ML20028G180
| ML20028G180 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/31/1983 |
| From: | Trowbridge G CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | EDDLEMAN, W. |
| References | |
| ISSUANCES-OL, NUDOCS 8302070490 | |
| Download: ML20028G180 (174) | |
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January 31, 1983 83 FEB -3. P2:51 l 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 COMPANY ) AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL
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(Shearon Harris Nuclear Power ) , Plant, Units 1 and 2) ) APPLICANTS' INTERROGATORIES AND REQUEST FOR' PRODUCTION OF DOCUMENTS TO INTERVENOR WELLS EDDLEMAN (FIRST SET) i Pursuant to 10 C.F.R. $$ 2.740b and 2.741 and to the Atomic Safety and Licensing Board's " Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference)" of September 22, 1982, Carolina Power & Light Company and North . Carolina Eastern Municipal Power Agency hereby request that Intervenor Wells Eddleman answer separately and fully in writing, and under oath or affirmation, each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identified in the l Under the Commission's responses to interrogatories below. i Rules of Practice, answers or objections to these interroga-i l tories must be served within 14 days after service of the interrogatories; responses or objections to the request for B302070490 830131 PDR ADOCK 05000400 0 PDR T $D <h a_ -
production of documents must be served within 30 days after service of the request. These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. 6 2.740(e), should Mr. Eddleman or any individual acting on his behalf obtain any new or differing information responsive to these interrogatories. The request for production of documents is also continuing in nature and Mr. Eddleman must produce immediately any additional documents he, or any individual acting on his behalf, obtains which are responsive to the request, in accordance with the provisions of 10 C.F.R. 5 2.740(e). Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, tran-script, report, handwritten notes, test data) and provide the following information as applicable: document name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person or persons having possession of the document. Also state the portion or portions of the document (whether sec-tion (s), chapter (s), or page(s)) upon which you rely. Definitions. As used hereinafter, the following defini-tions shall apply: ) l The " erd is the Environmental Report - Operating License ! Stage for the Shearon Harris Nuclear Power Plant, as amended. i l
The "FSAR" is the Final Safety Analysis Report for the Shearoit Harris Nuclear Power Plant, as amended.
" Applicants" is intended to encompass Carolina Power &
Light Co., Norch Carolina Eastern Municipal Power Agency and their contractors for the Harris Plant.
" Document (s)" means all writings and records of every type in the possession, control or custody of Mr. Eddleman or any individual acting on his behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings and all other writings or recordings of any kind;
" document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody, or control of Mr. Eddleman; a document shall be deemed to be within the " control" of Mr. Eddleman or any individual acting on his behalf if they have ownership, possession or custody of the document or copy thereof, or have the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.
General Interrogatories 1(a). State the name, present or last known address, and present or last known employer of each person known to you to l have first-hand knowledge of the facts alleged, and upon which you relied in formulating allegations, in each of your r
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l contentions which are the subject of this set of interrogatories. (b). Identify those facts concerning which each such person has first-hand knowledge. (c). State the specific allegation in each contention which you contend such facts support. 2(a). State the name, present or last known address, and present or last employer of each person, other than affiant, who provided information upon which you relied in answering each interrogatory herein. (b). Identify all auch information which was provided by each such person and the specific interrogatory response in which such information is contained. 3(a). State the name, address, title, employer and , educational and professional qualifications of each person you intend to call as an expert witness or a witness relating to any content, ion which is the subject of this set of interroga-tories. (b). Identify the contention (s) regarding which each such person is~ expected to testify. (c). State the subject matter to which each such person is expected to testify. 4(a). Identify all documents in your possession, custody or control, including all relevant page citations, pertaining l l l
l i to the subject matter of, and upon which you relied in formulating allegations in.each contention which is the subject of this set of interrogatories. (b). Identify the contention (s) to which each such document relates. (c). State the specific allegation in each contention which you contend each document supporta. 5(a). Identify all documents in your possession, custody or control, including all relevant page citations, upon which you relied in answering each interrogatory herein. (b). Identify the specific interrogatory response (s) to which each such document relates. 6(a). Identify any other source of information, not previously identified in response to Interrogatory 2 or 5, which was used in answering the interrogatories set forth herein. (b). Identify the specific interrogatory response (s) to which each such source of information relates. 7(a). Identify all documents which you intend to offer as exhibits during this proceeding to support the contentions which are the subject of this set of interrogatories or which you intend to use during cross-examination of witnesses presented by Applicants and/or the NRC Staff on each contention which is the subject of this set of interrogatories.
(b). Identify the contention (s) to which each document relates and the particular page citations applicable to each contention. Interrogatories on Contention 9 (Environmental Qualification of Electrical Equipment) 9-1(a). State whether you are aware that the Nuclear Regulatory Conmission ("NRC") has recently issued its final rule, 10 C.F.R. 6 50.49, on the environmental qualification of electrical equipment. See Notice of Final Rulemaking, 48 Fed. Reg. 2729 (January 21, 1983), a copy of which is attached hereto. (b). State whether you are aware that Applicants will be required to comply with the criteria of 10 C.F.R. $ 50.49 with respect to all safety-related electrical equipment not already qualified under NUREG-0588 (" Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment") (1979). (c). State whether you believe that Applicants will - fail to comply with the applicable criteria of 10 C.F.R. 5 50.49. (d). If the answer to (c) above is affirmative, identify all specific criteria of 10 C.F.R. 5 50.49 with which you believe Applicants will fail to comply. As to each such criterion, describe in detail the bases for your conclusion, including the reasons for identifying the criterion. 4 _ m -
(e). If the answer to (c).above is other than affirma-tive, explain in detail how your response is consistent with the allegations set forth in Contention 9. 9-2(a). State whether you believe that. Applicants are failing to comply with the applicable criteria of NUREG-0588. (b). If the answer to the preceding interrogatory is affirmative, identify all specific criteria of NUREG-0588 with which you believe Applicants are failing to comply. As to each such criterion, describe in detail the bases for your conclu-sion, including the reasons for identifying the criterion. (c). If the answer to (a) above is other than affirma-tive, explain in detail how your response is consistent with the allegations set forth in Contention 9. 9-3(a). Identify all NRC rules, regulations, regulatory guides, publications and endorsed national standards pertaining to the environmental qualification of electrical equipment, other than 10 C.F.R. $ 50.49 and NUREG-0588,.with which you believe Applicants fail or will fail to comply. As to each such item, describe in detail the bases for your conclusion, including the reasons for identifying the item. (b). Identify all specific criteria of each item identified in response to (a) above with which you believe Applicants fail or will fail to comply. As to each such criterion, describe in detail the bases for your conclusion, including the reasons for identifying the criterion. l
I 9-4(a). State whether you believe that FSAR 5 3.11 (" Environmental Design of Active Mechanical and Electrical Equipment"), as amended June 30, 1982 (Amendment 3), fails to show compliance with 10 C.F.R. 5 50.49. (b). If the answer to (a) above is affirmative, identify all specific criteria of 10 C.F.R. S 50.49 with which you believe FSAR S 3.11 fails to show compliance. As to each such criterion, describe in detail the bases for your conclu-sion, including the reasons for identifying the criterion. (c). As to each criterion identified in response to (b) above, state what change (s) you believe Applicants must make for FSAR 5 3.11 to show compliance with 10 C.F.R. 5 50.49? Describe in detail the bases for your conclusions. (d). If the answer to 'a) above is other than affirma-tive, explain in detail how your response is consistent with the allegations set forth in Contention 9. 9-5(a). State whether you believe that the format of FSAR Figure 3.11.1-1 (" Master List legend") fails to show compliance with the criteria of 10 C.F.R. 5 50.49. (b). If the answer to (a) above is affirmative, identify all specific criteria of 10 C.F.R. 5 50.49 with which you believe Figure 3.11.1-1 fails to show compliance. As to each such criterion, describe in detail the bases for your conclusion, including the reasons for identifying the crite-rion.
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(c). As to each criterion identified in response to (b) above, what change (s) do you believe Applicants must make for Figure 3.11.1-1 to show compliance with 10 C.F.R. S 50.49? Describe in detail the bases for your conclusions. (d). If the answer to (a) above is other than affirma-tive, explain in detail how your response is consistent with the allegations set forth in Contention 9. j 9-6(a). State whether you believe-that the format of FSAR
; Figure 3.11.1-2 (" Component Evaluation Sheet Legend") faila to l
show compliance with the criteria of 10 C.F.R. $ 50.49. , (b). If the answer to (a) above is affirmative, <
! identify _all specific criteria of 10 C.F.R. 9 50.49 with which i
you believe Figure 3.11.1-2 fails to show compliance. As to each such criterion, describe in detail the bases for your conclusion, including the reasons for identifying the crite-rion. . (c). As to each criterion identified in response to ' (b) above, state what change (s) you believe Applicants must make for Figure 3.11.1-2 to show compliance with 10 C.F.R. 5 50.49. Describe in detail the bases for your conclusions. (d). If the answer to (a) above is other than affirma-tive, explain in detail how your response is consistent with the allegations set forth in Contention 9. 9-7(a). State whether you believe that FSAR 9 3.11 fails to show compliance with NUREG-0588. 1 [ 9-1
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(b). If the answer to (a) above is affirmative, identify all specific criteria of NUREG-0588 with which you believe FSAR $ 3.11 fails to show compliance. As to each such criterion, describe in detail the bases for your conclusion, including the reasons for identifying the criterion. (c). As to each criterion identified in response to (b) above, state what change (s) you believe Applicants must make for FSAR $ 3.11 to show compliance with NUREG-0588. Describe in detail the bases for your conclusions. 4 (d). If the answer to (a) above is other than affirma-tive, explain in detail how your response is consistent with the allegations set forth in Contention 9. 9-8(a). State whether you believe that the format of FSAR Figure 3.11.1-1 fails to show compliance with the criteria of NUREG-0588. (b). If the answer to (a) above is affirmative, identify all specific criteria of NUREG-0588 with which you believe Figure 3.11.1-1 fails to show compliance. As to each such criterion, describe in detail the bases for your conclu-sion, including the reasons for identifying the criterion. (c). As to each criterion identified in response to (b) above, state what change (s) you believe Applicants must make for Figure 3.11.1-1 to show compliance with NUREG-0588. Describe in detail the bases for your conclusions. l
(d). If the answer to (a) above is ot;her than affirma-tive, explain in detail how your response is consistent with the allegations set forth in contention 9. 9-9(a). State whether you believe that the format of FSAR Figure 3.11.1-2 fails to show compliance with the criteria of NUREG-0588. (b). If the answer to (a) above is affirmative, identify all specific criteria of NUREG-0588 with which you believe Figure 3.11.1-2 fails to show compliance. As to each such criterion, describe in detail the bases for your conclu-sion, including the reasons for identifying the criterion. (c). As to eich criterion identified in response to (b) above, state what change (s) you believe Applicants must make for Figure 3.11.1-2 to show compliance with NUREG-0588. Describe in detail the bases for your conclusions. (d). If the answer to (a) above is other than affirma-tive, explain in detail how your response is consistent with the allegations set forth in Contention 9. 9-10(a). Identify all applicable NRC rules, regulations, regulatory guides, publications and endorsed national stand-ards, other than 10 C.F.R. 5 50.49 and NUREG-0588, with which you believe FSAR $ 3.11 fails to show compliance. As to each such item, describe in detail the bases for your conclucion, including the reasons for identifying the item. l l 1 l l
(b). Identify all specific criteria of each item identified in response to (a) above with which you believe FSAR 5 3.11 fails to show compliance. As to each such criterion, describe in detail the bases for your conclusion, including the reasons for identifying the criterion. (c). As to each criterion identified in response to (b) above, state what change (s) you believe App 7 ; ants must make for FSAR S 3.11 to show compliance with the applicable item identified in response to (a) above. Describe in detail the bases for your conclusions. (d). If the answer to (a) above is other than affirma-tive, explain in detail how your response is consistent with the allegations set forth in Contention 9. Interrogatories on Contention 11 (Polyethylene Cable Insulation Degradation) 11-1(a). Describe in detail the bases for your conclusion that " polyethylene, used as cable insulation, deteriorate [s] much more rapidly under long-term doses of gamma radiation than [it does] when exposed to the same total dose over a much shorter period of time." Supplement to Petition To Intervene by Wells Eddleman, dated May 14, 1982 (" Supplement"), at 56. (b). Identify the Sandia Laboratories study or studies by K. Gillen and R. Clough which you believe demonstrate the , degradation effect described in (a) above. (c). Identify all facts, findings and conclusions ; stated in each of the studies identified in response to (b)
above which you believe demonstrate the degradation effect described in (a) above. As to each such item, describe in detail the bases for your conclusion, including your reasons for identifying the item. (d). State whether you believe that dose rate testing l of polyethylene cable insulation which has been stripped from the wire, thereby exposing a much larger surface area to the i t ambient atmosphere than would be exposed if the cable were installed in an operating plant, could increase oxygen diffu-sion into the materials, thus increasing oxidation and degrada-tion of the insulation. If not, describe in detail the bases for your conclusion. (e). State whether you believe that Cobalt-60 used as the radiation source in dose rate testing of polyethylene cable insulation could produce a greater degree of degradation in the materials than the gamma emissions from an operating plant's radiation sources. If not, describe in detail the bases for your conclusion. . 11-2(a). State the lowest gamma radiation dose rate above which you believe the degradation effect described in Interrogatory 11-1 causes unsafe conditions to occur. Describe in detail the bases for your conclusion. (b). State tha-highest gamma radiation dose rate below which you believe the degradation effect described in Interrogatory 11-1 causes unsafe conditions to occur. Describe in detail the bases for your conclusion.
