ML20079L429
| ML20079L429 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/24/1984 |
| From: | Oneill T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Eddleman W EDDLEMAN, W. |
| References | |
| ISSUANCES-OL, NUDOCS 8401260117 | |
| Download: ML20079L429 (23) | |
Text
.
m January 24, 1984 00CgTJO UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION , - . , _
Before the Atomic Safety and Licensing Board In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN ) Docket Nos. S0-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL
)
(Shearon Harris Nuclear-Power )
Plant, Units 1 and 2) )
APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO WELLS EDDLEMAN CONCERNING
-EDDLEMAN CONTENTIONS 9, 11 AND 132C(II)
Pursuant to 10 C.F.R. 5 2.740b and 2.741, Appl'icants Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that Intervenor Wells ,
-Eddleman answer separately and fully in writing, and under oath or affirmation, each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identified in the responses to the interrogatories below. Under the Commission's Rules of Practice, answers or objections to these interrogatories must be served within 14 days after service of the interrogatories; 8401260117 840124 PDR ADOCK 05000 eq7 o cp 9
responses or objections to the request for production of documents must be served within 30 days after service of the request.
These interrogatories are intended to be continuing in
[
nature; and the answers should promptly be supplemented or amended as appropriate,. pursuant to 10 C.F.R. f 2.740(e),
-should Intervenor or any individual acting on his behalf obtain i any new or differing information responsive to these interrogatories. The request for production of documents is also continuing in nature and Intervenor must produce immedi-ately any additional documents he, or any individual acting on his behalf, obtains which are responsive to the request,. in ac-cordance with the provisions of 10 C.F.R. 5 2.740(e).
Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, transcript, report, handwritten notes, test data) and provide the following information as applicable: document name, title, number, author, date of publication and publisher, addressee, j date written or approved, and the name and address of the l~
( person or persons having possession of the document. Also state the portion or portions of the document (whether section(s), chapter (s), or page(s)) upon which Intervenor relies.
l Definitions: As used hereinafter, the following defini-
-tions shall apply:
i i
l
'2-l
1 The "FSAR" issthe Final Safety Analysis Report for the Shearon Harris Nuclear Power Plant, as amended.
The "SER" is the Safety Evaluation Report related to the operation of Shearon Harris Nuclear Power Plant, Units 1 and.2, NUREG-1038 (Nov. 1983).
" Applicants" is intended to encompass Carolina Power &
- Light Company, North Carolina Eastern Municipal Power Agency and their contractors for the Harris Plant.
" Document (s)" means all writings and records of every type in the possession, control or custody of Intervenor or any individual acting on his behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, voice recordings and all other. writings or recordings of-any kind; " document (s)"
.shall also mean copies of documents even though the original thereof are not in the possession, custody or control of Inter-
-venor; a document shall be deemed to be within the " control" of Intervenor cnr any individual acting on his behalf if Intervenor or.the individual acting on his behalf has ownership, possession or custody of the document or copy thereof, or has the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.
- General Interrogatories.
- 1. (a)_ State the name, present or_last known address, and present'or lastlknown employer of'each person known to In-
.tervenor to have'first-hand knowledge of'the facts alleged, and upon which Intervenor relied in formulating allegations in the contentions which;are the subject of this set.of
? interrogatories.
f(b) Identify those facts concerning which each such
. person has first-hand knowledge.
s(c) State the specific allegation in each contention wh'ich.Intervenor. contends such facts support.
- 2. :(a) State'the name, present or last known address, and present or last employer of each person, other than affi-ant, whoLprovided information upon which Intervenor relied in answering each interrogatory herein.
-(b) Identify all such information which was provided by each-such person-and the specific interrogatory response in which such information is contained.
- 3. (a) State the name, address, title, employer and
. education _and-professional qualifications of each person Inter-
.venor intends to call as an expert witness or a witness
' relating.to the contentions which are the subject of this set of interrogatories.
(b) State the subject matter to which each such
. person is expected to testify.
