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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20140A9961986-01-22022 January 1986 Responds to Eighth Set of Interrogatories Propounded by W Eddleman Re Communication Deficiency in Harnett County,Nc. Ti Hawkins Affidavit Encl.Related Correspondence ML20138R0961985-12-22022 December 1985 Responses to Applicant 851125 Emergency Planning Interrogatories & Request for Production of Documents (Third Set).Related Correspondence ML20138R1141985-12-20020 December 1985 Response to Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20138R1061985-12-20020 December 1985 Response to General Interrogatories.Related Correspondence ML20137L9851985-11-26026 November 1985 Interrogatories to NRC & FEMA on Studies,Info & Knowledge Re Contentions on Which Discovery Now Open ML20137M0031985-11-26026 November 1985 Interrogatories to Applicant & State of Nc.Certificate of Svc Encl ML20137H6291985-11-25025 November 1985 Third Set of Interrogatories Re Emergency Planning & Request for Production of Certain Documents.Certificate of Svc Encl. Related Correspondence ML20138D2761985-10-18018 October 1985 Supplementary Response to General Interrogatories 2-3 & 12-14 Re Eddleman Contention 57-C-3 Concerning Nighttime Emergency Siren Sys at Facility.Certificate of Svc Encl. Related Correspondence ML20128P8311985-05-29029 May 1985 Correction of Answer to Applicant Discovery Requests Re Interrogatories on Contention WB-3 Concerning Drug Abuse. Certificate of Svc Encl.Related Correspondence ML20128P8001985-05-29029 May 1985 Response to NRC Interrogatories Re Contention WB-3 Concerning Drug Abuse.Related Correspondence ML20128G7151985-05-24024 May 1985 Answers to Discovery Requests Re Contention WB-3 on Drug Abuse.Applicants Have Not Reinspected safety-related Work of Known Drug Abusers ML20127M8941985-05-20020 May 1985 Answers to Conservation Council Discovery Requests Re Contention WB-3, Drug Abuse During Const. Util Employee Assistance Program Provides Aid in Drug Rehabilitation. W/Certificate of Svc.Related Correspondence ML20116L1731985-05-0101 May 1985 Interrogatories & Request for Production of Documents Re Allegations in Contention WB-3,per ASLB 850315 Memorandum & Order Ruling on Contentions Re Diesel Generators,Drug Use & Harassment.Certificate of Svc Encl.Related Correspondence ML20102C3621985-03-0101 March 1985 Responses to Interrogatories & Request for Production of Documents on Contention 41-G.C Van Vo Considered to Be Well Qualified in Experience & Educ for Job.Related Correspondence ML20107D0491985-02-19019 February 1985 Response to W Eddleman 12th Set of General Interrogatories to Applicant Re Contention 41-G.Related Correspondence ML20107D0591985-02-19019 February 1985 Response to W Eddleman Request for Production of Documents Re Contention 41-G.Certificate of Svc Encl.Related Correspondence ML20106D0951985-02-0808 February 1985 Applicant Request That W Eddleman Answer Interrogatories & Produce & Permit Insp of Documents Re Contention 41-G Concerning C Van Vo Allegations.Certificate of Svc Encl. Related Correspondence ML20102A2061985-02-0404 February 1985 General Interrogatories & Request for Production of Documents Re Employment of Cv Vo.Related Correspondence ML20102A0791985-02-0404 February 1985 Seventh Set of Interrogatories & Request for Production of Documents Re Eddleman Contentions.Related Correspondence ML20101E9021984-12-21021 December 1984 Response to W Eddleman Second Round Interrogatories on 213-A to Applicant/Emergency Response Personnel & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20100G5971984-12-0303 December 1984 Second Round Interrogatories on 213-A to Applicants/ Emergency Response Personnel & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20100A5001984-11-30030 November 1984 Response to 841005 Discovery on Contention EPJ-3 (Volunteer Workers).Certificate of Svc Encl.Related Correspondence ML20099K4271984-11-26026 November 1984 Applicant Supplemental Responses to W Eddleman General Interrogatories to Applicant 11th Set.Certificate of Svc Encl.Related Correspondence ML20099D3771984-11-0909 November 1984 Response to Applicant 841005 Emergency Planning Interrogatories & Request for Production of Documents to Sponsors of EPJ-1,EPJ-4 & EPJ-5.Certificate of Svc Encl. Related Correspondence ML20107G1011984-10-31031 October 1984 Final Response to Conservation Council of North Carolina First Set of Interrogatories & Request for Production of Documents on Emergency Planning Contentions.Related Correspondence ML20107F3851984-10-31031 October 1984 Response to Conservation Council of North Carolina Interrogatories & Request for Production of Documents Re First Set of Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence 1999-09-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] |
