ML20111C026
| ML20111C026 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/04/1985 |
| From: | Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| CON-#185-972 OL, NUDOCS 8501090153 | |
| Download: ML20111C026 (24) | |
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' January 4, 1985 4
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 85 3An -a 99;j, BEFORE-THEATOMICSAFETYANDLICENSI m&
In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
)
and NORTH CAROLINA EASTERN
)
Docket No. 50-400.0L MUNICIPAL POWER AGENCY
)
'~"
)
-(Shearon Harris Nuclear Power
)
' Plant)
)
APPLICANTS' REPLY TO WELLS EDDLEMAN'S PROPOSED FINDINGS ON CONTENTION 65 Introduction 1.
As originally admitted by the Board on September 22,
-1982, Eddleman Contention 65 stated as follows:
Because Daniel International, CPEL's 3
prime' contractor.on the Harris project, has a history of-building defective base mats and containments (e.g. Callaway, Wolf Creek,:Farley) a complete ultrasonic t
re-examination of the containment and base mat, able to detect voids over 1 inch in any size (any dimension over 1") therein, or another type of examination with similar capabilities to detect voids, is necessary before Harris.1 is allowed.to operate. Oth-erwise the voids could become (through cracking from thermal stress, concrete aging, or external impact) paths for radioactivity-to leak from containment at unforeseeable times,: including during rad releases inside containment, e.g. from re-actor and primary system relief valves after_a reactor trip or feedwater trip.
Supplement to Petition to Intervene by Wells Eddleman at 171 8501090153 850104 A
PDR ADOCK 05000400
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_ _ _. _ ~ __ _
' (thur 14, 1982 ) ; Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference), LBP-82-119A, 16 N.R.C. 2069, 1
'2101 (1982).
2.
In a telephone conference on July 12, 1984, the Board announced its decision to grant in part and deny in part Appli-cants' Motion for Summary Disposition of Eddleman Contention 65 4
(January 18, 1984).
As a part of its ruling, the Board substi,-
tuted the following language for the original Contention 65, to reflect the matters which remained in dispute:
l Inspection of CPEL concrete pour packages has shown that numerous instancds of im-proper concrete placement have occurred in the basemat and containment structure.
In view of this, a complete examination of the basemat and containment structure must be L
conducted using ultrasonic techniques or, where use of such techniques is not feasi-ble, other appropriate tests.
Tr. 2168-69.
The Board further ruled that the concrete pour packages at issue are those discussed in Wells Eddleman's Re-sponse to Summary Disposition Motion on Eddleman 65 (Concrete)
(June 14, 1984), and the accompanying Affidavit of Charles C.
l Stokes, with the exception of matters related to the waterstop, which the Board excluded by rejecting proposed Eddleman Conten-i-
l tion 65-B.
Tr. 2172-75.
The Board also held that the second sentence of the revised contention (on testing) would not be at issue unless litigation of the first sentence revealed actual l
defects in the concrete.
Tr. 2170.
I 3.
Following the receipt of evidence on Eddleman Conten-i I
tion 65 and prior to the adjournment of the hearing on safety i l
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4 matters, the Board sua sponte reached a tentative decision on that contention.
Tr. 7368-7370.
The Board ".
tentatively concluded that there is no basis for questioning the integrity of the concrete in the Harris containment."
Tr. 7369.
In ex-planation of the grounds for its tentative decision, the Board stated its findings that ".
. the Applicant and Staff direct cases were very convincing," and ".
. that those cases were not shaken by the cross-examination."
Id.
With respect to Eddleman witness Stokes, the Board found that:
(1) he ".
was rather substantially impeached in his presentation";
(2) "... he retracted much of his testimony previously filed"; and (3) he did not raise ".
. any questions of a safety nature about the containment concrete."
Id.
The Board therefore adopted the direct testimony of Applicants and the Staff as its tentative decision _in favor of Applicants and the Staff on Eddleman Contention 65.
Tr. 7369-70.
