ML20080M828

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Further Answers to First Set of Interrogatories Per Agreement.Certificate of Svc Encl
ML20080M828
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 09/30/1983
From: Mcdaniel A, Morgan R, Parsons R, Reid M, Webster B
CAROLINA POWER & LIGHT CO.
To:
HARTSVILLE GROUP
References
83-484-03LA, 83-484-3LA, ISSUANCES-LA, ISSUANCES-OLA, NUDOCS 8310040282
Download: ML20080M828 (19)


Text

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00CNETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION BEFORE Tile ATOMIC SAFETY AND LICENSING BOARB3 E -3 P3 :28 In the Matter of ~) CFF!rE Cr Mcrno y

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CAROLINA POWER & LIGHT COMPANY ) Docket No. 50-261-OLA 1

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(H. B. Robinson Steam Electric ' ) ASLBP No. 83-484-03LA Plant, Unit 2) )

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  • APPLICANTS FURTiiER ANSWERS TO TIIE HARTSVILLE GROUP FIRST SET OF INTERROGATORIES - PURSU ANT TO LETTER AGREEMENT DATED SEPTEMBER 1,1983 e -. e e e e .

Dear Mr. Matthews:

Pursuant to the signed letter agreement dated September 1,1983, between George F. Trowbridge, Counsel for Applicant, and you as Representative for the Hartsville Group, Applicant herein sets forth its answers:

INTERROGATORY NO.1-34. Ilave any C P & L employees or contractor or subcontractor employees been warned, counseled, disciplined, transferred, demoted, penalized, suspended or terminated as a result of non-compliance with NRC operating and administrative procedures, rules or regulations at any licensed facility or for actions under any NRC license since January .1,1978? Identify the name, title, dates of employment, address and telephone number of each such employee; describe in detail the 1

action taken, the reason for each such action, the procedures, rules or regulations not complied with, and the safety significance of such non-compliance, l

ANSWER NO.1-34. Yes. This response relative to the characterized " Disciplinary

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Actions" to CP&L employees is based on (a)'a file search of documents related to the non-compliances covered by an NRC notice of violation and CP&L's response thereto since January 1,1978, and, where such documents reveal pertinent employee names, (b) a '

review of the personnel record of the CP&L employee (s) involved. Where documents did not specify employees by name, inquiries were made which resulted,in certain instances, in a determination of specific names. The violations or claims of violations since January 1,1978 are as represented by Applicant's responses identifying and responding to

! each violation. Copies of said responses have been previously furnished to the Hartsville

- Group in connection with Applicant's ANSWERS 1-30,1-31 and 1-35 (First Set).

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  • The following information references the nuclear plant involved, the Inspection Report # and date of CP&L's response, the action taken as to the employee (s), and the incident involved. The procedures, rules or regulations not complied with and safety significance of the violations are as set forth in said responses.
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H. B. Robinson Unit 2 l i

INSPECTION DATE REPORT OF RESPONSE INCIDENT INVOLVED ACTION TAKEN 78-13 7/26/78 A chain holding up a radiation area Employee involved sign had broken loose from the wall ,

was reprimanded and and a Radiation Control Technician counseled.

was instructed to submit a trouble ticket for the repair of the chain.

The technician failed to perform this task.

79-14 8/22/79 Individuals entered the reactor contain- Employees were ment, which was a locked, high radiation counseled. l I

area, without entering their names on a valid radiation work permit.

79-29 2/5/80 Fire protection program states that All parties involved every connection from a yard main to a were made aware of building be equipped with a post indicator the incident and valve, and large yard main systems must be cautioned to prevent provided with sectional controlling valves further occurrence.

at appropriate points. However, the yard main connection to the Auxiliary Building interior fire hose system was not provided with a post indicator valve and a post indicator sectional control valve was not provided for the northeast portion of the water main loop. This was a result of an FCR (field change request) made by Con- i struction that was disapproved by Engi- I neering but the change was actually made.

80-24 11/12/80 Field documents used to verify the Employees involved ,

as-built for safety-related system were cautioned and l ISO-RC-4 did not have any records of counseled. l inspection of clearances for the wall penetrations.

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INSPECTION DATE r REPORT ROF RESPONSE INCIDENT' INVOLVED ACTION TAKEN 81-07 7/30/81 An Auxiliary Operator was climbing in Employee involved the overhead piping in the Boric Acid was reprimanded.

Evaporator Room wearing only shoe covers and gloves instead of anti-contamination l clothing which were required.

1/29/82 An individual was observed in the Boric Employee involved Acid Evaporator Room without a dose rate was reprimanded.

survey instrument.