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- g. O UNITED STATES OF AMERICA Z Ti moc81983>b;j NUCLEAR REGULATORY COMMISSION G g, BEFORE THE ATOMIC SAFETY AND LICENSING BO O #C 5 g In the Matter of / I M
)
)
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 & 2) )
APPLICANTS' RESPONSE TO WELLS EDDLEMAN'S REQUEST FOR PRODUCTION OF DOCUMENTS (CONTENTIONS 75 and 83/84)
Pursuant to 10 C.F.R. S2.741(d), Applicants hereby respond to Wells Eddleman's Request for Production of Documents as contained in Wells Eddleman's General Interrogatories and Interrogatories on Contentions 75 and 83/84 to Applicants Carolina Power & Light et al. (Third Set) by stating that the documents identified in Applicants' Answers to Wells Eddleman's GeneralInterrogatories and Interrogatories on Contentions 75and 83/84 to Applicants (Third Set) will be made available to Mr. Eddleman for inspection and copying in the following manner:
The requested documents will be made available at the corporate offices of Carolina Power & Light Company,411 Fayetteville Street Mall, Raleigh, North Carolina, 27602. The documents will be made available during Carolina Power & Light Company business hours (or such other mutually agreeable time). Appeintments to inspect the documents may be arranged by telephoning Hill Carrow at 836-6839, at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before the requested inspection. Applicants will maintain the requested documents assembled in Carolina Power & Light Company offices available for inspection by Mr. Eddleman, for a reasonable time (i.e., through September 5,1983), after which they will be returned to their place of origin.
8308110244 830805 PDR ADOCK 05000400 G PDR
J Inspected documents which Mr. Eddleman wishes to have copied will be reproduced by Carolina Power & Light Company on a schedule compatible with other demands for duplicating equipment. A Carolina Power & Light Company employee will be available during the inspection in order to receive any requests for copying. Copies of such documents will then be furnished to Mr. Eddleman upon payment of 7 cents per page, to meet Carolina Power & Light Company's cost of reproduction.
AAM<J Hill Carrow CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 27602
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(919) 836-6839 Attorneys For Applicants: - ---- -~ --
Thomas A. Baxter ~
John H. O'Neill, Jr.
SHAW, 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 Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Dated: August 5,1983 l
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RECEIVED [g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 9.- AUG E ""3 > Fy h.
l BEFORE THE ATOMIC SAFETY AND LICENSING BOAR y 3E [gQ* .p *
/ SECY NHC c,N ( .
In the Matter of ) / Ilio
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CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN MUNICIPAL )
POWER AGENCY )
) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ) 50-401 OL Units 1 & 2) )
)
)
CERTIFICATE OF SERVICE I hereby. certify that copies of " Applicants' Answers to Wells Eddlamen's General Interrogatories and Interrogatories on Contentions 75 and 83/84 to Applicants Carolina Power & Light Company, g al. (Third Set)", " Applicants' Response to Wells Eddleman's Request for Production of Documents", and Certification of Counsel were served this 5th day of August,1983 by deposit in the United States mail, first class, postage prepaid, to the parties on the attached Service List.
^
')LA G Hill Carrow Attorney Dated: August 5,1983 e
4
SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of North Carolina U. S. Nuclear Regulatory Commission 307 Granville Road Washington, D. C. 20555 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 Post Office Box 12643 Washington, D. C. 20555 Raleigh, North Carolina 27605 i Dr. James H. Carpenter ~Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street l U. S. Nuclear Regulatory Commission Apex, North Carolina 27502-Washington, D. C. 20555 Mr. Wells Eddleman Charles A. Barth, Esquire 718-A Iredell Street Myron Karman, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U. S. Nuclear Regulatory Commission Thomas A. Baxter, Esquire Washington, D. C. 20555 John H. O'Neill, Jr., Esquire
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Shas, Pittman, Potts & Trowbridge r
Docketing and Service Section 1800 M Street, N.W.