4.
The Board provided Mr. Eddleman with the opportunity to file proposed findings on Contention 65 if he wished to con-tinue to pursue the matter.1/
In view of the Board's tentative decision and the state of the record, any proposed findings by Mr. Eddleman were to be filed by December 21, 1984.
Applicants i
and the Staff were provided the opportunity to file any reply on or before January 4, 1985.
Tr. 7369-70.
1/
Absent such proposed findings, the Board's tentative deci-sion would have become final.
Tr. 7370 (as corrected by Appli-cants).
1 4
~ -.
t 5.
Chi December 21, 1984, intervenor Eddleman filed
" Wells Eddleman's Proposed Findings on Contention 65" (cited as "Eddleman 1
- ).
Applicants submit this reply to the
~ Eddleman; proposed' findings.
While the Board intended that the other parties could focus on what Mr. Eddleman put forward and not sort through the whole record, Tr. 7370, Applicants feel compelled,-in view of the " scatter shot" approach of the Eddleman findings, to begin with a brief overview of the evi-dentiary record.
This is followed by specific replies to Mr.
Eddleman's proposed findings.
The Record 6.
The pre-trial sequence of events in the adjudication of Eddleman Contention 65 provided a unique opportunity for the parties to focus on the narrow matters which remained in dis-pute among their experts.
In opposition to Applicants' motion I
_ for. summary disposition and in support of his newly proposed Contentions 65-A and 65-B, Mr. Eddleman filed the Affidavit of Charles C. Stokes on June 14, 1984.
The Stokes Affidavit eval-uated 13 containment concrete pour packages 2/ produced by Ap-l plicants during discovery.3/
These same 13 pour packages
(
I 2/
A " concrete pour package" is the assemblage of documenta-l tion for each concrete placement which is required to be retained by Quality Assurance in its records vault.
See Appli-i cants' Testimony of George A. Kanakaris, Roland M. Parsons and Larry F. Garner in Response to Eddleman Contention 65 (Concrete i
Containment Structure), ff. Tr. 5764 (hereinafter "Kanakaris et al."), at 10.
i 3/
The 13 packages, which are in the record as Applicants' Exhibits 10 through 22, represent the two placements of the l
(Continued'next page) L
=_
4 became the exclusive subject of controversy as a result of the Board's rulings of July 12, 1984.
See 1 2, supra.
In the Af-i fidavit of Roland M. Parsons filed in support of Applicants' Response to Eddleman Proposed Contentions 65-A and 65-B (June i
29, 1984), Applicants provided a point-by-point refutation of Mr. Stokes' evaluation of each of the 13 pour packages.
7.
Thus, well in advance of the August 9, 1984 deadline for filing direct' testimony and exhibits, Mr. Eddleman knew not only the identity of the concrete documentation at issue, but also Applicants' defense to Mr. Stokes' evaluation of that doc-umentation.
Yet, Mr. Eddleman filed no new or revised testimo-ny responsive to Applicants' positions.
Instead, he chose to rely on the Stokes Affidavit of June 14, 1984, as testimony in support of Contention 65.
Indeed, not until it was time for 4
Mr. Stokes to take the witness stand on October 30, 1984, did g
Mr. Eddleman and his witness attempt to come to grips with the other parties' positions.
8.
. Applicants' direct testimony, filed on August 9, 1984, again included the point-by-point response to the Stokes Affidavit.
Kanakaris et al. at 13-22.
The NRC Staff's direct testimony, filed on the same date, included an even more (Continued) containment basemat, plus a ten percent sample of the place-ments in the containment exterior wall and dome.
Tr. 5778.
Thus, these 13 placements (out of a total of 106) represent considerably more than the five percent sample to which Mr.
Eddleman refers.
See Eddleman 11 6, 15.
2,
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detailed response to the Stokes Affidavit.
See NRC Staff Tes-4 timony of John R. Harris, Joseph J. Lenahan and Paul R. Bemis on Eddleman Contention Number 65, Concrete Placement, ff. Tr.
