ML20079E442

Supplemental Response to General Interrogatories & Interrogatories on Contentions 41 & 65.Certificate of Svc Encl

ML20079E442
Person / Time
Site:	Harris
Issue date:	01/13/1984
From:	Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Eddleman W EDDLEMAN, W.
References
ISSUANCES-OL, NUDOCS 8401170302
Download: ML20079E442 (7)

Text

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f??'?,TED Uu; c January 13, 1984 64 E'! !$ A11 :20

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UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMM>.SSION BEFORE THE ATOMIC SAtETY 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 )

)

(Snearon Harris Nuclear Power )

i Plant, Units 1 and 2) )

l APPLICANTS' SUPPLEMENTAL RESPONSES TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES AND INTERROGATORIES ON CONTENTIONS 41 AND 65 i

TO APPLICANTS CAROLINA POWER & LIGHT COMPANY, et al.

(FIRST SET)

Fursuant to the Licensing Board's " Memorandum and Order (Ruling on Discovery Disputes)" of October 6, 1983, and to the rulings issued by the Board during telephone conferences on September 22 and 23, 1983, Applicants herein provide their re-sponses to a portion of those interrogatories for which the Board granted intervenor Eddleman's Motion to Compel Discovery.

Additional supplemental responses were filed by Applicants on November 11, 1983. Responses to the remaining discovery re-quests which Applicants have been ordered to answer (i.e.,

8401170302 840113 PDR ADOCK 05000400 G PDR

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Interrogatories 41-1(1) and 41-1(m)), have been deferred  ;

pending the Board's disposition of Applicants' Motion for Pro-tective Order, dated January 13, 1984.

RESPONSES TO GENERAL INTERROGATORIES 4

INTE'RROGATORY NO. G1(c): Please state the name, present or last known address, and present or last known employer of each person whom Applicants believe or know (1) has first-hand

knowledge of the facts alleged in each such answer; or (2) upon l whom Applicants relied (other than their attorneys) in making

such answer.

ANSWER: W. D. Goodman, who is employed as project manager by Daniel Construction Company at the Shearon Harris Nuclear Power Plant, provided information upon which Applicants relied in answering Interrogatories 41-1(r), 41-1(s) and 41-5(g).

A. Fuller, who is employed by Carolina Power & Light Company at the Harris plant, provided information upon which Applicants relied in answering Interrogatory 41-4(i).

[ RESPONSES TO INTERROGATORIES ON CONTENTION 41 INTERROGATORY NO. 41-1(r): Were any welders discharged due to making defective pipe hanger welds at Harris prior to t

9/3/80? Identify each such welder.

INTERROGATORY NO. 41-1(s): Were any welders discharged due to-making defective pipe hanger welds at Harris after

9/3/80? Identify each such welder.

INTERROGATORY NO. 41-5(g): Provide the name and last known' address of any welders discharged for making defective welds after the welder retraining program. (Tr. 729).

ANSWER: Daniel has not discharged any welders for making I defective pipe hanger welds.

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w INTERROGATORY NO. 41-4(i): List all persons under g above who are no longer at Harris, giving last known address for each.

ANSWER: Not applicable. See answer to Interrogatory 41-4(g), dated May 12, 1983.

Respectfully submitted, L A. L 4 Thomas A. Baxter, P.C.

SHAW, PITTMAN, POTTS & 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: January 13, 1984

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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)

AFFIDAVIT OF ROLAND M. PARSONS County of Wake )

) ss:

State of North Carolina )

Roland M. Parsons, being duly sworn according to law, deposes and says that he is Project General Manager - Shearon Harris Nuclear Power Plant of Carolina Power & Light Company; tha. the answers to Interrogatories on Contention 41 contained in " Applicants' Supplemental Responses to Wells Eddleman's General Interrogatories and Interrogatories on Contentions 41 and 65 to Applicants Carolina Power & Light Company, et. al., (First Set)" are true and correct to the best of his information, knowledge and belief, and that the sources of his information are officers, employees, agents and contractors of Carolina Power & Light Company.

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Roland M. Parsons Sworn and subscribed to before me this // day of January, 1984.

d S *- M Notary Public My Commission expires

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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' Supplemental Responses to Wells Eddleman's Ceneral Interrogatories and Interrogatories on Contentions 41 and 65 to Applicants Carolina Power & Light Company, et al. (First Set) " were served this 13th day of January, 1984, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.

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Thomas A. Baxter, P.C.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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) )

SERVICE-LIST Janes L. Kelley, Esquire John D. Runkle, Esquire Atanic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Cmmission 307 Granville Road Washington, D.C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright- M. Travis Payne,. Esquire Atanic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Ccmmission P.O. Box 12607 Washington, D.C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atanic Safety and Licensing Board - 729 Hunter Street i U.S. Nuclear Regulatory Ctamission Apex, North Carolina 27502 Washington, D.C. 20555 Mr. Wells Eddleman Charles A. Barth, Esquire 718-A Iredell Street l Janice E. Itore, E= mire Durhan,' North Carolina 27705 l Office of Executive legal Director l U.S.' Nuclear Regulatory Otzmission Richard E. Jones, Esquire <

! Washington, D.C. - 20555 Vice President and Senior Counsel-Carolina Power & Light Ctmpany Docketing and Service Section P.O. Box 1551 Office of the Secretary Raleigh, North Carolina 27602 U.S. Nuclear Regulatory Ctzmission Washington, D.C. 20555 Dr. Phyllis Iotchin i 108 Bridle'Run

' Mr. Daniel F. Read, President Chapel Hill, North Carolina 27514 CHANGE /EIP 5707 Waycross Street Dr. Linda W. Little Raleigh, North Carolina '27606 Governor's Waste Managenent Board 513 ALWrle Building 325 North Salisbury Street Raleigh, North Carolina .27611 h

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• Bradley W. Jones, Esquire U.S. Nuclear Regulatory Ccmnission Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atanic Safety and Licensing Board Panel U.S. Nuclear Regulatory C-iasion Washington, D.C. 20555 Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 1

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