ML20087G465

Supplemental Responses to W Eddleman General Interrogatories & Interrogatories on Contentions 41 & 65.Certificate of Svc Encl.Related Correspondence

ML20087G465
Person / Time
Site:	Harris
Issue date:	03/14/1984
From:	Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	EDDLEMAN, W.
References
OL, NUDOCS 8403200030
Download: ML20087G465 (7)

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RELATED CORRESPONDEM4h March 14, 1984 o

UNITED STATES OF AMERICA 00LKETED NUCLEAR REGULATORY COMMISSION UDE BEFORE THE ATOMIC SAFETY AND LICENSING %A @ 19 A!0:23 CFFicE cr sgcg.

In the Matter of ) ERTp:G a SEM '

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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

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(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' SUPPLEMENTAL RESPONSES TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES AND INTERROGATORIES ON CONTENTIONS 41 AND 65 TO APPLICANTS CAROLINA POWER & LIGHT COMPANY, et al.

(FIRST SET)

Pursuant to the Licensing Board's " Memorandum and Order (Ruling on Discovery Disputes) " of October 6, 1983, and to rulings issued by the Board during telephone conferences on September 22 and 23, 1983, and on March 8, 1984, Applicants herein provide their responses to the remaining portion of those interrogatories for which the. Board granted intervenor Eddleman's Motion to Compel Discovery. Additional supplemental responses were previously filed by Applicants on November 11, 1983 and January 13, 1984.

The information provided in Exhibits A and B, which are discussed below, is confidential and is being supplied only to intervenor Eddleman. The Board ruled, during the telephone conference on March 8, 1984, that the answers to Eddleman Interrogatories 41-1(1) and 41-1(m) are to be provided to

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Mr. Eddleman subject to, and conditional upon, implementation by Mr. Eddleman of the commitments and agreements made in

" Wells Eddleman's Response to Applicants' Motion for Protective Order," dated January 30, 1984. The Board ordered that those commitments and agreements to protect the information are binding upon Mr. Eddleman. Tr. 759.

RESPONSES TO GENERAL INTERROGATORIES INTERROGATORY NO. Gl (c) : Please state the name, present j or last known address, and present or last known employer of

, each person whom Applicants believe or know (1) has first-hand j knowledge of the facts alleged in each such answer; or (2) upon whom Applicants relied (other than their attorneys) in making 4

such answer.

ANSWER: W. D. Goodman, who is employed as project manager by Daniel Construction Company at the Shearon Harris Nuclear

! Power Plant, provided information upon which Applicants relied l in answering Interrogatories 41-1(1) and 41-1(m) .

i i RESPONSES TO INTERROGATORIES ON CONTENTION 41 1

INTERROGATORY NO. 41-1 (1) : Provide a list of.the names and last-known addresses of those structural ~ welders in Craft 66,

! the pipe fitter craft. (Tr.;722; Oct. 6, 1983 Memorandum and

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Order at 3.)

INTERROGATORY NO. 41-1 (m) : For each welder identified l above, state the date hired and, if applicable,-the date dis-i charged, laid off or resigned. -For'a random sample (to be worked out .between the parties) , provide - information on quali-fications when hired, including a. general description of any I

welding training coursas and the date' failed, if' applicable.

4 (Tr. 665)

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ANSWER: Exhibit A hereto sets forthLthe name, last.known-l address and dates of employment at the Harris Plant for each 1

l Craft 66 structural welder.

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t Exhibit B hereto contains the qualifications when hired of, and post-employment training received by, a random sample of those employees (agreed to previously by Mr. Eddleman and Applicants) identified in Exhibit A.

Respectfully submitted, Thomas A. Baxter, P.C.

SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1090 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Counsel for Applicants

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Dated: March 14, 1984 i

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UNITED STABS OF AMERICA NilCLEAR RECITLATORY COMMISSION

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BEFORE THF. ATONIC _SAFL"f? AND LICENSD:0 ICARD In the Matter of '

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CAROLINA PORER & LICHT COMPAN7 ) Docket Fos. 50-400 OL -

and HORtB CAROLINA EASTERN .) 50-401 OL -

5 MlTHICIPAL POWER AGENCY )

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(Shearon Harris Nuclear Powsr ) f!

Plant, Unita 1 and 2)

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• AFFIDA7_IT OF ROLAND Ff. PAR $0Ne County of Wake ) '

) set state or. North Carolina )

Roland M. Parsons, being duly sworn according,to lav, deposes and says that. he is Project Ceneral Manager - Shearen Harris Nucle.ar Power Plant of Carolina P'cwer & Light Company, that the answers to Ir.terrogatories 41-1(m) and 41-1(l) centsined in " Applicants' Supplemental Respprsas to Wells Eddisman!g General Interrogatories and Interro8atories on Contentiots 41 and 65 to Applicants Carolina PQ wer & Light Co=pany, g al. , (First Set)"' are true and correct to the best of his information, knowledge and belief, and that the sources of his infomation Are officers, employe48, agaota and cent actors of Carolina Pcwar & Light Company. .

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Rolthil' S. Parson 7 ~ l Swer= and subscribed to before me this j g . day of March i 1984.

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Notary Public J ..

Hy Commission expires:

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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION B_EFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

) l (Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Supplemental Responses to Wells Eddleman's General Interrogatories and Interrogatories on Contentions 41 and 65 to Applicants Carolina Power & Light Company, et al. (First Set) " were served this 14th day of March, 1984, by deposit in the U.S. mail, first class, postage prepaid, upon the parties on the attached Service List.

Exhibits A and B were served only upon Mr. Eddleman.

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Thomas A. Baxter, P.C.

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b UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In uhe 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 i

Janes L. Kelley, Esquire John D. Runkle, Esquire Atanic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Ccmnission 307 Granville Road Washington, D.C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atanic Safety and Licensing Board Dielstein and Payne U.S. Nuclear Regulatory Ccmnission P.O. Box 12607 Washington, D.C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atanic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Ccmnission Apex, North Carolina 27502 Washington, D.C. 20555 Mr. Wells Eddlenan Charles A. Barth, Esquire 718-A Iredell Street Janice E. Moore, Esquire Durhan, North Carolina 27705 Office of Executive Legal Director U.S. Nuclear Regulatory Omrnission Richard E. Jones, Esquire Washington, D.C. 20555 Vice President and Senior Counsel Carolina Power & Light Coupany Docketing and Service Section P.O. Box 1551 Office of the Secretary Raleigh, North Carclina 27602 U.S. Nuclear Regulatory Ccmnission Washington, D.C. 20555 Dr. Phyllis Iotchin 108 Bridle Run Mr. Daniel F. Pead, President Chapel Hill, North Carolina 27514 CHANGE /ELP 5707 Waycross Street Dr. Linda W. Little Raleigh, North Carolina 27606 Governor's Waste Managenent Board

513 A1 W rle Building 325 North Salisbury Street Raleigh, North Carolina 27611 l J

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! Bradley W. Jones, Esquire U.S. Nuclear Regulatory Osmission Region II 101 Manietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atanic Safety and Licensing Board Panel U.S. Nuclear RegulatoIY Ccmnission Washington, D.C. 20555 Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 I

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