ML20024B117

Response to First Set of Interrogatories.Affidavit of Svc Encl

ML20024B117
Person / Time
Site:	Robinson
Issue date:	06/27/1983
From:	Matthews B HARTSVILLE GROUP
To:	CAROLINA POWER & LIGHT CO.
Shared Package
ML20024B114	List: ML20024B113 ML20024B117
References
NUDOCS 8307050236
Download: ML20024B117 (6)

Text

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A UNITED STATES OF AMERICA y NUCLEAR REGULATORY COMMISSION ,

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Before the Atomic Safety and Licensing Board ,

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In the Matter of ) 'q[ E cket No. 50-2 CAROLINA POWER & LIGHT COMPANY

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(H.B. Robinson Steam Electric ) June 27, 1983 Plant, Unit 2) )

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RESPONSES OF THE HARTSVILLE GROUP TO APPLICANT'S FIRST SET OF INTERROGATORIES The Hartsville Group hereby responds to " Applicant's First Set of Interrogatories To Hartsville Group."

1(a). At this point, the Hartsville Group has not identi-fied any model other than the Cost Assessment of Nuclear Sub-stitution (CANS) model which it intends to or contemplates using in support of the portions of Contention 3 which refer to early retirement of Robinson 2 as the most cost-beneficial alternative. If any other model is so identified and adopted, Hartsville will timely notify the parties.

IF the CANS model is employed in this proceeding by Hartsville, that model may differ in detail from that used by Energy Systems Research Group (ESRG) in preparing its Study of the Economics of Closing the Indian Point Nuclear Plants.

Other analytical methods may be employed by The Hartsville Group in support of its Contention 3. Until the EIS is received and reviewed, however, Hartsville cannot identify what other analytical methods it will rely upon. At this point, those would be employed on cross examination rather 8307050236 830627 PDR ADOCK 05000261 9 PDR

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than in direct testimony. If that changes, Hartsville will notify the parties in a timely fashion.

1(b). See response to 1(a) .

2(a). No.

2(b). See response to 2(a).

2 (c) . No.

2(d). The Hartsville Group is currently engaged in discussions with ESRG with regards to their availability to conduct and present a study of early retirement of Robinson 2 in these proceedings.

If ESRG is not available to it, Hartsville will seek other expert assistance. The parties will be informed as soon as expert assistance is engaged.

2 (e) . No.

2 (f) . The Hartsville Group has requested the data necessary to establishing the data inputs to any model from the Applicants.

To date, Applicants have not provided that information to us. We do not know.

Applicants did furnish certain materials to Hartsville's Authorized Representative, B.A. Matthews, in connection with SC Public Service Commission Docket No. 82-328-E which may contain the answers to these questions. Without expert l l

assistance, however, Hartsville has been unable to identify which inputs would be employed in a model.

Applicants possess all materials previously provided to Matthews.

.c-2 (g) . See response to 2 (f) .

Dated: June 27, 1983

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e-l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

Before the Atomic Safety and Licensing Board In the Matter of )

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CAROLINA POWER & LIGHT COMPANY) Docket No. 50-261 OLA

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(H.B. Robinson Steam Electric ) June 27, 1983 Plant, Unit 2) )

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AFFIDAVIT I, B.A. Matthews, do hereby affirm that I am the Authorized Representative of the Hartsville Group in this proceeding.

I have been responsible for answering the Interrogatories on all The Hartsville Group's contentions. Those responses are true and correct to the best of my knowledge and belief.

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0WWA4556 Affirmed and subscribed to before me this 2.7" day of June 1982.

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NOTARY PUBLIC FOR SOUTH CAROLINA (L.S.)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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CAROLINA POWER & LIGHT COMPANY) Docket No. 50-261 OLA

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(H.B. Robinson Steam Electric )

Plant, Unit 2) )

)

AFFIDAVIT OF SERVICE Appeared before me B.A. Matthews who does affirm that he caused to be placed in the United States mail, U.S. postage prepaid copies of the attached RESPONSES OF THE HARTSVILLE GROUP TO NRC STAFF INTERROGATORIES AND REQUESTS FOR THE PRO-DUCTION OF DOCUMENTS and RESPONSES OF THE HARTSVILLE GROUP TO APPLICANT'S FIRST SET OF INTERROGATORIES addressed to the attached Service List. ,

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Affirmed and subscribed before me this 2 7" day of June 1982.

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NOTARY PUBLIC FOR SOUTH CAROLINA (LS)

My Commission Expires: 13 .1 % 3

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N UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter.of: )

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CAROLINA POWER & LIGHT COMPANY) Docket No. 50-261 OLA

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(H.B.' Robinson Steam Electric )

Plant, Unit 2) )

I SERVICE LIST Morton B. Margulies Dr. Jerry B. Kline Chairman Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. David L. Hetrick George F.Trowbridge, Esq.

Professor of Nuclear Engineering Shaw, Pittman, Potts & Trowbridge University of Arizona 1800 M Street NW Tuscon, AZ 85721 Washington, DC 20036 Samantha Francis Flynn, Esq. Atomic Safety & Licensing Board Carolina Power & Light Co. U.S. Nuclear Regulatory Commission P.O. Box 1551 Washington, DC 20555 Raleigh, NC 27602 Atomic Safety & Licensing Docketing & Service Section Appeal Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Myron Karman Karen Long, Esq.

Office of Executive Legal NC Utilities Commission Public Staff Director P.O. Box 991 U.S. Nuclear Regulatory Commission Raleigh, NC 27602 Washington, DC 20555 1

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