ML20077E199
| ML20077E199 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/26/1983 |
| From: | Bauser D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8307280185 | |
| Download: ML20077E199 (21) | |
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t BEFORE THE ATOMIC SAFETY AND LICENSING EOARD In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN
)
50-401 OL MUNICIPAL POWER AGENCY
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(Shearon Harris Nuclear Power
)
Plant, Units 1 and 2)
)
APPLICANTS' ANSWER TO INTERVENOR EDDLEMAN'S MOTION TO COMPEL DISCOVERY RE EDDLEMAN 29 AND 37B In a Motion to Compel dated July 11, 1983, Wells Eddleman asks the Licensing Board to require Applicants to respond to
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all but one interrogatory or part thereof to which Applicants objected in their June 17, 1983 Responses to Wells Eddleman's l
l General Interrogatories and Interrogatories on Contentions 29 and 373 to Applicants Carolina Power & Light Company, et al.
(Second Set)
(" Applicants' Responses").
Recognizing the Li-censing Board's preference that parties not file answers to motions to compel, Applicants have chosen not to respond to Mr.
Eddleman's arguments on Interrogatory 29-1(g) with respect to l
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cost, Interrogataries 29(d) through 29(g) regarding Appendix R (fire protection), and Interrogatories 373-3(g) and (h), con-cerning health effects not caused by radiation; we instead rely on our objections as stated in Applicants' Responses.
- However, with respect to the other interrogatories to which objections have been raised, Applicants do feel constrained to address arguments advanced by Mr. Eddleman for the first time in his Motion to Compel.
Generally, Applicants recognize that in NRC proceedings, pretrial discovery is liberally granted.
See South Carolina Electric and Gas Company, et al. (Virgil C.
Summer Nuclear Station, Unit 1), ALAB-642, 13 N.R.C.
881, 888-89 (1981),
citing Pennsylvania Power and Light Co. (Susquehanna Steam Electric Station, Units 1 and 2), ALAB-613, 12 N.R.C. 317, 322 (1980), Pacific Gas and Electric Co. (Stanislaus Nuclear Project, Unit 1), LBP-78-20, 7 N.R.C.
1038, 1040 (1978), and Hickman v. Taylor, 329 U.S.
495, 501 (1947).
Consistent with this principle, Applicants' Responses provided a very consider-able amount of information to Mr. Eddleman notwithstanding Ap-plicants' doubts about the relevance of much of the informa-tion.
Applicants direct the Board's attention to this fact not because it provides an independent basis for denying Mr.
Eddleman access to information to wnich he is entitled, but be-cause we believe that a review of Applicants' Responses establishes their willingness to meet the Commission's broad discovery rules.
There were only a very limited number of
-S.
t instances where Applicants objected to Mr. Eddleman's interrogatories.
Applicants raised objections only where the interrogatory appeared to be so beyond the scope of the conten-tion that the question was considered to be unreasonable, or the effort required to obtain the information was judged to be unreasonably burdensome.
1.
Interrogatory 29-1(g) (in part).
In addition to asking about the cost of all radiciodine monitoring equipment to be used at the Harris facility, in response to which Appli-cants rely on their objection as stated in Applicants' Re-sponses at 20, in Interrogatory 29-1(g) Mr. Eddleman also asks for the model number, type and manufacturer of all such equip-ment.
Applicants have partially answered this interrogatory by providing Mr. Eddleman with information about environmental samplers.
See Applicants' Responses at 20.
However, as stated in Applicants' Responses, Applicants do not have the requested information on in-plant monitors in the form requested.
Appli-cants can identify GA Technologies as the vendor from whom Ap-plicants, through its agent, Ebasco Services, Inc., have purchased various kinds of monitoring equipment.
Some moni-toring equipment has not yet been purchased.
The purchased equipment is required to meet certain specifications; however, the specific model number and type of equipment would not be stated on either the specifications for the equipment, or on the purchase contract between Ebasco and the vendor.
Thus, the information would have to be specially requested from the.
vendor.
Very little of this equipment has been delivere<1 to Applicants -- the monitoring system is ene of the last systems installed; it is not put in place while heavy construction activities are still ongoing.
Prior to plant operation, Appli-cants will have obtained this detailed information; however, we simply do not have it now.
Applicants referred Mr. Eddleman to Chapters 11 and 12 of the FSAR because information about the quality of the equip-
- ment, e.g.,
sensitivity and range, and about the location of the equipment, is set forth there.
