ML20217E146

Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence

ML20217E146
Person / Time
Site:	Harris
Issue date:	10/13/1999
From:	Curran D CAROLINA POWER & LIGHT CO., HARMON, CURRAN, SPIELBERG & EISENBERG, LLP.
To:	Atomic Safety and Licensing Board Panel
References
CON-#499-20898 99-762-02-LA, LA, NUDOCS 9910190086
Download: ML20217E146 (15)

Text

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m m. e m v vvr m r. n DOCKETED frupc October 13,1999 9 OT 15 P4 :18 UNITED STATES OF AMERICA NUCLEARREGULATORY COMMISSION Before the Atnmic Rafety and I icensing knard In the Matter of )

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CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

(Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA 1

REQUEST FOR ENTRY UPON HARRIS SITE Pursuant to 10 C.F.R. { 2.741(a)(2), and as agreed to by the parties, Orange County hereby requests entry upon the Harris nuclear power plant site for the purpose of inspecting the spent fuel pool building and associated piping. " nant to the parties' agreement, representatives of Orange County will conduct their inspection on October 20, 1999, beginning at 2 p.m. The individuals who will take part in the inspection are as follows:

Diane Curran, attorney for Orange County Dr. Gordon Thompson, expert witness for Orange County Dr. Alice Gordon, Orange County Commissioner Margaret Brown, Orange County Commissioner Paul Thames, Orange County Engineer l Richard Pratt, Member of Orange County Commission for the Environment i

The County will provide identifying information requested by CP&L under separate cover.

ectful ubmitted, ane Curran HARMON, CURRAN, SPIELBERG, & EISENBERG l 1726 M Street N.W., Suite 600 Washington, D.C. 20036 l

l 9910190086 991013 PDR ADOCK 05000400 C

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October 13,1999 UNITED STATES OF AMERICA NUCLEARREGULATORY COMMISSION Before the Atomic Safety and Liceming Board l In the Matter of )

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CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

(Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA l

NOTICE OF DEPOSITION OF MIKE DEVOE Pursuant to 10 C.F.R. Q 2.740a, Orange County hereby gives notice that on l

October 20,1999, its counsel will take the deposition upon oral examination of Mike DeVoe, Project Engineer, Nuclear Fuel Services, for Carolina Power & Light Company l

! ("CP&L"). Mr. DeVoe will be deposed with respect to Contention TC-2 in this proceeding. The deponent is hereby instructed to produce at that time all documents upon which he has relied or intends to rely with respect to Contention TC-2, and which have not previously been produced to Orange County by CP&L. The deposition will commence at 9:30 a.m. at the offices of CP&L,411 Fayette Street Mall, Raleigh, NC 27602. The deposition testimony will be taken before a duly authorized court reporter

.under oath and will be transcribed.

Respectfull ubmitted, i h Diane Cunan HARMON, CURRAN, SPIELBERG, & EISENBERG 1726 M Street N.W., Suite 600 Washington, D.C. 20036 202/328-3500 i

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October 13,1999 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic 9 "ety and Licensing Board In the Matter of )

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CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

(Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA NOTICE OF DEPOSITION OF R. STEVEN EDWARDS Pursuant to 10 C.F.R. Q 2.740a, Orange County hereby gives notice that on October 19,1999, its ;:ounsel will take the deposition upon oral exmnination of R. Steven Edwards, Supervisor - Spent Fuel Project, Harris Nuclear Plant, for Carolina Power &

Light Company ("CP&L"). Mr. Edwards will be deposed with respect to Contention TC-3 in this proceeding. The deponent is hereby instructed to produce at that time all '

documents upon which he has relied or intends to rely with respect to Contention TC-3, and which have not previously been produced to Orange County by CP&L. The I

deposition will commence at 3 p.m. at the Harris Energy and Environmental Center,3932 New Hill-Holleman Road, New Hill, North Carolina. The deposition testimony will be taken before a duly authorized court reporter under oath and will be transcribed. l Respectfully submitted, l

Diane Curran HARMON, CURRAN, SPIELBERG, & EISENBERG '

1726 M Street N.W., Suite 600 Washington, D.C. 20036

[ 202/328-3500

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October 13,1999 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atnmic Safety and Licensing Board In the Matter of )

)

CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

(Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA NOTICE OF DEPOSITION OF DR. AHMAD A. MOCCARI Pursuant to 10 C.F.R. { 2.740a, Orange County hereby gives notice that on October 19,1999, its counsel will take the deposition upon oral examination of Dr.

