ML20138N728

Applicant Exhibit A-45,consisting of 850906 Suppl to 850524 & 29 Discovery Requests Re Contention WB-3 Concerning Drug Abuse During Const.Miriello Affidavit Suppls Responses to Listed NRC & Applicant Interrogatories

ML20138N728
Person / Time
Site:	Harris
Issue date:	10/03/1985
From:	Runkle J CONSERVATION COUNCIL OF NORTH CAROLINA, RUNKLE, J.D.
To:
References
OL-A-045, OL-A-45, NUDOCS 8511060003
Download: ML20138N728 (2)

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$80 YO8 8L & h. 5 September 6, 1985

/d UNITED STATES OF AMERICA j q\dlEp./h NUCLEAR RECULATORY COMMISSION / /g-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g

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In the Matter of N

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s Carolina Power & Light Company and ) Docket No. 50-400 OL j North Carolina Eastern Municipal ) x ',s ,

Power Agency )

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(Shearon Harris Nuclear Power Plant) )

CONSERVATION COUNCIL'S SUPPLEMENT TO DISCOVERY REQUESTS Pursuant to 10 CFR 2.740(e), now comes the Conservation Council with a supplement to our answers to interrogatories and discovery requests ~

propounded by the Applicants and the Staff on Contention WB-3 (Drug Abuse During Construction). The affidavit by Ms. Miriello which is attached to our Response to Applicants' Motion for Summary Disposition is new infor=ation which was not available to us when we answered the other parties discovery requests on May 24 (Applicants) and May 29 (Staff). Ms. Murrell contacted us this past weekend and we became aware of the details which have been placed in the affidavit only in the past two days. The information contained in the affidavit will supplement our responses to Staff interrogatories 70 through 72 (from their April 24 discovery request) in that alleged drug abusers working on safety-related systems are identified. "

The information also will supplement our response to Applicants interrogatories 19, 23, and 24 (from their May 1 discovery request).

Respectfully submitted, 4

John Runkle Counsel for Conservation Counsel 8511060003 85 PDR ADOCK O p, G -