ML20063A445

Response Opposing Applicant 820810 Position on Svc of Documents to Intervenors.Lack of Svc Creates Time Delays Not Conducive to Prompt Intervenor Responses.Certificate of Svc Encl

ML20063A445
Person / Time
Site:	Harris
Issue date:	08/17/1982
From:	Eddleman W AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8208240341
Download: ML20063A445 (4)

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C- 00f;KETED

• August 17, 1982 USHRC USA- URC Dockets 50-L'00 Before the Atonic Safety & Licensing Board & $MO$6E20. A9 50 Q D ^

b Wells Eddlenan's responsed to " Applicants ' nosition 0FFICE OF 3ECRt W'Y DOCKEfm3 & SU:vtCE J on service of documents to intervenors" of August 10 BRANCH h

p I can't take seriously CP&L's attennt not to serve copies

-g kp of the documents they originate. All it does is waste time and create inconvenience. NRC Staff has been coonerative in

'providing copies of what they originate, but their summaries Q %<4 like are so brief as to be substanceless, xxgr "we met CP&L and y

g talked about hydrology and feel their nositions are nostiv 10K".

v6) A Cov4- letlW (Af ghco4c pu) w9 telis snwaf eKr$fS, tM* 4A} 0V'shdk/ sh Sf hC.,

% Even if Apulicants' claims of cooperation are taken at face value, it took an hour or so of talking to CP&L, and four weeks,

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$ to get copies of h anendments to their FSAR and ER. (Copies of 1, V4 CP&Lis misleading cover letter, and my response which fills in 6A_ 4.':s some of the more important omissions from it, are attached.)

Such time delays are not conducivez to pronpt responses from A

y) intervenors, yet how can one respond to a document unless one

- v (hasit? CP&L's attempts to place anendments directly in the local M 38 public

% document rooms actually d to confusion uhen they do not t

m i update the main FSAR or ER index, throw out the sheets showing s

what pages have been replaced (the "out and uitch" sheets) and white-8 out the marks showing where only a few words have been changed,

%Q L thus forcing one to read whole pages to see if CP&L's clain that C gsuch changes are uninportant is true (if so uninportant, why nake I

0 pppca# ytfeance 4b %scoby Wks" 6 Mf OW M g 3p (t(es -11ase kcumeh

• H& Mtastf O %fL%?Nh W$ry

$ ]2'"$0h Intervenors must serve CP&L with document's intervenors originate.

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$yINRC Staff is serving all of us with what they originate. I see no

~- reason for CP&L not to do the sane, to avoid the above problems

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and in fairness to the other parties.

8208240341 820817 g  % o f DR ADOCK 05000 cf)O

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Carolina Power & Iight Com 'N POST OFFICE BOX 1551 Raleigh, North Carolina 27602g ASD 20 49:51 LEGAL DEPARTMENT OFFIc-Wriur's Direct Dial Number 00cghg{gyLgra;<s (919)836 7707 BaANCH Telecopier (919) 836 7678 August 9, 1982 Mr. Wells Eddleman 718-A Iredell Street Durham, North Carolina 27705

Dear Mr. Eddleman:

At the special prehearing conference in the Shearon Harris operating license proceeding on July 13-14, 1982, you requested that CP&L furnish you with copies of Amendments 1, 2 and 3 to the Harris Final Safety Analysis Report (FSAR) and Amendmant 1 to the Harris Environmental Report (ER); and you offered to pay CP&L's cost of providing you with such documents. CP&L has agreed to furnish you with copies of those documents at CP&L's cost.

l I advised you by telephone on August 6, 1982 that the cost to CP&L of providing you with the documents would be $270.00 and you requested me to send them to you.

Enclosed are copies of FSAR Amendments 1, 2 and 3 and;ER Amendment 1.

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t Please make your check in the ainount of $270.00 payable to Carolina Power & Light Company and send it to my attention.

Sincerely,

/ . 00

+ Tee rm e-< m

1. Samantha Francis Flynn Associate General Counsel SFF/dlt Enclosures

Tiumntha Frar:cis iicnn Associa.te General Counccl CP&L .