Ahmad A. Moccari, Senior Engineer for Carolina Power & Light Company ("CP&L").

Dr. Moccari will be deposed with respect to Contention TC-3 in this proceeding. The deponent is hereby instructed to produce at that time all documents upon which he has relied or intends to rely with respect to Contention TC-3, and which have not previously been produced to Orange County by CP&L. The deposition will commence at 9 a.m. at the Harris Energy and Environmental Center,3932 New Hill-Holleman Road, New Hill, North Carolina. The deposition testimony will be taken before a duly authorized court reporter under oath and will be transcribed.

Respectfully submitted, L

lane Curran HARMON, CURRAN, SPIELBERG, & EISENBERG i

1726 M Street N.W., Suite 600 Washington, D.C. 20036

, 202/328-3500 L

n October 13,1999 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licencing Board In the Matter of )

)

CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

(Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA NOTICE OF DEPOSITION OF CHARLES H. GRIFFIN Pursuant to 10 C.F.R. Q 2.740a, Orange County hereby gives notice that on October 19,1999, its counsel will take the deposition upon oral examination of Charles H. Griffin, Engineer, Corporate Nuclear Engineering, for Carolina Power & Light Company ("CP&L"). Mr. Griffin will be deposed with respect to Contention TC-3 in this proceeding. The deponent is hereby instructed to produce at that time all documents upon which he has relied or intends to rely with respect to Contention TC-3, and which have not previously been produced to Orag.:,e County by CP&L. The deposition will commence at 12:30 p.m. at the Harris Energy and Environmental Center,3932 New Hill-Holleman Road, New Hill, North Carolina. The deposition testimony will be taken before a duly authorized court reporter under oath and will be transcribed.

Respectfully submitted, iane Curran HARMON, CURRAN, SPIELBERG, & EISENBERG 1726 M Street N.W., Suite 600 Washington, D.C. 20036 202/328-3500 f'

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October 13,1999 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board in the Matter of )

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CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

(Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA NOTICE OF DEPOSITION OF DR. EVERETT L. REDMOND II Pursuant to 10 C.F.R. Q 2.740a, Orange County hereby gives notice that on November 2,1999, its counsel will take the deposition upon or sl examination of Dr.

Everett L. Redmond II, Principal Engineer, Ho'tec International. Dr. Redmond will be deposed with respect to Contention TC-2 in this proceeding. The deponent is hereby instructed to produce at that time all documents upon which he has relied or intends to rely with respect to Contention TC-2, and which have not previously been produced to Orange County by CP&L. The deposition will commence at 9 a.m. at the offices of Holtec International, Holtec Center,555 Lincoln Drive West, Marlton, NJ 08053. The  !

deposition testimony will be taken before a duly authorized court reporter under oath and will be transcribed. l l

Respectfully submitted, l

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i Diane Curran HARMON, CURRAN, SPIELBERG, & EISENBERG 1726 M Street N.W., Suite 600 Washington, D.C. 20036 202/328-3500

October 13,1999 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

Be. fore the Atomic Safety and Licensing Board In the Matter of )

)

CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

(Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA NOTICE OF DEPOSITION OF DR. STANLEY E. TURNER )

Pursuant to 10 C.F.R. { 2.740a, Orange County hereby gives notice that on i

Nove nber 4,1999, its counsel will take the deposition upon oral examination of Dr. )

l Stanley E. Turner, Senior Vice President and Chief Nuclear Scientist, Holtec International. Dr. Tumer will be deposed with respect to Contention TC-2 in this proceeding. The deponent is hereby instructed to produce at that time all documents upon which he has relied or intends to rely with respect to Contention TC-2, and which have not previously been produced to Orange County by CP&L. The deposition will commence at 9 a.m. in the Goya Conference Room at the Four Points Sheraton Hotel, 37611 U.S. Highway 19 Nonh, Palm Harbor, Florida 34684. The deposition testimony will be taken before a duly authorized court reponer under oath and will be transcribed.

