ML20076C765
| ML20076C765 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/18/1983 |
| From: | Trowbridge G CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | HARTSVILLE GROUP |
| References | |
| ISSUANCES-OL, NUDOCS 8308230171 | |
| Download: ML20076C765 (5) | |
Text
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u$f[C August 18, 1983 T3 AM3 22 A10 :46 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIOlkFFiCE OF SECFt iaH -
G00KETins & SEpviu, BEFORE THE ATOMIC SAFETY AND LICENSINO BOARDiCH In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
) Docket No. 50-261-OLA
)
(H.
B. Robinson Steam Electric
)
Plant, Unit 2)
)
APPLICANT'S OBJECTIONS TO HARTSVILLE GROUP'S SECOND SET OF INTERROGATORIES AND REQUESTS TO PRODUCE Applicant objects to the following interrogatories included in Hartsville Group's Second Set of Interrogatories, served August 1, 1983, for the reasons stated below.
Interrogatory 3-24.
This interrogatory relates to sleeving, an alternative method of repairing steam generators.
Sleeving is not put into issue as an alternative by Contention 3, which is -- by its express terms --
limited to the alternative of retirement.
The interrogatory is thus beyond the scope of the contention, and irrelevant.
See
" Applicant's Objections To Hartsville Group's First Set of Interrogatories and Requests To Produce" (June 30, 1983), at 5, and " Applicant's Answer To Hartsville Group's Motion To Compel" (Augustl5, 1983), at 15-17.
8308230171 83001s PDR ADOCK 05000261 0
PDR 3 503
4
. Interrogatories 3-27 and 3-30.
Applicant continues its objection to interrogatories (such as these) to the extent that they would require Applicant to perform new studies or calculations.
However, the commitment by Applicant's counsel in the August 1,1983 letter to the representative of the Hartsville group with resoect to new studies and calculations which may hereafter be made by Applicant applies equally to the studies and calculations requested in the second set of interrogatories.
Respectfully submitted
- SHAW, ITTMAN, POTT
& TROWBRIDGE NJ l
G rge/. Tr6wTridge,P[.
D issa A. Ridgway Counsel for Applicant Dated:
August 18, 1983
-y,.. - - -
-, ~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
) Docket No. 50-261-OLA
)
(H.
B. Robinson Steam Electric
)
Plant, Unit 2)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Objections to Hartsville Group's Second Set of Interrogatories and Requests to Produce" were served this 18th day of August, 1983 by deposit in the U.S. mail, first class, postage prepaid, to all persons on the attached Service List.
hjbA.
iMin Dells (a A.
Rid 9gway 3 0
(
Dated:
August 18, 1983
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
)
Docket No. 50-261-OLA
)
(H.
B. Robinson Steam Electric
)
ASLBP No. 83-484-03LA Plant, Unit 2)
)
SERVICE LIST Administrative Judge Morton B. Margulies Chairman, Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission 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 Docketing & Service Section (3)
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 B. A. Matthews Hartsville Group P. O. Box 1089 Hartsville, South Carolina 29550
Dr. John C.
Ruoff P. O. 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 Samantha Francis Flynn, Esq.
Carolina Power & Light Company P. O. Box 1551 Raleigh, North Carolina 27602 I
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