ML20087J507
| ML20087J507 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/19/1984 |
| From: | Oneill J CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | JOINT INTERVENORS - SHEARON HARRIS |
| References | |
| CON-DSB-58 OL, NUDOCS 8403220261 | |
| Download: ML20087J507 (21) | |
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DOCKETED 56 usunc March 19, 1984
'84 WR 22 n9 33 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. 50-400 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 JOINT INTERVENORS (SEVENTH SET)
Pursuant to 10 C.F.R. $$ 2.740b and 2.741, Carolina Power
& Light Company and North Carolina Eastern Municipal. Power Agency hereby request that Joint Intervenors (Kudzu Alliance, CCNC, CHANGE /ELP & Wells Eddleman) answer separately and fully in writing, and under oath or affirmation, each of the follow-ing interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identi-fied 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 8403220261 840319 PDR ADOCM 05000400 -
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s the interrogatories; responses'or objections to the request for production of documhnts must be served within 30 days after
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service of the request".
These interrogatories are intended to be continuing in na-ture, and the' answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. $ 2.740(e),
should Joint Intervenors or any individual acting on their be-half obtain any new or differing information responsive to these interrogat'ories. The request for production of documents is also continuing in natur,e'and Joint Intervenors must produce immediately any additional documents they, or any individual acting on their behalf, obtain which are responsive to the re-quest, in accor' dance with the provisions of 10 C.F.R.
$ 2.~740(e).
Whereiden(ificationofadocumentisrequested,briefly describe the document (e.g., bo'k, o letter, memorandum, tran-script, report, handwritten notes, test data) and provide the
~following information as applicable: document name, title,
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number, suthor, date of' publication and publisher, addressee, date written-' or approv _' and the name and addresa of the per-son'or persons .having' posss -4on of the document. Also state
! the portion or-portion's pf the cocument (whether section(s),
cNapter(s), or page(s))'upc'n which Joint Intervenors rely.
Definitions: As 'used'.hereinaf tar, the follo' wing defini-tions chall apply:
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The "FSAR" is the Final Safety Analysis Report for the Shearon Harris Nuclear Power Plant, an amended.
The "SER" is the Safety Evaluation Report related to the operation of Shearon Harris Nuclear Power Plant, Units 1 and 2, t
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.
" Joint Intervenors" is intended to encompass the following organizations and individuals, jointly and severally: Chapel Hill Anti-Nuclear Group Effort, the Environmental Law Project, the Conservation Council of North Carolina and the Kudzu Alli-ance, as organizations, their members, and their representa-tives, and Mr. Wells Eddleman.
" Document (s)" means all writings and records of every type in the possession, control or custody of Joint Intervenors or any individual acting on their behalf, including, but not lim-ited to, memoranda, correspondence, reports, surveys, tabu-lations, charts, books, pamphlets, photographs, maps, bulle-tine, minutes, notes, speeches, articles, transcripts, voice recordings and all other writings or recordings of any kind;
" document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody, or i control of Joint Intervenors; a document shall be deemed to be within the " control" of Joint Intervenors or any individual l acting on their behalf if Joint Intervenors or the individual 1
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1 acting on their behalf have ownership, possession or custody of the document or copy thereof, or have the right to secure the document or copy thereof, from any person or public or private l l
entity having' physical posression thereof.
General Interrogatories
- 1. Please provide supplemental answers to Applicants' General < Interrogatories (Sixth Set) on Joint Contention VII, based upon any additional information obtained to date.
2(a). State the name, present or last known address, and present or last employer of each person, other than affiant, who provided-information upon which Joint Intervenors relied in answering each interrogatory herein, or who otherwise assisted you 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.
(c). For each such person who provided you with informa-tion upon which you relied in answering any interrogatory here-in or who assisted you in answering any interrogatory herein and who is an expert (i) provide that person's expertise and
, facts supporting his expertise, (ii) if that person has been i
" retained or specially employed," state in detail the facts underlying any " retained or speciallyjemployed status," (iii) if that person's.. identity is being withheid, (A) er. plain the.
i s need to withhold suchv person's identity,- and (B)~ state,the s
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protection or privilege upon which you rely in withholding the person's identity (see Licensing Board's Memorandum and Order of May 27, 1983).
(d). For each such person who provided you with informa-tion upon which you relied in answering any interrogatory here-in or who assisted you in answering any interrogatory herein and who is not an expert, identify that person in accordance with the Licensing Board's Memorandum and Order of May 27, 1983.
- 3. Provide the information requested in Interrogatory 2(c) and (d) above for " Alice Ace," referred to in your re-j sponses to Applicants' Sixth Set of Interrogatories.
