ML20076A679

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Responses to Interrogatories Per Agreement.Notice of Appearance & Certificate of Svc Encl
ML20076A679
Person / Time
Site: Robinson 
Issue date: 08/15/1983
From: Mcdaniel A
CAROLINA POWER & LIGHT CO.
To:
HARTSVILLE GROUP
References
83-484-03LA, 83-484-3LA, ISSUANCES-OLA, NUDOCS 8308180266
Download: ML20076A679 (8)


Text

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a DOCKETED U3NRc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSJQN O Alls 17 A11 :52 BEFORE THE ATOMIC SAFETY AND LICENSING-BOARD GE:Tp3'G{l,Y rRAHC4 In the Matter of

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CAROLINA POWER & LIGHT COMPANY

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Docket No. 50-2Cl-OLA

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(H. B. Robinson Steam Electric

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ASLBP No. 83-484-03LA Plant, Unit 2)

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APPLICANT'S RESPONSES TO LETTER AGREEMENT

Dear Mr. Matthews:

Pursuant to the signed letter agreement dated August 1,1983 between George F.

Trowbridge, P.C., Counsel for Applicant, and you as Representative for the Hartsville Group, Applicant herein sets forth its answers pursuant to said agreement:

General Interrogatory No. 3 (Calculations)

ANSWER.

Applicant presently anticipates that it will rely on the following calculations:

Contention 3 Cost Comparison Report Year Study.

Applicant has under compilation a report providing in more detail the bases for the cost comparisons furnished to the NRC on July 14, 1983. The report willinclude a sensitivity analysis of the effect of varying the assumptions in the report as to system load projections and the projected capacity factor and O&M costs for H. B.

Robinson 2. A copy of this report will be furnished to the Hartsville Group and the NRC Staff.

Applicant anticipates completing this report around September 30, 1983.

PTS Screening Criteria Calculations.

Attached hereto and entitled H. B. Robinson PTS Screening Criteria Calculations are calculations of the length of time before the Robinson 2 vessel will reach the NRC embrittlement criteria based on (a) continued operation with the present Cycle 9 core design and (b) installation of a low flux core design following Cycle 9. The latter calculations assume a flux reduction factor of at least 7. Tne documents ano 8308180266 830815 PDR ADOCK 05000261 g3 G

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work sheets supporting this factor are available to the Ilartsville Group for inspection and copying at CP&L's General Office in Raleigh, NC.

H. B. Robinson 2 FSGRR Repair Program Occupational Exposures.

Estimated occupational exposures during the repair program are listed by repair activities in the FSGRR. A detailed sample calculation for one of the activities is also provided therein for one of the activities.

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General Interrogatory No. 4 (Communications)

ANSWER.

Applicant presently anticipates that it will rely on the following t

documents:

Contention 1(a) and 1(b)

Corporate Quality Assurance Program Manual, Revision 5 (Blue Book)

Responses to NRC to Notices of Violations.

Contention 3 February 9,1983, April 1,1983 letters from CP&L to NRC relative to NRC Pressurized Thermal Shock Screening Criteria In-Service Inspection Reports H. B. Robivon 2 SGRR, as revised H. B. Robinson 2 Updated FSAR Contention 8 Plans and Specifications for on-site storage building.

Contention 1 -Interrogatory No. 31 (Severity LevelIV Violation)

ANSWER.

Attached hereto and included as part of attachments marked Attachment ilBR Violations, Attachment BSEP Violations, and Attachment SHNPP Violations are copies of the full text of documents previously provided to the liartsville i

Group as HBR Attachment 2.a., BSEP Attachment 2.b., and SHNPP Attachment 2.c.

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8 Contention 1 -Interrogatory No. 35 (Violations)

ANSWER. On the bases of a file search, attached hereto are all violations or claims of violations since January 1,1978, as represented by copies of Applicant's responses identifying and responding to each violation.

These copies are marked Attachment HBR Violations, Attachment BSEP Violations, and Attachment SHNPP Violations.

Contention 3 -Interrogatory 5 (Reactor Embrittlement)

ANSWER. Attached hereto is the letter and its enclosures dated April 1,1983 from CP&L to the NRC. Said letter is marked Attachment April 1,1983 Letter.

