ML20023C617

Clarification & Supplementation of 830303 Responses to 830131 Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20023C617
Person / Time
Site:	Harris
Issue date:	05/13/1983
From:	Wilson R WILSON, R.
To:	CAROLINA POWER & LIGHT CO.
References
ISSUANCES-OL, NUDOCS 8305170486
Download: ML20023C617 (4)

Text

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UNITED STATES OF AMERICA giir%

NUCLEAR REGULATORY COMMISSION ,g in the matter of CAROLINA POWER & LIGHT CO. Et al. )

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Dockelt. 50-40%.;f &p Shearon Harris Nuclear Power Plant, Units 1 and 2 ) and 50El01,0 L. t_

47 c b 13, May D Me CLARIFICATION AND SUPPLEMENTATION OF b #<~

RICHARD WILSON 3 MARCH 1983 RESPONSES N -

TO APPLICANTS 31 JANUARY 1983 INTER 0-GATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS In the attached letter, Applicants asked me to clarify some of my responses and specify some sources more precisely. This document then is a supplement to, not a replacement for, my 3 March 1983 responses. Extensions of filing date were granted by S. Flynn in telephone conversation.

General Interogatories 4,5,7 Because the ER and FSAR have been supplemented several times since my contentions were formula ted (March and April 1982), and because I have no way of knowing the exact pages of the previous form cf the doc: ment, which relate to my contentions (I did nct n

include page numbers in my notes, not knowing that the ER and FSAR would be amended

! by replacement), I cannot provide ;pecific page numbers, f will specify, as precisely as T.y notes will allow, the sections of ER & FSAR 1 based oy contentions on I did not-refer to the ER and FSAR in formulaty responses to inte ogatories and have not selected any sections for exhibits at hearing.

l Contention la based on ER 5.3-4 -

Contention Ib based on ER 5.3-4

' Contention Ic based on ER 5.3-4 Contention Id based on ER 5.3-4 Contentions le and if 1-4 based on FSAR 2-4 .

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8305170486 830513 Specific Interogatories PDR ADOCK 05000400 PDR g

la - 1(a) Answer should have been preceeded by No.

1(c) Answer was complete. Further analysis will follow receipt of Applicants responses to interogatories.

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l 1(d) Answer was complete l l(a) - 2(a) Answer should have been preceeded by No

. . '2(c) Answer was complete. Further analysis will follow receipt of Applicants responses to interogatories.

2(d) Answer was complete, f

.l(a) - 3(a) Answer should have been preceeded by No.

.3(c) Answer was complete. Further analysis will follow receipt of Applicants responses to interogatories.

3(d) There is no such interogatory.

l(a) - 4(a) Answer should have been preceeded by No.

4(c) Answer was complete. Further analysis will follow receipt of Applicants respcnses to interogatories.

4(d) Answer was complete.

lab) -'1(a) Answer should have been ,oreceeded by Yes.

1(c) Answer was complete. Further analysis will follow receipt of Applicants .

responser to-interogatories, i

f(d) NA i(c) - 1(a) linswer should have been preceed6d by No.

t 1(c) Answer was complete. Further analysis will follow receipt of Applicants L

responses to interogatories, f 1(d) Answer was complete.

1

. l(d) - 1(a) Answer should have been preceeded by No.

!' 1(c) Answer was complete. Further analysis will follow receipt of Applicants respo.1ses to interogatories.

l l(d) Answer was complete.

l f (e) - 3(b) Answer was complete.

4(b) Answer should have been preceeded by No.

4(c) Further analysis will follow receipt of Applicants responses to interogatories.

. _ _ . . . - - _ . = _

i' - page 3 -

• 4 j 1(f) - 1(a) Answer should be preceeded by No.

1 1(b) NA' l(f) - 2(a) Answer should.have been preceeded by No.

I -2(b) Answer was complete.

l(f) - 9(b)'I know of no analysis of this question.

l(f)' - Il(a) Answer should have been preceeded by No.

These responses are true and correct to the best of my information, knowledge and belief.

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Richard Wilson  :

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UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISS10N _

2 In tne raatter of CAROLINA POWER & LIGHT CO. Et al. ) ' Dockets.50-400

- Shearon Harris Nuclear Power Plant, Units I and 2 ) 'and 50-401 0.L.

CERTIFICATE OF SERVICE 1 hereby certify that copies of RICHARD WILSON INTER 0GATORIES TO APPLICANT (SECOND SET), RICHARD WILSON RESPONSE TO NRC STAFF INTEROGATORIES (3/18/83) and CLARIFICATION AND SUPPLEMENTATION OF RICHARD WILSON 3 MARCH 1983 RESPONSES TO APPLICANTS 31 January 1983 INTER 0GATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS have been served this 13th day of May 1983, by deposit in the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are marked with an asterisk, for whom service was accomplished by __

i Judge James Kelly Phyllis Letchin,. PH.D.

Atomic Safety and Licensing Board 108 3ridle Re.1 US Nuclear Regulatory Conrr,ission Chapel Hill N.C. 27514 Uashington, DC 20555

, 03:.' Read George F. Trowbridge CHANGE /ELP Shaa, Pittman, Potts, & Trowbridge Box 524 1800 M. St. NW Chapel Hill, N.O. 27514 Washington, DC 20036 Ruthanne G. Miller. Eiq.

Office of the Executive Legal Director Atomic Safety an<1 Licensing Board Attn Dockets 50-400/401 0.L. U.S. Nuclear Regulatory Commission USNRC Washington, D.C. 20555 Washington, DC 20555 Deborah Greenblatt, Esq.

Office of the Secretary 1634 Crest Rd.

Docketing and Service Station Raleigh, N.C. 27606 Attn Dockets 50-400/401 0.L.

USNRC Bradley W. Jones, Esq.

Washington, DC 20555 U.S. Nuclear Regulatory Commission Region 11

! John Runkle 101 Marrietta Street CCNC Atlanta, GA 30303

, 307 Granville Rd.

Chapel Hill, N.C. 27514 gj3 Travis Payne /

l Edelstein & Payne Certi fied by l- Box 12643 Raleigh, N.C. 27605 Wells Eddleman 718-A Iredell St.

Durham, N.C. 27705 l . .

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