4(a). Identify all documents in Joint Intervenors' pos-session, custody or control, including all relevant page cita-tions, upon which Joint Intervenors relied in answering each interrogatory herein.
(b). Identify the specific interrogatory response (s) to which each such document relates.
5(a). Identify any other source of information, not pre-viously identified in response to Interrogatory 2 or 4, which was used in answering the interrogatories set forth herein.
(b). Identify the specific interrogatory response (s) to l which each such source of information relates.
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Interrogatories on Joint Contention VII (Steam Generators)
Please refer to " Joint Intervenors' Response to Appli-cants' Sixth Set of Interrogatories (On Joint I and VII)" dated February 22, 1984.
VII-34. Please provide complete answers to Interrogato-ries VII-1, VII-2, VII-3, VII-6, VII-7, VII-9, VII-10, VII-11, VII-13, VII-17, VII-18, VII-19, VII-20, VII-22, VII-24, VII-25, VII-26, VII-27, VII-28, VII-29, VII-31, VII-32, VII-33, for which you previously responded that your analysis or review was
" incomplete."
VII-35. Refer to your response to Interrogatory VII-1.
NUREG-1014 provides the NRC Staff analysis of the modifications to Westinghouse Model D4 steam generators reviewed by the Tech-nical Review Committee ("TRC") of the' Counter Flow Steam Gener-ator Owner's Review Group. Appendix B to NUREG-1014 provides the independent evaluation of the TRC of the Westinghouse pro-posed modifications.
(a) Identify any and all conclusions and analy-ses set forth in NUREG-1014 (including Ap-pendix B), relevant.to Contention VII, with which you take issue.
(b) State in detail the factual basis for your disagreement with each conclusion and anal-ysis identified in response to (a) above.
(c) Do you contend that additional analyses must be performed to ensure the modifica-tions'to Westinghouse D4 steam generators, identified in NUREG-1014, are adequate to protect public health and safety?
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(d) If the answer to (c) above is other than an unequivocal negative, identify each such additional analysis and the factual basis for your proposing it.
(e) The expanded tubes, which are part of the D4 modifications, must meet the acceptance criteria set forth in NUREG-1014, Appendix B, Section 2.4.1. (item 6) and Section 5.4.3. Do you contend that the evaluation and these acceptance criteria are inade-quate?
(f) If the answer to (e) above is other than unequivocal negative, state the factual basis for your response.
(g) If the answer to (c) and/or (e) above is negative, explain how your response is con-sistent with the allegations set forth in Contention VII.
VII-36. In your Response to Interrogatory VII-1, you al-lege that expanding certain of the steam generator tubes will make them more subject to denting. Testing performed by Westinghouse and reported in NUREG-1014, Appendix B, Section 5.4.2, demonstrates that the tube expansion does not increase susceptability of the tubes to denting. State the factual basis for any disagreement that you have with the analysis and conclusion set forth in NUREG-1014, Appendix B, Section 5.4.2.
VII-37. Refer to your Response to Interrogatory VII-1.
(a) Do you. contend that the 124 expanded tubes in each steam generator (after the modifi-cation to the D4 steam generator at the l
Harris Plant) will be susceptible to' multi-ple tube ruptures?
(b) If the answer to (a) above is other than_an unequivocal ~ negative, state in detail the factual basis for your' answer.
(c) If the answer to (a) above is negative, explain how your response is consistent l
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with the allegations set forth in Conten-
- tion VII.
VII-38. Refer to your Response to Interrogatory VII-2.
(a) State in detail the basis for your allega-tion that the stresses from expanding the steam generator tubes "may weaken the tube or part of it or make it more susceptible to Corrosion."
(b) The stresses on the tubes as a result of
- tube expansion must meet acceptance i criteria, including ASME Code Section III, 4
set forth in NUREG-1014, Appendix B, .Sec-tion 2.4 and Section 5.6. Do you-contend
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that the analysis therein and the estab-lished acceptance criteria are inadequate?
(c) If the answer to (b) above is other than an unequivocal negative, state the factual basis for your answer.
(d) If the answer to (b) above is negative, explain how your response is consistent with the allegations set forth in your ear-lier response to Interrogatory VII-2.
(e) Do you disagree with the finding in Appen-dix B of NUREG-1014 (at B-101) that the ex-
- pansion of the tubes will result in an in-crease in thertube yield strength, thereby resulting in an increase in the margin be-tween leak and break?.
1 (f) If the answer to (e) above is other than an unequivocal negative, states the factual basis for your answer.
i 1 (g) If the answer to (e) above is negative, explain how your response is co.nsistent with the allegations set forth in your ear-lier response to Interrogatory VII-2. .