81-10 6/17/81 Radiation surveys of the hot leg compart- Employees involved ment inside Steam Generators A, B, C were cautioned as performed 9/17/80 were not maintained or to the importance preserved. of retaining all i survey documentation.

81-20 9/10/81 Changes were made in the Gas Calibration Employees involved

, step of procedure RCP-1, without prior were cautioned.

review by Plant Nuclear Safety Committee or approval by the General Manager.

81-31 12/22/81 An operator failed to follow valve lineup Employee involved procedure OP-38A for positioning of valve was counseled regarding ,

RHR-764 from locked open to locked shut the seriousness of position. improper performance '

of valve lineups.

~82-04 4/15/82 Equipment control policy was not imple- Employees direa.tly mented in that Local Clearance and Test involved were Request 113 listed incorrect auxiliary admonished, feedwater system valves for the maintenance per formed, and clearance was canceled without opening the isolation valve for a local suction pressure gauge.

82-33 12/2/82 QA~ audits were not performed within the Employees (0QA) 24 month frequency. responsible were counseled by the Corporate QA, not by the HBR management.

82-42 3/4/83 Various Fuel Shuffle procedures were Employee involved not implemented during the 12/26-12/28 had disciplinary fuel movement. action taken against him involving loss of pay. The employee's Shift Foreman was i 4

counseled.

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INSPECTION DATE REPORT OF RESPONSE INCIDENT INVOLVED ACTION TAKEN 83-08 6/22/83 Disposal of 1 gallon of liquid waste Employees responsible containing licensed material by way were admonished and of Chem-Nuclear Systems, Inc., SC, counseled, who was not authorized to receive liquid waste.

BRUNSWICK STEAM ELECTRIC PLANT 78-17 9/20/78 Individual was observed not wearing Employee involved the required protective clothing as was counseled on specified, importance of radiation control techniques.

79-04 3/12/79 After an individual had received an Employees involved 79-03 exposure in excess of 5 rem (whole were counseled on body), Licensee failed to submit value of prompt a written report within 30 days. submittals.

79-07 4/2/79 Reviewers failed to notice out of Employee involved specification stroke time for valve was counseled.

F046 during RCIC Pump and Valve Operational Test.

79-26 7/24/79 Two Auxiliary Operators without lab Employees involved coats entered a contamination area were counseled by the in the Reactor Building which required Shift Foreman.

lab coats for entry.

79-33 10/25/79 QA Test results had discrepancies Employees involved 79-34 that had not been identified by were cautioned about Licensee's review process. seriousness of not recognizing and evaluating deficiencies.

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INSPECTION DATE RZPORT OF RESPONSE INCIDENT INVOLVED ACTION TAREN 79-37 12/20/79 A fire protection sprinkler and stand- Employees involved pipe system for the No. 3 Diesel Generator were counseled regarding was isolated and the continuous fire watch the proper actions to was not stationed, take.

80-37 1/13/81 Valve lineup verification documentation Appropriate corrective showed that locked valve PT46.1, RCIC, or disciplinary actions and HPCI turbine exhaust manual stop for employees were check valves were verified open, when taken - two Shift in fact both were closed. Foremen received no nuclear license supplement pay for one week; two Auxiliary Operators given one day off with no pay.

80-38 12/30/80 Sampling and analysis of airborne Involved RC&T tech-80-41 particulate radioactivity was nicians were counseled.

inadequate: 40% of total particulate activity in Reactor Building roof vents were not identified.

80-42 2/3/81 Training requirements for BSEP QA Appropriate employees 80-39 Surveillance Personnel, which had were counseled, not been revised since 9/75, referenced procedures that no longer existed and did not cover more than 25 standards and procedures that were then a part of QA Control.

80-44 12/18/81 Various vent monitors were found to be Technicians responsi-80-46 inoperable due to lack of maintenance. ble were counseled.

81-09 7/1/81 Approval requirements for temporary Employees involved changes made to procedures RC-ER-12 were counseled.

and RC-ER-18 were not met.

81-14 8/26/81 As a result of operator error, the Disciplinary action reactor mode switch was taken out of was taken with the the refueling mode, placed in startup, employees involved, and controlled withdrawal commenced with Letter of reprimand the A-loop RHR torus suction valve shut. placed in file for one year period.

INSPECTION DATE REPORT OF RESPONSE INCIDENT INVOLVED ACTION TAKEN 81-16 10/30/81 Radiation Hazards Survey concerning All three employees repair of a valve was inadequate, involved were counseled causing a worker to exceed dose and disciplinary action limit. was taken - one employee was given two weeks off without pay; two employees were assigned to Caswell Beach Pump-ing Station.

