante and Staff on SER contentions and Motion to Cont'.nue Deferral of narts of Eddleman Contention 107 Applicants, on February 6, 198h, onporod the notion and admicsion of all contentions on the S59. Stnff asked ne for an e:rtension of tine for filing their resconsen; it was granted.
Nithout trying to correct all the nisimrensions o* the S?9 contentiens that Apolicants seen to be conveying, lot ne clarify a few of the more imnortant points. The TD! diesel content'ons rest on.NRC Staff's finding a widespread breakdown ir TJ7 duiesci qualit" and analysis that is anplicable to Harric. Content *.ons on the smaller issues Applicants point to could quite nossibly have beer filed earlier.
This epntention probably could rot have been, until the Staff issued TM Novak (NRC)s letter- to Clinton of ppP - dated 19-1 8 IproblemsapplytoHarris.
2, its statement ( received by ne 12-19-$ } . 3 that the TD gene =al Since then, the Staff has had a neet'nc I
- on the TDI diesels and scnt out a transcript. That transcrint reveals I '
-< widespread nroblems. As a result, the Staff requested more data n
I By oral order of Februar" 14,19Sh, Judge Kelley alloued filino g ef*)
of this response, within no nore than 10 days of ny receirt of the staff filing, preferably no more than 5 days tha=eaftew. I "eceived it ?/21 but illness, which Judge Kelley & T discussed (usaaubv w phone,
.a p, hrevented filing tp> vngl pm.
2 . .
concerning all tynet of diesels they make, including tha V-Pos which are at Harris. I have nislaid the ikE notice, but it is a recent one (Feb 1984 or thereabouts), and was sent to all boards for plants with TDI diesels. The record in the Shorehen case shows that the Applicants there are installing new diesels (I believe in a new building built to house the new diesels )
to get around trying to fix or disorove the TDI diesel oroblems there.
The Staff has stated that no plant with TDI diesels should be licensed. That should be enough basis to admit Eddle-nn 1978 right there, and I believe notice of that oosition was sent to all boards (including this one ) where TDI diesiex1s are involved with the plant seeking a license.
Staff cites (vs SEE contentions) an appeal board decision that the Staff's obligation to help Boards by telling then about generic safety issues "is not enforceable by a cart to the OI.
eroceeding". However, this decision oostdates the f!11ng of contention 107 by about a year. Contention 107 should not be judged under it.
Re contention 173, Staff alleges the information was available in the FSAR. But it aopears the Staff nade inquiries of its own, indicating sone inadequacy in Applicants ' analysis.
Staff alleges I haven't shown any useful ernertise on reliability.
I an reasonably familiar with reliab4.11ty testing methods, sta tist? cs, and with logical analysis of systens fo" reliability. This experience should be of use in establishing a sound record on this issue.
Staff says why should events like those in the contention be costulated? Why-- because they can thannen. If you have to consider earthquakes and tornadoes in plant design, it is logical to consider then as happening to the power alines where they cone into the plant, also. That 's just basic good sense.
3 Staff argues,re earthquake contentions 17h-77, that some of them (unspecified) have adequate basi.m and specificity, but they could have been filed earlier (Staff r esnonse at 13, 2-16-8h).
However, their argument is a votential catch-22. If I had raisdd such a contention based on the DSE9 as Staff suggests, they could have argued it was oremature or had insufficient basis because they were going to address tha issue in the SER (as thev state in tha DSER).
Thus the contention would have been deferred to the SER or I mirht have been advised to make a contention when the SEM was issued, had such an argument been accented. But now, not havinF made such a contention before, I'm attacked for not having made it, even though the bases of the contentions 17h-77 are in the SEP and ACPS s tatements of the Staff.
Staff appears to accent contentions 178 and 179. (p.16).
They do argue that I have demonstrated no expertise in design and construction of diesel generators. However, I do naxa know about industrial mathining, reliability testing, netallurgy, materials science, and systems (having studied all of these at the college level and done reliability testing nyself for some clients).