- 4. (a) Identify all documents in Intervenor's
. possession, custody or control, including all relevant page ci-tations,' pertaining to the subject matter of, and upon which Intervenor relied in formulating allegations in the contentions which are the subject of this' set of interrogatories.
(b) Identify the contentions to which each such document relates.
(c) State the specific allegation in each contention which Intervenor contends each document supports.
- 5. (a) Identify all documents in Intervenor's possession, custody or control, including all relevant page ci-tations, upon which Intervenor relied in answering each. inter- -
rogatory herein.
'(b) Identify the specific interrogatory response (s)
'to-which'each such document relates.
- 6. .(at) Identify any other source of information, not previously-identified in response to Interrogatory 2 or 5, which was'used in answering the interrogatories set forth herein.
(b) Identify the specific interrogatory response (s) to which each such source of information relates.
- 7. (a) Identify all documents which Intervenor intends to offer as exhibits during this proceeding to support the con-tentions which are the subject of this set of interrogatories or which Intervenor intends to use during cross-examination of witnesses presented by Applicants and/or the NRC Staff on the O
contentions which are the subject of this set of interrogatories.
4 (b) Identify the particular page citations of each document applicable to each contention.
Interrogatories on Contention 9 (Environmental Qualification of Electrical Equipment) 9-1. State each and every. reason why you believe that Ap-plicants' program for environmental qualification of electrical equipment at Shearon Harris Nuclear Power Plant is "not suffi-ciently established." Supplement to Petition To Intervene by Wells Eddleman, dated May 14, 1982 (" Supplement"), at 52. De-scribe in detail the bases for your answer.
9-2. State each and every reason why you believe that Ap-plicants' program for environmental qualification of electrical equipment is " deficient." Supplement at 52. Describe in de-tail the bases for your answer.
9-3. State each and every reason why you believe that Ap-plicants' program for environmental qualification of electrical equipment is "in-error." Supplement at 52. Describe in detail the bases for your answer.
9-4. State each and every reason why you believe that Ap-plicants' program for environmental qualification of electrical equipment " lacks up-to-date information." Supplement at 52.
Describe in detail the bases for your answer.
9-5. (a) State whether you are aware that Applicants are required to comply.with the criteria of 10 C.F.R. S 50.49 with respect to all electrical equipment important to safety located in.a harsh environment at Shearon Harris Nuclear Power Plant and not already qualified under NUREG-0588 (" Interim Staff Po-sition on Environmental Qualification of. Safety-Related Elec-
. trical Equipment") (1979).
(b) State whether you are aware that applicants for operating licenses that are granted prior to November 30, 1985 are not required under 10 C.F.R. S 50.49 to complete equipment qualification prior to November 30, 1985. .
9-6. (a) State whether you believe that FSAR S 3.11 .
-(" Environmental Design of Active Mechanical and Electrical Equipment"), .as amended August 31, 1982 (Amendment 4), fails to show compliance with 10 C.F.R. S 50.49.
(b) If the answer to (a) above is affirmative, ide:.cify all specific criteria of 10 C.F.R. S 50.49 with which you believe FSAR S 3.11 fails to show compliance. As to each such criterion, describe in detail the bases for your conclu-sion, including the reasons for identifying the criterion.
(c) As to each criterion identified in response to
-(b) above, state what change (s) you believe Applicants must make for FSAR S_3.11 to show compliance with 10 C.F.R. S 50.49.
Describe.in detail the bases for your answer.
9-7.' (a) State whether you believe that the format of
~
FSAR Figure 3.11.1-l'(" Master Llst Legend") fails to show compliance.with the criteria of 10 C.F.R. S 50.49.
e
-(b) If the answer to (a) above is affirmative, identify all specific criteria of 10 C.F.R. S 50.49 with which you believe Figure 3.11.1-1 fails to show compliance. As to each such criterion, describe in detail the bases for your con-clusion, including the reason for identifying the criterion.
(c) As to each criterion identified in response to (b) above, state what change (s) you believe Applicants must make for Figure 3.11.1-1 to show compliance with 10 C.F.R.