(c). State the total, integrated gamma radiation dose above which you believe the degradation effect described in Interrogatory 11-1 causes unsafe conditions to occur. Describe in detail the bases for your conclusion. , 11-3(a). Identify what you believe to be the specific property or properties -- e.g., tensile strength, elongation, insulation resistance, dielective strength -- necessary for polyethylene cable insulation to perform its proper function. As to each such property, describe in detail the bases for your conclusion, including the reasons for identifying the property. (b). State what you believe to be the acceptable percentage of retuction of each property identified above in order for polyethylene cable insulation to perform its func-tion. As to each property, describe in detail the bases for your conclusion. 11-4(a). Describe in detail the bases for your conclusion that the " loss of cable ... insulation would lead to short circuits" at Shearon Harris Nuclear Power Plant ("SHNPP"). Supplement at 57. (b). Explain the discrepancy between your statement that short circuits "would" occur and your statement that short circuits would "very likely" occur if cable were to lose its insulation. If.
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11-5. Identify all incidents, of which you are aware, in which the degradation effect described in Interrogatory 11-1 has caused unsafe conditions to occur in commercial nuclear power plants which are now operating or at one time did operate. As to each such incident, provide all pertinent details. 11-6. Identify all electrical cables with polyethylene insulation within SNHPP which you believe to be potentially dangerous as a result of the degradation effect described in Interrogatory 11-1. As to each such cable, describe in detail the bases for your conclusion, including the reasons for identifying the cable. 11-7. Identify all locations within SHNPP which you believe to be potentially dangerous as a result of the degrada-tion effect described in Interrogatory 11-1. As to each such location, describe in detail the bases for your conclusion, including the reasons for identifying the location. 11-8(a). Identify all areas within SHNPP, by radiation zone, in which the gamma radiation dose rate during normal operating conditions falls within the range of dose rates which you identified in response to Interrogatory 11-2 as causing unsafe conditions to occur. As to each such area (radiation zone), describe in detail the bases for your conclusion, j including the reasons for identifying the area (radiation ) zone). l l I
i (b). Identify all areas within SHNPP, by radiation zone, in which the total, integrated gamma radiation dose during normal operating conditions exceeds the total, inte-grated dose which you identified in response to Interrogatory 11-2 to be necessary to produce the degradation effect described in Interrogatory 11-1. As to each such area (radia-tion zone), describe in detail the bases for your conclusion, including the reasons for identifying the area (radiation zone). 11-9(a). Identify all areas within SHNPP, by radiation zone, in which the gamma radiation dose rate during accident conditions falls within the range of dose rates which you identified in response to Interrogatory 11-2 as causing unsafe conditions to occur. As to each such area (radiation zone), describe in detail the bases for your conclusion, including the reasons for identifying the area (radiation zone). Also identify each accident condition assumed in answering the Interrogatory, and which areas (radiation zones) are relevant as to that condition. (b). Identify all areas within SHNPP, by radiation zone, in which the total, integrated gamma radiation dose during accident conditions exceeds the total, integrated dose which you identified in response to Interrogatory 11-2 to be necessary to produce the degradation effect described in Interrogatory 11-1. As to each such area (radiation zone), I
describe in detail the bases for yout conclusion, including the reasons for identifying the area (radiation zone). Also identify each accident condition assumed in answering the Interrogatory, and which areas (radiation zones) are relevant as to that condition. (c). State whether you believe that the degradation effect described in Interrogatory 11-1 need be addressed for accident conditions, since accident dose rates will decay rapidly following reactor shutdown. If so, describe in detail the bases for your conclusion. 11-10(a). State what you believe to be acceptable inspec-tion standards - e.g., inspection methods, inspection frequencies - in order to detect the degradation effect described in Interrogatory 11-1. As to each such standard, describe in detail the bases for your conclusion. (b). Identify all NRC regulations, regulatory guides, publications and endorsed national standards which you believe to establish ace'eptable inspection standards for safety-related electrical cables in order to prevent the degradation effect described in Interrogatory 11-1. As to each such item, ,' describe in detail the bases for your conclusions, including 1 the reasons for identifying the item. i I l
Interrogatories on Contention 22A (Fuel Cost Estimates) I 22A-1. ER Table 8.2.1-1 sets forth components in the fuel cycle costs for the Harris Plant. The four components are as follows: (1) ~ Enriched uranium costs (which, in turn, includes I uranium costs, conversion costs and enrichment costs); (2) Fabrication costs; (3) Spent fuel storage and disposal costs; and (4) Carrying charges. Do you contend that there are other components of the Harris fuel costs which are not included in ER Table 8.2.1-l? If so, state what other components you believe should be included, the cost associated with each, and explain in detail the basis for your belief. l 22A-2(a). ER Table 8.2.1-1 sets forth the estimated lifetime levelized costs in mill per kilowatt hour for each component of the fuel cycle cost. State in detail which costs, as set forth in Table ER 8.2.1-1, you contend are erroneously low. (b). For each cost identified in response to (b) above, state what ycu believe the estimated cost should be and 1 explain in detail the basis for your allegation that the i 1 methodology utilized by Applicants for determining the cost of enriched uranium is flawed.
(c). If the answer to (a) above is other than affirma-tive, state in detail how your response is consistent with the allegation set forth in Contention 22A. 22A-3(a). ER 9 8.2.1 states that fabrication cost estimates are based on the contract cost for the initial core for each Harris Unit. Future cost estimates are determined using market prices and are escalated using established indices. Do you contend that Applicants' methodology for establishing the fabrication cost for Harris fuel is flawed? (b). If the answer to (a) above is affirmative, set forth in detail the basis for your allegation that Applicants' methodology for determining fabrication costs is flawed. (c). If the answer to (a) above is other than affirma-tive, explain in detail how your response is consistent with the allegations set forth in Contention 22A. 22A-4(a). The Nuclear Waste Policy Act of 1982, enacted on January 7, 1983, establishes a fixed fee of 1 mill per kilowatt - - hour for disposal costs for high-level radioactive waste and spent fuel. This fee will be collected by the Departmect of Energy on all nuclear generated electricity which is sold after April 7, 1983. Reference 8.2.1-1, listed in the ER, is a study by the Congressional Budget Office which establishes the adequacy tf the 1 mill per kilowatt hour charged. Do you contend that Applicants' use of the charge established by Congress as the basis for the estimated cost of spent fuel storage and disposal is incorrect? i
l (b). If the answer to (a) above is affirmative, set forth in detail the basis for your contention that Applicants' l estimate of spent fuel storage and disposal costs is incor-rectly determined. (c). If the answer to (a) are e is other than affirma-tive, explain how your response is consistent with the allega-tions is set forth in Contention 22A. 22A-5(a). The final component in Applicants' estimate of Harris fuel costs is projection of carrying charges based on established indices supplied by Data Resources Incorporated (DRI). Do you contend that the use of such established indices is a flawed methodology in determining carrying charges? (b). If the answer to (a) above is affirmative, set forth in detail the basis for your contention that the carrying charges based on established excalation indices are incorrectly determined. (c). If the answer to (a) above is other than affirma-tive, explain in detail how your response is consistent with the allegation set forg) in Contention 22A. Interrogatories on Contention 22B (Operating Payroll) 22B-1. ER S 8.2.1 states that Carolina Power & Light Company expects to spend approximately $615 million of the total life of the plant operation and maintenance costs in salaries. These salaries are based on Applicants' estimates of all company personnel, both onsite and offsite, and contract
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l labor required for operation of the Harris Plant. Explain in detail the basis for your allegation that this estimate is not accurate. 22B-2(a). As the basis for your contention that Applicants' estimate of the operating payroll for Harris Units 1 and 2 is not accurate, you allege that the operating payroll estimates have not decreased by any significant amount compared to the estimated operating payroll for four units at the construction permit s'tage. Do you contend that there has not been a significant increase in staffing needs at all nuclear power plants due to new regulatory requirements instituted since the date of the information provided in the ER, Construction Permit stage? (b). If the answer-to (a) above is affirmative, set forth in detail the basis for your assertion that staffing levels for commercial nuclear power plants have not increased due to the new regulatory requirements during the period of time since the construction permit proceeding for the Harris Nuclear Power Plant. (c). If the answer to (a) above is other than affirma-tive, explain in detail why the fact of an increase in the estimated operating payroll since the date of the information provided in the ER, Construction Permit stage, supports your contention that Applicants' present estimate of operating payroll is inaccurate. i I l i
Interrogatories on Contention 41 (Defective Hangar Welds) Interrogatories 41-1(a) through 41-S(e) all relate to Applicants' " Final Report,. Weld Symbol Errors and Misappli-cation of Weld on Bergen-Patterson Pipe Hangers", and to NRC IE Inspection Report 50-400/401/402/403-81-12, attached hereto. 41-1 (a). Do you contend that Applicants failed to take effective corrective action upon discovery of the pipe hangar welding deficiencies? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that Applicants failed to take effective corrective action upon discovery of the pipe hangar welding deficiencies. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 41. 41-2 (a). Do you contend that the additional welding and inspection training and instructions initiated by Applicants following discovery of the pipe hangar welding deficiencies was , 1 or will be ineffective in preventing subsequent occurrences of similar deficiencies?' (b). If the answer to the preceding interrogatory is l affirmative, state in detail all facts which support this allegation. l i
i (c). If the answer to (a) above is other than i l affirmative, explain in detail how your response is consistent I with the allegations set forth in Contention 41. l 41-3 (a). Do you contend that the weld rework / repair efforts undertaken by Applicants were inadequate in restoring the welds to an acceptable condition? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation.
,(c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 41.