Office of the Secretary Washington, D. C. 20036 U. S. Nuclear Regulatory Commission ,:
Washington, D. C. 20555
' Dr. Phyllis Lotchin 108 Bridle Run Mr. Daniel F. Read, President
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Chapel Hill, North Carolina 27514 Chapel Hill Anti-Nuclear '
Group Effort _. .
Bradley W. Jones, Esquire Post Office Box 524 U. S. Nuclear Regulatory Commission
, Chapel Hill, North Carolina 27514 Region 11 101 Marietta Street Dr. Linda Little Atlanta, Georgia 30303 Governor's Waste Management Board 513 Albemarle Building Karen E. Long, Esquire 325 Salisbury Street Staff Attorney Raleigh, North Carolina 27611 Public~ Staff
~ ~ ~ ~ ~
North Carolina Utilities Commission Ruthanne G. Miller, Esquire Post Office Box 991 Atomic Safety and Licensing Raleigh, North Carolina 27601 Board Panel U. S. Nuclear Regulatory Commission '
Washington, D. C. 20555
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- cpal e Carolina Power & Light Company July 10, 1981 / '
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Mr. J. P. O'Reilly m Region II United States Nuclear Regulatory Commission k DocKnrxc a c
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101 Marietta Street, hv Atlanta, Georgia 30303 q'p i SHEARON HARRIS NUCLEAR POWER PLANT UNIT NOS. 1, 2, 3, AND 4 DOCKET NOS. 50-400, 50-401, 50-402, AND 50-403 IE BULLETIN 81-03
Dear Mr. O'Reilly:
As requested by IE Bulletin 81-03, " Flow Blockage of Cooling Water to Safety System Components by Corbicula sp. (Asiatic Clam) and Mytilus sp.
(Mussel)," Carolina Power & Light Company has evaluated the problem and its applicability to the Shearon Harris Nuclear Power Plant (SHNPP). It has been determined that the potential for biofouling exists since the Asiatic clam is present in the vicinity of the station. The results of seven consecutive years of field biological monitoring programs indicate Corbicula fluminea is present in the Cape Fear River. Corbicula fluminea has also invaded portions of Buckhorn Creek, which is the primary water source for the main reservoir.
At present, field observations indicate that these clams inhabit areas of Buckhorn Creek downstream of the main dam. There is no indication that the clams are present in any area of the main reservoir nor are they present in any inflowing headwater streams.
The mussel (Mytilus sp.) does not inhatit any local environments and is probably restricted to coastal habitats which begin many river-miles downstream from the SHNPP.
Corbicula fluminea is expected to eventually be introduced into the Shearon Harris Reservoir; however, any introduction of clams should be detected by the ongoing benthic macroinvertebrate monitoring program. Once a clam population is detected in the reservoir, macroinvertebrate monitoring efforts will be increased in the area of plant intake structures. This monitoring will determine clam population dynamics including spawning periods and organism densities. These studies will give a clear indication of potential biofouling problems due to high clam densities near plant intake structures. At that time, power plant personnel will be informed that the potential for biofouling exists.
... . . . . . , . _ . , ..m . , . - .... , _ . . . , , ,
411 Fayetteville Street
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. O O Since at present SHNPP is still in the construction phase and there is no indication that the clams inhabit the reservoir, a control program other than environmental monitoring has not yet been finalized. Several control .
measures are being evaluated and upon detection of Corbicula fluminea in the l reservoir, any protective actions deemed to be necessary will be acted upon. !
If you have any further questions on this subject, please contact our staff.
Yours very truly, W/ '
-t E. E. dtley ExecutiveVicePresident}
Power Supply and Engineering & Construction ONH/je (N#64) _ _ _
cc: Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission-Washington, D. C. 20555 _
Mr. E. Licitra (NRC)
E. E. Utley, having been first duly sworn, did depose and say that the information contained herein is true and correct to his own personal knowledge or based upon information and belief.