S 50t.49. Describe in detail the bases for your conclusion.
9-8. (a) State whether you believe that the format of-FSAR Figure 3.11.1-2 (" Component Evaluation Sheet Legend")
fails to show compliance with the criteria of 10 C.F.R. -
S 50.49.
(b) If the answer to (a) above is affirmative, identify all specific criteria of 10 C.F.R. S 50.49 with which you believe Figure 3.11.1-2 fails-to show compliance. As to each'such criterion, describe in detail the bases for your con-clusion, including the reasons for identifying the criterion.
(c) As to each criterion identified in response to (b) above, state what change (s) you believe Applicants must make for Figure 3.11.1-2 to show compliance with 10 C.F.R.
S 50.49. Describe in detail the bases for your conclusion.
9-9. (a) State whether you believe that FSAR S 3.11 fails to show compliance with NUREG-0588.
(b) If the answer to (a) above is affirmative, identify all specific criteria of NUREG-0588 with which you
s believe FSAR 5 3.11 fails to show compliance. As to each such criterion, describe in detail the bases for your conclusion, including the reasons for identifying the criterion.
(c) As to each criterion identified in response to (b) above, state what change (s) you believe Applicants must make for FSAR 9 3.11 to'show compliance with NUREG-0588. De-scribe in detail the bases for your answer.
9-8. (a) Identify all applicable NRC rules, regulations, regulatory guides, publications and endorsed national standards, other than 10 C.F.R. $ 50.49 and NUREG-0588, with which you believe FSAR $ 3.11 fails to show compliance. As to each auch item, describe in detail the bases for your answer, including the reasons for identifying the item.
(b) Identify all specific criteria of each item identified in response to (a) above with which you believe FSAR
$ 3.11 fails to show compliance. As to each such criterion, describe in detail the bases for your conclusion, including the reasons for identifying the criterion.
(c) As to each criterion identified in response to (b) above, state what change (s) you believe Applicants must make for FSAR 5 3.11 to show compliance with the applicable I item identified in response to (a) above. Describe in detail the bases for your answer.
9-9. State whether you believe that there are any deficiencies, errors or other inadequacies in SER & 3.11, with respect to environmental qualification of electrical equipment.
-If so, describe in detail'the bases for your answer.
l
_g.
Interrogatories on Contention 11 .
(Polyethylene Cable Insulation Degradation) 11-1. (a) Describe in detail the bases for your conclu-sion that " polyethylene, used as cable insulation, deterio-rate (s) much more rapidly under long-term doses of gamma radia-tion than (it does) when exposed to the same total dose over a much shorter period of time." Supplement at 56.
(b) Identify the Sandia Laboratories study or studies by K. Gillen and R. Clough which you believe demon-strate the degradation effect described in (a) above.
(c) Identify all facts, findings and conclusions stated in each of the studies identified in response to.(b) above which you believe demonstrate the degradation effect de-scribed in (a) above. As to each such item, describe in detail' the b~ases for your answer, including your reasons for identi-fying the item.
(d) State whether you believe that dose rate
' testing of polyethylene cable insulation which has been stripped from the wire, thereby exposing a much larger surface area to the ambient atmosphere than would be exposed if the cable were installed in an operating plant, could increase oxygen diffusion into the materials, thus increasing oxidation and degradation of.the insulation. If not, describe in detail the bases for your conclusion.
(e) State whether you believe that polyethylene cable insulation installed in evnduit is shielded from the
degradation effect described in Interrogatory #11-1, supra. If not, describe in detail the bases for your conclusion.
11-2. (a) State the lowest gamma radiation dose rate above which you believe the degradation effect described in In-terrogatory #11-1, supra, causes unsafe conditions to occur.
Describe in detail the bases for your conclusion.
(b) State the highest gamma radiation dose rate below which you believe the degradation effect described in In-terrogatory #11-1, supra, causes unsafe conditions to occur.
Describe in detail the bases for your conclusion.
