ML20083K546

Response to Joint Intervenors Request for Production of Documents Re Contention Vii.Requested Documents Will Be Made Available at Harris Energy & Environ Ctr.Certificate of Svc Encl.Related Correspondence

ML20083K546
Person / Time
Site:	Harris
Issue date:	04/09/1984
From:	Patricia Anderson CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20083K535	List: ML20083K530 ML20083K546
References
OL, NUDOCS 8404160211
Download: ML20083K546 (8)

Text

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. ggo CO3RESPOSDMW5. April 9, 1984 DOpgCKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION'84 NM 13 m):

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD. .

Att in iiN3 6 SEHvirs nPANCH In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY)

AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL l MUNICIPAL POWER AGENCY ) 50-401 OL l

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

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l APPLICANTS' RESPONSE TO JOINT INTERVENORS ' REQUEST FOR PRODUCTION OF DOCUMENTS '(CONTENTION VII) l Pursuant to 10 C.F.R. S 2.741(d), Applicants hereby respond to Joint Intervenors' Request for Production of Docu-ments as contained in " Joint Intervenors' General Interroga-tories and Interrogatories on Contention 7(VII) to Applicants Carolina Power & Light et al. (First Set) . "

Certain of the documents requested by Joint Inter-venors contain confidential or proprietary information that Carolina Power & Light Company is under a legal obligation not to disclose to the public. Therefore, proprietary docu-ments will be made available to Joint Intervenors, if they desire to have their representative review such documents, after a protective agreement has been executed that ensures that the information obtained will not be disclosed to other individuals or entities or used for any purpose outside the context of the above-captioned proceeding. Subject to the 8404160211 840409 PDRADOCK05000gg Q

4 requirement of execution of a protective agreement prior to disclosure of proprietary information, the documents identified in " Applicants' Responses to Joint Intervenors' General Interrogatories and Interrogatories on Contention-VII (First Set)" will be made available to Joint Intervenors for inspection and copying in the following manner:

The requested documents that are located in Appli-cant's files and library at Carolina Power & Light Company's Engineering and Licensing sections in Raleigh, North Carolina will be made available at the corporate offices of Carolina Power & Light Company, 411 Fayetteville Street Mall, Raleigh, I

North Carolina, 27602. The documents will be made available during Carolina Power & Light Company business hours (or such 4

other mutually agreeable time). Appointments to inspect the documents may be arranged by telephoning Ms.'Edie McCrae, Legal Assistant,at (919)836-8162, at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before the requested inspection.

4 The requested documents that are located in-Appli-cants' files and library at the, Harris Energy and Environmental Center and the Harris Plant site will be made available at the Energy and Environmental Center, Route 1, New Hill, North Carolina. The documents will be made available during the business hours of the Energy and Environmental Center (or another convenient time) and appointments can be arranged by l

contacting Ms. McCrae as set forth above.

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f Many of the documents requested by Joint Intervenors are located at the H. B. Robinson Plant site. These documents-cannot be relocated because of logistical difficulties and, in some cases, because of regulatory requirements that such documentation remain at the plant site. Therefore those documents will be made available at the H. B. Robinson Plant site for Joint Intervenors' inspection at a mutually agreeable time. Appointments to inspect these documents must be made at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before the requested inspection to allow plant personnel to make the necessary arrangements. Appoint-ments for inspection of these documents may be arranged by telephoning Ms. Edie McCrae at the above number.

The requested documents will be made available to Joint Intervenors in the above-described manner for a reason-able period of time (i.e., through May 10), after which they will be returned to their place of origin. Inspection of documents contained on microfilm and reproduction of docu-ments by Carolina Power & Light Company will proceed on a schedule compatible with other demands for the necessary equipment. A Carolina Power & Light Company employee will be available during the inspection in order to receive any

i requests.for copying. Copies of such documents will be furnished to Joint Intervenors upon payment of 7 cents per page for reproduction to meet Carolina Power & Light Company's cost of reproduction.

Respectfully submitted, By:

Thomas A. Baxter, P.C.

John H. O'Neill, Jr., P.C.

Pamela H. Anderson Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036

'(202)822-1148 and Richard E. Jones Samantha F. Flynn Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina- 27602 (919)836-6839 Counsel for Applicants Dated: April 9, 1984 1 .

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0,4 l r l DOCHETED UitP' UNITED STATES OF AM g C4 NUCLEAR REGULATORY COMPIISS%A3 All :18 BEFORE THE ATOMIC SAFETY AND LICENSINGaBOARD id.6 4 SERVlu BRaHCH In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY)

AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the documents on the Document List attached hereto were served this 9th day of April, 1984, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.

Mw Pamela H. Anderson I

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DOCUMENT LIST

1. Applicants' Responses to Joint Intervenors' General Interrogatories and Interrogatories on Contention VII (First Set)

2. Affidavit of M. G. Zaalouk

3. Applicants' Response to Joint Intervenors' Request for Production of Documents (Contention VII)'

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAF*CTY 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 Jens L. Kelley, Esquire John D. Runkle, Esquire Atmic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Camission 307 Grarwille Road Washington, D.C. 20555 Chapel Hill, North Carolira 27514 Mr. Glenn O. Bright M. ""ravis Payra, Esquire Atmic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Camission P.O. Box 12607 Washington, D.C. 20555 Raleigh, North Carolira 27605 Dr. Jens H. Carpenter Dr. RicPard D. Wilson Atmic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatcry C-4 =sion Apex, North Carolina 27502 Washingten, D.C. 20555 Mr. Wells Eddleman Charles A. Barth, Esquire 718-A Iredell Street Janice E. Mocre, Esquire Durham, North Carolira 27705 Office of Executive Imgal Director U.S. Nuclear Regulatory Camission Richard E. Jones, Esquire Washi:vJton, D.C. 20555 Vice President arxi Senicr Ccunsel Carolina Power & Light Ca pany.

Docketing and Service Section P.O. Box 1551 Office of the Secretary Raleigh, North Carolina 27602 U.S. Nuclear Regulatory Camission Washington, D.C. 20555 Dr. Phyllis I.ctchin 108 Bridle Run Mr. Daniel F. Road, President Chapel Hill, North Cazolina 27514 OGNGE/EG 5707 Waycross Street Dr. Linda W. Little Raleigh, North Carolina 27606 Governor's Waste Management Berri 513 Albemarle Building 325 North Salisburf Street Raleigh, North Carolina 27611

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Bradley W. Jones, Esquire j U.S. Nuclear Segulatory Camission j Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atcmic Safety and Licensing Board Panel U.S. Nuclear Regulatory Ccruission Washington, D.C. 20555 Mr. Robert P. Gruber -

Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 R