Respectfully submitted, Diane Curran HARMON, CURRAN, SPIELBERG, & EISENBERG 1726 M Street N.W., Suite 600 Washington, D.C. 20036 202/328 3500

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October 13,1999 UNITED STATES OF AMERICA NUCLEARREGULATORY COMMISSION Before the Atomic Rnfety and I icensing Board In th$ Matter of )

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CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

(Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA

! NOTICE OF DEPOSITION OF LAWRENCE KOPP Pursuant to 10 C.F.R. Q 2.740a, Orange County hereby gives notice that on

, . November 4,1999, its counsel will take the deposition upon oral examination of Lawrence Kopp, Senior Reactor Engineer, Reactor Systems Branch, Division of Systems Safety Analysis, U.S. Nuclear Regulatory Commission. Mr. Kopp will be deposed with

( . respect to Contention TC-2 in this proceeding. The deponent is hereby instructed to l

l produce at that time all documents upon which he has relied or intends to rely with respect to Contention TC-2, and which have not T: eviously been produced to Orange County by CP&L. The deposition will commence at 2 p.m. in the Goya Conference Room at the Four Points Sheraton Hotel,37611 U.S. Highway 19 North, Palm Harbor, Florida 34684. The deposition testimony will be taken before a duly authorized court reporter under oath and will be transcribed.

1teigectfully bmitted, (f . .

DFane'Cunan HARMON, CURRAN, SPIELBERG, & EISENBERG 1726 M Street N.W., Suite 600

. Washington, D.C. 20036 202/328-3500

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t October 13,1999 UNITED STATES OF AMERICA NUCLEARREGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

(Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA NOTICE OF DEPOSITION OF CHRISTOPHER GRATTON Pursuant to 10 C.F.R. Q 2.740a, Orange County hereby gives notice that on October 29,1999, its counsel will take the deposition upon oral examination of Christopher Gratton, Reactor Systems Engineer, Plant Systems Branch, Division of Systems Safety and Analysis, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. Mr. Gratton will be deposed with respect to Contention TC-3 in this proceeding. The deponent is hereby instructed to produce at that time all documents upon which he has relied or intends to rely with respect to Contention TC-3, and which have not previously been produced to Orange County by CP&L. The deposition will commence at 3:00 p.m. at the offices of Harmon, Curran, Spielberg, & j Eisenberg,1726 M Street N.W., Washington, D.C. 20036. The deposition testimony 1

will be taken before a duly authorized court reporter under oath and will be transcribed.

c:fuljl submitted,

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e Curran HARMON, CURRAN, SPIELBERG, & EISENBERG 1726 M Street N.W., Suite 600 l Washington, D.C. 20036 I 202/328-3500 l

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October 13,1999 UNITED STATES OF AMERICA NUCLEARREGULATORY COMMISSION Before the Atomic Safety and T_icensing Board In the Matter of )

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CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

(Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA NOTICE OF DEPOSITION OF DONALD G. NAUJOCK Pursuant to 10 C.F.R. Q 2.740a, Orange County hereby gives notice that on October 29,1999, its counsel will take the deposition upon oral examination of Donald G. Naujock, Technical Reviewer, Materials and Chemical Engineering Branch, Division i

of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. Mr. Naujock will be deposed with respect to Contention TC-3 in this proceeding. The deponent is hereby instructed to produce at that time all documents )

l l upon which he has relied or intends to rely with respect to Contention TC-3, and which i  !

have not previoucly been produced to Orange County by CP&L. The deposition will commence at 9 a.m. at the office; of Hannon, Curran, Spielberg, & Eisenberg,1726 M l

Street N.W., Washington, D.C. 20036. The deposition testimony will be taken before a i

duly authorized court reporter under oath and will be transcribed.