6320 (hereinafter " Harris et al."), at 11-50.
Nevertheless, it was only-on the third day of Mr. Eddleman's examination of Ap-plicents' witnesses that the Board and parties were informed that Mr. Eddleman's witness had abandoned some undefined por-tion of his testimony upon review of the information provided in the testimony of Applicants and the NRC Staff.
A recess was 1
{
actually required at that point in order for Mr. Eddleman and his witness to confer and to reach a position on the subjects which remained in controversy.
See Tr. 6035-6045. Consequent-ly, not only had substantial hearing time been wasted on exami-nation of Applicants' witnesses on matters later abandoned by the intervenor, but hearing time was also expended while he de-termined what the areas of controversy actually were and while the witness and the intervenor proceeded to edit Mr. Stokes' testimony on the record.4/
See Tr. 6046-6068.
To repeat, all of this could have occurred prior to the filing of testimony on August 9, and should in any case have occurred prior to October 30, 1984.
The path followed, however, is partially responsible for a record which the Board described as " extremely convoluted and confused."
See Tr. 7370.
4/
In spite of the recess afforded to enable Mr. Eddleman and his witness to sort out the remaining issues, the editing of the testimony on the record was so cumbersome and disorganized that the Board Chairman termed the situation "a mess."
See Tr.
6049. - -.-.
9..
While the record is difficult to parse because of the moving target launched by the intervenor, it is also complete.
'Further, the witnesses for Applicants and the Staff were well qualified and provided competent testimony.
Applicant's panel l
included three-witnesses.
Mr. Kanakaris is Manager of Civil Engineering.for Ebasco Services,.Inc., the architect / engineer for the SENPP.
He is responsible for direction of all civil engineering and design of Ebasco power plant projects, and has i
over 25 years-of experience in the civil engineering and design of generating stations.
Kanakaris et al. at 1.
Mr. Parsons, also a civil engineer, has been employed by CP&L at the Harris site since major construction activity was undertaken in 1976.
Previously Project General Manager of the Harris Plant Con-struction Section, Mr. Parsons is now in charge of the Comple-tion Assurance.Section.
Id. at 2; Tr. 5754-55 (Parsons).
Mr.
L Garner JLs employed by CPEL as Senior Construction Specialist in
- the Harris Plant Construction Section.
During containment con-struction he was the Construction Inspection (CI) Supervisor-Civil, with extensive responsibilities in the inspection of concrete placements.'
Kanakaris et al. at 2-3.
Applicants' di-rect. case on Eddleman Contention 65 also included FSAR S 3.8.1, which describes the design of the concrete containment.
Appli-cants' Ex.- 9.
- 10. In addition to the witnesses sponsored by Applicants, five Harris site employees, who were involved in one or more of
- the 13 containment concrete placements at issue, appeared j i.
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voluntarily _in response to the Board's grant of Mr. Eddleman's August 17,-1984 request that these individuals be subpoenaed to testify at the hearing.
Mr. Sealey is employed by CP&L as a Senior Construction Specialist and, during containment con-struction, served as a CI inspector and supervisor.
Mr.
French, now a Senior Engineer with CP&L, was also in the CI de-partment during containment concrete placements.
Mr.
Breedlove, an employee of Daniel Construction Company, contin-ues to work in the CI department at Harris, and was involved as a CI inspector throughout the majority of the containment con-struction.
Mr. Strickland, an employee of Daniel, served as a Quality control inspector who conducted the field tests of con-crete being placed in containment.
As a Quality Assurance 4
technician employed by CP&L, Ms. Woltz performed break tests on compressive strength cylinders in the concrete lab.
Tr.
6222-6228.
l 11.
The NRC Staff's direct case was presented through a panel of three witnesses.
Mr. Harris, a Civil Construction In-l spector in the Plant Systems Section in NRC's Region II, in-spects nuclear power plants in civil and geotechnical areas.
