ML20074A473
| ML20074A473 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 05/11/1983 |
| From: | Tronbridge G, Trowbridge G CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | HARTSVILLE GROUP |
| References | |
| 83-484, ASLBP-83-484, ISSUANCES-OLA, NUDOCS 8305130092 | |
| Download: ML20074A473 (6) | |
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May 11, 1983
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION p Sm,,,
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BEFORE THE ATOMIC SAFETY AND LICENSING BOAd612fggy j,0
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In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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Docket No. 50-261-OLA
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(H.
B.
Robinson Steam Electric
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ASLBP No. 83-484-03LA Plant, Unit 2)
)
APPLICANT'S FIRST SET OF INTERROGATORIES TO HARTSVILLE GROUP The following interrogatories are addressed to Hartsville Group Contention 3.
l(a).
In support of its contention that the retire-ment of Robinson 2 would be cost-beneficial, does Hartsville Group intend to rely on any model or cost-benefit analysis l
methodology other 'than the Cost Assessment of Nuclear Substitu-tion model (hereinafter ESRG model) contained in the October, 1982, Study of the Economics of Closing the Indian Point Nuclear Power Plants prepared by Energy Systems Research Group, Inc.?
(b).
If so, identify any such model or methodology l
and the document, study or report in which it is contained, and either furnish any such documents, sttGies or reports to Appli-cant's counsel or make any such documents, studies or reports available to Applicant for copying.
8305130092 830511
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2.
With respect to Hartsville Group's contention that application of the ESRG model would show that the proposed steam generator repair to keep Robinson 2 operating is not cost-effective:
(a)
Have any written calculations been made by or on behalf of Hartsville Group applying the ESRG model or any comparable model or cost-benefit analysis methodology to the re-a tirement of Robinson 2?
(b)
If the answer to (a) is yes, either furnish to Applicant's counsel or make available'for copying by Applicant any such calculations.
(c)
Has Hartsville Group engaged the services of ESRG or any other consultant to perform 4
such calculations?
Identify any such consultant.
l l
l (d)
If the answer to (c) is no, does Hartsville Group plan to engage the services of ESRG or any other consultant to perform such calcula-tions?
Identify any such consultant.
(e)
Does Hartsville Group have within its member-i ship any individual or individuals qualified to make suc.1 calculations?
If so, identify
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the individual or individuals and describe his I
or their qualifications.
l (f)
Provide the principal assumptions to be used by Hartsville Group as input for the ESRG model or other model or methodology.
These include, without limitation, the assumed capacity factor for Robinson 2, the assumed CP&L system load growth, the assumed nuclear fuel and fossil fuel costs, the assumed nuclear and fossil plant operating and maintenance costs,.and the assumed availability, source and cost of replacement power.
(g)
Identify any documents, studies or reports on which Hartsville Group will rely in selecting i
such principal assumptions.
Furnish to Appli-cant's counsel or make available for copying by Applicant all such documents, studies or re-i ports.
i In accordance with the Licensing Board's Memorandum and Order dated April 12, 1983, responses to this discovery request j
are due within 45 days after receipt thereof.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE
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Geo Dated: May ll, 1983
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May 11, 1983 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 l
)
(H. B.
Robinson Steam Electric
)
ASLBP No. 83-484-03LA Plant, Unit 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's First Set of Interrogatories to Hartsville Group," dated May ll, 1983, were served upon those persons on the attached Service List, by de-l posit in the United States mail, postage prepaid, this lith day of May, 1983.
i NJ Y*J eor [eF. Trowbridge, C.
Dated: May ll, 1983
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
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(Steam Generator (H.
B.
Robinson Steam Electric
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Repairs)
Plant, Unit 2)
)
SERVICE LIST Administrative Judge Morton B.
Margulies Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comqission Washington, D.C.
20555 Administrative Judge Jerry R.
Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge David L.
Hetrick Atomic Safety and Licensing Board Professor of Nuclear Engineering University of Arizona Tucson, Arizona 85721 i
Docketing & Service Section (3) l Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Myron Karman, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l
B. A. Matthews Hartsville Group P. O. Box 1089 Hartsville, South Carolina 29550
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i Dr. John C.
Ruoff P.
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Box 96 Jenkinsville, South Carolina 29065 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 I
Samantha Francis Flynn, Esq.
Carolina Power & Light Company P. O. Box 1551 Raleigh, North Carolina 27602 1
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