In Applicants' view, this information is responsive to Mr. Eddleman's inquiry because it indicates the nature of the monitoring system Applicants will use at the Harris facility.
Moreover, without any basis asserted for challenging the adequacy of any particular type of monitoring equipment, Mr. Eddleman's request for this informa-tion, which is of questionable relevance to begin with, ought to be denied.
2.
Interrogatory 29-1(j)(ii), (iii) and (iv).
Appli-cants do not understand how the monitoring equipment and practices at other nuclear facilities has any relevance to Con-tention 29/30.
The unreasonable scope of such an inquiry is unjustified, in the absence of some substantial reason for t
pursuing the ceparate issue of other licensees' ability to com-L ply with Appendix I.
As discussed below, the specific arguments advanced by Mr. Eddleman do not support the need for such a broad-sweeping inquiry.
Applicants also note their
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particular concern about this interrogatory, and others like it, because of the potential for this kind of inquiry about every other nuclear facility in the country to lead to a further expansion of what, based on Mr. Eddleman's interpreta-tion, is already an unmanageably broad contention.
In his Motion to Compel, Mr. Eddleman makes various state-ments which he considers to be self-evident' propositions, including:
(1) "Certainly if other plants have continuous radiciodine monitors and Harris does not, the reasons why Harris does not are relevant"; and ( 2-) "Whether Harris has better, worse, or the same monitors for radiciodines as do other plants is surely relevant to Harris' ability to control radiciodine releases, at least as compared to those other plants' ability."
Motion to Compel at 4.
Not only are these statements not self-evident, but Applicants disagree with them.
With respect to the first statement, Applicants' motives in choosing its monitoring system and procedures has no relevance whatsoever to the question of whether Appendix I compliance has been demonstrated.
Similarly, regardless of the equipment uti-lized at other facilities -- "better, worse, or the same" --
the use of this equipment elsewhere does not establish Appli-cants' compliance with Appendin I, nor does it establish Appli-cants' inability to so comply.
Finally, and perhaps most im-portantly, Contention 29/30 is not a monitoring contention.
See Licensing Board Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference), September 22, 1982, at l
-s-1
46-47.
For Mr. Eddleman to pursue, in the name of Appendix I, the historical operating experience of each and e'rery monitor to be used at the Harric facility is in itself an entire subject separate and apart from the issue of Appendix I compli-ance.1/
These interrrogatories also constitute a fishing expedition, absent some suggestion by Mr. Eddleman that a 4
particular component or sys' tem has had mechanical difficulties of a dimension and frequency such that it cannot be relied upon at the Harris facility.
Mr. Eddleman has not suggested that he has any basis whatsoever for challenging the cperability of the Harris monitoring systems.
While Applicants recognize that Mr.
Eddleman must be afforded, through discovery, a reasonable op-l portunity to develop his case, asking broad-sweeping questions l
of dubious relevance to a broadly stated contention is not rea-sonable.
See Duke Power Comoany, et al. (Catawba Muclear Station, Units 1 and 2), Memorandum and Order (Ruling on Various Discovery Disputes), December 22, 1982, at 12.
In sum, because the scope of Contention 29/30 could be virtually unlimited were Applicants to accede to Mr. Eddleman's request for such information, Applicants vigorously object to Interrogatory 29-1(j).2/
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While Applicants recognize the nexus betseen the adequacy of monitoring equipment and establishing Appendix I compliance, there is almost always some nexus between all of the issues in OL proceedings, where all issues relate to safe operability of the facility.
Applicants have found Mr. Eddleman to be unable to disconnect one issue from the myriad of other issues which are tangentially related to it, as illustrated by Interrogatory i
29-1(j).
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Applicants have not gone through the considerable effort l
to ascertain whether anyone in Applicants' employ, or working (Continued Next Page)
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3.
Interrogatory 29-4(o).
Interrogatory 29-4(o) is re-ally a series of interrogatories.
Having asked Applicants to provide answers to a number of interrogatories, 29-4(e) through (n), about the Harris facility, in Interrogatory 29-4(o),
Mr. Eddleman then asks Applicants to provide the same informa-tion about the Robinson 2 plant.
Applicants provided answers to Interrogatories 29-4(e) through (n); however, we object to Interrogatory 29-4(o).
Applicants' general objection to Interrogatory 29-4(o) is similar to the objection to Interrogatory 29-1(j):
the Rob-inson 2 plant's ability or inability to comply with Appendix I does not establish or refute Applicants' Appendix I calcula-l tions for the Harris facility, or the adequacy of Applicants' means of establishing Appendix I compliance once the Harris fa-cility is operating.