VII-39. Refer to your Response to Interrogatory VII-3.
l (a) State in detail the factual basis for your statement that "the NUREG-1014 modifica-
-tions . . . [may] weaken the tubes'or make them more subject to . . . rupture due'to loose objects in.the steam-generators. . .
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o (b) What is the factual basis of your statement that "it may not be possible to sleeve a tube which has only been expanded at cer-tain points?"
1 (c) What is meant by the phrase " expanded i l
evenly?"
1 (d) Do you allege that the ability to sleeve an expanded tube is necessary in order to pro-tect public health and safety?
(e) If the ancwer to (d) above is other than an unequivocal negative, state in detail the basis for your answer.
(f) Do you contend that expansion of certain steam generator tubes may affect the abili-ty to plug such tubes?
(g) If the answer to (e) above is other than an unequivocal negative, state in_ detail the factual basis for your answer.
- VII-40. Refer to your Response to Interrogatory VII-6.
Interrogatory VII-6 asked you to id3ntify the increases in oc-cupational exposures to maintenance workers at the Harris Plant that you contend will result from operation of the Harris Plant with the proposed modifications to the D4 steam-generators and to state in detail all facts which support your allegation.
Your answer only talked in general about increasing radiation exposure resulting from steam generator problems. Please iden-tify specifically how the proposed modifications to the D4 steam generators will result in any increase in the occupation-al exposures to maintenance workers at the Harris Plant.
VII-41. Refer to your response to Interrogatory VII-7.
What statements in SECY-82-72 do you contend show that " Harris Steam' Generators cannot be operated consistent with ALARA and the public health and safety"? l l
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VII-42. State in detail the factual basis for your state-ment in response to Interrogatory VII-7 that "[wje don't be- l lieve that the proposed modifications are consistent with ALARA."
VII-43. Describe in detail your understanding of the ALARA principle as it applies to the D4 steam generator modifi-l cations, including whether you contend that ALARA is meant to preclude any radiation exposure. State the factual basis for your answer.
VII-44. In your Response to Interrogatories VII-9 and VII-13, you assume that CP&L's H.B. Robinson Unit 2 operated
'with AVT steam generator water chemistry. State the factual basis for this assumption.
VII-45. In your Response to Interrogatory VII-9, you link AVT water chemistry to denting of steam generator tubes.
(a) Please list every plant at which steam generator tube denting has occurred and where the plant (1) has utilized AVT water chemistry from initial op-erations and (ii) is cooled with fresh water.
(b) Describe in detail your understanding of the denting phenomenon and how AVT water chemistry is linked to denting.
(c) Do you contend that AVT, in and of
'itself will cause denting?
(d) If the answer to (c) above is other than an unequivocal negative, state the factual basis for.your answer.
(e) If.the answer to (c) above is nega-tive, explain how your response is consistent with the allegations set forth in your earlier response to Interrogatory VII-9.
VII-46. Provide any other factual basis, not discussed in your Response to Interrogatory VII-9, upon which you rely to support your allegation that the efforts to be undertaken by Applicants (see FSAR S 5.4.2.1; SER 5 5.4.2) will be inadequate to minimize corrosion or cracking of the steam generator tubes.
Address again, in particular, the AVT water chemistry program described in FSAR S 5.4.2.1.3.
VII-47. In response to Interrogatory VII-11, you state that you "are not sure that any available water chemistry con-trols by themselves will be sufficient to minirize or prevent tube corrosion or cracking . . ." Identify any water chemis-try program which you believe will acceptably minimize steam generator tube corrosion or cracking and state in detail the factual basis for your belief.
VII-48. In response to Interrogatory VII-11, you sug-gested " changes in the steam generator materials, use of sacri-ficial anodes or other modifications or outright replacement of steam generators may be required" in order to minimize tube corrosion and/or cracking. Describe in detail each such action you claim necessary or desirable and state the factual basis for proposing each such action.
VII-49. State in detail the basis for your statement in-response to Interrogatory VII-11 that "[e]xpanding the tubes may actually increase susceptibility to corrosion for those tubes."
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VII-50. In response to Interrogatory VII-17, you state "we believe that both the sensors and the [ loose parts moni-toring] system's other components should be safety grade."
Please state in detail precisely which sensors and components you believe should be safety grade (including a definition of what you mean by " safety grade"), and state in detail the fac-tual basis for this belief.