(c) State the total integrated gamma radiation dose above which you believe the degradation effect described -
in Interrogatory #11-1, supra, causes unsafe conditions to occur. Describe in detail the bases for your conclusion.
11-3. (a) Identify what you believe to be the specific property or properties -- e.g., tensile strength, elongation, insulation resistance, dielective strength -- necessary for polyethylene cable insulation to perform its safety function.
As to each such property,. describe in detail the bases for your answer, including the reasons for identifying the property.
(b)~ State what you believe to be the acceptance criteria for each property identified above in order for polyethylene cable insulation to perform its safety function.
As to each property, describe in detail the bases for your answer.
c - - - - - - - -, - . - -
11-4. (a) Describe in detail the bases for your conclu-sion that the " loss of cable . . . insulation would lead to short circuits" at Shearon Harris Nuclear Power Plant.
Supplement at 57.
(b) Explain the discrepancy between your statement that short circuits "would" occur and your statement that short circuits would "very likely" occur if cable were to lose its insulation. Supplement at 57.
11-5. Identify all incidents, of which you are aware, in which the degradation effect described in Interrogatory #11-1, supra, has caused unsafe conditions to occur in commercial nu-clear power plants which are now operating or at one time did operate. As to each.such incident, provide all pertinent de-tails.
11-6. Identify all electrical cables with polyethylene insulation within Shearon Harris Nuclear Power Plant which you believe to be potentially dangerous as a result of the degrada-tion effect described in Interrogatory #11-1, supra. As to each such cable, describe in detail the bases for your answer, including the reasons for identifying the cable.
11-7. (a) Identify all locations within Shearon Harris Nuclear Power Plant, by radiation zone, in which the gamma ra-diation dose rate during normal, full-power operating conditions falls within the range of dose rates which you iden-tified in response to Interrogatory #11-2, supra, as causing unsafe conditions to occur. As to each such radiation zone,
1 1
describe in detail the bases for your answer, including the ,
reasons for identifying the radiation zone.
(b) Identify all locations within Shearon Harris Nuclear Power Plant, by radiation zone, in which the total in-tegrated gamma radiation dose during normal, full-power operating conditions exceeds the total integrated dose which you. identified in response to Interrogatory #11-2, supra, to be necessary to produce the degradation effect described in Inter-rogatory #11-1, supra. As to each such radiation zone, de-scribe in detail the bases for your answer, including the reasons for identifying the radiation zone.
11-8. State whether you believe that the degradation -
effect described in Interrogatory #11-1, supra, neod be addressed for accident conditions, since accident dose rates will decay rapidly following reactor shutdown. If so, describe in detail the bases-for your conclusion.
11-9. (a) State what you believe to be acceptable in-spection standards -- e.g., inspection methods, inspection frequencies -- in order to detect the degradation effect de-scribed in Interrogatory #11-1, supra. As to such standard, describe in detail the bases for your conclusion.
(b) Identify all NRC regulations, regulatory guides, publications and endorsed national standards which you
'believe to establish inspection standards for safety-related electrical cables in order to detect the degradation effect de-scribed in Interrogatory #11-1, supra. As to each such item,
describe in detail the bases for your answer, including the reasons for identifying the item.
11-10. (a) State what you believe to be appropriate cor-rective actions for electrical cablee which are subject to the degradation effect described in Interrogatory #11-1, supra.
Describe in detail the bases for your answer.
(b) Identify all NRC regulations, regulatory guides, publications and endorsed national standards which you believe to establish maintenance standards for safety-related electrical cables.in order to correct the degradation effect described in Interrogatory #11-1, supra. As to each such item, describe in detail the bases for your answer, including.the reasons for identifying the item.
11-11. Identify all cable insulation materials which you believe are not subject or are less subject to the degradation effect described in Interrogatory #11-1, supra. As to each such material, describe in detail the bases for your conclu-sion, including the reasons for identifying the material.
11-12. (a) State whether you are aware that 10 C.F.R.
$ 50.49(e)(4) requires that Applicants' program for environ-mental qualification of electrical equipment account for radia-tion dose-rate effects.
