ML20028C313

Response Opposing Applicant 821217 Motion for Codification of Admitted Contentions.Ref to SER in Contention 9 Should Stand.Removal of Effect of Steam Generator Problems on Capacity Factors from Contention E-15 Inappropriate

ML20028C313
Person / Time
Site:	Harris
Issue date:	01/03/1983
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8301070321
Download: ML20028C313 (2)

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UNITED STATES OF AMERICA NUCLEAR REGULATOBY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD %MZH Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of

) Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )

Units i and 2) )

)

Wells Eddlenan's Resnonse to Applicants'

" Motion for Codification of Admitted Contentions" I don't like the idea of Applicants' attorneys re-w"iting my contenticns. In nany cases I an not yet certain what their changes nean. Therefore I file this resnonse, tinely since 15 days fron Decenber 17 was January 1, a holiday, and detail my objections to the alterations.

In Eddlenan 9, Anolicants renove the reference to the Sr" (not SEP). In light of receint arneal board decisions on new information's inpact on adnissibility of contentions af ter the E"3 l or other documents are issued, the reference to the SER should s_tand.

Anolicants' revision of E-11 annears to sinnly delete "eferences to nolyvinylchloride (PVC) throughout. To the extent that it only does that, it is accentable to mean and I so stated at the snecial I

nrehearing conference.

( Anolicants' "ecasting of E-15 renoves the effect of stean l generator eroblens on canacity factor. The continuing difficult 5es of nlante like McGuire, V.C. Sumner (with D-hs), Krsko (Yuogoslavia)

"*rghale, Alniwaz, and so on make thi s inannronriate. The Board's language (9/22/82 Order, n. 41, last naragranh) srce?'icall" includes the stean generator nroblems. It is nossible Annlicants' Dronosed language could be cured by adding "Anplicants ' canacity factor analysis also 1 nores E the effect of steam generator eroblens l

j og on capac4.ty factors achievable in oneration".

QS@ With respect to Eddlenan 22, the final sentence should stand,

<o which alleges error in C &L's original, Amendment 2 to E9, on 80 both estinates.

lm8 Anolicants ' restating of the Board's nosition on rddlenan 29 (a serious safety concern) apnears plausible. I note the Board

!gg nv deferred ruling on 29D and 30. Thus this is only Eddlenan 29.

f Apolicants ' restatement of Eddlenan 373 annears to only a; make tynogranhical changes fron the conies (sonetines tha e and R 88 don't pick up well. The tyrograrhical changes are OK.

mmo 3)$03

With resnect to E hl, Apolicants ' restatement would be accentable to ne if combined with the naragranh on p.21 of Barth's draft.

l I think the centention would n=onerly address sunport structures, containnent walls and other wo 11s, as it states. But the Board anpears to disagree, although they do state that snecific concerns in this contention are to be addressed.

I think sunnort structures and containment walle are specific enouEh, I certainly as specific as "pi With resnect to E-h5, pe thehangers" Barth concilat$ or which on there are a lot nore.

at up 21-22, corrected to vend FSAR and PSAR, Rusche N70, and "shutu" (not " rut" welds, should be pavt of the cortention, as $t includes the basis.

Otherwise, C?&L sinply is restat'ng one of ny naragranhs.

With resnect to E 6h(f), Anolicants have a tyno -- it's "radi.oactive contaninat!on" although I would accent the language j

" breach of containnent releasing radioactive contaminati on" instead.

Of course, the Fuel should not nake a fule of the tynist. l l E 6h(g), tha Ann 11 cants change the snelling of one wo*d to I correct the tyning. That's fine.

I E 65, the Apnlicants are co ying Barth. To that extent, It's OK but the full basis may not be in there as stated.

E 67, m n11 cants seek to have the references to thei- style or operation to olant capacity and electrical outnut, deleted.

at Brunswick and its unusually large volune of LLW relative

~

I think these matters strongly affec t this contention, but if they don't have to be in it to be relevant evidence (I susnect they don't, since the bear on the ancunt of LLW North Carolina would have to disnose), y there would be no nroblem. My concern is that the issue of C?&L's radwaste operations elsewhere be included in dealing vith this contention in order to assess the magnitude of the nroble, and the likelihood of CP&L and co-annlicants hav?ng no e LLW than they can dispose of within assured sites, thus not having an a ssured disposal site for Harris LLW, Anolicants ' nodifications to E 75 annear to all be tynogranhical, and nrovided the basis of serious safety cc nsea.uences if the condensers this looks OK. cannot cool the nlant or tre fouled is granted to be adeounte, On Eddlenan 80, Ba"th's draf t (p.26) has the exponent correct.

It should be used, not Anrlicants' lenguaFe.

Eddleman 83 and 8h a"e the c orrect nunbeas , but Barth 's draft (p.27 ff) seems to have the chenien1 symbols riE ht. The sentence about the Board. a separate content? on on NE?A ni E ht need clavificat$ on by Did the 3oa"d adntt a UE?A contention based on the cost of the health effects, effects on biota, etc as detailed on this pronosed vedraf t by me (at the snecial nreheav'ng conference) ??

"ddlanan 132 by Annlicants reads just like Barth's drne t to ne.

Ithat's find OK.this confusing; if the Board accented the languere nr I had it, In any event the detailed control roon design review is out nou, and I nay have to file more detailed or additional contentions on this noint.

With respect to the Joint contentions , many of then involve roints negotiated with Annlicants and things the Staff agreed to.

I think it best to let then stand.

Finally, I think Aunlicants can understand Eddleman 15 and the Board's Order re steam generators therein. It 's uretty obvious.

Nothirg he ein annlies to the othe~ adnitted g p dfm gddleman contentions. They should stand. - - 7 / z '##^

Wells Eddlenan

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