Harris-et al.-at 1-3.
Mr. Lenahan, formerly a Civil Construc-tion Inspector in the Plant Systems Section at Region II, is now a-Reactor Inspector in the Test Program Section.
A civil i
engineer, Mr. Lenahan's inspection responsibilities at con-struction sites have included structural concrete, structural i
l steel and installation of post-tensioning systems.
Id. at 1, l' i
3-4; Tr. 6306 (Lenahan).
Mr. Harris has been inspecting civil-construction activities at the Harris site since 1977, and Mr.
Lenahan has conducted such inspections at SENPP since 1978.
-Harris et al. at 5.
Mr. Bemis, formerly Chief of Projects Sec-tion 1C at Region II, is now Director of the Division of Reac-tor Safety.
Id. at 1; Tr. 6305-06 (Bemis).
12.
Mr. Eddleman's witness on Contention 65 was Mr.
Stokes, an engineer who has been self-employed since October of 1983.
Tr. 6128 (Stokes).
Mr. Stokes' previous experience in the nuclear power > industry concentrated on pipe support system design and stress analysis.
Affidavit and Resumes of Charles C. Stokes, ff. Tr. 6177 (hereinafter " Stokes"), at Resumes.
While Mr. Stokes had college courses on concrete and some con-crete' work. experience, Tr. 6143-44, 6157-58 (Stokes), he has never:
(1) designed a concrete containment; (2) designed con-crete mixes for a containment; (3) developed or written proce--
duree'for concrete placement, testing or inspection; (4) had
' field responsibility for concrete placements; (5) been respon-1sible for, supervised or conducted concrete field tests on con-tainment placements or compressive strength test'ing of contain-ment concrete.-
Tr. 6131-34 (Stokes).
13.
As a result of the withdrawal by Mr. Stokes of por-
.tions of his testimony and the striking of two paragraphs by the Board (Tr.'6164, 6176), 7 of the 13 concrete pour packages once at issue under Contention 65 were no longer questioned by Mr. Eddleman's only witness as of the October 30, 1984 hearing '
n-session.
Those seven are pour packages:
ICBXW242001 (Appli-cants' Ex. 11), ICBXW308001 (Applicants' Ex. 15), 1CBXW336003
-(Applicants' Ex. 16), 1CBXW386001 (Applicants' Ex. 17),
1CBXW396002_(Applicants' Ex. 18), 1CBXW425001 (Applicants' Ex.
19), and 1CBXW444001 (Applicants' Ex. 20).
The Eddleman Proposed Findings 14.
Mr. Eddleman begins with a proposed finding that
" Stokes was qualified as an expert."
Eddleman 1 1.
More pre-cisely, the Board held that Mr. Stokes had the necessary quali-fications and experience to overcome objections to the admissi-bility of his testimony, while observing that any deficiencies in his qualifications would go to the weight accorded to the testimony.
Tr. 6158-59.
The record subsequently developed, as well as the evidence elicited on voir dire examination, shows that the Stokes testimony is entitled to little if any weight.
Beyond the matters discussed below, Applicants note that Mr.
Stokes began reviewing the relevant documentation approximately one week prior to writing his affidavit of June 12, 1984, and that a number of the documents reviewed by him and identified as " governing the acceptability of the work" were documents clearly inapplicable to the Harris containment.
Stokes at 2-3; Tr. 6183, 6186-89 (Stokes).
Even though he knew, from regula-tory guides listed as reviewed by him, that ACI code 359 applies to containments and that ACI-349 applies to structures other than containments, Mr. Stokes utilized and relied upon, <
. - ~. - -
in his testimony, ACI-349.
Tr. 6190-92 (Stokes).
While even a casual reader of a concrete Placement Report 1/ can distinguish
.the portion of the form completed in advance of a placement, Mr. Stokes in his filed testimony interpreted remarks in this section (on the_ requirement for an exposed aggregate finish as the type of contact surface preparation) as evidence of improp-i er consolidation (or vibration) during the placement.