Contention 29/30 is limited to the issue of the Harris facility's compliance with Appendix I; it does not encompass cther facilities' compliance history.
Moreover, with respect to the specific information sought by Mr. Eddleman about Robinson 2, Applicants do not believe the Robinson 2 technical specifications or operating history are (Continued) for an agent of Applicants, such as Ebasco, has information re-sponsive to Interrogatory 29-1(j).
This is because Applicants strongly object to this subject area as irrelevant to the liti-gation of Contention 29/30.
Because we have not made this de-termination, Applicants were not and are not in a position to provide a "We don't know" answer, one of the suggestions made by Mr. Eddleman.
See Motion to Compel at 5.
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relevant because Robinson 2 is a much older facility than SHNPP.
Because it is a plant of a different vintage, the equipment is different, the basis for its technical specifica-tions is different -- they were established without the benefit of the standard Westinghouse technical specifications -- and its fuel is different.
Thus, notwithstanding the fact that both plants are 3-loop Westinghouse PWRs, as Mr. Eddleman notes, there is no basis for comparing expected releases or leakage requirements.
Mr. Eddleman argues that Robinson 2's technical specifica-tions for leakage, on which these interrogatories focus, are
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relevant because "any violations of them or inadequacies in them is relevant to whether Applicants will actually carry cut proper control of radiciodinea at the next PWR they operate (Harris)."
Motion to Compel at 6.
Applicants disagree.
It would take many, many hypothetical " ifs" to establish any connection between a violation of a technical specification on primary to secondary leakage at Robinson 2, on the one hand, and the ability of the Harris facility to comply with Appendix I,.on the other.
One of the links in such a chain of events would involve an inquiry into the competence of operations personnel and manage. ment at both facilities.
Not only has no basis been provided for getting into this long and hypothetical chain of events, but the nexus between these two events is so attentuated that causation -- viz., proximate cause -- is lacking.
Furthermore, had Mr. Eddleman proferred a __
contention which suggested this chain of events, which Contention 29/30 does not, he would really be inquiring into management competence at the Harris facility, not Appendix I compliance.
In Applicants' view, the pursuit of this informa-tion is irrelevant, does not appear reasonably calculated to lead to the discovery of admissible evidence and, consequently, is impermissible.
l Mr. Eddleman also argues that recurrence at the Harris fa-cility of specific problems at the Robinson plant, e.g.,
steam generator leaks and primary coolant pump seal failures, could lead to high radiation releases.
Motion to Compel at 6.
While this may or may not be true, these events, analyzed in Chapter 15 of the FSAR, are accidents; accordingly, they are not governed by Appendix I unless the leakage is very low.
If leakage is low, the equipment will not be challenged in the manner suggested by Mr. Eddleman.
Thus, the possibility of uncontrolled leakage, alluded to by Mr. Eddleman, is beyond the scope of Contention'29/30.
Furthermore, to assume as a predi-cate to this inquiry, without any foundation whatsoever, that such hypothetical events will occur at Harris is unreasonable and wholly tangential to the issue of Appendix I compliance.
4.
Interrogatory 29-6(f)(111), (iv), (xiii), (xiv), (xv) and (xvi).
Interrogatery 29-6(f) asks for a great deal of in-formation about mounting or sealing gaskets, frames and devices to be used in connection with radiciodine-absorbing filters and other devices used to remove or trap gaseous or liquid
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radioiodines (or particulates) from effluent streams at the Harris facility.
See Applicants' Responses at 59; Motion to Compel at 6-9.
Applicants provided to Mr. Eddleman a substantial amount of the information he requested in Interrog-atory 29-6(f)(i)-(xviii).
See Apnlicants' Responses at 60-63.
However, with respect to six subparts of this interrogatory, Applicants objected.
Applicants consider the name of the manufacturer (s) of all sealing gaskets, the dimensions of such components, the design life, anticipated replacement schedules and personnel exposures to be information of no probative value to resolution of Con-tention 29/30.
Mr. Eddleman appears to interpret the conten-tion as, in part, a challenge to the reliability and design of Applicants' monitoring equipment.
As previously stated, Con-tention 29/30 was not admi tted as a monitoring contention.
To the extent Mr. Eddleman is concerned about a particular effluent pathway, he has available to him diagrams of these pathways and could have asked about a monitor in a specified location.