41-4 (a). Do you contend that Applicants improperly accepted any welds without requiring rework, i.e., accepted in the "as-is" condition? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 41. 41-5 (a). Do you contend that the NRC Staff improperly closed out the infraction involving the pipe hangar welding i deficiencies by accepting Applicants' corrective action? i l l 1
5 (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this
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allegation.~ (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 41. Interrogatories on Contention 45 (Water Hammer) 45-1(a). Do you contend that the design of the Harris Plant feedwater system described in Section 10.4.7.1 of the FSAR is an inadequate design against possible water hammer events? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support this allegation. (c). If not contained in the answer to Interrogatory 45-1(b), please identify specifically the alleged inadequacies of design and the specific adverse effects of water hammer which allegedly would occur using this design. (d). If the answer to 45-1(a) is other than affirma-tive, explain in detail how your response is consistent with the allegations set forth in Contention 45. 45-2(a). Do you contend that the design of the feedwater system described in Section 10.4.7.1 of the FSAR does not comply with any applicable NRC regulation, guidance, report or other applicable NRC document?
l (b). If the answer to the preceding incerrogatory is l l affirmative, identify, with citation, each such applicable NRC regulation, guidance, report or other applicable NRC document ) l which supports this allegation. 1 (c). If the answer to Interrogatory 45-2(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 45. 45-3(a). Do you contend that inspection and testing of the feedwater system will not be adequate with respect to possible water hammer events? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support this allegation. (c). If the answer to Interrogatory 45-3(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 45. 45-4(a). Do you contend that the design and safety evaluation of the Harris Plant auxiliary feedwater system described in Section 10.4.9 of the FSAR is an inadequate design against possible water hammer events? ( (b). If the answer to the preceding interrogatory is l affirmative, state in detail all the facts which support this allegation. (c). If not contained in the answer to Interrogatory 45-3(b), please identify specifically the alleged inadequacies l l l l l
of design and the specific adverse effects of water hammer which allegedly would occur using this design. (d). If the answer to Interrogatory 45-4(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 45. 45-5 (a). Do you contend that the design of the auxiliary feedwater system described in Section 10.4.9 of the FSAR does not comply with any applicable NRC regulation, guidance, report or other applicable NRC document? (b). If the answer to the preceding interrogatory is affirmative, identify, with citation, each such applicable NRC regulation, guidance, report or other applicable NRC document which supports this allegation. (c). If the answer to Interrogatory 45-5(a) is other ' than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 45. 45-6 (a). Do you contend that the testing and inspections of the auxiliary feedwater system described in Section 10.4.9.4 of the FSAR is inadequate with respect to possible water hammer events? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support this allegation. (c). If not contained in the answer to Interrogatory 45-5(b) above, please identify specifically the alleged
inadequacies in such testing and inspection and the specific adverse effects of water hammer which allegedly would occur as a result of such alleged inadequacies? (d). If the answer to Interrogatory 45-6(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 45. 45-7 (a). Do you contend that the testing and inspections of the auxiliary feedwater system described in Section 10.4.7.1 of the FSAR does not comply with any applicable NRC regulation, guidance, report or other applicable NRC document? (b). If the answer to the preceding interrogatory is affirmative, identify, with citation, each such applicable NRC regulation, guidance, report or other applicable NRC document which supports this allegation. (c). If the answer to Interrogatory 45-7(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 45. Interrogatories 45-8(a) through 45-8(c) all relate to Applicants' Response to NRC Review Question 440.49, a copy of which is attached hereto. . 45-8 (a). Do you contend that the design of the ECCS piping described by Applicants is inadequate to preclude the effects of water hammer? r
(b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support this allegation. (c). If not contained in the answer to Interrogatory 45-8(b), please identify specifically the alleged inadequacies of design and the specific effects of water hammer which allegedly would occur using this design. (d). If the answer to Interrogatory 45-8(a) is other ! than affirmative, explain in detail how your response is consistent with the allegations set forth in contention 45. 45-9 (a). Do you contend that the design of the main steam system of the Harris Plant is an inadequate design against possible water hammer events? (b.) If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support this allegation. (c). If the answer to Interrogatory 45-9(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 45. 45-10(a). Do you contend that inspection and testing of the main steam system will not be adequate with respect to possible water hammer events? (b). If the answer to the preceding interrogatory is i affirmative, state in detail all the facts which support this I allegation.
(c). If.the answer to Interrogatory 45-10(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 45. 45-11. In your contention, you refer to the " Plant Water Hammer Experience Report, PWR S.G. (steam generator), feedwater, ECCS & Main Steam System water hammer events evaluation (including systems effect) ... and the CR and NUREG reports on the water hammer question." Please state the exact title and citation of each such report. Interrogatories on Contention 65 (Defective Base Mat) 65-1 (a). As used herein, a " deficiency" is a minor deviation from a procedure or specification which can be dispositioned on-site by Applicants; a "nonconformance" is a deviation from a procedure or specification, the disposition of which must be approved by the architect / engineer for the Harris Plant. Do you contend that there are deficiencies or noncon-formances associated with any of the concrete placements (pours) for the Harris Plant containment building [s] which will prevent those structures from performing their intended function? (b). If the answer to the preceding interrogatory is affirmative, identify each such alleged deficiency or noncom-pliance.
l (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 65. 65-2 (a). Do you contend that there are deficiencies or nonconformances associated with the Harris Plant containment building concrete placements for which Applicants have failed to take appropriate corrective measures? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to the preceding interrogatory is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 65. 65-3 (a). Do you contend that the Harris Plant QA/QC program is such that deficiencies or nonconformances associated with the Harris Plant containment building concrete placements could have gone undiscovered? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 65. l l
+ 65-4. Identify the source of information upon which you base your contention that Daniel . International "has a , history of .1uilding defective base mats and containments (e.g., Callaway, Wo.f Creek, Farley)." 65-5. Is your concern regarding the quality of the concrete construction of the Harris Plant containment and base mat based merely on the fact that Daniel International is the contractor for the Harris Plant? If so, have you examined the experience of other contractors for similar problems? 65-6. Identify the main determinants in concrete placements which could lead to the type of. concrete defi-ciencies discussed in your contention (i.e., voids over 1 inch in size"). Your answer should include a discussion of the influence of the structural steel design in the area of the pour. 4 65-7. Have you examined the structural steel design 6 and concrete placement reports for the Callaway, Wolf Creek and Farley plants as compared to the Harris Plant? If so, describe any similarities between those plants and the Hurris Plant. 65-8 (a). Do you contend that the alleged deficiencies associated with the containnent building concrete placements at the Wolf Creek Generating Station were of such a nature It s to prevent that structure from properly performing its intended l function? l ,i
,f _ - - ,_ . ,
c_-__ - - . , - - - . . - . . . , , . , , . , _ , , , , _ _ _ - _ . . , . ~ . , , _ _ _ , , .y.- - .,-. ,.__ .n, ,_-,-. %,mm , m, - _,, - - - . , - . , _ - ,
i (b). If :he answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 65. 65-9 (a). Do you contend that structural modifications were required as a result of the alleged deficiencies asso-ciated with the containment building concrete placements at the the Wolf Creek Generating Station? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support tnis allegation. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 65. 65-10(a). Do you contend that the alleged deficiencies - associated with the containment building concrete placements at the Callaway Plant were of such a nature as to prevent that structure from properly performing its intended function? I (b). If the answer to the preceding interrogatory is I affirmative, state in detail all facts which support this 1 allegation.
- (c). If the answer to the preceding interrogatory is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 65.
l l t
5 65-11(a). Do you contend that structural modifications were required as a result of the alleged deficiencies associa-ted with the; containment building concrete placements at the Callaway Plant? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation.
'(c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 65.
65-12(a). Do you contend that the alleged deficiencies associated with the containment building concrete placements at the Joseph M. Farley Nuclear Station were of such a nature as to prevent that structure from properly performing its intended function? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to (a) above is affirmative, do you contend that the NRC acted improperly in issuing an operating license for the Farley plant? (d). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 65.
65-13(a). Do you contend that structural modifications were required as a result of the alleged deficiencies asso-ciated with the containment building concrete placements at the Joseph M. Farley Nuclear Station? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 65. Interrogatories on Contention 75 (Clams and Marine Growth) 75-1(a). Do you contend that the Harris Plant cooling tower. basins are required for safe shutdown or cooldown of the reactors? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that the Harris plant cooling tower basins.are required for safe shutdown or cooldown of the reactors. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent l l with the allegations set forth in Contention 75. 75-2. State in detail all the facts which support your allegation that marine growth will possibly prove resistant to biocider Your answer to this interrogatory should include, l l l
l but not be limited to, a list of each and every type (as ! specific a name or description as possible) of marine growth, and a list of each and every type of biocide to which each marine growth will possibly prove resistant. 75-3(a). Do you contend that Applicants have not taken appropriate measures to control biological fouling of the condenser tubes and circulating water piping? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that Applicants have not taken appropriate measures to control biological fouling of the condenser tubes and circulating water piping. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 75. 75-4(a). Do you contend that Applicants have not taken appropriate-measures to reduce or prevent the entr,y of debris via the water intake? (b). If the answer to the preceding interrogatory is affirmative, state in detai,1 all the facts which support your allegation that Applicants have not taken appropriate measures to reduce or prevent the entry of debris via the water intake. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 75. i i
i 75-5(a). Do you contend that Applicants' monitoring I program to detect any introduction of asiatic _ clams into the . j i Harris Reservo__ is inadequate? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that Applicants' monitoring program to detect any introduction of asiatic clams into the Harris Reservoir is inadequate. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 75. 75-6(a). Do you contend that Applicants have failed to address or to take appropriate measures to prevent corrosion of the main condensers? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that Applicants have failed to address or to take appropriate measures to prevent corrosion of the main con-densers. 75-7(a). Do you contend that Applicants in designing the Harris Plant main condensers have failed to take into account possible pressure changes therein? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that Applicants, in designing the main condensers, have failed to take into account possible pressure changes therein. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 75. Interrogatories on Contention 80 (Mixing and Dispersion Models) 80-1 (a). Do you contend that the mixing models and dispersion models described in Section 5.2.2 of the ER are deficient? (b). If the answer to the preceding interrogatory is affirmative, state in detail all of the facts which support such allegation, including a detailed explanation of such deficiencies. (c). If the answer to Interrogatory 80-1(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 80. 80-2 (a). Do you contend that the mixing models and dispersion models described in Section 5.2.2 of the ER take-insufficient account of rainout? (b). If the answer to the preceding interrogatory is , affirmative, state in detail all the facts which support this allegation. (c). If the answer to Interrogatory 80-2(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 80.
80-3 (a). What do you consider to be the most limiting scenario of radiological release that Applicants ought to have considered? (b). Are the mixing and dispersion models described in Section 5.2.2 of the ER inadequate for consideration of that scenario? (c). If the answer to Interrogatory 80-3(b) is affirmative, state in detail all the facts supporting this allegation and explain specifically all alleged inadequacies. (d). If the answer to Interrogatory 80-3(b) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 80. 80-4 (a). Do you contend that the mixing and dispersion models described in Section 5.2.2 of the ER do not conform to the guidance of NRC Regulatory Guides 1.109 and 1.113? (b). If the answer to the preceding interrogatory is affirmative, state in detail all of the facts which support this allegation, including a detailed explanation of each way in which the models allegedly do not conform to such Regulatory Guides. (c). If the answer to Interrogatory 80-4(a) is other then affirmative, explain in detail how your response is l consistent with the allegations set forth in Contention 80. l 80-5(a). Do you contend that the mixing and dispersion models approved by the NRC in Regulatory Guides 1.109 and 1.113 are deficient?
(b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support this allegation, including a detailed explanation of the ways in which the models approved by the NRC in such Regulatory Guides are deficient. (c), If the answer to Interrogatory 80-5(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 80. Interrogatories on Contention 83/84 (Ch'emical Pollutantsl 83/84-1. State in detail all the facts which support your allegation that the discharges into the Harris cooling lake can and will interact to form carcinogenic compounds including I NCl 3, hcl , and NH Cl among others. Your answer 2 2 to this interrogatory should include, but not be limited to: (1) a list of each and every chemical which you contend will be discharged into the Harris cooling lake which can interact to form carcinogenic compounds; (2) a list of each and every chemical which you contend will be discharged into ths Harris cooling lake which will interact to form carcinogenic com-pounds; (3) a description of the chemical processes which take place in the Harris Plant which you contend will produce each of those discharge chemicals listed by you in answer to (1) and (2) of this interrogatory; (4) the concentration of each and every one of the discharge chemicals listed by you in answer to (1) and (2) of this interrogatory which you contend is required
8. i for interaction to form carcinogenic compounds; and (5) a list of each and every carcinogenic compound which you contend will i be formed by such interaction of discharges. ' L 83/84-2(a). For each and every carcinogenic compound listed in your answer to part (5) of the interrogatory above, l please provide (1) the magnitude and type of risk you contend each one poses to anyone swimming in the lake and the concen-tration of each compound which you contend is required to pose such a risk, and (2) the magnitude and type of risk you contend each one poses to anyone eating fish from the lake and the magnitude and the type of concentration of each such compound in the lake food chain which you contend is required to pose t such a risk. 1 (b). State in detail all the facts which support your answer to Interrogatory 83/84(a). 83/84-3. For each and every carcinogenic compound listed in answer.to Interrogatory 83/84-1, provide (1) the concentration of each which you contend will be put in the water supply for each and every downriver community which draws water from the Cape Fear River, and (2) the concentration of each which you contend will be put into river food chains and fish stocks (a) in the river, and (b) off the North Carolina coast where the Cape Fear enters the Atlantic Ocean. i
. . - - - - - - - . - - - . - , - , . . , , . - - - - - , . . - . - - - , - . - - - , -- , - - - c-,, . - ~ . . ,-.------...-. -. --, .--------,-,n -
83/84-4. State in detail all the facts which support your allegation that substantial amounts of organic chemicals in the Cape Fear River, including dyes and phenol-based ) i chemicals, become more carcinogenic and have reactions with 1 i chlorine, ammonia and hydrazine. Your answer should include, but not be limited to, (1) each and every organic chemical, dye and phenol-based chemical in the Cape Fear' River that becomes more carcinogenic after reactions with chlorine, ammonia, and hydrazine; (2) for each such chemical named provide the concentration of chlorine, ammonia, and hydrazine which you contend is required for a reaction which would cause that chemical to become more carcinogenic; and (3) a specific description of the chemical reaction itself which you contend will cause each such chemical to become more carcinogenic, including a list of each and every carcinogenic chemical which you contend will result from reactions of organic chemicals, dyes and phenol-based chemicals in the Cape Fear River with chlorine, ammonia and hydrazine. l 83/84-5. Please describe in detail the manner of testing for organic chemicals, dyes and phenol-based chemicals in North Carolina river waters which you would consider
" adequate".