81-19 10/6/81 Two employees were observed in posted Employees involved radiation areas without proper dress, were counseled.

81-20 10/12/81 An inadvertent release of approximately Employee involved 300 gallons of liquid waste from the was counseled.

"B" floor drain sample tank without prior sampling for gross activity.

Temporary changes to PT-A3 Rev. O and Operations emp19yees OP-50.1 Rev. I3 were approved by Plant were cautioned.

Nuclear Safety Committee in 16 and 17 days instead of the required 14 days from implementation date.

81-24 11/2/81 Inoperable instrumentation channel All Senior Reactor was not placed in the tripped mode Operators were within one hour of determination counseled as well as that this instrumentation could not I&C periodic testing be calibrated. personnel.

81-28 11/30/81 Temporary change to Liquid Radioactive Operations employees Waste Processing System Procedure was were cautioned, not reviewed although it remained in effect through August 1981.

82-01 3/11/82 A primary coolant sample taken at Employees involved 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> exceeded .2 UCi/ gram dose were counseled.

equivalent I-131, and the subsequent samples required once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> were not taken.

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INSPECTION DATE REPORT OF RESPONSE INCIDENT INVOLVED ACTION TAKEN 82-02 8/16/82 Reactor vessel water level low Employees involved instrumentation ~(transmitter), required were counseled, by Technical Specifications,'was inoperable. However, trouble ticket was prepared, stating that the trans-mitter was not required by Technical Specifications.

'82-05 4/30/82 shift Foremen failed to complete an Employees involved Event Evaluation Check Sheet or make were counseled.

entry in the Shift Foremen's log when informed that the Standby Liquid Control heat tracing circuits were inoperable.

82-18 7/2/82 1A-1 battery charger was momentarily Two operators not positioned as per clearance responsible were procedure, and service water vital counseled.

header crosstie valve was not positioned as per operating procedure.

82-30 8/5/82 contrary to Technical Specification Technician involved 6.8.1(a), Regulatory Guide 1.33 was counseled.

Appendix A was not implemented in that safety-related equipment mainte-nance instruction was not correctly performed.

i f 83-03 6/24/83 Reactor Water Cleanup System was not Senior Reactor Operator isolated, as required by Table 3.3.2-1 was removed from Item 3.a. within one hour, licensed duties for l- two weeks and during t

that time was counseled.

I

83-17' 8/11/83 Unit 2 augmented off-gas system was On-shift personnel I

out of service and the air ejector 6xcluding radioactive

, off-gas monitors were inoperable, yet waste and fire protec-l a reactor shutdown was not initiated. tion) were immediately counseled. One Control Operator was removed I. from licensed duties

, with loss of license

!- supplement pay for 14

[ days. Approximately

! 10 Shift Operating

(. Supervisors, Shift

! Foremen, and Control Operators involved were given verbal 'epri-r mands evidenced by L memo to'their. files.

l INSPECTION DATE REPORT OF RESPONSE INCIDENT INVOLVED ACTION TAKEN 83-18 8/4/83. A representative air sample was not The Health Physics collected in an individual's breathing Technician involved zone while he was splitting radiocctive was been counseled.

waste bags containing material with unknown contamination levels and radiation levels of 30 mrem /hr.

SHEARON HARRIS NUCLEAR POWER PLANT 81-20 11/17/81 Tests were improperly performed on Concrete Compressive concrete cylinders due to excessive Testing certification loading. for the technician involved was rescinded until the technician passed both oral and written exams.

82-01 3/25/82 Weld inspector failed to identify and Employee responsibic report deficiencies because he did not was removed from pipe see them, weld inspection, pending reinstruction.

82-06 4/23/82 Weld inspector either overlooked or Employee responsible arbitrarily failed to reject defects was removed from pipe in welds, weld inspection and is no longer employed l

by CP&L.

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INTERROGATORY NO. 1-36. What are the bases for .your responses to Interrogatories 34 and 35? Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.

ANSWER NO.1-36. The bases of the response set forth in Answer 1-34 are the documents as described in said Answer.

INTERROGATORY. NO.- 1-38. Identify in detail any instances in which allegations have been made of pressure, intimidation, harrassment, encouragement, direct orders,

- suggestions, or inducement of any sort of employees of C P & L or its contractors or subcontractors intended to result in the violation of or non-compliance with NRC operating and administrative procedures, rules or regulations. For each such instance, set forth the name, address and telephone numbers of the person (s) making the allegation or involved in the matter alleged, describe fully any investigations made by C P & L or the NRC Staff, and describe in detail any actions taken.