See FSAR Chapter 11.
He did not choose to do so, instead requesting a monumental quantity of material of ques-tionable relevance.
The inappropriateness of this inquiry is further evidenced by one of Mr. Eddleman's arguments in his Motion to Compel.
Applicants consider it unreasonable to view this contention as does Mr. Eddleman, as encompassing the issue of whether high radiciodine releases with resultant greater exposures in the i
plant will cause deferral of needed repairs because of the unavailability of a sufficient number of maintenance personnel q
to account for this possibility, which will cause unreliable equipment to be used.
Nevertheless, characteristically, Mr.
Eddleman argues that this series of hypothetical events does fall within the scope of Contention 29/30.
See Motion to i
Compel at 9.3/
5.
Interrogatory 37B-1(c) and (d).
Notwithstanding Mr.
Eddleman's suggestion to the contrary, discovery rules do not require Applicants to respond to Mr. Eddleman's blanket request for all information in Applicants' possession concerning, in effect, all aspects of the issue of health effects of radiation as it pertains to the licensing of the Harris facility.
See Hickman v.
Taylor, supra, 329 U.S.
at 507; Illinois Power Company (Clinton Power Station, Unit Nos. 1 & 2), ALAB-340, 4 l
N.R.C.
27, 34 (1976) citing 4A Moore's Federal Practice, 2d ed.,
par. 34.07.
Such a request is unduly broad, and represents an impermissible attempt to shift Mr. Eddleman's burden of case preparation to Applicants.
Cf. Duke Power Company, et al. (Catawba Nuclear Station, Units 1 and 2), Memo-randum and Order (Rulings on Motion to Compel), April 18, 1983, at 2.
3/
In this regard, Applicants note that while radiciodine releases from the normal cleanup system are in Mr. Eddleman's view " relevant to the question of whether the Harris plant can limit their release adequately," Motion to Compel at 7, this statement assumes the such releases are not contained -- a major assumption to begin with.
It also assumes that such releases are significant, viz., not within anticipated levels. _
4 r
With respect to-Interrogatory 375-1(d), not only would Ap-plicants have to review every document in their possession which may address 1the health effects of. radiation -- the.re; quest posed in Interrogatory 37B-1{c) -- but Applicants then would have to review'all'of these materials to determine what, if any, diseasew are discussed in them.
Applicants object to the unreasonable breadth of such a request.'
We al'so believe -
thic effort woul'd bonst2tute extensive independent research in which a party is not required to engage.
Pennsylvania Power;&
Lignt Company, et al. (Susquehanna Steam Electric Station, Units 1 and 2), ALAB-613, 12 N.R.C.
317, 334.(1980); Boston Edison Company, et al. (Pilgrim Nuclear denerating Station, Unit 2), LBP-75-30, 1 N.R.C. 579, 5 8 4 ( 1 9 7 5 )'.
6.
Interrogatory _37R-2.
In this interrogatory, Mr.
Eddicman asks for informatipn Applicants have ytth respect to documents cited by Mr. Eddisman in his response to Applicants' first rounu of interrogatories on Contention 37B.
To the ex-tent Mr. Eddleman provided only partial citations to theC
' 4 studies on which he may:raly to supporc Contention 37B, Appli ~?
cants accordingly have been limited in their ability-to.rbspond
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to this request.
In an effort to minimize discover-j disputes, Applicanto have endeavored to partially answer this interroga-s tory.
In order for the answer to be clear, we have. stpached hereto as Appendix 1 a list of citations,, sor.e complete and
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some incomplete, which counsel hhs asked Mr. William,H.
s bater, $anager, Radiological & Chemical Support for the
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9 Harris facility, to review for purposes of answering this interrogatory.
Applicants note that, with respect to the major vague references made by Mr. Eddleman, we have asked follow-up interrogatories of Mr. Eddleman in order to clarify these cita-i tions.
See Applicants' Interrogatories and Request for Produc-tion of Documents to Intervenor Wells Eddleman (Fifth Set)
(Eddleman Contentions 29/30 and 373), July 20, 1983, at 25-26.
To Mr. Webster's knowledge, Applicants have made no studies of the references included in Appendix 1, nor do Appli-cants possess any such studies done by others.
Applicants note c
that, in the course of trial preparation, we will rely on con-rultant(s) hired in anticipation of litigation of Contention 737B and, eventually, on designated witness (es), to respond to i
Cont'ention 37B.