VII-51. In response to Interrogatory VII-18 you state "the whole system should be safety grade and tested for large weights." Please define specifically (a) what you mean by "the whole system", (b) what you mean by " safety grade", (c) how you contend the system should be tested for large weights, (d) what additional information would be provided that is not presently available as a result of testing with small weights and (e) how "large weights" could be found loose within the steam genera-tor. State the basis for your answer.
VII-52. Refer to your response to' Interrogatory VII-21.
In view of the occupation exposures which you contand would re-sult from the removal of discovered loose parts, do_you there-fore not favor the use of a loose parts monitoring system at the Harris Plant? State the factual basis for your answer.
VII-53. Do you contend that the Staff's acceptance criteria for loose parts monitoring systems, set forth'in Regu-latory Guide 1.133, are inadequate?
l VII-54. If the answer to Interrogatory VII-53 above is other than an unequivocal negative, state in detail the factual basis for your answer.
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VII-55. Do you contend that the Harris Plant loose parts monitoring system does not meet the intent of Regulatory Guide 1.133?
VII-56. If the answer to Interrogatory VII-55 above is other than an unequivocal negative, state in detail the factual basis for your answer.
VII-57. Refer to your Response to Interrogatory VII-22.
(a) Do you contend that any radiation ex-posure incurred "when people work near radioactive things" violates ALARA principles?
(b) What is the factual basis to your an-swer to (a) above?
VII-58. Refer to your response to Interrogatory VII-24.
(a) Please state any and all recommenda-tions in the Report by Science Appli-cations, Inc. ("SAI") that you believe supports 2n any way the allegations set forth in Contention VII.
(b) State in detail the factual basis for your answer to (a) above.
VII-59. Do you contend that the guidelines set forth in NUREG-0800 for steam generator tube rupture ("SGTR") analyses are inadequate?
VII-60. If the answer to Interrogatory VII-59 above is other than an unequivocal negative, state in detail the factual basis for your answer and any recommendations that you have to address the inadequacies you perceive with the NRC guidelines.
VII-61. If the answer to Interrogatory VII-59 above is negative, state how your response is consistent with the allegations in Contention VII.
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t VII-62. Do you contend that the SGTR analyses presented in Chapter 15 of the Harris FSAR, as amended, fail to comply with the guidelines of NUREG-0800?
VII-63. If your answer to Interrogatory VII-62 above is other than an unequivocal negative, state in detail the factual basis for your answer.
VII-64. If your answer to Interrogatory VII-62 above is negative, state how your answer is consistent with the allega-i tions set forth in Contention VII.
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VII-65. Do yca contend that the offsite doses which are analyzed in the ESAR to result from an SGTR exceed applicable guidelines?
VII-66. If your answer to Interrogatory VII-65 above is other than an unequivocal negative, state in detail the factual basis for your response.
VII-67. If your answer to Interrogatory VII-65 above is negative, state how your response is consistent with the alle-gations set forth in Contention VII.
VII-68. Do you contend that the offsite doses resulting from an SGTR demonstrate that the Harris Plant will not ensure adequate protection to the public health and safety in the event of a tube rupture?
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! VII-69. If the answer to Interrogatory VII-68 above is other than unequivocal negative, state in detail the factual basis for your response.
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I s l VII-70. If the answer to Interrogatory VII-68 above is negative, state how your response is consistent with the alle-gations set forth in Contention VII.
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VII-71. Refer to your response to Interrogatory VII-31.
(a) Please provide the page reference in NUREG-0909 which you contend shows that multiple tube ruptures occurred at the Ginna Plant.
(b) What, if any, statement in NUREG-0909 do you contend supports in any way the allegation set forth in Contention VII?
(c) State in detail the basis for your an-4 swer to (b) above.
VII-72. Refer to your response to Interrogatory VII-31.
(a) State in detail the basis for your alle-gation that " events like SGTR , . . re-lease radioactivity inside containment."
(b) State in detail the basis for your alle-gation that "such release of radioactivity inside containment" is not consistent with ALARA.
VII-73. Please refer to Eddleman Proposed Contention 180, which questions the ability to isolate the steam generators in a timely manner following a steam generator tube rupture.
(a) State in detail the factual basis for the statement that "[t]he need for such isolaiton is clear in light of the Ginna accident, which released
, redioactivity to the public."
l l (b) Do you disagree with the statements at
- p. 1-7 of NUREG-0909 that ". . .other offsite releases were estimated to be less than-25% of the limit for unrestricted areas. All releases would result'in doses which were sig-nificantly less than the 10 CFR 100 guidelines"?
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(c) If the answer to (b) above is other than an unequivocal negative, state in detail the factual basis for your an-swer.