83/84-6. State in detail all the facts, other than those contained in your contention, which support your allega-tion that neither Applicants nor anyone else has considered the
&ctual levels of numerous organic carcinogens in Cape Fear water, nor considered the interaction of these carcinogens and other chemicals with Harris Plant discharges and consequences thereof.
l l 1 83/84-7. State in detail all the facts which suppect your allegation that interaction of Harris Plant discharges i with metals contained in the Haw and Cape Fear Rivers will l chemically mobilize those metals so they will be more readily absorbed by living creatures in the food chain in the Cape Fear River areas and Atlantic Ocean near the Cape Fear River discharge point. Your answer to this interrogatory should ( include, but not be limited to, (1) a description of what is l meant by your use of the term " mobilize", (2) a list of each and every Harris Plant discharge chemical which you contend will mobilize chemicals in the Haw and Cape Fear Rivers; (3) each and every chemical in the Haw and Cape Fear Rivers which you contend will be mobilized by interaction with Harris Plcut discharge chemicals; (4) the manner in which you contend this mobilization will take place, including specific chemical reactions, and the concentration of each and every such chemical listed in answer to (2) and (3) above required for such mobilization to take place; and (5) a list of each and every living creature in the Cape Fear and Atlantic Ocean food chans (at the Cape Fear mouth) which you contend will more readily absorb such chemicals once mobilized.
l 83/84-8. For each and every mobilized toxic metal identified by you in answer to the interrogatory above, state in detail all the facts which support your allegation that Applicants have not properly analyzed or taken into account the health effects of that particular metal in drinking water, washing water, bathing water and food on humans. Interrogatories on Contention 132 (Reactor Vessel Level Instrumentation System) 132-1. Westinghouse has developed a Reactor Vessel Level Instrumentation System ("RVLIS"), suitable for installation in operating plants and plants under construction, to meet the recommendation of Item II.F.2 of NUREG-0737 (TMI Action Plan) for additional instrumentation to detect inadequate core cooling. The RVLTS is designed to provide a relatively simple and straight forward means to monitor the water level in the reactor vessel, and serves to provide additional information to
'ane operator during accident conditions. The RVLIS utilizes differential pressure (d/p) measuring devices to indicate water level and relative void content of the circulating primary coolant system fluid. The NRC Staff's review, which accepts the Westinghouse RVLIS, is reported in NUREG-CR-2628. If Applicants commit to install the Westinghouse RVLIS at SHNPP, is your Contention 132 satisfied? If not, explain in detail the basis for the answer.
132-2. If Applicants commit to install the Westinchouse RVLIS at SHNPP, will you voluntarily withdraw Contention 132? If not, explain in detail the basis for the answer.
REQUEST FOR PRODUCTION OF DOCUMENTS Applicants request that Intervenor Wells Eddleman respond in writing to this request for production of documents and produce the original or best copy of each of the documents identified or described in the answers to each of the above interrogatories, at a place mutually convenient to the parties. Respectfully submitted, M/ 1 M * // CeVrge S. TroWbridge, F.C. Thomas A. Baxter, P.C. John H. O'Neill, Jr. Shaw, Pittman, Potts and Trowbridgei 1800 M Street, N.W. Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Dated: January 31, 1983
Fediral Register / Vol. 48. No.15 f Friday, an ry 21.1983 / Ruins and Regulations 2729 - h,. . . tf y h Is f2i demand in regultted fresh channtis is expected to require about 56 percent of artsurem:nt at a right angis to e - m .rketing policy wts recommended by straight line runmng from the stem to the the committee following discussion at a this volume. The remaining 44 percent blossom end of the fruit. - public meeting on July 6.1982. The j ifng committee met again publicly on ps s* would be available for utilization in (Secs.1-19,48 Stat. 31. as amended; 7 U.S.C. January 18,1983, at 1.os Angeles. l 8 export and processing outlets. The e01-474; California, to consider the current and
). committee indicates that volume and size composition of the crop of navels -
Dated: January 17.1983. D. S. Kurylooki. prospective conditions of supply and h r; are such that more than ample supplies demand and recommended a quantity of e Deputy Director. fruit and vegetable 4 of the more desirable larger sizes will be Division. Agneultum1MarketmgService. Iemons deemed advisable to be handled ed ,. during the specified week. The p available to satisfy the demand in regulated channels. The committee also p ,_
. , , , , , __g comnuttee reports the demand for lemons continues easier.
reports that when more than ample nts U supplies oflarger sizes are available for It is further found that it is
-impracticable and contrary to the public fOf 0
f shipment. disposition of the sizes which would be eliminated by this regulation 7 CFR Part 910
.. interest to give preliminary notice,
[ Lemon Reg. 3951 engage in public rulemaking, and can be accomplished only at a substantial pnce discount and this tends postpone the effective date until 30 days Gm M Mhw after publication m the Federal Register g< to depress the market for all sizes. Naval m MhWMM (5 U.S.C. 553), because of insufficient
;j oranges failing to meet such b requirements could be shipped to fresh Ansucv: Agricultural Marketing Service, time between the date when information export markets,left on trees to attain USDA. became available upon which this Y regulation is based and the effective k further growth. or utilized in processing. AcTiosa: Final rule.
in those circumstances, elimination of date necessary to effectuate the sizes smaller than those specified is sussesAny:This regulation establishes declared purposes of the Act. Interested appropriate in the interest of producers the quantity of fresh California. Arizona persons were given an opportunity to and consumers. lemons that may be shipped to market submit information and views on the It is further found that it is- during 'he period January 23-29,1983. regulation at an open meeting. It is impracticable and contrary to the public Such action is needed to provide for necessary to effectuate the declared interest to give preliminary notice, orderly marketing of fresh lemons for purposes of the Act to make these eng:ge in public rulemalring. and the period due to the marketing situation regulatory provisions effective as postpone the effective date until 30 days confronting the lemon industry, specified, and handlers have been
,.- after publication in the Federal Register spenCTIVE DATE: January 23.1963. apprised of such provisions and the
'. (5 U.S.C. 533), because ofinsufficient pon ruemesa moonesATeoes contact: effective time.
time between the date when information William J. Doyle. Chief. Fru u3 ranch. I.ist of Subjects in 7 CFR Part 910 became available upon which this F&V. AMS, USDA. Washington, D.C. 1' Marketing agreements and orders, regulation is based and the effective 20250 telephone 202-447-5975.
- p date necessary to effectuate the suppe.seesnTAny eseromsATiosc This California. Arizona. I.emons.
. 1 declared purposes of the act. Interested fLial rule has been reviewed under 5 l persons were given an opportunity to PART 91HAMENDEDI Secretary's Memorandum 1512-1 and submit information and views on the Executive Order 12291, and has been Section 910.895 is added as follows:
regulation at an open meeting. Handlers designated a "non-major" rule. William 7 . have been apprised of such provisions T.Manley, Deputy Administrator. I me.ses Lemon M 395, and the effective date. Agricultural Marketing Service. has. The quantity oflemons grown in' determined that this action will not have. California and Arizona which may be Ust of Subjectsin 7 CFR Part 937 a significant economic impact on a handled during the period January 23 Marketing agreements and orders, substantial number of small entities. 1983, through January 29,1983. is California. Arizona. Oranges (Navel). This action is designed to promote established at 180.000 cartons. orderly mari.4 ting of the California- (Secs.1-ts. 4e Stat. 31. as amended:7 U.S.C. L PART 907--{ AMENDED] Arizona lemon crop for the benefit of e01.e74) llierefore.1907.880 is added to read producers, and will not substantially Deted: January 2o,1983. as follow: (g 907.800 expires March 24, affect costs for the directly regulated D. S. Kuyinsid. i 1983, and will not be published in the handlers. DeputyDiivetor.Muit and Vegetable annual code of Federal Regulations): This finalrule isissued under gj,j,j,,,3,ycultum/MarAecog Service.
-Marketing Order No.910, as amended (7 * * * " " " "
I E8ee Mond orange regWedon 500. CFR Part 910: 47 FR 50196), regulating ' " ' " * * * * * * * * ' " (s) During the period Janaury 21,1983. the handling oflemons grown in ) through March 24.1963. no handler shall California and Arizona.The order is 1 handle any navel oranges grown in the effective under the Agricultural production area which are of a size Marketing Agreement Act of1937, as NUCl. EAR REGULATCRY I q smaller than 2.32 inches in diameten COMMISSION amended (7 U.S.C. 001-674). The action Provided. that not to exceed 5 percent. is based upon recommendations and v 16 Part M l by count of the oranges in any information submitted by the I.emon h h container may mcssure smaller than Admmistrative Committee and upon EnvironmentalQueMcation W Elec W +32 inches in diameter. other available information. It is hereby Equipment " ' " Sa f (b) As used in this section. " handler". found that this action will tend t Nuclear Po l
,, handle , and " production area" mean effectuate the declared policy of the Act. l the same as defined in the marketing This action is consistent with the Acancy: Nuclear Regulatory '
order. Diameter shall mean the largest marketing policy for 1982-83.The Commission. i l i l x _ .
. 2730 . Federal Register / Vol 48, No.15 rid %y, January 21. 1933 / Rults and Reguilti:ns i
ScT10ec Final rub. Tha NRC h s used a viristy of .requiremints of NUREG-0588, which m1thods to ensure th:t thrse genrral supplanent tha rec:mmanditions of ans sussesAny:The Commission is amending requirements are met for electric apply to equipment qualified in its regulations applicable to nuclear equipment important to safety. Prior to accordance with IEEE 323-1974, apply ta power plants to cianfy and strengthen 1971, qualification was based on the fact nuclear power plants for which the j the criterfa for environmental that the electric components were of construction permit safety evaluation qualification of electric equipment ' high industrial quality. For nuclear report was issued after July L 1974. i important to safety. Specific ' plants licensed to operate after 1971 Category II requirements, which qualification methods currently qualification.was jud.ed on the basis of contained in national standards, supplement the recommendations of and IEEE 323-1971. For plants whose Safety apply to equipment qualifiedin , regulatoryguides, and certain NRC Evaluation Reports for construction- accordance with IEEE 323-197L apply to ! publications for equipment quaHScation permits were issued stoce July L 1974, nuclearpowerplants for which the have been given different interpretations the Commiselon has used Regulatory construction permit safety evaluation and have not had thelegalforce of an Guide Lao "Quaufication of Class 18-agency regulation.%is amendment report was issued prior to July L 1974. Equipment for Light-Water-Cooled' In CLI-ao-21, the Commission stated codiBes the environmecital quahfication Nuclear Power Plants," which endorses methods and criteria that meet the that unless there were sound reacons to IEEE 323-1974,*"IEEE Standard for the contrary, replacement parts should Comminaion's requirements in this area. Qualifying Class IE Equipment for be quallfled to the standards set forth in EPPECTIVE DATE Fecruary 22,1983. Nuclear Power Generating Stations," Category I of NUkEG-05a8 or IEEE 323-Pos PuerrHER NsPonstAU006 COerrACTr subject to supplementary provisions. 1974.De Commiazion reafBrms that Satish IC Aggarwal.OfBee of Nuclear Currently, the Commission has under posidanin thh r'il- -Wi- Such way a-program to reevaluate the -
. Regulatory Research. U.S.Nuclaar '
qualification constitutes complicnco Regulatory Commi== ion. Washington, quaHBcatimof electric equfpment in,all with the provisions ofparagraph D.C. 20555, Telephone (301) 443-6948, operating nuclear power plants. As a 50.49(1). De Commission's position is-
- summerrany upOmaAnost
[ta bvire=== nth cation u th nvi n n Previous Nodos of electric equipment important to safety quanacadon andreHabuf ty dinstaHed On January 20.19s2.NRC =Mi=h-d in have been deveolps,ni by the NRC. A ekctric equipment. Situadons may arise. theFederalRegiseura notice of dar===nt endtled Guidelines for however in which such upgrading will 9 proposed relamaldag on environmental Evaluating Environmental QualiReation not be feasible or compatible with qualf8mtion of electric eqnipment for , dClass 1E t
, overall plant safety. Licensee must nuclear power plants (47 FR 2878). no . Operadng p ,,I review each situation on a case-by-case comment period expired March 211982. wasissued n ovember197E In basis to determine that " sound reasons addition. the NRC has issued NUREG-A total of 80 commant letters raising 10 to b contrary" do exist to justify an '; maior issues were received by April 6. O5aR tterim S6sma on exception imm upgrading. Examples of
- 1982. An additional 10 cmament letters Envimamental QuaHScadon o,,f Safety- acceptable "$ound reasons to the were received by April 2L 1982. but no new issues were raised.The major
, f** ,, , ["I ,,,
, contrary" Guide 1.a8.