- ANSWER NO.1-38. This response relative to the characterized " Allegations of Harassment" of CP&L employees is based on (a) a file search of documents related to the non-compliances covered by an NRC notice of violation and CP&L's response thereto since January 1,1978, and, where such documents reveal pertinent employee names, (b) a review of the personnel record of the CP&L employee (s) involved. The violations or claims of violations since January 1,1978 are as represented by Applicant's responses i

identifying and responding to each violation. Copies of said responses have been -

p previously furnished to the Hartsville Group in connection with Applicant's ANSWERS 1-30,1-31 and 1-35 (First Set).

CP&L's said document search has identified no instance of an allegation of any of the types described in Interrogatory No.1-38.

A INTERROGATORY NO. 1-39. Identify in . detail all documents reflecting disagreements,' disputes or differences of opinion between employees of CP&L and their supervisors or C P & L management regarding compliance or sufficiency of compliance with NRC operating and administrative precedures, rules or regulations. Include the subject, date, names of persons involved and resolution for each such instance.

ANSWER NO.1-39. CP&L has made additional inquiry of each plant general manager and past plant managers covering a period from January 1,1978 to the present. Such additional inquiry discloses no documents of a kind described in Interrogatory No.1-39.

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. ., 1 The following further response relative to the characterized " Disagreements" , '

betweal CP&L employees and their supervisors / managers is based on a file scarch of '

documents related to the nor.--compliances covered by an NRC notice of violation and CP&L's response thereto since January 1,1978. The violations or claims of violations , ,

, , 'I since January 1,1978 are as represented by Applicant's responses identifying and responding to each violation. Copies of said responses have been previously furnished to the Ilartsville Group in connection with Applicant's ANSWERS 1-30,1-31 and 1-35 (First Set).

CP&L's ,said document search has identified no documented instance of disagreements of the types described in Interrogatory No.1-39.

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INTERROG ATORY No. 8-27. Is the on-site storage of the SGLAs the preferable option for disposal of the SGLAs?

ANSWER 8-27. Yes.

INTERROGATORY NO. 8-28. What are the bases for your response to Interrogatory 27?

ANSWER 8-28. The bases for this response are given in detail in Section 3.5

" Disposition of Steam Generator Lower Assemblies (SGLA)" of the FSGRR, Rev.1.

INTERROGATORY NO. 8-41. What is the basis for the determination that no cask

~ is needed for transporting the SGLAs from the reactor containment building to the SGLA vault?

ANSWER 8-41. Casks for the shipment of radioactive material are used primarily to prevent the release of radioactive material under accident conditions possible during transport on the public roadways. The transfer of the SGLAs from the reactor containment building (RCB) to the long-term storage building will be over a very short distance, within an area where public access is controlled and under special handling procedures discussed in the FSGRR. Because of these conditions, no cask is required for this transfer. In addition, the radioactive material contained witnin the SGLAs will be sealed and the outer surface of the SGLAs will be covered and/or decontaminated before removal from the RCB. Thus, no radioactive material will be released during the transfer of the SGLAs from the RCB to the long term storage building.

INTERROGATORY NO. 8-42. What route will the truck take to haul the SGLAs from the RGB to the SGLA vault?

ANSWER 8-42. Drawing FSC-713-465, attached hereto, depicts the routing of the lower assemblies to be removed. This drawing should replace Figure 3.1-1 (in FSGRR) in the list of figures.

INTERROGATORY NO. 8-43. Describe in detail the design and construction of the special tractor-trailer arrangement to be used to haul the SGLAs from the RCB to the SGLA vault.

ANSWER 8-43. The tractor-trailer combination to be used is standard rental equipment for heavy haul utilization. CP&L presently will rent a Talbert trailer, Model I

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9 Tr4LW-250-FG-T1 or TT4LW-200-RG-1-T1. These trailers are available (for rental) from several companies. The tractor to be utilized will most likely be a tri-axle " Mack" tractor with air-lift suspension.

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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'No. 50-261-OLA

)

(H. B. Robinson Steam Electric ) ASLBP No. 83-484-03LA Plant, Unit 2) )

AFFIDAVIT OF RICHARD E. MORGAN ,

DARLINGTON COUNTY )

)

SOUTH CAROLINA )

Richard E. Morgan, being duly sworn according to law, deposes and says that he is General Manager - Robinson Plant with Carolina Power & Light Company; that the Answers to Interrogatories 1-34, 1-36, 1-38 and 1-39 contained in Applicant's Further Answers to The Hartsville Group First Set of Interroga-tories - Pursuant to Letter Agreement dated September 1, 1983, are true and correct to the best of his knowledge, information and belief insofar as the same pertains to H. B. Robinson Unit 2, and that the sources of his information are officers, employees, and agents of Carolina Power & Light Company.