Also the Catawba board recognized a Duke Power Connany emnloyee as an exnert on diesel generators who had the "excevtise" of working on his own car (which, I am informed, was not a diesel). I have done some work on a car of mine which has a gasoline V-8 engine, c.g. adjusting the valves, replacing seals, adjustinn the engine and tuning it up), and while I don't think that's a lot of exnertise, it may be as good as the Duke witnessax', and does show that I know how engines work (mine still runs OK) mand have basic familiarxity with them.
Re contention 181, Staff alleges (p.17) that it should be rejected, though they don't challenge its tineliness nor deny its basis.
kl h-However, the failure of Auplicants to nrovide adequate infornation N !
to the Staff re control room design Is a problem, and thew $9 no guarantee that the Staff's SER supplement will solve it. TC n l l There is a contradiction between the Appeal Board rulings cited by Staff (that the SER is not litig~able) and the clear statement that 4
~s the SER is the basic safety documen* deonsidered in this proceedinF, 2 which I believe our Board has made. If the Staff files the SER and s C
it is a basic document, its defects or inadecuacies should be litiFabler o
just as defects in the DES or FES are litigable. If thev make a $
statenent, they should be prenared to defend it. He e, however, h
the Staff is naking a statement on faith that the control roon l eJ design will prove OK. That should be litigable, sir:c e CW L has f not yet provided the information requii'ed (though CP&I c1cins it } '
has conpleted its DC9D9. CP&L didn't follow standawd N9C control room design guidance in its review, either).
Anolicants, as usual, a near to attack the merits of 3
most of my SER contentions. On contentions 17h-177 they appear to @
concede basis and snecificity, and attack timeliness, sayinF 7 could g have fi E ured out these contentions earlier. I am baffled by th61r assertion (pe22-23, fn h) that T should have challenged the Staff's ha c,
position on Harris before they took a nosition (Staff said it would .
respond to USGS in the Harris SE9 They did and I challenged the f response). See argument above (ton of o.3) re the " cater-2x2" = thi s CP&L argument also entails.
Re contentions 178-179 (op2hff), the list or un P6-27 does not aupear to ine'lude any documents requirinF action by Har"is plant personnel. The failure nattexrn I refer to in the contentions is the s awide. one identified by N90 staff in its 12-1 letter, i.nd confirmed by later staff action and inquiries which were sent te nur Board. [
Fe contention 181, Staff rsvised the SE9 up til November 1983 I found this out via a FOIA,#8h-35 (see document list in lette" fron i N9C to Eddleman resconding to this FOIA,Feb 7, 108h (cony attached). 1 Yet the Staff did not OK CP&L's resconses of August and Sentenber in \
the SER. It's reasonable to infer something was wrong with the .,
because the Staff OK'd lots of othen stuff in the SER. Staff notes (p.1V-- A CP&L did not file a statenent, of how all DCD3' regs we.uld be net.
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. UNITED $TATES NUCLEAR REGULATORY COMMISSION
{ .l WASMNGTON. D. C. 20555
\..../ FEB 0 71984 Docket No. 50-400/401 Mr. Wells Eddleman Staff Scientist Box 2901 IN RESPONSE REFER Durham, NC 27705 TO F01A-84-35
Dear Mr 8.ddleman:
This is in partial response to your letter dated January 12, 1984, in which you requested, pursuant to the Freedom of Information Act, all extant drafts of sections or portions of the Safety Evaluation Report (SER) for the Shearon Harris Nuclear Power Plant, along with documents showing dissenting opinions of the staff reviewers.
Appendix A is list of documents responsive to your request. These documents are being placed in the NRC Local Public Document Room (LPDR) located at the Wake County Public Library,104 Fayetteville 5treet, Raleigh, North Carolina, 27601. In order to obtain access to these documents, please contact Mr. Roy Dicks at the LPDR on (919) 755-6092. .
Our search for additional documents relevant to your request is continuing.
You will be notified later of our determination.
Sincerely,-
s r-l J. N. Felton, Director Division of Rules and Records Office of Administration
Enclosure:
Appendix A I: :. -,
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q P' F0!A-84-35 . .