espectfully submitted, b- _

Diane Curran HARMON, CURRAN, SPIELBERG, & EISENBERG 1726 M Street N.W., Suite 600 Washington, D.C. 20036

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l October 13,1999 )

l UNITED STATES OF AMERICA NUCLEARREGULATORY COMMISSION '

Before the Atomic Safety and Licencing Board i In the Matter of ) q

) J CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

(Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA 1 NOTICE OF DEPOSITION OF JAMES A. DAVIS Pursuant to 10 C.F.R. @ 2.740a, Orange County hereby gives notice that on October 29,1999, its counsel will take the deposition upon oral examination of James A.

Davis, Technical Reviewer, Materials and Chemical Engineering Branch, Division of ,

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Engineering, OfTice of Nuclear Reactor Regulation, U.S. Nuclear Regulatory 1 Commission. Mr. Davis will be deposed with respect to Contention TC-3 in this i

proceeding. The deponent is hereby instructed to produce at that time all documents upon which he has relied or intends to rely with respect to Contention TC-3, and which have not previously been produced to Orange County by CP&L. The deposition will commence at 12:30 p.m. at the offices of Harmon, Curran, Spielberg, & Eisenberg,1726  ;

I M Street N.W., Washington, D.C. 20036. The deposition testimony will be taken before a duly authorized court reporter under oath and will be transcribed.

Respectfully submitted, n_

Diane Curran HARMON, CURRAN, SPIELBERG, & EISENBERG 1726 M Street N.W., Suite 600 Washington,D.C. 20036

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October 13,1999 UNITED STATES OF AMERICA NUCLEARREGULATORY COMMISSION Before the Atomic Safety and I icenning Board In the Matter of )

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I CAROLINA POWER & LIGHT ) Docket No. 50-400-LA COMPANY )

l (Shearon Harris Nuclear Power Plant) ) ASLBP No. 99-762-02-LA NOTICE OF DEPOSITION OF KENNETH C. HECK Pursuant to 10 C.F.R. Q 2.740a, Orange County hereby gives notice that on i

October 18,1999, its counsel will take the deposition upon oral examination of Kenneth  !

C. Heck, Quality Operations Engineer, Office of Nuclear Reactor Regulation, U.S.

Nuclear Regulatory Commission. Mr. Heck will be deposed with respect to Contention TC-3 in this proceeding. The deponent is hereby instructed to produce at that time all documents upon which h. ha relied or intends to rely with respect to Contention TC-3, and which have not previously been produced to Orange County by CP&L. The deposition will commence at 9 p.m. at the offices of the Nuclear Regulatory Commission.

The deposition testimony will be taken before a duly authorized court reporter under oath l and will be transcribed.

Respectfully submitted, LC Diane Curran HARMON, CURRAN, SPIELBERG, & EISENBERG 1726 M Street N.W., Suite 600 Washington, D.C. 20036 202/328-3500 t

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RElATED CORWnWo%

007EFC

UNITED STATES OF AMERICA N NUCLEAR REGULATORY COMMISSION l

BEFORE THE ATOMIC SAFETY AND LICENSING BOAR @ 00: 15 P4 :17 l In the Matter of ') ,'

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l . CAROLINA POWER & LIGHT ) Docket No. 50-400 -OLA .

(Shearon Harris Nuclear ) ASLBP No. 99-762-02-LA Power Plant) . )

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CERTIFICATE OF SERVICE  !

I certify that on October 13,1999, copies of the following documents were served on the

, service list below by e-mail and/or first class mail as indicated below:

Orange County's Motion for Extension of Discovery Schedule Request for Entry Upon Harris Site Notice of Deposition of Dr. Ahmad Moccari Notice of Deposition of Charles H. Griffin i Notice of Deposition of R. Steven Edwards -

Notice of Deposition of Mike DeVoe Notice of Deposition of Dr. Everett L. Redmond II l

Notice of Deposition of Dr. Stanley E. Tumer J Notice of Deposition of Lawrence Kopp Notice of Deposition of Christopher Gratton Notice of Deposition of Donald G. Naujock Notice of Deposition of James A. Davis Notice of Deposition of Kenneth C. Heck ;

Orange County's Second Supplemental Response to Applicant's First Set of Interrogatories and First Supplemental Response to NRC Stafrs First Set of Discovery Requests Secretary of the Commission Steven Carr, Esq. .