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"RichardE.Morgp Swern to and subscribed before me this dt[dayofSeptember,1983.

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( Notary Public My commission expires: -d["h

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) )

AFFIDAVIT OF~ROLAND M. PARSONS WAKE COUNTY )

)

NORTH CAROLINA )

Roland M. Parsons, being duly sworn according to law, deposes and says that he is Proj5ct General Manager with Carolina Power & Light Company; that the Answers to Interrogatories 1-34, 1-36, 1-38 and 1-39 contained in Applicant i s Further Answers to The Hartsville Group First Set of Interroga-tories - Pursuant to Letter Agreement dated September 1, 1983, are true and correct to the best of his knowledge, information and belief insofar as the same pertains to Shearon Harris Nuclear Power' Plant, and that the sources of his information are officers, employees and agents of Carolina Power &

Light Company.

k 21 3l9fF V Roland M. Parsons

= l :Ww Sworn to and subscribed before me this 29% day of September,1983.

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Notary Public My commission expires: My Commission Ex;: ires 4 20 31

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 2i )

AFFIDAVIT OF B. H. WEBSTER County of Wake )

)

State of North Carolina )

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B. H. Webster, being duly sworn, according to law, deposes and says that he is Manager - Radiological & Chemical Support Section of Carolina Power & Light Company; that the answers to Interrogatories 8-27, 8-28, and 8-41 contained in Applicant's Answers to The Hartsville Group First Set of Interrogatories to Applicant, Carolina Power & Light Company, 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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/ B. H. Webster .

Sworn to and subscribed before -(Ih.IIO.7;)...

me this a9+L day of September, 1983.

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gtary Public \'ff}.,j.,!%.,>.,

My Commission Expires:

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UNITED STATES OF AMERICA-NUCLEAR REGULATOR 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- -

)

AFFIDAVIT OF MATTHEW J. REID DARLINGTON COUNTY )

)

-SOUTH CAROLINA )

Matthew J. Reid, being duly sworn according to law, deposes and says that he is the Robinson Construction Manager with Carolina Power &

Light Company; that the Answers to Interrogatories 8-42 and 8-43 contained

in Applicant's Further Answers to The Hartsville Group First Set of 1

Interrogatories --Pursuant to Letter Agreement. dated September 1, 1983, are true and correct to the best of his knowledge, information and belief, and thati the sources of h'is information are officers,' employees, agents and

. contractors of Carolina Power & Light Company.

Matthe# J. Reid .

Sworn to and subscribed before.

me-this y day of September, 1983.

. . , en 4 = .vbnh Notary Public My commission espr es: ,N,,yt,_ . //7/' -

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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 No. 50-261-OLA

)

'(H. B. Robinson Steam Electric .) ASLBP No. 83-484-03LA Plant, Unit 2) )

CERTIFICATE'0F SERVICE I hereby cert.ify that copies of " APPLICANT'S FURTHER ANSWERS TO THE HARTSVILLE GROUP FIRST SET OF INTERROGATORIES - PURSUANT TO LETTER AGREEMENT DATED SEPTEMBER 1, 1983" were served this 30th day of September,

'1983 by depositing in the United States mail, first class, postage prepaid, to the parties on the attached _ SERVICE LIST. -The affidavit of C. R. Dietz, as to InterroSatories 1-34, 1-36,'l-38 and 1-39 with respect to the Brunswick Plant,.is not attached to said ANSWERS and will be subsequently provided. .

, / fi _ / nd Andrew McDaniel i_

September 30, 1983

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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 No. 50-261-OLA

)

(H. B. Robinson Steam Electric ) ASLBP No. 83-484-03LA Plant, Unit 2) )

SERVICE LIST Administrative Judge Morton B. Margulies Atomic Safety and Licensing Board Chairman, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington,D.C. 20555 Administrative Judge Jerry R. Kline Atomic Safety and Licensing Appeal Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge David L. Hetrick B. A. Matthews Atomic Safety and Licensing Board Hartsville Group Professor of Nuclear Engineering P. O. Box 1089 University of Arizona Hartsville, South Carolina 29550 Tucson, Arizona 85721 Dr. John C. Ruoff Docketing & Service Section (3) P. O. Box 96 Office of the Secretary Jenkinsville, South Carolina 29065 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

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