will be included in Regulatory pj ,ts reviewed in acco ce
., issues are discussed below. ne dates spec Sedin this rule for l Nature and Scope of the E'- ' L- p to in accordance with """Ej"Hond
' at
- Nuclearpower plant equipment important to safety apply to all!!censees important to safety must be able to g
. ' perform its safety functions Coo.sM M da and applicants a id supersede any date Cosnn'i g previously i==-d No changes to itsinstalledlife.His r=W. stis pmceed wi& a reismaldng a licenses or technical specifications are embodied in General Design Criteria 1. necessary to reflect these new 14s and 23 of Appendix A. " General envimnmental quaH8 canon d safety-rela e and to a completion dates.
Design Criteria forNuclear power . die aho The scope of the Baal rule covers that Plants." to 10 CPR Part 50. " Domestic 9" biat tha. DOR G delines and portion of equipment important to safety Licensing of Produedan and UtilizatPm commonly referred to as " safety. Facilities"; in Criterion III. " Design NUREG-osas form b bash for b
- Scansees and 11 related"(which the Commisalon Control.", and Criterim Mut '"Ymeet
,us jtil the miemaldn has interputs as asentiaHy " Class 1E" Control,, of Appendix B. "Qualfty e9uipment dannad in IEEE 323-1974).
Assurance Criteria forNuclear Power hd.Dh M bad on 6e and nonsafety-related electric Plants and Fuel R.g - 1 Plants, to QG,,uil,dehnos g,,,,,,,, ,,'a recognhos and NUREG-05as.The b quuBeadon equipment whose failure under to CPR Part 3R andin paragraph efforts of the industry as a result of CLI- postulated envuunnetal condidons a um(h) of10 CFR Part 50. which could prevent the satisfactory incorporates by reference IEEE 279- 80-21. Herefore, the rule provides that 197L 5 " Criteria for Protection Systems requaliHcation of electric equiE ont will acconipushinent dmqmrsd safety H functions by safety-related equipment. for Nuclear Power Generating Stations." {0t g embeMmqmrod opera fornu at Safety-related structures, systems, and His .wo-oent is applicable to components are those that ar s relied equipmentlocatedinside as wellas plets mviousi mquired by outsido the containment. NR o eq fp in accaduce upon to remain functional during and with DOR Guidelines or NUREG-0588 f Ilowing design basis events to ensure (CategMy I or II). CategoryI N die integrity of the reactor coolant
'Incorporados by refo'wtoe appromi by tlw Director of the OfBee of Federal Reipater on Jensary pressure boundary. (ii) the capabihty to 1.19e2. Coppe may be obtamed fmn the Insutute of 'Copwe may be obtained fmn the InsWtute of shut down the reactor and maintain it in sectncal and Escoomca Ensneers. Inc M6 East Doctncal and Electromca PP-=*e. Inc.,345 East a safe shutdown condition and (in) the 47th Street. New York. N.Y.10017. 47th Street. New York. N.Y.10017. capability to prevent or mitigate the 1
i
, \,,
. Federal Register / Vol. 48. No.15 / Friday, January 21, 1983 / Rults and Regulztions 2731 t
? l; consequences of accidents that could equipment must be submitted by May industry's qualification effort. most and ' result in potential offsite exposures 20,1983. certainly introduces sigmficant neve comparable to the guidelines of10 CFR The general requirements for seismic costs and obligations with no ly ts . part 100. Design basis events are defined and dynamic qualification for electric demonstrated improvement in safety.
as conditions of normal operation. equipment are contained in the General Response: Regulatory requirements in n ;
Design Criteria and we not included including a'2ticipated operational effect at the time of!! censing of the t occurrences; design basis accidents; within the scope of this rule. Further majority of operating reactors did not i extemal events: and natural phenomena guidance is provided in Regulatory require that all electric equipment and
""d for which the plant must bulesigned to Guide 1.100. " Seismic Quahfication of systems necessary to bring the reactor
- E; ensure functions (i) through ;ul) above. Electric Equipment for Nuclear Power to cold shutdown be classified as safety TD -
~
Also covsredin the scope of the final Plants." (Revision 1) and NUREG-0800. related. However, electric equipment F rule is certain postaccident monitoring " Standard Review Plan." NRC is and systems necessary to shut down the l
- equipment specified as " Category 1 and considering future rulemaking reactor and maintain it in a safs
- ."in Revision 2 of Regulatory Guide concuning mquirments for *he shutdown condition are required to be ed envimmental quahncation of electric , classified as safety related and therefore 1.97. " Instrumentation for Light. Water-
' equipment important to safety and the are covered by the rule.
jd Cooled Nuclear Power Plants to Assess plant and Environs Conditions During requirements for seismic and dynamic no Commissionis currently studying k and Following an Accident." Included in the final rule are specific quaufication of electric equipment.
-'= On no Proposed Rule -
the requirements for shutdown decay heat removal under Unresolved Safety technical requirements pertaining to (a) He Commission received and Ism NSI) A-45. no aman purpose of qualification parameters. (b) considered the comments on the A-45 is to evaluate the adequacy of qualification methods. anu (c) proposed rule contained in the 6e letters current licensing requirements to ensure . documentation. Qualification received from the public by April 6. that failure to remove shutdown decay parametera include temperature. 1982. Copies of those letters and a staff heat does not pose an unacceptable risk. pressure. humidity, radiation, chemicals. response to each comment are available Under A-45 a comprehensive and d and submergence. Qualiacation for public inspection and copying for a consistent set of shutdown cooling ise, methods include (a) testing as the fee at the Commission's Public requirements for existing and future 11 principal means of quahfication and (b) Document Room at 1717 H Street NW plants is being developed.The final analysis in ca.sbination with partial Washington, D.C. technical resolution of A-45 is presently type test data or operating experience. De msforissues raised by the scMuled for October 1964. se The final rule requires that the comments and NRC staff responses are. The Commission believes it would be a~ quaufication program include , as follows: pmmture at this time to impose the - synergistic effects, radiation. . . requirement to environmentally qualify UlS8NUC CRdUyDam C electric equipment and systems if environmental conditions and margin h M48(c) considerations. Also, a record of QU31/fical/08-A2tu8mP necessary to achieve and maintain cold
>ry quahfication must be maintained. Issue: Seismic and dy:mmic shutdown prior to the final resolution of Proposed Revisic21 to Regulatory qualifications are an in**gral part of A-45. Derefore, this requirement is not Cuide 1.30, whie.h has been Jsened for environmental qualific.ation. It is . included in,the final rule.
public comment, describes methods therefora inappropriate to codify these 4/ Scope EppmentinaMild acceptable to the NRC for meeting the i.wd. ents separately. Envimnmcre L+ph24s(b) a provisions of this rule and includes a list Response Electric eculpment at i of typical equipment cova'ed by it g ersting nuclear power plants was - Iseus ne rule makes no distinction Revision 1 to Regulatory Guide 1.as will generally quaufled for environmental between equipmentlocatedin a harsh beissued after resolution of public - and seismic stresses separately. Le by or mild environment. The stresses for comments. using separate prototypes for equipment in a mild environment are -
' NRC will generallYnot accePI environmental and seismic quahfication less severe than for those in a harsh tests. The Commi== ion has decided. environment.
et analysis alone in lieu of testing. ty after considerable deliberation, to Response:The finalrule does not erfence has shown that gna (Mention pursue the issue of seismic and dynamm cover the electric equipment located in a equipment without test data may not e sd to to dem qua!!ncation separately at a future date. mild environment.no Commission has tra uncu n ty during mn A future seismic rule may not require concluded that the general quality and onditions. Parsgraph 50.49(f) provides mteg fwhammal em survedanca rimo.. ents applicable to because a single prototype was not used electric equipment as a result of other ur methods for quaufication. Testing during the original quahScadon. Also. Commi== ion regulations, including 10 WiU be pufernd. To ense integrity of CFR Part 50. Appendix B (see for a testing program, the Commission the Commi==fon has concluded that protection of electric equipment example. Regulatory Guide 1.33, 8xpects eat de same piece of impartant to safety against other natural "Quahty Assurance Program equipment will be used throughout the phenomena and external events should Requirements (Operatiou)." Revision 3) complete test sequence. not be within the scope of this rule. are sufBcient to ensure adequate De finalrule reqmres that ea :h performance of electric equipment holder of an operating license provide a 4/ Scope-ColdShutdown important to safety located in mild list of electric equipment important te Requuement-Parugmph 248(b) environments. Since it has been safety within the scope of this mle Issue: ne rule introd. aces a new concluded that no further environmental [ previously quahfled based on testing, requirement to qualify " equipment qualification requirements are needed
)
analysis, or a combination thereof, and needed to complete one path of for such equipment provided they fully 2 a list of equipment that has not been achieving and maintaining a cold satisfy all other applicable regulations.
,4 4ualified.These lists and the schedule shutdown condition." A change of this the Commission has determined that no 6
for completion of qualification of electric magnitude, at this advanced stage of the additional requirements are necessary
'l
2732 Federal Register / Vol. 48. Nm 15 / Friday Janu:ry 21. 1983 / Rulis cnd Regul:ti:ns with respect to electric equipment (s) Analysis andponialtest dota- ths Commission hereby certift:s th:t important to safety located in mild Phregmph 50.m(f)(d) this rule will not have a significant environments in order for !!censees to Issue:If partial type test data that - ecmmic impact a a substandal satisfy, with respect to such equipment, adequately support the analytical number of small entities. This final rule i existing license condition + or technical affects the method of qualdication of ! assumptions sad conclusions are specificetions calling for qualification of available, their analysis should be- electric equipment by utilities. Utilities i safety.related electnc equipment in allowed to extrepolate or interpolate do uot fallwithin the de8aidon of a accordance with DOR Guidelines or these results for equipment, regardless small business found in Section 3 of the NUREG-05as. Small Business Act.15 U.S.C. 831 of ur. base date.