Attention: Rulemakings and Adjudications Carolina Power & Light Co.

. Staff 411 Fayetteville Street Mall  !

U.S. Nuclear Regulatory Commission Post Office Box 1551 - CPB 13A2 1

Washington, D.C. 20555 Raleigh, NC 27602-1551 l E-mail

hearingdocket@nrc. gov E-mail: steven.carr@cplc.com I

Susan L. Uttal, Esq. Alice Gordon, Chair Office of the General Counsel Orange County Board of Commissioners U.S. Nuclear Regulatory Commission P.O. Box 8181 Washington, D.C. 20555 Hillsborough, NC 27278 E-mail: mlz@nrc. gov E-mail: gordonam@mindspring.com i l

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Paul Thames Adjudicatory File County Engineer Atomic Safety and Licensing Board Orange County Board of Commissioners U.S. Nuclear Regulatory Commission P.O. Box 8181 Washington, D.C. 20555-0001 Hillsborough,NC 27278 1

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. Dr. Peter S. Lam Frederick J. Shon

.v.omic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T 3F-23 Mail Stop T 3F-23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 E-mail: psl@nrc. gov E-mail: fjs@,nrc. gov l

John H. O'Neill, Jr., Esq. G. Paul Bollwerk, III, Chairman William R. Hollaway, Esq. Atomic Safety and Licensing Board

. Shaw, Pittman, Potts & Trowbridge Mail Stop T 3F-23 ,

2300 N Street N.W. U.S. Nuclear Regulatory Commission  !

Washington, D.C. 20037-1128 Washington, D.C. 20555 E-mail: John _o'neill@shawpittman.com, E-mail: gpb@nrc. gov i william.hollaway@shawpittman.com I also certify that each of the following deponeres was ' : ed with a notice of his deposition at i the following addresses:

Michael J. DeVoe Dr. Stanley E. Turner Project Engineer Holtec International Nuclear Fuel Services 230 Normandy Circle East Carolina Power & Light Co. Palm Harbor, FL 34683 P.O. Box 1551 Raleigh, NC 27602-1551 I

Charles H. Griffin, Engineer Dr. Everett L. Redmond II Corporate Nuclear Engineering Holtec International Carob Power & Light Co. Holtec Center

. 411 Fayetteville St. 555 Lincoln Drive West P.O. Box 1551 Marlton, NJ 08053 i- Raleigh, NC 27602-1551 L

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i' Christopher Gatton Lawrence Kopp ,

' Reactor Systems Engineer Senior Reactor Engineer L Plant Systems Branch Reactor Systems Branch l Division'of Systems Safety and Analysis Division of Systems Safety and Analysis -

Office of Nuclear Reactor Regulation Office of Nuclear Reactor Regulation i U.S. Nuclear Regulatory Come Jrsie U.S. Nuclear Regulatory Commission  ;

' Washington, D.C. - 20555 - Washington, D.C. 20555 i Kenneth C. Heck Donald G. Naujock

' Quality Operations Engineer Technical Reviewer Office of Nuclear Reactor Regulation Materials and Chemical Engineering Branch U.S. Nuclear Regulatory Commission Division of Engineering Washington, D.C. 20555 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James A. Da ris Dr. Ahmad A.Moccari

! Technical Reviewer Carolina Power & Light Co.

Materials and Chemical Engineering Branch Harris Energy and Environmental Center Division of Engineering 3932 New Hill-Holleman Road Office of Nuclear Reactor Regulation , New Hill, NC 27652 U.S. Nuclear Regulatory Commission

. Washington, D.C. 20555 R. Stevea Edwards

' Harris Nuclear Plant Carolina Power & Light Co.

P.O. Box 165 (HNP-124)

New ' Hill, NC 27562-0165 Diane Curran 1

I