(b) State whether you believe that the NRC Staff's evaluation of Applicants' program for environmental qualification of electrical equipment with respect to radiation dose-rate effects on polyethylene cable insulation will be inadequate.
(c) If the answer to (b) above is affirmative, describe in detail the bases for your conclusion.
Interrogatories on Contention 132C(II)
(Control Room Layout) 132C(II)-1.(a) Referring to Figure 2 at page 12 of Appli-cants' " Human Factors Design Evaluation Report for the Shearon Harris Unit 1 Control Room" (September 16, 1981-Revised) (here-inafter referred to as the "DCRDR"), state precisely the posi-tion within the Shearon Harris Nuclear Power Plant Control Roon
(" control room") that an operator's view of any part of panel
- 1 through #10, inclusive, would be obstructed in any way by panels #12, #13, #14 and/or #15 such that the " inability to see information on these panels can imperil public safety." Use as reference point the operator's desk (#18 at Figure 2, page 12) and state any such position as X feet in a compass direction from the operator's desk.
(b) For each such position identified in re-sponse to 1.(a) above, provide the following:
(i) all information that you contend would be out-of-view of the operator which is L necessary for the operator "to see, read accu-rately, or integrate;"
(ii) under what circumstances the operator would be required to have an unobstructed view of the information identified in (i) above from
[ such position; and l
4 (iii) why the operater would not be able to deal with the situation described in (ii) above from another position in the control room or with information available from different panels.
(c) If you are unable to answer 1.(a) and (b) above for any individual panel (out of panels #1 through 10, inclusive, referred to in Contention 132C(II)) are you willing to withdraw such panel (s) from the scope of Contention 132C(II)?
(d) If the answer to interrogatory 1.(c) above is other than affirmative, explain the basis for your answer.
132C(II)-2. (a) Section 2.2(b) of Appendix D of the DCRDR states that the Condensate Sooster Hydraulic Control Cabinet (equipment panel #7 on figure 2, DCRDR at page 12) does not have any front panel controls, and has little or no signif-icance in being located in the control room. In light of this
'information with regard to equipment panel #7, explain why you are concerned that the view of or from panel #7 may be obstructed from operators at any time?
t (b) Explain each and any situation during
! which you contend that panel #7 would provide information or controls to an. operator where an unobstructed view of any other cabinet or equipment referenced in Contention 132C(II) is required.
l l
l i
132C(II)-3. (a) Section 2.2(b) of Appendix D of the DCRDR states that the Cooling Tower and River Water Make-up Control Cabinet (equipment panel #6 on figure 2, DCRDR at page 12), with few controls, has minimal requirements for even
' occasional monitoring and little or no significance in being located in the control room. In light of this information with regard to equipment panel #6, explain why you are concerned that the view of or from panel #6 may be obstructed from opera-tors at anytime?
(b) Explain eech and any situation during which you contend that panel #6 would provide information or controls to an operator where an unobstructed view of any other cabinet or equipment is required.
132C(II)-4. (a) Do you contend that the layout of the SENPP control room fails to comply with any provision of NUREG-0737, Supplement 1, or of any other relevant NRC require-ment or regulatory guidance?
(b) If the answer to 4.(a) above is affirma-tive, please state which section of NUREG-0737, Supplement 1, or other NRC requirement or regulatory guidance you contend the control room layout fails to comply.
(c) Explain why you contend the control room layout does not comply with each section of each document indi-cated in answer to 4.(b) above.
(d) If the answer to 4.(a) above is other than affirmative, please explain how your answer is consistent
-with Contention 132C(II).
l i
132C(II)-5. (a) Do you contend that the analysis contained in Appendix D to the DCRDR is inadequate in any way with respect to the control room layout?
(b) If the answer te 5.(a) above is affirma-tive, please indicate the specific parts or sections of the
-analysis which you contend are inadequate.
r (c) For each part or section indicated in answer to 5.(b) above, explain why you contend that part or section is inadequate.