In the course of such trial preparation and testimony preparation, Applicants may discover studies which address the references cited in Appendix 1.
If so, Applicants will update this interrogatory response.
However, to the ex-
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t'ent Applicants' consultants, witnesses or counsel prepare their own critiques of Mr. Eddleman's references as a part of trial preparation, such efforts clearly fall within the trial preparation and/or the work product exception to the general rules of discovery.
See 10 C.F.R. 6 2.740(b)(2); Rule 26(b)(3) s of the Federal Rules of Civil Procedure and Notes of Advisory Committee on Rules with respect to Subdivision (b)(3) (West Publiehing Co. 1982) at 73-75 ("The requirement of a special showing for discovery of trial preparation materials reflects :
i the view that each side's informal evaluation of its case shculd be protected, that each side should be encouraged to pr" pare independently, and that one side should not automat-
[
ically have the benefit of the detailed preparation work of the other side.").
Mr. Eddleman's claim of substantial need is in-sufficient to overcome this exception.
See Motion to Compel at
,e 11.
To the extent Mr. Eddleman is burdened because he has cho-Y sen to litigate so many contentions in this proceeding, Appli-f cants are not required to compensate for this burden by as-sisting Mr. Eddleman.in the preparation of his case on Conten-tion 29/30.
Cf. Duke Power Company, et al. (Catawba Nuclear Station, Units 1 and 2), Memorandum and brder (Rulings on
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- s Motion to Compel), April 18, 1983, at 2 (interrogatory
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" represents an impermissible attempt to shift [intervenor's]
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bdrden of case preparation to the Applicants").
While Mr.
- Eddleman points out that he is intervening pro se, Motion to l
,4 Compe p at 'l'1, his status also does not relieve him of his responsibili, ties as a party to this proceeding, nor shift those responsibilities to Applicants.
See Commission Statement of
'/
Policy in Conduct of Licensing Proceedings, CLI-81-8, 13 N.R.C.
-7 452, 454 (1981).
I Finally, App 4icants do continue to object to Mr.
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Eddleman's inquiry as to whether and when Applicants obtained Y
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copies of documents referred to by him in his interrogatory re-
-7 sponse.
The answers to such questions simply have no bearing j
on Contentloh 37B.,While Mr. Eddleman may have more or less
_14 a
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confidence in the strength of his position based on Applicants' answers to such questions, the timing of Applicants' prepara-tion is irrelevant to litigation of Contention 373.
- Moreover, Mr. Eddleman has not offered any basis for believing that the answers to such questions are reasonably calculated to lead to relevant information.
See 10 C.F.R. 5 2.740(b)(1).
7.
Interrogatories 37B-3(a)-(e) and (k).
Applicants objected to Interrogatories 37B-3(a) to (d) insofar as Mr.
Eddleman sought information beyond that provided by Applicants.
Applicants in fact made an effort to answer these interrogatories by expressing their method of analysis of health effects caused or enhanced by radiation.
See Appli-cants' Responses at 70-71.
To the extent Mr. Eddleman seeks a catalogue of diseases, see Interrogatory 37B-3(e) and (k), Ap-plicants have not done this research effort, nor do Applicants believe that this request is reasonable.
If Mr. Eddleman is interested in particular diseases which he believes may be linked to radiation, hq should identify those diseases.
Appli-cants are not obligated to conduct this kind of sweeping analysis for Mr. Eddleman.
See Susquehanna, supra, ALAB-613, 12 N.R.C.
at 334; Pilgrim, supra, LBP-75-30, 1 N.R.C.
at 584.
In response to Interrogatories 37B-3(a), (b), (c) and (d),
Applicants note that the health effects of radiation are not analyzed in Applicants' Environmental Report for the Harris fa-cility; rather, this is a subject addressed by the NRC Staff in the Draft Environmental Statement (April 1983) for the Harris..
plant, pursuant to the NRC's responsibilities under the National Environmental Pclicy Act of 1969 and 10 C.F.R. Part 51 of the Commission's regulations.
For the reasons stated above, Applicants ask the Board to deny Mr. Eddleman's Motion to Compel dated July 11, 1983.
Respectfully submitted, OLb<mxA,o /b. M Thomas A.
- Baxter, P.C.
Deborah B.
Bauser SHAW, PITTMAN, POTT 3 & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1090 Richard E." Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O.
Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Counsel for Applicants Dated:
July 26, 1983 --.