Kanakaris et al. at 13.
While his testimony indicated concerns with weather and temperature data recorded, Mr. Stokes never compared this data with the Ebasco design specification, listed among the documents reviewed by him, to determine their accept-ability.
Tr. 6192-93 (Stokes).
Mr. Stokes'was also unable to explain coherently why.he related overcast weather conditions to potential void formation in the containment concrete.
Tr.
6193-94,' 6208 (Stokes).
In sum, Mr. Stokes did not display an appropriate level of competence in the subject matter, and re-vealed that his review of the placement documentation had been at'best niipshod.
15.
Mr. Eddleman proceeds to imply that he and Mr. Stokes were the victims of misleading information because, in a few instances, the QA-24 form (concrete Test Report) in the pour package identified an incorrect slump and/or air content speci-fication, and because Non-Conformance Reports are not in the packages.
Eddleman 11 2-5.
Compliance with air content and 5/
See e.g., Attachment 4.to Kanakaris et al. '
y-slump specifications is' determined by CI personnel, not the QC tester, by comparing the test results on the QA-24 form with the design specification, however, and not with the requirement noted on the QA-24 form by the field tester.1/
Tr. 5947-48, 5957-58 (Parsons); Tr. 6299-6300 (Breedlove).
Mr. Stokes had the Ebasco design specification available to him and testified that he reviewed it.2/
Stokes at 3.
As to the documentation resolving nonconformances, it was never claimed that pour pack-ages are required to include such information.
See Tr. 6239 (Breedlove); Tr. 6243 (French).
However, out-of-specification conditions can be determined from the test data on the QA-24 form, which is in the package.
The documentation in the pour packages provided to Mr. Eddleman includes, in short, the in-formation needed to assess concrete quality.
'Tr. 6095-96 (Par-sons); Tr. 6098-99 (Kanakaris); Tr. 6240 (Strickland).
16.
On a more substantive level, Mr. Eddleman addresses I
insufficient clearance from asbestos board to cadweld in two l
pours, and claims there is "no evidence this problem was ever corrected."
Eddleman 1 8.
To the contrary, the documentation i
l
[
1/
While the specification requirement written on the form j
should be correct, it is a subsidiary document and not the l
governing one.
Tr. 5948, 5957-58 (Parsons).
If Mr. Eddleman did not learn this during discovery, it is because he did not
- ask, i
2/
It is ludicrous to suggest, as Mr. Eddleman does, that the major surgery performed on the Stokes Testimony is attributable to errors in Applicants' presentation.
See Eddleman 1 6.
On the contrary, it was the substantive information provided by Applicants and the Staff which partially enlightened Mr.
Stokes. L
r shows that all spacing. violations were resolved, Tr. 6073 (Kanakaris), and that a below minimum clearance was never ac-
'cepted.
Harris et al. at'45.
17.
While Mr. Stokes, in his original testimony, was con-corned with concrete allegedly out-of-specification with slump values that are too high, Mr. Eddleman now cites Mr. Stokes for proposed findings expressing concern that the slump on several placements was.too low -- i.e., below two inches.
Eddleman 1 9.
Mr. Stokes here is challenging the Ebasco design specifica-tion governing the Harris containment.
The considered judgment of that architect / engineer is that no minimum slump is re-quired.
See Eddleman Ex. 10,Section I at 18 (" Concrete shall be placed with the lowest slump possible provided it is proper-ly placed and consolidated.").
The significance of specifying slump is with the upper-range value because of the desire to achieve maximum strength.
Consequently, the goal is to achieve a slump as low as possible.
Tr. 6101-02 (Kanakaris); see also Tr. 6394-96 (Lenahan, Harris).
Nothing in the record tempts the adoption of Mr. Stokes' lone view over those of the knowl-edgeable concrete experts.
18.
The balance of Mr. Eddleman's proposed findings ad-i-
dress the strength testing and evaluation of placement 1CBXW290001 (Applicants' Ex. 14).