'8pase h Camissim agrees. In addition. ' utilities are required by (4/ Scope-Previous Qualificadon Reference to " purchase date" has been the Commission's Me norandum and Efforts-Phragraph Sam (&f Order CI.MN1. dated May 23.1980 to deleted.
ts contained in the Issue:& rule does not recognise that meet the ._ - plants have completed qualification of "N'8 8"#"'I/N'"" DOR " Guidelines for Evaluating equipment to the DOR Guidelines or l#lD""s"a*4// Agnsph Environmental Quali8 cation of Class 1E NUREG-osas. Without such recognition. Issus:%e requirement for a central Electrical Equipment in Operatinct industry efforte, manpower, end biHions file shceld be deleted since it is not cost Reactors(November 1979) and of dollars will go down the drain. effective and has no safety trenefit. NUREG-0588 " Interim Staff Positym on Response:The Co==i==iaa agrees. Environmental Quali8 cation of Safety-Response:& Bnalrule has been expanded to aHeviate this concorm See This 4 '. -- t has been subject to Related Electrical Equipment." which ' different interpretations. A record of form the basa of this rule. Paragraph snee(k). qualification must be maintained in an Consequently, this rule codifies existing (5) Humidity 4memyh sam (e)(21 "auditable form" but not necessarily in requir:,ments and imposes no new costs a central Sla for the entire period during or obligations on utilities. hh effect of N ' -- 4==t - which the covered item is installed in a l variations of relative hunddity during nuclear power plant. Recordkapms IJst of Subjectsin10 CFR Part 50 normal operation cannot bm==hiared requirussent of 10 CFR Part Appendix B for ag " bre are no detaHM Antitrust. Classified informadon. Fire mut be met. Certain records can be orevention. Intergovernmental relations i standards for how thiatype of testing kept at the vender's shop. Nuclear power plants and reactors. i should be performd. , (20)fusdffcudors ofcarrdaued operadon Penalty Radiation protection. Reactor Response: The Commi== ion agrees. siting criteria. Reporting requirements. Humidity variation during normal foroPerotingp/onts, laeue:'Ihe requirement to submit Pursuant to the Atomic Energy Act of
- operation are difBcult to predict. It has not been demonstrated that the time, 1954, as amended, the Energy . justificadon for the condnued operation of operadas plants should be deleted Reorganisation Act of1974. as amended. , dependgnt variation in humidity will -
produce any differences in degradadon since this information has been and secdon 553 of title 5 of the United' i of electric equipment.De words " Time- previously submitted to NRC. States Code 10 CFR Part 50 is amended dependent variation of relative" have Response: His i_W. - =t has been as follows:
- been deleted from Paragraph sade(e)(2). sati=Ame'arily met and Paragraph 50.4e(J) of the proposed rule has been deleted in PART ssW(ARIENDED)
=~e"*"#48f*ll81
'f . (81 Aew.__ _ its entirety from the Snal rule. 1.h authority citation for Part 50 Issue:'11 e requirement that ongoing m addition. Paragraph 50.4e(s) of the condans to road as foHows-q==linnatic ?s be done using i .;.;, proposed rule has been deleted from the Saal rule since it is too prescriptive.it A"8hmim seas.tas.104. tot, tar.tas.taa equipment ratually aged"is overly tea as seat ma ar. 9m us, eso, saa, set as restrictive. Use of accelerated aging to willbeincludedin Ragulatory Guide ---i-f sec. 234, as stat.12n as ===-i-i define a qualified life is not *=A=ie=11y 1.ae.
. E#sede DauerDie rule replaces the (a UAc un 2:34.2m 22n 22n 22n Jessible. " 22sm 22mk seas. m 2nz. ma as seat.1242.
"interta rula" publI=h-8 in the Federal tan t2n asw----<-i (4 UAc seet, ses2.
Response:Proconditioning by Registerom Jam 3E 1982 (47 FR 2ases). seest, unless otherwise nr.+ed. accalarsted aging is technically feasible le electric equipment for plant De laterim rule" ===p=uad Secdos sa7 aise issued under Pob. I. SS-for emir =====*=3 quaHBeadbn deadlines for complex electric equipment est, sec. ta se stat.2sst (4 UAc sent). life ' a=*=*==d in license a==dn'sa== or sectica sara mise issued under sec.122. as for a shorter designeted life.N technical spectScations of operating stat. as (a UAc 21sa). Sections saso ac.st r a==i==ia= recognises that state-of. art else issued under sec. tea, en stat. es4. as plants. On the effective date of this rule technology will be utilised in any aging (em abon), the "interta rule"is ====i= i (4a UAC 22se). Sections so.too. Reference to quallflod life has lated from paragraph 50.4e(e)(5). supWand the =^=d=Im for Sata mise issued under sec. taa as stat. ses : enviromaantal q==liflaation contained in (4a UAc 22 ssp.
.,A sads(e)(8/ this rule takes effect f6r all plants. For the purpoose of sec. 2R eS stat 958. as (7)Me gic ., m 4 amended (a UAC 2273). H 50.10 (a). (b).
Issue:De margins applied in addition Paperwerk ah Act and (c), san so.4a. snes, sas4. and saso(al to known conservatisms lead to are issued under we, telb. et stat. s48 as De Snal rule contains information excessive strees that could lead to collecdoni L =ts that have been ===i 1(42 UAC 2201(bil: H 50.10 (b) and (c) and so.se are (seued under sec.1sti, as failures of equipment in unrealistic approved by the OfBce of Management qualib'ation tests. and Budget: OMB approval numberis stat. on as =w-i (4a UAc 22mm and < H sass (e). saseN. sara sart. sarz. and Response: Tim Commission agrees. 3150-0011. Sa78 are issued under sec. teto. Se stat. 9so, his requirement could have caused Regulatory Flexdmilty Statement as amended (42 UAC .201(o)). excessive margma.The paragraph has been modified to recognize In accordance with the Regulatory 2. Section 50.49 is revised to read as conservatisms that can be qualified. Flexibility Act of 1980. 5 U.S.C. 605(b). follows:
~
Federal Register / Vol. 48. Ns.15 / Frid;y, Janunry 21. 1981 / Rules and Regulttions 2733 ==-. 1-(d)Tbpplicant orlicensee shall equipm:nt.!f preconditioning to an end-lt t ,i.So.as ectric EEA- _m quanfleetion
= Important to safety for of prepare a list of electric equipment of-installed life condition is not nucrear power pianta. important to safety covered by tMa practicable, the equipment may be section. In addition. the appEcant or preconditioned to a shorter designated p * (a) Each holder of or each applicant for a license to operate a nuclear power licensee shallinclude the following life. The equipment must be replaced or i
d mformation for this electric equipment refurbished at the end of this designated %,s -iant shall establish a program for F important to safety in a qualification life unissa ongoingqualification qualifying the electric equipment defined in paragraph (b) of this section. file: demonstrates that the item has , th2 L (b) Electric equipment impfortant to (1)De perfor:'sance specifications additionallife. L safety covered by this section is: - under conditions existing during and (e) Sabotergence(If subject to being (1) Safety-related electric equipment
- followmgdesign basis accidanta, submerged). -
r Tla equipment is'that relied upon to (2)The voltage. frequency load, and (7) Synergistic Effects. Synergistic 'b. g' l remain functional during and following other electrical charactenstics for which effects must be considered when these b design basis events to ensure (I] the the peeferiune= specified in accordance effects are believed tn have a significant integnty of the reactor coolant pressure with paragraph (d)(1} of this section can e,ffect on equipment performance. i1E , boundary. (ii) the capability to shut be ensured. (8) Margins. Margins must be applied down the riractor and maintain it in.au. (3) %e en. - - -'=1 eaadiHaa= to account forunquantified uncertainty, ineW temposeture. pressure. such as the effects of production safe shutdown condition. and(lii) the Ina capsbility to prevent or mitigate the humidity. radiation. ch==irmla, and variation 1 andinscenracies in test consequences of accidents that could. submergene= at the locatinn where the instruments.These maripna are in [* l result in potential offsite ewosurea equipment must perform as pcmad in addition to any conservatisms applied l comparable to the 10 CFR Part 100 . accordance with paragraphs (d)(1) and during the derivation oflocal gj gunielines. Design basis events are (2) of this section. enetranmantal conditiona of the equipment unless these c====rvatisms
; defined as conditions of nnrmal (e) The electric equipment operation. including anticipated qualification program must include and can be quantified and shown to contain operational occt.rrensee, design basis be based on thefollowmg: appropriate margma.
accidents, extemai events, and natural (1) Temperature andPhrseure. The (f) Each item of electric equipment g important to safety mast be qualified by phenomena for which the plant must be time dependenttemperature and '" designed to ensure functions (II through pressure at the laestian of tha electric. one of the follouangmethodz (iii)of this paragraph. equipment 14mi 4 to safety amatbe (1) Testing an identicalitem of ,- (2) Nonsafety-refated electric established for the most severe design equipment underidentical conditionc or 8- equipment whose failure under basis accidentdunngor following which under similarconditions with a of postulated environmentalconditi na this equipment is required to remain supporting analysis to show that the could prevent satisfactory Wa*=L equipment to be qualified is acceptable. ed. - accomolishment ofsafety functions (2)11aasddy.Hanuditydarms damign (21 Testing a similaritem of equipment
' specified in subparagraphs (1) through besis accidents must beconsidered. with a supporting analysis to show that led :
ital of parsgraph (b][1) of this section by (3) Chemical Effects. He composition the equipment to be qualified is he safaty-related equipment. of chemicale used must be et least as ecceptable. (3) Certain post-accident monitoring severe as that resulting froar the most (3) Exponence with identicalor equipment.* limiting mode of plant operunion (e.g. sindar equrgment undersundae (c) Requirements for (1) dynamic and containm=nt spray, emergency core conditions with a ..pymiiug analysis to seismic qualification of metric cooling, or recirt: detion fkour show that the equipment to be goal 15ed equipment important to safety. (ii) containei=nt samp). If the composition is acceptable. protection of electric equipment of tfie charnicet sprey curr be affsened by (4) Analysisincombinationwith
** important to safety against other natural equipmentmalfbuctions themeet partial type test data that supports the phenomena and external events, and severy chemical sprey environment that analytical assumptions and conclusions.