APPENDIX A
- 1. Memo 4-27-82, from Benaroya to Miraglia, " Request for Additional Information on Shearon Harris Nuclear Power Plant, Unit Nos. I and 2."
(4 pages)
- 2. Merno 5-17-82, from Benaroya to Miraglia, " Fire Protection Request for Information for Shearon Harris Units 1-4." (7 pages)
- 3. Memo 10-20-82, from Knight to Novak, " Draft Safety Evaluation Report -
Geology and Seismology - Shearon Harris, Units 1 and 2." (22 pages)
- 4. Memo 10-21-82, from Rubenstein to Novak, "Shearon Harris Draft Safety Evaluation Report." (70 pages)
- 5. Memo 10-28-82, from Benaroya to Knighton, "Shearon Harris Draft Safety Evaluation." (1 page)
- 6. Memo 11-4-82, from Rubenstein to Novak, " Draft Safety Evaluation Report for Shearon Harris Nuclear Power Plant." (171 pages)
- 7. Memo 11-9-82, from Lear to Kerrigan thru Knight, " Draft Safety Evaluation Input and Requests for Additional Information - Geotechnical Engineering."
(40 pages)
- 8. Memo 11-17-82, from Johnston to Novak, " Draft Safety Evaluation for Shearon Harris Nuclear Power Plant, Units 1 and 2 (OL), Carolina Power & Light Company, Docket Nos. 50-400/401." (21 pages)
- 9. Memo 12-3-82, from Lear to Knighton thru Knight, " Hydrologic Engineering Input to the Shearon Harris Draft SER." (25pages)
- 10. Memo 12-6-82, from Knight to Novak, " Draft Safety Evaluation Report."
(16pages)
- 11. Memo 12-21-82, from Knight to Lainas, " Revision 1 to Draft Safety Evaluation Report - Geology and Seismology - Shearon Harris, Units 1 and 2." (24 pages)
- 12. Memo 12-22-82, from Muller to Novak, "Shearon Harris Draft SER Input."
(9pages)
- 13. Memo 1-10-83, from Johnston to Novak, " Supplemental Safety Evaluation Report Input for Environmental Qualification of Mechanical and Electrical Equipment for Shearon Harris." (3 pages)
- 14. Memo 8-26-83, from Knight to Novak, " Safety Evaluation Report for Environmental Qualification of Equipment Import;nt to Safety for Shearon Harris Units 1 and 2." (5 pages) i w- - ,
r
.- ' Re: F01A-84-35 APPENDIX A
- 15. Memo 8-31-83, from Rubenstein to Novak, " Safety Evaluation Report -
Shearon Harris Units 1 and 2." (78pages) 16 Memo 9-1-83, from Rubenstein to Novak, "Shearon Harris Safety Evaluation Report." (69pages) 17.. Memo 9-2-63, from Lear to Knighton thru Knight, " Final Safety Evaluation Report - Geotechnical Engineering." (27pages) 18, Memo 9-8-83, from Knight to Novak, " Safety Evaluation Report - Geology and Seismology - Shearon Harris, Units 1 and 2." (45pages)
- 19. Report, 8-22-83, Shearon Harris SER (M) , " Auxiliary Systems."
(50 pages)
- 20. Memo 9-14-83, from Rubenstein to Novak, " Safety Evaluation Report for Shearon Harris Nuclear Power Plant, Units 1 and 2, Auxiliary Systems Branch." (243 pages)
- 21. Memo 9-14-83, from Johnston to Novak, " Hydrologic Engineering Irput to the Shearon Harris SER." (24 pages)
- 22. Memo 9-15-83, from Knight to Novak, " Safety Evaluation Report (Structural Engineering)." (16pages)
- 23. Memo 9-21-83, from Russell to Novak, "SER for Shearon Harris Nuclear Power Plant - Plant Personnel Training." (21 pages)
- 24. Memo 10-4-83, from Kniel to Knighton, "SER Input - Shearon Harris Nuclear Station, Units 1 and 2." (26 pages)
- 25. Memo 10-6-83, from Knight to Novak, "Shearon Harris Nuclear Power Plant Unit #1." (4 pages)
- 26. Memo 10-6-83, from Johnston to Novak, " Safety Evaluation for Shearon Harris Nuclear Power Plant Units 1 & 2 (0L), Carolina Power & Light Company, Do:ket Nos. 50-400/401." (3 pages)
- 27. Memo 10-7-83, from Houston to Novak, "Shearon Harris 1 & 2 - Safety Evaluation Report (SER)." (49 pages)
- 28. Memo 10-11-83, from Johnston to Novak, "Shearon Harris SER Input."