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Contention 3 -Interrogatories Nos.130 through 167 (Attorney General Interrogatories)

ANSWER. Applicant attaches hereto the affidavit of B. M. Williams stating that the answers provided to the Attorney General's interrogatories were true and correct to the best of affiant's knowledge, information and belief as of June 30,1983 - the date the same answers were provided to the Hartsville Group, with the exception of the projected I

schedule of future outages as set forth on pages AG-90 and AG-91 of the Attorney General Attachment, which pages have been revised as indicated on the hereto attached table marked Attachment Revised Pages AG-90 and AG-91.

Affiant believes this revision to be true and correct to the best of his knowledge, information and belief.

This 15th day of August,1983.

Af}

dm1 Andrew McDaniel

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Associate General Counsel Carolina Power & Light Company cc: George F. Trowbridge _ _ _ _ _ _

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.g 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

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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)

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AFFIDAVIT OF B. M. WILLIAMS WAKE COUNTY

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NORTH CAROLINA

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B. M. Williams, being duly sworn according to law, deposes and says that he is Director-Staff Services with Carolina Power & Light Company; that the Answers contained in the ATTORNEY GENERAL ATTACHMENT in Applicant's Answers to the Hartsville Group First Set of Interrogatories to Applicant, Carolina Power & Light Company, were true and correct to the best of his knowledge, information and belief as of June 30, 1983, with the exception of the OUTAGE SCHEDULE FOR 1983, 1984 as contained on pages AG-90 and AG-91 of said ATTORNEY GENERAL ATTACHMENT, and that the sources of his information were officers, employees, agents and contractors of Carolina Power & Light Company; that attached to this Affidavit is a REVISED OUTAGE SCHEDULE FOR 1983, 1984, and that said information contained therein was true I

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,7 and correct to the best of his knowledge, information and belief as of June 30, 1983, and that the sources of his information are officers and employees of Carolina Power & Light Company.

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B. M. Williams Sworn to and subscribed before me this /SN day of August, 1983, h'Ih A

Notdry Public ssion expires: //hrk7

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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!DfISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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CAROLINA PO!JER & 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)

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NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter.

In accordance with 10 C.F.R. 5 2.713(a), the following information is provided:

Name:

Andrew McDaniel Address:

Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 Telephone Number:

(919) 836-6513 Admission:

State of North Carolina Name of Party:

Carolina Power & Light Company Respectfully submitted.

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Andr'e'w' Rc' Daniel l

Associate General Counsel Carolina Power & Light Company Dated this 15th day of August, 1983

a UNITED STATES OF A> ERICA NUCLEAR REGULATORY COFDfISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 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)

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CERTIFICATE OF SERVICE I hereby certify that copies of " APPLICANT'S RESPONSES TO LETTER AGREE *ENT" and a " NOTICE OF APPEARANCE" for Andrew McDaniel in the above-captioned proceeding have been served this 15th day of August, 1983 by depositing in the United States Postal Service, first class, postage prepaid, to the parties on the attached SERVICE LIST.

Copies of ATTACHFENTS referred to in said RESPONSES are attached only to Mr. Matthews' copy, Dr. Ruoff's copy, and Mr. Karman's copy.

la) $r Andrew 'McDaniel

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Associate General Counsel Carolina Power & Light Company l

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a UNITEDSTATES OF AMERICA NUCLEAR REGULATORY COMMISSION a

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4

In the Matter of

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CAROLINA POWER & LIGHT COMPANY

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ASLBP No. 83-484-03LA (H. B. Robinson Steam Electric

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Plant, Unit 2)

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SERVICE LIST Administrative Judge Morton B. Margulies Atomic Safety and Licensing Board Panel Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Atomic Safety and Licensing Appeal Administrative Judge Jerry R. Kline Board Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 B. A. Matthews Administrative Judge David L. Hetrick Hartsville Group 4

Atomic Safety and Licensing Board P. O. Box 1089 Professor of Nuclear Engineering Hartsville, South Carolina 29550 University of Arizona Tucson, Arizona 58721 Dr. John C. Ruoff P. O. Box 96 Docketing & Service Section (3)

Jenkinsville, South Carolina 29065 Office of the Secretary l

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Myron Karman, Esquire-l Office of Executive Legal Director l

U.S. Nuclear Regulatory Commission I

Washington, D.C. 20555 1

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