(d) If the answer to 5.(a) above is other than affirmative, please explain how your answer is consistent with Contention 132C(II). .
-132C(II)-6. If not previously identified, please identify by title, authors, and publication date each and every report, study,-transcript, order, _ analysis or any other document or video presentation which you possess on control room layouts.
Request for Production of Documents Applicants request that Mr. Eddleman respond in writing to this request for production of documents and produce the original or best copy of each of the documents identified or described in the answers to each of the above interrogatories at a place mutually convenient to the parties.
Respectfully submitted, s
gr Tho4as A. Baxter, P.C.' [ )
Johr H. O'Neill, Jr., l Mic ael A. Swiger P .(C .
SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn H. Hill Carrow CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 26602 (919) 836-7707
' Dated: January 24, 1984 l
4 l January 24, 1984 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) )
t NOTICE OF APPEARANCE ,
The undersigned, being an attorney at law in good standing.
admitted to practice before the Court of the District of Columbia ,
, - hereby enters his appearance on' behalf of Carolina Power & Light Company and. North-Carolina Eastern Municipal Power Agency in proceedings related to the above-captioned matter.
Respectfully submitted, iCh0Lk 0. $0'fyL. -----
Michael A. Swiger f Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1178 DATED: Janua_7 24, 1984 i
l 4 ..~i,-..-... . - _ _ ~ -, . , , - - , - . . - . , . - - - . . . - - - - _ - . - , , - , , , - . - . . . , _ - - - - - . - . . -,.-,,,--..o.,,
January 24, 1984 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' Interrogatories and Request for Production of Documents to Wells Eddleman Concerning Eddleman Contentions 9, 11 and 132C (II) " and " Notice of Appearance" both dated January 24, 1984, were served this 24th day of January, 1984, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.
f Ih 1
~ S Jo H. O'Neill, Jr. ?.C.
I Dated: January 24, 1984
i e
UNITED STATES OF AMERICA NUCLEAR REGULATCRY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l'
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) )
e:
SERVICE LIST '
James L. Kelley, Esquire John D. Runkle, Esquire Atcmic Safety and Licensing Boatti Conservation Council of North Carolina
' U.S. Nuclear Regulatory Ccmrission 307 Granville Road
. Washington, D.C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atcmic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Camission P.O. Box 12607 Washington, D.C. 20555 Raleigh, North Carolina 27605 Dr. Janes H. Carpenter Dr. Richard D. Wilson Atcznic Safety and Licensing Board 729 Hunter Street i 4
U.S. Nuclear Regulatory C - iasion Apex, North Carolina 27502 Washington, D.C. 20555 Mr. Wells Eddleman Charles A. Barth, Esquire 718-A Iredell Street Janice E. Moore, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U.S. Nuclear Regulatory Ccxmlission Richard E. Jones, Esquire Washington, D.C. 20555 Vice President and Senior Counsel Carolina Power & Light CcInpany Docketing and Service Section P.O. Box 1551 Office of the Secretary Raleigh,' North Carolina 27602 U.S. Nuclear Regulatory Ccanission Washington, D.C. 20555 Dr. Phyllis I.ctchin 108 Bridle Run Mr. Daniel F. Read, President Chapel Hill, North Carolina 27514 CIENGE/ELP 5707 Waycross Street Dr. Linda W. Little Raleigh, North Carolina 27606 Governor's Waste Management Scard 513 Alberurie Building 325 North Salisbury Street Raleigh, North Carolina 27611 J
, e , , . . , -- .,,e - - . , -- -- ,. .v.,_._-,,~,-- ,_.-..w- ., v.,,. .vcm.s- .-w~.----
)
Bradley W. Jones, Esquire U.S. Nuclear Regulatory Cm mission Region II -
101 Marrietta S' M Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atanic Safety and Licensing Board Panel U.S. Nuclear Pegulatory Camission Washington, D.C. 20555 Mr. Ibbert P. Gruber Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 1
6 1
w _ g , e--m, -, w ,, ,- , -,, +-,y,,-g,, ,-, , ,,,, , -