(d) If the answer to (b) above is nega-tive, explain how your answer is con-sistent with the allegations set forth in Contention VII (as it incorporates certain allegations set forth in Eddleman 180).
Please refer to the " Affidavit of Robert H. Koppe" dated February 27, 1984 (hereinafter "Koppe Affidavit"), filed in support of " Applicant's Motion for Summary Disposition of Eddleman Contention 15AA" (February 28, 1984).
VII-74. The worst steam generator corrosion problems have occurred at plants which are on seawater and/or used phosphate chemistry. To date the Westinghouse three-loop plants (similar to the Harris Plant) have lost an average of 8.0% of capacity factor due to steam generator corrosion while those Westinghouse plants which have never used phosphates and are not located on seawater have lost an average of only 0.8%.
Koppe Affidavit at 12-13. Do you disagree with these state-ments?
VII-75. If the answer to VII-74 above is other than an unequivocal negative, state in detail the factual basis for your answer. Include with your answer (a) a list of all nucle-ar plants which have operated only with AVT (no phosphates) water chemistry and are not cooled with sea water systems, (b) 1 any significant tube corrosion or cracking in any plant identi-fied in (a), (c) the reason for the tube corrosion and/or
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l cracking, and (d) the similarities between the steam generators in such plants and the D-4 steam generators in Harris Unit 1.
VII-76. If the answer to VII-74 above is negative, explain in detail why your answer is consistent with the alle-gations set forth in Contention VII.
VII-77. It is the presence of crevices (along with the i use of phosphates) which is responsible for most steam genera-tor problems at existing non-seawater plants, including Point i
Beach 1 and CP&L's H.B. Robinson 2, both of which are now un-dergoing steam generator replacement. Koppe Affidavit at 13.
Do you disagree with this statement?
VII-78. If the answer to VII-77 above is other than an unequivocal negative, state in detail the factual basis for your answer.
VII-79. If the answer to VII-77 above is negative, state how your answer is consistent with the allegations set forth in Contention VII.
VII-80. Since Shearon Harris is not on seawater'and will 2
not use phosphates, its steam generator performance would be expected to be better than the historical average for all
- Westinghouse plants, even if nothing else changed. Koppe Affi-davit at 12. Do you disagree with this statement?
VII-81. If the answer'to VII-80 above is other than an unequivocal negative, state'in detail the factual' basis for your answer.
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i VII-82. If the answer to VII-80 above is negative, state how your answer is consistent with the allegations set forth in Contention VII.
Request for Production of Documents Applicants request that Joint Intervenors respond in writ-ing 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.
Respectfulysub mitted i
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, h ,U Thodas A. Baxter, Py \'
Johnl H. O'Neill, Jr., P.
, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1148 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 26602 (919) 836-7.707 Dated: March 19, 1984
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter )
)
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 Joint Intervenors (Seventh Set)" were served this 19th day of March,1984, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.
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John H. O'Neill, Jr., P.C DATED: March 19, 1984
- i. 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 Jaues L. Kelley, Esquire John D. Runkle, Esquire Atanic Safety and Licensing Board . Conservation Council of North Carolina U.S. Nuclear Regulatory Ca nission 307 Granville Road Washingten, D.C. 20555 Chapel Hill, North Cerolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atanic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Canission P.O. Box 12607 Washington, D.C. 20555 Raleigh, North Carolina 27605 I- Dr. Janes H. Carpenter Dr. Richard D. Wilson Atanic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Camu.ssion Apex, North Carolina 27502 Washington, D.C. 20555 Mr. Wells FM 1eman Charles A. Barth, Esquire 718-A Iredell Street Janice E. MDore, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U.S. Nuclear Regulatory Cattnission ~ Richard E. Jones, Esquire Washington, D.C. 20555 Vice President and Senior Counsel Carolina Power & Light Cacpany Docketing and Service Section P.O.-Box 1551
- Office of the Secretary -Raleigh, North Carolina 27602 l U.S. Nuclear Regulatory Camlission l Washington, D.C. 20555 Dr. Phyllis Ictchin 108 Bridle Run.'
.Mr. Daniel F. Read, President Chapel Hill, North Carolina 27514 CHANGE /ELP
! 5707 Waycross Street ~Dr. Linda W. Little l Raleigh, Nori Carolina 27606 Governor's Waste Management Board 513 Albamarle'Buildirg' 325 North Salisbury Street Raleigh, North Carolina 27611 i
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l Bradley W. Jones, Esquire '
U.S. Nuclear Regulatory Ccanission Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atanic Safety and Licensing Board Panel U.S. Nuclear Regula" wry Ccmnission Wastungton, D.C. 2055$
Mr. Robert P. GnWer Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602
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