Dear-'S5mantha Francis Flynn,

Enclos-ed is my. check for 3270.00 to Carolina Power E Light Co. for Sbearon Habris' FSAR amendmentis 1 through 3 and .ER ameridment'. l_

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Tour letter omits some aspects of this exchange that'I note here:

(1) On_ July 1h,1982 I had asked you to determine the costs-of FSAR Amendnents 1 thrcugh 3 and IR Amendments 1 through 3 I. did not give a " blank check" aErcement to nay any such costs, but rather asked you to deternine CP&L's costs and contact ne the next. week, which you said would be enough tine to find the

. cost informatien, you believed. .

(2) Irr the week fellowing, you did contact me, and .eaid CP&L's cost of all 6 amendnents would be 42!t0.00 delivered, and that.. this; would . include.. the "put. and piteb? sheets that tell where' this- infornation goes in the PSAR. and ER.; . I asked if you had that broken down by cost for each amendment. You had that data in hand, and we discussed y getting only FSAR amendments 1 through 3 and n amendment' 1 fron C?&L, since I had been able to obtain ER anendmentss 2 and 3 elsewhere at a lower cost.

You were flexible and agreed to urovide FSAR amendments 1 through 3 and ER amendnent 1 at a cost of ^pl80.00 which you stated was CP&L's cost based 'on the infornation xx you had in hand. I asked -

you 'to send a bill for that annunt along with the informat" on, which was to be delivered by Unite.d 'a-cel Service.

'You had als o checked , at nw recuest, the cost to zerox (photo 9 copy) the- amendnents instead- of printing then. You renorted that that cost was higher, includin5 labor of "$7 an hour or whatever -

the neonle that do tha t make".. Under those considerat'ons ue agreed en the price of $180.00 and delivery as stated abo.ve. . -

(3) On August 6, 1982 you.did telenhene me, and stated that

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due to errors in the information on cost from CP&L's other ceonle, the urice for FSAR amendments 1 through 3 and "R anendnent 1, including "nostaSe" (i.e. delivery charges) would be $270.00.

I was rather surorised, but agreed to pay that price. .I no.te here that I have no idea wha.t it actually cost CP&L to "roduce this rr.terial.- I have taken" your word for it. I have aleo taken

.your word for the increase in cost and the error involved.

I recall your saying that labor charSes had been omitted from the $180.00 price.

(14) my notes on thct conversation do not natch your statenents in your phone call of August 9, but I do not think that is worth l rehashing and make this note only so you do not think I have deliberately onitted this matter. My objective has been to get this inf ormat'.on . I now have it in hand and cresune it is conclete although I have not been able to inspect it in any detail.

That is because of g inability te lif t th $.n6s . The tons of the amendments do show the "put and nitch" sheets and ther a*e bound l as conolete sets. / p f

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UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION In the matter of CAROLI!'A P0'ilER & LIGHT CO. Et al. ) Dockets $0-h00 Shearon Harris Nuclear Power Plant, Units 1 and 2 ) and 50lth01 0.L.

CERTIFICATE 0F SERVICE I hereby certify that copies of bM/6t+ tap f58&t5e g[/C

$e pat 00seh a on ser+ a of docamots A o%Ers" HAVE been served this f h day of [t(4Dd 198h, by deposit in S y J .. !

h6d the US Mail, first-class postnge prepaid, upon all parties whose W6 names are listed below, except those whose names are parked with kb an asterisk, for whom service was acconnlished by -

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\ eW Judges James Kelley, Glenn B=ight and James Ca y nter (1 cony each) 6:PA)MAtomic Safety and Licensing Board US Nuclear Regulator Washington DC 20$$$ y Commission George F. Trowbridge (attorney for Anplicants)

Shaw, Pittman, Potts & Trowbridge 1800 M St. NW Washington, DC 20036 Office of the Executive Legal Director Phyllis Lotchin, Ph.D.

Attn Docke ts 50-400/401 Q?L. 108 Bridle Run USNRC Chanel Hill

' NC 2751h Washingt~on DC-20555 .

Dan Read Docketing and Service Section -nm CHAUGE/ELP Attn Dockets 50-400/401 0.L. Box 524 Office of the Secretary Chapel Hill NC 2751h USNRC Washington DC x 20$$$ Pat & Slater Newman CANP John Runkle 2309 Weynouth Court CCNC Raleigh NC 27612 307 Granville Rd -

Chapel Hill Nc 27514 Travixs Payne Edelstein & Payne Ra e ITC 27605 _

g Richard Wilson, M.D. Certified by g#sezw 729 Hunter St.

Apex NC 27502

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