(6pages) 4
- 29. Memo 10-28-83, from Rubenstein to Novak (Enclosure 3), "Shearon Harris SER Update - Docket Nos. 50-400/401." (50pages)
O
e 3 - Re: F01A-84-35 . .
APPENDIX A 30, Memo 10 2.-83, from Lear to Knighton, "Shearon Harris SER Input (Revisit,..J - Structural Engir.eering." (4 pages)
- 31. Memo 11-9-83, from Partlow to Youngblood, " Harris Draft SER Section 17."
(3 pages)
- 32. Memo 11-3-83, from Johnston to Novak, " Fire Protection Revised Safety Evaluation Report - Shearon Harris Units 1-4." (2 pages)
- 33. Memo 11-10-83, from Johnston to Novak, " Revised Hydrologic Engineering Input to the Shearon Harris SER." (15 pages)
- 34. Memo 11-14-83, from Lear to Knighton, "Shearon Harris SER Input (Revision) - Structural Engineering." (3 pages)
- 35. Memo 11-17-83, from Rubenstein to Novak (Enclosure 4), "Shearon Harris SER Update (Docket Nos. 50-400/401)." (89pages)
- 36. Memo 11-18-83, from Muller to Novak, "METB Input for Safety Evaluation Report for Shearon Harris, Unit Nos. 1 and 2." (275pages) 37, Memo 11-18-83, from Lear to Knighton thru Knight, " Update to Final Safety Evaluation Report - Geotechnical Engineering." (6 pages) 38, Memo 11-18-83, from Johnston to Novak, "Shearon Harris SER Input-Supplement." (2 pages)
- 39. Memo 11-23-83, from Srinivasan to Sheron, "PSB Review of Draft Safety Evaluation Report Response to Open Item 47 on Reactor Coolant System Vents for Shearon Harris Units 1 and 2 - Docket Nos. 50-400 and 50-401."
(2pages)
- 40. Memo (undated) from Matthews to Knighton, " Emergency Preparedness Input for Shearon Harris SER." (06 pges)
- 41. Memo 12-14-83, from Johnston to Novak, " Fire Protection Supplemental Safety Evaluation Report." (12 pages)
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3 Box 2901 3)nrham NC 27705 12 January 1984 Joseph Felton FREEDOM OF INFORMATION Div. of Rules & Records ACT REQUEST USNBC Qff g _Q l Washington, DC 20555
Dear Joseph Felton,
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1 Under the Freedom of Infom ation Act, NC Public Interest Research Group, a nonprofit organization, hereby requests copies of all extant drafts of sections or portions of the Safety Evaluation Report (SER) for tne Shearon Harris Nuclear Power Plant, and any documents by or in the possession of Staff reviewers which show dissenting" opinions as .to any contents or concinaions of the Harris SER.
NC PIRQ ic a research and advocacy organization with over .3,000
)
members and publishes reports on various matters affecting the public interest, e.g. generic drugs, tenant rights, rape awareness, utility rates, toxic chemicals, and nuclear waste transportation.
NC PIRG is ful.Ly qualified to present information from this request to be used by the public, and therefore requests a waiver of fees since we do not have sufficient funds to pay for extensive copying wnich may be required, given that the drafts could exceed the 2 inch thick SER in extent. Please feel free to contact me' at 919-286-2275 (work) or 919-286-3076 (home) concerning this request.
u Wells Eddleman Staff Scientist g 9 0
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