(iii)eunm- ; :quahffcatienof resulty from a singfu failure in the sprar (g) Each holder of an operating license electric equrpment innportant to safwT sys enrmustbeessamed. Issued prior to February 22.1983, shall. - Jocated in a mild environment are not (4?Rochoriorr.The radiation by May 20.1983. Idantify the electrte meluded within the scope of tfris section envfranment must be based on the type
- egnqnn==t important to safety withm A mild environment is an environment of radiation, the total dose expected the scopeof thissection already that would at no6 time be significantly duringnonnaf operatfoeover the quidified and submit a schedule for s1 = more severs than the environment that installedlifle of tfm equipment, and the either the qualification to the provisions would occur during normal plant radiation envir=wn=nt associated'with of this secties or for the reptar==e it of operation. including anticipatad the most severe design basis accfdent the r=====g electne equipment opetinal occurrniema- during or fbDowingwhich the equrpment important to safety within the scope of n
le required ta r=nnirr functional. this section.This schedule must L ,, D N $ , M Y ,"mC y"' including the radiathm s..Jiius fitnn establish a goalof final environmental qualification of the electric equipment 3 f of tht: t.edent = y tman.* -4 Ema t r , recirculating finide forequrpment t of c.ctricalandm coomemansmeare las ses, locatad near the recuculating lines and within the scope of this section by the East 47th Seest.New York. NY lost 7. Includingdose-rate effects. end of the second rwfueling outage after d [n N D ,, T,,,, d Y M s (5) Aging. Equipment qualii%i by test March 31.1962 or by March 31.1985, must be pseconditioned bynatural or whicheveris eadier. The Director of the [ of Regulatory Code 1.sr. "taso=====*arta= for IJebs,. Water Cooled Nucteer Power Plants to A.sses Plant artificial (accelerated) agmg to its end- Office of Nuclear Reactor Regulatory j and Enytrans Conditions Dunns and Followme as of. installed life condition. Consideration may grant requests for extensiona of this
^' " t oot N M Noc.'.f7 M o 7c N o".r.," must be given to all sigmfi . ant types of deadline to a date nolater than cocen.nt wa=,-a.nt aranch, w unnstos, oc degradation which can have an effect on November an. isas, for specific pieces of 2 553- the functionalcapability of the equipment if these requests are filed on r
I i i 1
^~ ~
"2734 ' ~
4
~ Federal Register / Vcl. 48. N$.1S / Frid y. January 21 1983 / Rules and Reg
*. a timel? basis and demonstrata good (k) Applicants f;r and holders cf cause for the extension, such as Co==imaion's hadqu.rtirs office. Th
- procurement lead time, test operating licenses are not required to
' Co==iasion is amending regulation courslications, and installadon requalify electri:: equipment important i140.1 to clarify that there is no problems. In exceptional cases, the to safetyin accordance with the me !. provisions of this section if the distinction between its Commission itself may consider and physi location and mailing addresd j grant extensions beyond November 30. Commission has previously required ! qualification of that equipmentin he sole address of the Commission'sI I 1968, for completion of environmental headquarters omce as of January 18. qualification. accordance with " Guidelines for 1983 wt!! be 2033 K Street. N.W., Evaluating Enviromnental QuallScation Washington. D.C. 20581. (h) Each licensee shallnotify the ca==ianian of any signi8 cant of Class 1E ElectricalEquipmentin Operadas Reactors." November 1979 The ca==ianian is amending mg'dation 140.2 to reflect the fact that equi; ment qn=lineation problem that (DOR Guidelines), or NUREG-0588 may require ex*===ian of the completica Conunset version),"Interta Staf (For the Western Regional omce of the ! date provided ni accordanceivith ra==i=iaa has moved from San paragraph (g) of this section within so Position on Envirummental Qualificaden Fr=aciaaa to 20080 Wilshire Boulevardj days ofits discovery. ' of Safety Related Electrical Equipment." Suite 510. Los Angeles. California 90024 (1) Replacement equipment must be (1) Applicants for operating licenses qualisedin accordance with the The telephone number for general that are to be granted on or after information is (213) 20ew.6783Jin February 22.1983. but prior to November provisions of this section unless there addition, regulation i 140.2 is being , i are sound reasons to the contrary. ! 30.19es. shall perform an analysis to ===adad to nots the Southwestern ensure that the plant can be safely Dated at Washteston. D.C. this 17th day of RegionaloSco has moved from Room Jasmary. seen. opereted pend. ing completion of -20s to Suite 400 at 4eet Main Street, equipment q==31nandon required by this yor the Nuclear Regulatory ca==d-daa Xansas City. Missouri 64112.& section.Ris analysis must be submitted sammell.( m . telephone number forgeneral to the Director of the OfBce of Nuclear g c ,,,,,,,,,,, informaden remains (816l 374-5425. Reactor Regulation for consideration 3'"""*""***"""I Certain other provisions of the prior to the granting of an dag f'a==iamiaa's reguladons contain t he==== and must include, references to or addresses of the appropriate, an==ad-stion afh ra==i=iaa's Western and (1 A= - CORII00W7Y PUTWEES TRADNIG Southwestern Regional'ofBces.The by so)me designated alternative-," " Coedesamme . the safety fhacdon appropriate changeshave been made @ equipment if the principal equipment resect the new addreses in each of 17 CpH Parts 140 amt 14g these provisions. i has not been M-ated to be fhily qualiBed. Based on the foregoing. pursuant to i , (2)ne validity of pardal test datein Commisalon Headquarters Offlee and Western and Soumweetern flogional authority contained in section 2(a)( u support of the original q==leMantion. thera ==arlity hehanga Act. 711S.C. ! OfflooesChangeof Address (3)1.imited use of administredve 4a0)(1878). the ca==i= ion hereby controls over equipment that has not been demonstrated to be fully qualinarl f^""I""'""ca=My Futums Tading ===ada Parts 140 and 145 of the Code o Federal Regulations as follows: (4) Completion of the ibaction Admosu Final rule ===ad===*= pri# 2 uposum to se t PART 140=(aseraarirrij evironment maldagh a deelga saamaamyt ne t'a==adity Futures basis went and anaring est de ' Trading ena-ad==ian is ===arling its 1.Section 140.11e revised to read as follows: t failure of the espdgment regulations in an attempt to clarify that does not degrade any safety fhassion w M se phystalbom ad se i14e.1 HeadquartsreOmee, mislead the operator. madin
'^ g address of the r ===i-i- 's (a) General ne headquarters ofBee (5)No significant degradauan of any . ,,,, f,-7=. of the &-- ' "a is located at 2033 K
' ,aB oSco arepurposes.
one and In the ofety funcdon o< =ial== ding pracdcol Street NW Washington.D.C 10681.
"* "** addition, theca==i==ian is amending 2. Section 140.2 is amended by~
" j"'9"IP"**Q"'$ 8 'b*f,, its regulations to include new addresses revising paragraphs (c) and (d) to read enviramment resulting from,a design for its roosatly reloceNd Western and as follows:
basis went. . Soudnwern agional oSom.N
- 0) A record of the qualiscadon Western RegionalofBee has been i148.2 RegimN including documentation in paray' aph mood fmm San Framisoo & * * *
(d) of th;s section, must be maintained in W Califor da.no Smewmmen *
- d an auditable form for the andre period Regmaalosa,lastaiin h Citw (c)ne Western Regional ofBee is which the covenditem is Missourt, has moved to a different suite located at 10e50 WHshim Boulpard, Ins la the nuclearpowerplant oris of ofBces in the same building. Suite 510.Los Angeles Califomia 90024 stored for future use to permit - N oa W anuary E 1983, and is responsible for enforcement of
- verification that each item of electric Po# Pismeen essponesafiose coastasm the Act and ad-inistration of the equipment important to safety covered Donald I. Tandick. Acting Executive programs of the Commission in the by this section States of Alaska. Arnona. California, Director. Commodity Futures Trading (1) 1s qualified for its applicadon: and Conunission. 2033 K Street NW Hawall. Idaho, Montana. Nevada.
I (2) Meets its specifIed performance Oregon, Utah. Washington, and requirements when it is subjected to the Wa=h'a-*on. D.C. 20681. (202) 25417558.Wyoming. supptaserrany seronesafiose conditions predicted to be present when (d) The Southwestern Regional office it must perform its safety function up to. Commission regulation i 140.1 currently provides a separate physical location is located at 4901 Main Street Suite 400, the end ofits qualified life, Kansas City. Missouri 64112 and is and mailing address for the responsible for enforcement of the Act l i i -_ - , _ - - _ _ _ _ - - .-. . _-. . - _ - - - . . - -
l .. T FC%M 21 10CM . O ,S p l g.V 4 ts M C.3 h 0 fy - \d II//j$p,q.
; Carolins Power & Ught Company
,cY113: lIyg!^$2fidi Raleigrt. N. C. 27602 -
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';*:- :.?j M 11, 1981.A f Mr. James P. O'Reilly f United States Nuclear Regulatory Coimaission i l
Ragion II 101 Marietta Street, Northwest Atlants, Georgia 30303 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO. 50-400 WELD STM30L dRRORS AND MISAPPLICATION OF WELD ON 3ERGEN-PAIERSON PIPE HANGERS (HRC INFRACTION 400/80-22-01)
Dear Mr. O'Reilly:
In accordance with 10CFR50.55(e), a final report on the subject deficiency was forwarded to you on May 1, 1981. Attached is Revision 1 to that report reflecting certain editorial changes. Pages revised are:
- 1) Page 4
- 11) Exhibit No. 2, pages 1, 4 iii) Exhibit No. 3, pages 7, 8, 15 iv) Exhibit No. 5 v) Exhibit No. 7, pages 2, 3, 4, 5, 6, 7 vi) Exhibit No. 8, pages 1, 2 If you have any quest:Lons regarding the above, please do not hesitate to contact me.
NJC/at (7239) Yours very truly, Atemeh==nt n. , On..gma snec U By cc: Mr. G. Maxwell W/A_ Mr. V. Stallo (2) W/A \ J. J. (%ima d - Manager En P m ing & Construction Qu= Hey Assurance / Quality Control
l CAROLIWA POWER & LIGliT COMPANY SHEARON HARRIS NUCLEAR POWER PLAh7 UNIT NO. I WELD SYMBOL. ERRORS AND MISAPPLICATION OF WELD ON BERGEN-PATERSON PIPE HANGERS FINAL REPORT PREPARED BY: CAROLINA POWER & LIGHT COMPANY l REVISION 1
INTRODUCTION
Seismic Class 1 Bergen-Paterson pipe hangers are detailed on design drawings which specify location, geometry, material and joint welding requirements. Welding pro-cesses, filler metal, etc. are uescribed in Procedure MP-08 " General Welding Procedure for Structural Steel (Seismic and Non-Seismic) and Hangers". Weld in-spection require =ents are specified in Site Specification No. 034, " Nondestructive Examination, Visual Inspection and Testing Requirements for Code Class 1, 2, 3, Balance-of-Plant Piping Systems, Seismic and Non-Seismic Structures for Permanent Plant Construction".
Work Procedure WP-110 " Installation 'of Safety Related (Seismic class I) Pipe Hangars and Thermally Analyzed Pipe Hangers" provides instruction to the craft regarding the installation of the pipe hangers. Weld types most often used in the installation of pipe hangers are the. fillet weld and the flare-bevel weld. Occasionally, a groove weld is used. DESCRIPTION on September 3, 1980, the Resident NRC Inspector identified a problem with unclear s and incorrect weld symbols on Bergen-Paterson Seismic Class I pipe hanger drawings. Also, field inspection by the Resident NRC Inspector identified situations where the weld actually applied on the pipe hangers differed from.that required by the design drawing; i.e., over-welding (more weld length than required)'and ove'r-sized fillets. l The problem identified above prompted.an immediate investigation of other pipe hanger drawings and reinspection of s'lected e completed and inspected pipe hangers.
- 1. Approximately 1,200 pipe hanger drawings (representing hangers whose installation was either in progress or complete) were reviewed for errors and clarity. The results were many incorrect and unclear weld symbols.
- 2. Approximately 100 installed pipe hangers were reinspected by QA inspecters. The results were: 1) Welds larger and smaller than specified by the drawings; 2) fillet welds applied where full penetration groove welds were specified; 3) no evidence of complete penetration on some full penetra' tion groove welds rendering them questionable; and, 4) welds being applied on more sides or fewer sides than specified.
SAFETY IMPLICATION 0 Those hangers welded with smaller fillets, fewer sides than specified (under-welding) and improper welds, pose a potential safety concern in that these hangers, as installed, may not be capable of supporting their design loads or meeting their design margins. Those hangers welded on more sides than specified (over-welding) pose a potential safety concern in that some hangers require flexibility at specific joints in order to not transmit large moment loads to the embedded steel support plates. Flexibility is obtained by no weiding or minimal welding on certain sides of the jotnt. l 1 l 1 t
Those hanger drawings with incorrect and unclear wald symbols posa a potential safety concern in that, if left uncorrected, would result in incorrect or quas-tionable translation of design requiramints in the installation and inspection process.
- This itam is considered reportable due to design drawing errors by Bergen-i Patersen, failure to fabricate in accordance with design drawings by the craft
)
personnel and failure of QA to translate design requirements to insure proper
- construction.
J CORRECTIVE ACTION ! l The cause of the problem is three-fold: 1) Design drawing with incorrect or ! unclear weld details were provided by the vendor and, passing through all checking stages, were issued to the field uncorrected. 2) Field personnel failed to weld the pipe hangers in accordance with the design drawings and/or made welds when details were missing or unclear. 3) QA failed to insure that welds were applied
- in accordance with design drawings and/or that welds applied were clearly indicated j on design drawings.
To prevent future occurrences, the following actions were taken:
- 1. The Site Mechanical and Welding Units are now reviewing pipe hanger design drawings for missing, unclear, and incorrect weld symbols prior to issuance to the field. Drawings with problems are reported to Ebasco/Bergen-Paterson fo.r correction via pipe hanger problem memos (PHPs) written by the Site Mechanical Unit. Ebasco discussed the I ddsign drawing problems with~Bergen-Paterson who identified the problem to their design personnel. Bergen-Paterson agreed to revise their review procedures to insure that design drawings show proper weld symbols. All drawings being issued from Bergen's three design offices are now routed through the Hempstead Office to provide more consistent review by Bergen engineering personnel. A review of 37 hanger design drawings issued by Bergen-Paterson since January 1, 1981 revealed only-3 design drawings with weld symbol problems.
- 2. Weld symbol identification training classes were conducted by Site Welding and Mechanical Engineers. Superintendents, general foremen, foremen, and welders of pipe and pipe hangers attended along with construction inspectors, QA inspectors, and mechanical unit personnel involved with pipe hangers. In addition to instruction on weld symbol identification, emphasis was given on the importance of welding the pipe hanger exactly as the design drawing requires. In those instances where this is not possible, due to physical limitations or drawing errors, the hanger drawing is to be returned to the Site Mechanical Unit. Analysis of QA intpection reports on welding performed since the training classes indicate that corrective action has been effective. For example, a test case of hangers welded and inspected since the training yielded the results shown in Exhibit 1.