5Ad?m.Y ~YffMdlu18e '
Notary Publ tN /g My commission expires: October 4, 1981 3 / ".- e 3 o O T A a y ,g 3 5 i. #UBLIC j j
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C9&L Carolina Power & Light Company MAR 251983 SERIAL: LAP-83-86 Mr. James P. O'Reilly, Regional Administrator y #
United States Nuclear Regulatory Commission S Region II 101 Marietta Street, NW, Suite 3100 arcEnzo h
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Atlanta, GA 30303 -
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AUG 81983 > -i. .
DocErmo a J
% EERDc5 BnA,ica p SHEARON HARRIS NUCLEAR POWER PLANT UNIT NOS. 1 AND 2 limas spt Cv ,,, /
DOCKET NOS 50-400 AND 50-401 N IE BULLETIN NO. 81-03
Dear Mr. O'Reilly:
As requested by IE Bulletin No. 81-03, " Flow Blockage of Coo, ling Water to Safety Components by Corbicula sp. (Asiatic Clam) and Mytilussp.
(Mussel) " dated December 10, 1982, and in accordance with the schedule set forth in our February 8,1983 letter, Carolina Power & Light Company hereby submits, in the attachment to this letter, responses to the requested additional information for the closing of the issue.
If you have any further questions on this subject, please advise.
Yours very truly, Original Signed Bv WALTER J. HURFOk0 W. J. Hurford Manager Technical Services PS/ mag (6436P3A)
Attachment cc:
Mr. N. Prasad Yadambi (NRC)
Mr. G. F. Maxwell (NRC-SHi&P)
Mr. J. P. O'Reilly (NRC-RII) 411 rayittaville Street
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4
- bec: Mr. H. R. Banks Mr. L. I. Loflin Mr. D. L. Bensinger Mr. R. L. Mayton, Jr.
Mr. C. S. Bohanan Mr. S. McManus Mr. J. R. Bohannon Mr. C. H. Moseley, Jr.
Mr. C. Carmichael (2) Mr. R. M. Parsons i
Mr. N. J. Chiangi Mr. J. J. Sheppard Mr. A. B. Cutter Mr. Sheldon D. Smith Dr. T. S. E11eman Mr. M. A. Weaver (Westinghouse) '
Mr. G. L. Forehand Mr. J. L. Willis Mr. J. F. Garibaldi (Ebasco) Mr. R. C. Yates Dr. W. T. Hogarth Nr. T. A. Baxter (Shaw, Pittman, Dr. J. D. E. Jeffries Potts & Trowbridge)
Mr. I. A. Johnson File: HI/A-2D File: H-X-0550 S
C REQUEST FOR ADDITIONAL INFORMATION IE BULLETIN NO. 81-03 t
1.(4A)
No discussion of instrusion potential if and when Corbicula sp.
becomes established in reservoir. Please assess and respon~d .
If and when Corbicula sp. becomes established in the Harris main and/or auxiliary reservoirs, the potential will exist for adults, larvae, and shells to be entrained into the service water and fire protection systems of the SHNPP. However, various design and operating conditions are expected to reduce the probability of flow 1
l reduction or blockage to safety system components by_Corbicula sp.
No flow reduction or blockage problems are expected to result in the normal Service Water System (SWS). This system is designed to withdraw (CWS) at service water the cooling f rom the closed-loop Circulating Water System towers. Because the physical and chemical climate of the cooling towers will be unfavorable to Corbicula sp.
habitation; and because the service water is designed to be _
chlorinated to maintain a 0.5 ppm residual chlorine concentration at the heat exchanger outlet, _Corbicula sp. intrusion of the SWS is not probable.
The EmerSency Service Water System (ESWS) will withdraw water from the auxiliary main reservoir.reservoir or, if that source is unavailable, from the From either source, the emergency service water will be pumped to the normal SWS.
Because the ESUS pumps will be operated monthly, no accumulation of silt or _Corbicula sp. will occur in the ESWS pipelines f rom the intake structure to the junction with the normal SWS.