See Eddleman 11 7, 10-14.
The proposed findings are not supported, however, by the record.
The design specification by Ebasco governs the evalua-tion of compressive strength tests of test cylinders.
It i i l
l
V provides that the strength level of the concrete shall be con-sidered satisfactory if:
i
~
a - No individual strength test results falls more than 500 psi below the required class strength at 28 days.
b - The averages of all sets of three consecutive strength test results equal or exceed the required class strength at 28 days.
Each 28 day strength test result shall be the average of two cylinders from the same sample.
The variation between the two cylinders shall not be more than five (5) percent of their av-erage.
Eddleman Ex. 10,Section I at 21-22.
19.
The 28-day test cylinders for this placement (lab specimen number 9265) met the first criterion quoted above since the average of the two cyclinders (4,865 psi) was not more than 500 psi below the required class strength of 5,000 psi.
Harris et al. at 26.
However, the second criterion was not met because of other, albeit cor.socutive, batches (not in this placement) of the same mix design.
Id_.; Kanakaris St al.
)
at 17-18;'Tr. 6082-83, 6065-86 (Parsons).
The reserve cylinder for specimen 9265 (representing placement ICBXW290001) was tested at 90 days and yielded a strength of 5,660 psi -- well in excess of the required strength.
Harris et al. at 27.
This
~ test eliminates any concern with the strength in the contain-ment placement at issue in this hearing.
Tr. 6083 (Parsons);
Tr. 6324 (Harris).
20.
Nevertheless, Applicants drilled five core samples from this placement for additional testing.
The results of
two of the five cores were rejected on the basis of the small size of the cores or improper testing.
Harris et al. at 27.
One was taken 11 inches from a passing core test, and the other was taken 9 inches from a passing core test.
Id.; Tr. 6087 (Parsons).
The other three cores met design requirements.8/
' Harris et al. at 27; Kanakaris et al. at 18.
21.
In his proposed findings, as in his examination at the hearing, Mr. Eddleman confuses the cylinder tests, which have a consecutive running average requirement for a given mix, with the drilled core samples tested.9/
See Tr. 6081, lines 21-24; Tr. 6082,. lines 19-23; Tr. 6084, lines 1-6 (Eddleman).
As to core samples, there is no requirement to test them in a I
particular order.
Tr. 6081-82 (Parsons).
Nevertheless, Mr.
.B$dleman asks the Doard to take official notice of such a re-4 quirement for three consecutive cores in the 1977'and 1981 edi-tions of ACI-318.
Eddleman 1 11.
Leaving aside the applica-bility-of that code,lE/ if the Board chooses to pursue Mr.
Eddleman's request, it will find a requirement that the average of three core strength values not be less than 85 percent of j
design strength, with no one value less than 75 percent.
The 8/
None of the three cores tested at below 75 percent of de-sign strength.
Compare Eddleman 1 10 with Harris et al. at 27.
9/
Concrete cylinder test specimens are routinely made to:
test compressive strength.
Kanakaris et al. at 10.
In con-trast, placement lCBXW290001 is the only one of~the 13 place-ments for which drilled core samples were taken.
Tr. 5977-78 (Parsons).
10/
See Tr. 6082 (Kanakaris).
-,..,~,--,-,,,,,,,--,,..,- n
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- Staff so testified.
Tr. 6325 (Harris).
The three acceptable cores tested (consecutiveness is irrelevant and is not applica-ble to cores, as the code makes clear, id.) meet these require-ments.(4,580, 4,030 and 5,100 psi).
Applicants' Ex. 14, PW-C-3769.
Thus, Eddleman proposed findings 11 and 12 are in error.
22.
Crediting Mr. Stokes with a revelation discussed in the direct testimony of Applicants and the Staff,ll/ Mr.
Eddleman returns to test cylinders and points out the acknowl-f edged failure to meet the 28-day, running average criterion for
-three consecutive tests of batches of the same mix.