APPENDIX 1 Gen. Int. 5(a)
Bertell, Rosalie, "The Nuclear Worker and Ionizing Radia-tion," American Industrial Hygiene Association Journal 40.
395-401, 916-22 (May 1979).
Int. 37(B)-1 Gofman, Radiation and Human Health (1981).
" Inherited Disease," The Metabolic Basis of Genetic Diseases (5th Ed. 1983) at 35-59, 14, 15-16.
Heredity and Disease at 20-29, 30-76.
An ABC of Medical Genetics, 31-49, 54-60.
Jackson and Schimke, Eds., Clinical Genetics - A Source Book for Physicians (1979) at 33-244, 246-47, 261, 269-594.
Nyan and Sakati, Genetic and Malformation Syndromes in Clinical Medicine (1976).
Genetic Disorders of Man (1970) at 107-980.
Progress in Clinical and Biological Research, Vol. 32 (1978) at 27-306, 523-732, 746-47.
Porter, Heredity and Disease (1968).
UNSCEAR 1977 at 514-19, 520.
- Harris, H.,
The Principles of Human Bio-Chemical Genetics (1980) at 441-68.
Auerbach F.R.S.,
Genetics in the Atomic Age (1965) at 88-106.
ICRP Publication 18 (1972) at 28-29, 32-33.
- McCusick, V.A.,
Mendelian Inheritance in Man (1978) at 1
850.
- Edwards, J.H.,
" Cost of Mutation," Genetic Damage in Man Caused by Environmental Aaents (1979) at 465-83. 4
-r-,
.....y-.
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Cellular Basis and Aetiology of Late Somatic Effects of Ionizing Radiation at 313-16 (Lindop and Rotblat);
285-94 (Upton, Kastenbaum, Conklin); 273-75 (Mole) and 7, 17, 23, 25.
UNSCEAR 1962.
UNSCEAR 1966.
Trimble and Doughty, "The Amount of Hereditary Disease in Human Populations," Annals of Human Genetics (London) 38:199-223 (1974).
Stevenson, A.C.,
"The Load of Hereditary Effects in Human Populations," Radiation Research Supplement 1:306-25 (1959).
Vogel and Rathenberg, " Spontaneous Mutation in Man,"
Advances in Human Genetics 5:223-318 (1975).
A Morgan, Bulletin of thq Atomic Scientists (September 1978).
i Bross and Driscoll, " Direct Estimates of Low-Level Radia-tion Risks of Lung Cancer at Two NRC-Complaint Nucle-ar Installations:
Why Are the New Risk Estimates 20 to 200 Times the Old Official Estimates?"
Yale Journal of Biology and Medicine 54:317-28 (1982).
- Rossi, H.H.,
Yale Journal of Biology and Medicine 54:340-41 (1981).
BEIR-III.
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN
)
50-401 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Answer to Intervenor Eddleman's Motion to Compel Discovery Re Eddleman 29 and 37B" were served this 26th day of July, 1983, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.
l S h /v A. [ h l
l Deborah B.
Bauser i
Dated:
July 26, 1983 l
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.s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
. In the'Matiter of'4
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)
CAROLINA POWER & LIGHT COMPANY
)
Docket Nos. 50-400 OL
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and NORTH CAROLINA EASTERN
)
50-401 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant, Units 1 and 2)
)
SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Commission 307 Granville Road Washington, D.C.
20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Commission Post Office Box 12643 Washington, D.C.
20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D.C.
20555 Mr. Wells Eddleman Charles A. Barth, Esquire (4) 718-A Iredell Street Myron Karman, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U.S. Nuclear Regulatory Commis'sion Richard E. Jones, Esquire Washington, D.C.
20555 Vice President and Senior Counsel Docketing and Service Section (3)
Carolina Power & Light Company l
Office of the Secretary Post Office Box 1551 U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27602 Washington, D.C.
20555 Dr. Phyllis Lotchin Mr. De.niel F. Read, President 108 Bridle Run Chapel Hill Anti-Nuclear Group Effort Chapel Hill, North Carolina 27514 Post Office Box 524 Chapel Hill, North Carolina 27514 Dr. Ianda Little Governor's Waste Managenent Board 513 Albenarle 9tileling 325 North 91ich ry Street t
Raleigh, North Carolina 27611
o Service List Page Tico Bradley W. Jones, Esquire U.S. Nuclear Regulatory Commission
. Region II...
101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Karen E. Long, Esquire Public Staff - NCUC Post Of fice Box 991 Raleigh, North Carolina 27602 5
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