Corbicula sp. does not attach, so any young adults that grow from larvae that settle there will be flushed through the system before growing large enough to reduce or block service water flow.
The greatest potential for flow reduction or blockage in the SWS will result f rom the accumulation of silt and _Corbicula adults and/or shells in the ESUS pump suction bays behind the travelling screens.
The travelling screens with a mesh size of 3/8" will prevent other adults or shells from entering the ESWS intake bays. If significant buildups occur, the adults or shells would be picked up by tt2 ESWS pumps suction; however,1/16" self cleaning strainers are ' located at the discharge of the ESWS pumps to preclude passage into the ESWS.
Two factors which may reduce the likelihood of high Corbicula sp.
densities in the intake bays are the water depth and the monthly operation of the service water pumps. At normal water level, the depth at the ESWS intakes on the auxiliary reservoir and main reservoir will be 60 feet and 30 feet, respectively.
Low oxygen levels at these depths during summer months should inhibit occurrence '
and growth of Corbicula sp.
The monthly operation of the ESUS pumps should minimize the buildup of silt in the intake bays thus minimize f avorable substrate for Corbicula larvae to settle and grow into adults.
The potential intrusion by Corbicula sp. into the Fire Protection System (FPS) may be possible by makeup of water containing larvae.
The larvae could-settle in low points of the system where they may grow into adults.
Also, as described for the ESWS, Corbicula adults and/or shells would be entrained f rom possible accumulations behind travelling screens at the intake bays on the auxiliary reservoir.
Any adults or shells that enter or develop in the FPS could then reduce or block flow through small pipes, valves, or sprinklers.
Because the FPS pumps will be operated weekly for testing and because portions of the system will be flushed as of ten as quarterly; Corbicula larvae, and possibly adults and shells, would be entrained.
- 1. (4 b) No information provided regarding planned control or detection methods. Please respond and describe inspection procedures and control technology under consideration.
Because the potential for Corbicula sp. intrusion of the SWS, ESUS, and FPS exists, the following inspection procedures and control measures will be planned:
SWS and ESWS
- a. During normal refueling outages, selected service water heat exchangers will be inspected for the presence of_Corbicula sp.
b.
The SWS will be chlorinated as described in 1.(4a) above if Corbicula sp. or other biofouling is t uspected or found in the SWS.
c.
Once Corbicula sp. are found in the reservoir during regular environmental monitoring of the benthic macroinvertebrate populations, periodic sampling of the intake bays behind the travelling screens will be initiated.
- d. If significant densities of adults or accumulation of shells are found in the intake bays, periodic treatment of the bays with oxygen scavenging chemicals [e.g. , sodium-metabisulfate (Na2253 0 )] will be initiated as required to control the Corbicula sp.
FPS a.
Low point blowdown drains will be used to periodically inspect the FPS for evidence of Corbicula sp.
b.
Once Corbicula sp. are known to inhabit the auxiliary reservoir, chlorination units will ba installed at the intake pumps.
Chlorine would be injected consistant with pump operation.
c.
When Corbicula sp. are found in the auxiMary reservoir, the FPS intake bay behind the travelling screens will be inspected and treated as described for the ESWS intakes in (c) and (d) above.
- 2. (4 b) No information provided regarding status of construction. Please respond and, if any systems have been filled, describe inspection procedures and results.
All fire protection systems have been filled and pressurized as needed to protect equipment already installed. With the exceptian of fire protection, no piping associated with those systems of interest
are presently filled at SHNPP. These systems may be filled for hydrostatic testing as early as May of 1983, and subsequently 'oe flushed, drained, and thoroughly inspected no earlier than January 1984.
3.a Provide last sampling date and results.
Quarterly sampling of the benthic community developing in the Harris Reservoir was conducted during February, May, August, and November 1982. No_Corbicula sp. were found in any of the samples reservoir.
collected indicating that the clams are not in the main
--- C Sampling planned for 1983 will include two new stations. One will be in the main reservoir near the mouth of the cooling tower makeup intake channel, and the other will be in the auxiliary reservoir near the mouth of the emergency service water intake channel.
3.e See 1.(4b) above for planned _ corrective and preventive actions.
(6436PSA mag)
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