Eddleman 11 13, 14.
However, the resolution is documented (as discussed above) in the package, and no cylinder in this placement tested nearly 1,000 psi below design strength as Mr. Eddleman states in paragraph'14.- Rather, those two 28-day cylinders tested at 4,780 and 4,950 psi.
See Harris et al. at 26; Applicants' Ex.
14, form QA-24.
l Conclusion-23.
The credible witnesses expressed no doubt about their unanimous conclusion that there are no significant unknown con-
~
L crete deficiencies'in the Harris Plant containment structure.
i f
Kanakaris et al. at 27-28; Harris et al. at 50-51; Tr. 6296-97 (Breedlove); Tr. 6394 (Harris, Lenahan, Bemis).
The Eddleman 11/
Mr. Stokes, however, attributed the wrong lab specimens to the placement at issue.
Kanakaris et al. at 17; Harris et al.
at:26.
t proposed findings present no basis for the Board to reconsider its-tentative conclusion that the weight of the evidence strongly' requires a result in favor of the Applicants and Staff on Eddleman Contention 65.
There simply are no safety concerns i
-ra sed with respect to the containment concrete at SENPP.
Respectfully submitted,
- ==
Thomas A. Baxter,'P.C.
SHAW, PITTMAN, POTTS & TROWERIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1090 Richard E. Jones CAROLINA POWER & LIGHT COMPANY P.O. Box 1551
-Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants
- Dated:
January 4, 1985
cr 9
January 4, 1985 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 No. 50-400 OL MUNICIPAL POWER AGENCY.
)
)
(Shearon< Harris Nuclear Power
)
' Plant)
)
CERTIFICATE OF SERVICE 1 -
I hereby certify.that copies of " Applicants' Reply to Wells.Eddleman's Proposed Findings on Contention 65" were served this 4th day of January, 1985, by deposit in the U.S.
mail, first class, postage prepaid, to the parties on the atta-ceh d Service List.
==
Thomas A. Baxter, P.C.
x.
c e we,eee=+w--m.wa-m
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEUSING BOARD In the Matter of-
)
)
CAROLINA POWER & LIGHT COMPANY
)
Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN
. )
MUNICIPAL' POWER AGENCY-
)
)
(Shearon-Harris Nuclear Power
)
Plant)
)
SERVICE LIST
' James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of U.S. Nuclear Regulatory Commission North Carolina Washington' D.C.
20555 307 Granville Road Chapel Hill, North Carolina-27514 Mr. Glenn O. Bright-M. Travis Payne, Esquire
- Atomic Safety and Licensing Board Edelstein and Payne
-' U.S.-: Nuclear Regulatory Commission P.O. Box 12607 Washington, D.C.
20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. *411 son
-Atcalic-Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D.C.
20555 charles A. Barth, Esquire Mr. Wells Eddleman Janice E. Moore, Esquire 718-A Iredell Street
~
Office of Executive Legal D.irector
'Durham, North Carolina 27705 U.S. Nuclear Regulatory Constission l:
Washington, D.C..
20555 Docketing and Service Section Richard E. Jones, Esquire l
Office of'.the Secretary Vice President and Senior Counsel L
U.S. Nuclear Regulatory Commission Carolina Power & Light company i
Washington,.D.C.
20555 P.O. Box 1551 Raleigh, North Carolina 27602 Mr. Daniel F. Read, President Dr. Linda W. Little l-CHANGE Governor's Waste Management Board P.O._ Box 2151 513 Albemarle Building Raleigh,. North Carolina 27602 325 North Salisbury. Street Raleigh, North Cardlina 27611 i
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Bradley W.' Jones, Esquire U.S. Nuclear. Regulatory Commission Region II 101 Marrietta Street Atlanta, Georgia-30303 Steven F. Crockett, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 Administrative Judge Harry Foreman Box 395 Mayo University of Minnesota.
Minneapolis, Minnesota 55455 4
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