ML20081B777

Supplemental Answer to Applicant Interrogatories & Requests for Production of Documents on Joint Contentions I & Vii. Certificate of Svc Encl.Related Correspondence

ML20081B777
Person / Time
Site:	Harris
Issue date:	03/07/1984
From:	Payne M EDELSTEIN & PAYNE, JOINT INTERVENORS - SHEARON HARRIS, KUDZU ALLIANCE
To:
References
NUDOCS 8403120002
Download: ML20081B777 (4)

Text

I 1 3gg cogsv0MD5' March 7 , 1984 hshf UNITED STATES OF AMERICA '84 MAR -9 A11 :08 NUCLEAR REGULATORY COMMISSION t E OF SE Llit.M BEFORE THE ATOMIC SAFETY AND LICENSING BOARD hNC In the Matter of )

)

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

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

JOINT INTERVENORS' SUPPLEMENTAL ANSWER TO APPLICANTS' INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS ON JOINT CONTENTIONS I AND VII As a result of telephone conversations conducted on March 1 and 2, 1984, between John H. O'Neill, counsel for Applicant, and M. Travis Payne, counsel for Kudzu Alliance, Joint Intervenors hereby file th'eir supplemental answers to the above-referenced Interrogatories.

Answer to General Interrogatory #4 With regard to Joint Contention I, it does not appear that any specific documents were used in drafting that contention. The various individual contentions on Applicants' management capability that were ultimately replaced by Joint Contention I were drafted largely based on the recollection of press reports of various NRC citations and fines levied against Applicants at their various nuclear stations. In addition, those contentions were also based to some. extent on the recollection of testimony of various 8403120002 840307 PDR ADOCK 05000400 d)7 C PDH

witnesses before the North Carolina Utilities Commission.

With regard to Joint Contention VII, as indicated in our prior response, Mr. Eddleman has a file of documents that relate to steam generators. At this time, Joint Intervenors are unable to say with any certainty which specific documents were used in draf ting the various steam generator contentions that became Joint Contention VII. However, it is likely that all documents that may have been relied on are contained within Mr. Eddleman's file. It should be noted that Mr.

Eddleman's file on steam generators is a " working file" and documents are continuously being added to it. Thus, many of the documents inthat file were obtained after the initial drafting of contentions in this proceeding, and may actually be dated subsequent to the filing of contentions in this proceeding. Obviously, these documents were not employed in drafting any of the original steam generator contentions in this proceeding. As agreed between Mr. O'Neill and Mr.

Payne, Mr. Eddleman will produce his steam generator file for inspection and copying by Applicants at their headquarters in Raleigh at a mutually agreed-upon date. Mr. Eddleman should be contacted directly to establish that time and date.

Answer to Interrogatory VII-24 In our previous response to this Interrogatory, Joint Intervenors indicated that they were unable to find the document referenced as " Letter dated July 1, 1983 to the NRC staff (LAP-83-248)". We therefore were not able to respond to this Interrogatory. Joint Intervenors have now located 2

this document and are reviewing it. We will file a response, based on our analysis of this document in the very near future.

This the h7 day of March, 1984.

EDELSTEIN, PAYNE AND JORDAN Attorneys for Kudzu Alliance 1 --

j. By: - W '

l M. Travis Payne 49' l

723 W. Johnson Street

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P. O. Box 12607 Raleigh, NC 27605 (919)828-1456 CERTIFICATE OF SERVICE Certified that on this day service of the foregoing Response was mde by depositing the same in the United States Mail, postage prepaid, properly addressed as follows:

James L. Kelley John D. Runkle Atomic Safety and Licensing Board Conservation Councel of U.S. Nuclear Regulatory Commission North Carolina Washington, DC 20555 307 Granville Road Chapel Hill, NC 27514 Mr. Glenn O. Bright Dr. James H. Carpenter Atomic Safety and Licensing Board Atomic Snfety and Licens-U.S. Nuclear Regulatory Commission ing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Charles A. Barth Washington, D.C. 20555 Janice E. Moore Office of Executive Legal Director Dr. Richard C.. Wilson U.S. Nuclear Regulatory Commission 729 Hunter Street Washington, D.C. 20555 Apex, NC 27502 Docketing and Service Section Mr. Wells Eddleman

-Office of the Secretary 718-A Iredell Street U.S. Nuclear Regulatory Commission Durham, NC 27705 Washington, D.C. 20555 Richard E. Jones Mr. Daniel F. Raad V. President and Senior CHANGE /ELP Counsel 5707 Waycross Street Carolina Power & Light Raleigh, NC 27606 P.O. Box 1551 Raleigh, NC 27602 3

Dr. Phyllis Lotchin 108 Bridle Run Dr. Linda W. Little Chapel Hill, NC 27514 Governor's Waste Manage-ment Board Bradley W. Jones 513 Albermarle Building U.S. Nuclear Regulatory Commission 325 North Salisbury St.

Region II Raleigh, NC 27611 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller Atomic Safety and Licens-Mr. Robert P. Gruber ing Board Panel

. Executive Director U.S. Nuclear Regulatory P.O. Box 991 Commission Raleigh, NC 27602 Washington, D.C. 20555 Thomas A. Baxter John H. O'Neill, Jr.

Shaw, Pittman, Potts and Trowbridge 1800 "M" Street, N.W.

Washington, D.C. 20036 This the 52 day of March, 1984.

<- O M. Travi~s Payne [~

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