- 3. In addition to attending the weld symbc1 identification classes refer-enced in 2. above, QA personnel attended similar classes given within the QA organization in order to strengthen weld symbol recognition skills and to emphasize the necessity for inspections to be in strict accordance with drawing details. QA personnel were instructed to report
, incorrect design drawings to the Site !?echanical Engineering Unit. l
Due,to the safety implications datailed earlier in this report, a program of
- corr'ective action was required for the hangers previously installed or partially installed. This corrective action was a 100% QA reinspection of all seismic pipe hangers that had ever been issued to the craft for vork that were still active. Some pipe hangers were deleted by Ebasco or Bergen-Paterson and were omitted from the reinspection scope. This corrective action also included 100%
in-house review of these hangers' design drawings. The results of the reinspec-tion and in-house review of these hanger drawings and the resolutions of the , probless identified are detailed on Exhibit No. 2. The hangers involved are shown on Exhibit No. 3. As a result of our investigations of the welding problems of pipe hangers, we began to investigate other areas of welding activity for similar problems. The following report details our investigation and corrective and preventive actions oh the welding of HVAC duct hangers and electrical cable tray and conduit hangers. HVAC, CABLE TRAY AND CONDUIT SEISMIC SUPPORT HANGERS DESCRIPTION To begin the investigation of potential welding problems, several HVAC and elec-trical hanger drawings were reviewed. It was noted that numerous inccasistencies and unclear welding symbols and details existed on the design drawings. The dis-covery of clarity problems on the design drawings prompted a field spot check on several HVAC and electrical hangers t,o reveal any potential weld problems similar to the pipe hangers. The results of the spot check revealed: a) welds larger and smaller than design; b) welds being applied on more sides than required; c) welds improperly located; d) welds over holes or gaps between embedded plates; e) missing welds; f) missing welder's symbol. Welds for HVAC, cable tray and conduit hangers were detailed on Ebasco Services design drawings as well as erection drawings furnished by the hanger vendor, Peden Steel. Welding processes are described in Procedure MP-08 " General Welding Procedure for Structural Steel (Seismic and Non-Seismic) and Hangers" and weld inspection requirements are specified in Site Specification No. 034.
. Work Procedure WP-400 " Installation of HVAC Seismic Category I Support" and WP-203 " Installation of Seismic Clas's I Electrical Cable Tray, Tray Support, Conduit, Conduit Support, Boxes and Box Support", provides instructions to the craft re3arding hanger installation.
The weld type most frequently found in the design of electrical and HVAC hangers , is a fillet weld. Flare-bevel welds are used on the attachment of unistrut supports and combination supports (supports that carry both HVAC duct and cable tray). SAFETY IMPLICATIONS Those hangers welded with smaller fillets, fewer sides and missing welds pose a ! potential safety concern in that if the condition was left uncorrected, the hangers i may not ba capable of supporting their design loads. i Consideration for flexibility was not a concern as HVAC anchor type hangers are rigidly braced to prevent movement and HVAC guide type hangers are rigidly braced and designed to allow for thermal move =ent of the duct in one plane only. Fleni- f bility was also of no concern for electrical hangers since they are of rigid design. i 1 Tha occurrence of HVAC and electrical hangar problems ware atttibuted to 1) failura of the A/E or tha vsador to supply correct and clesr dscign drawings; 2) failure of crEf t personnel to properly read and. interpret tha design drawings, and to bring to the attention of on-site engineering unclear information or questions; and 3) fail-ure of QA personnel to interpret and to inspect welds to the ejesign drawing. To prevent future occurrences, the following actions were taken:
- 1. The A/E was notified and requested to make the design drawing corrections and to review additional design drawings to evaluate their present method of indicating design welds to welded connections.
- 2. Additional sessions of the weld symbol identification training classes were conducted by site welding and mechanical engineers. Craft supervisors, craft personnel, QA inspectors and construction inspectors involved with HVAC and electrical hangers attended. The subjects discussed were the same as those addressed in the classes conducted for pipe hanger personnel.
1
- 3. WP-400 " Installation of HVAC Seismic Category I Supports", and WP-203 - l
" Electrical Cable Tray, Cable Tray Support, Conduit, Conduit Support, Boxes l and Box Support", have been revised to include hold points during the 1 erection and welding processes. The procedures also prohibit the craf t I from proceeding with work when problems arise during the erection process l without resolution from the discipline engineer.
- 4. As a result of the problems identified during the field spot check of HVAC and electrical hangers, QA welding inspectors were assigned to reinspect all of the HVAC and electrical hangers that had been previously accepted.
Approximately 100 HVAC and
- 300 cable tray and conduit hangers were reinspected for field errors and discrepancies. The results revealed that approrimately 95% of the hangers reinspected had nonconforming conditions or deviations from the design drawings.
Ths results of the 100% reinspection are shown on Exhibits 4 and 5. A list of the affected HVAC and electrical hangers are shown on Exhibits 6 and 7 respectively. Umids were rejected based on the same criteria as applied to pipe hangers. The rejected hangers.were resolved by the following means:
- 1. Hangers with missing and undersized welds were rewelded in accordance with design documents with work controlled through the use of a rework package in which QA inspection and acceptance of the rework was documented.
- 2. Hangers that were missing welder's stencils were corrected in like manner as the pipe hangers.
- 3. Hangers with arc strikes, spatter, cold lap, undercut, slag and porosity were reworked with controls similar to item 1. and reinspected by QA.
- 4. Hangers with discrepancies such as oversized welds, welds over holes and gaps, improper weld locations, improper weld lengths, improper hanger fit-up and design drawing problems were dispositioned by engineering l evaluations with permanent waivers (PWs) or field change requests (FCRs).
j See Exhibit 8 for listing of applicable FCRs and PWs.
- Rev. 1, 05/27/81 m_ 2___ _ -
_*"W _ _ "*F'*P^
** - ' Analysis of QA Inspsetion Reports -
Test Case of 63 Pipe Hangers Welded After 'delder Training Class y hangers in test case g hangers acceptable; 87.3% 8 hangers rejectable; 12.7% Rejected Hangers:
- 1. A-3-236-1-PD-H-1266 Rejected 3/20/81 overlap, lack of fusion
- 2. A-2-236-1-PD-H-1519 Rejected 1/9/81 Convexity; Accepted 1/20/81
- 3. A-2-236-1-PD-H-1526 Rejected 3/24/81 Oversized; Accepted 1/20/81
- 4. A-2-236-1-PD-H-1550 Rejected 3/24/81 Overlap, weld splatter, are strikes
- 5. T-2-261-1-FW-H-30 Rejected 3/25/81 Arc Strikes, missing welds, lack of fusion
- 6. T-2-261-1-FW-H-31 Rejected 3/25/81 Arc Strikes, undercut, overlap, undersize, missing welds
- 7. F-1-236-1-SF-H-463 Rejected 3/28/81 Undercut; Accepted 4/3/81
- 8. W-6-236-1-WG-H-1706 Rejected 3/28/81 Rejected 4/4/81 Slag, overlap, weld splatters
~
l l l
~
EXHIBIT NO. 2 Results of 100: In-House Review of Pipe Hanger Design Drawings and Reinspection of Pipe Hanger Welding
- 1. Drawing Review 1786 hanger design drawings were reviewed
- 617 PHPs (pipe hanger problems) were written to report to Ebasco/
Bergen -Paterson the problems identified. Problems were of three groups: a) Unclear symbols b) Missing symbols c) Incorrect symbols Most PHPs reported problems with one hanger drawing only. A few reported problems with more than one hanger drawing. The j PHP resulted in the issuance of a new drawing revision with corrections to the problems.. :
- 2. Reinspection 1786 pipe hangers issued for QA reinspection r 701 determined to be not installed 487 pipe hangers found acceptsble ;
598 pipe hangers rejected Pipe hangers were rejected when the following conditions were found:
- a. missing welder's symbols i. welding over holes / gaps t in embeds
- b. oversized welds (greater than 1/8")
- c. undersized welds j. slag i I
- d. weld type applied not the same as k. porosity drawing
- e. overweld 1. undercut ,
- f. missing welds m. overlap
- g. incomplete penetration of groove n. are strikes l welds
- h. welder's stencil in heat affected o. weld splatter f zones ;
I l l
- Rev. 1, 05/27/81 L
t
Tha rejseted pips hcngars wara resolved by the following maans:
- 1. Hangers with missing and undarsized welds and those with cosmatic deficiencies (conditions j through c) were reissued to the craft for corrective rework and each was subsequently reinspected and accepted by QA. There were only a few hangers with missing or undersized welds. Some hangers rejected for missing welds were not reworked because the hanger's installation was only partially complete. The missing welds, will be made when the hanger installa-tion resumes. A few hangers that required rework were removed completely and the QA record of: previous work was voided. This was done when the rework was extensive. These hangers will be reinstalled with new material and new QA inspections at a later date.
- 2. The overwelding condition found on hangers was resolved by FCR-H-286 if the overwelded hanger joint was not a flexible joint (pinned connection). If the overwelded j'oint was flexible, the joint was reworked by the craft. Seven hangers that were overwelded were determinedbyEbasco/Bergen-PktersonandtheHarrisPlantEngineering Section to have flexible joints. These seven were reworked.
- 3. Hangers with oversized welds on non-flexible joints were resolved by FCR-H-286. Oversized welds were evaluated and determined to be of no consequence or detriment to the hanger's ability to perform its support function. However, if any case of local deformations or evidence of excessive heat being applied in the vicinity of oversized welds is noted during inspections this will be evaluated. Our in-spection of oversized welds revealed no evidence of these two effects.
Hangers with oversize welds (greater than 1/8" oversize) on flexible joints were resolved by rework.
- 4. Welds applied that did not agree with the hanger design drawing were of two types and were resolved as followsr a) The weld differed because the weld symbol on the hanger design drawing was incorrect. The drawing error was reported to Ebasco/
Bergen-Paterson via a PHP and a new dr' awing revision was issued showing the correct weld symbol.
~
b) The v21d differad btcause the craft did not apply the propar wald. Example: The craft may htve applied a fillet wald when the proper weld would have required groove joint preparation and welding. In this case, resolution was either rework of the joint or a per=anent waiver approved by Ebasco/Bergen-Paterson to accept the fillet weld "as-is". A new drawing revision was issued showing the new weld symbol.
- 5. Hangers reported to be missing a welder's stencil were resolved by several means:
a) Initially, some of these hangers were wire brushed, the stencils identified and accepted by QA. b) Later, some hangers whose initial inspection reports recorded the welder's stencil were accepted without brush-up work. c) Finally, those hangers without initial inspection reports and/or any recording of the welder's symbols were accepted based on the fact that our code requirements do not commi,t us to impression stamp the hanger welds. See RCI-H-110 for details. Also, we are confident of our welder qualification program's ability to provide us with qualified pipe hanger welders and this small number does not significantly alter trend analysis data.
- 6. Groove welds which showed no evidence of complete penetration or complete penetration could not be verified from inspection records were resolved by two methods:
a) In most cases, these hangers were resolved by a Permanent Waiver to accept fillet welding of the joint. b) In a few cases, the weld joint was reworked by removing the old weld material, repreparation of the hanger member and rewelding of the joint.
- 7. Some welds joining. hanger members to the embed plates were to be located over the 1/4" diameter holes which secure the embed to the concrete forms and across gaps between adjoining embed plates. These welds, if made, were rejected as " questionable", and, if not made, were rejected as
" missing". RCI-W-49 clarified the conditions for which acceptable welds could be made over holes and across gaps. Rework in accordance with RCI-W-49 was accomplished where conditions allowed. When rework was not allowed, 1" thick splicer plates were used to join the embeds and the hanger members was welded to the splicer plate. This was done in accordance with approved Ebasco design details.
. 8. Wald:r'o ctencilo c2ttd in tha h:mt offseted zon ' -wera rcpcirca oy rsmoving the stencils and ralcesting them outcido tha hast affsetid zones. The removing of the stencils was accomplished by grinding.
- 9. A total of *258 hangers were reworked in the instances described above.
f.. i l t
- Rev. 1, 05/27/81
l i l EXHIBIT NO. 3 Sheets 1 thru 16 Listing of installed Bergen-Paterson Hangers that received a QA field reinspection. Mangers with " Void" listed were deleted by Be'rgen-Paterson after the QA reinspection. i-i-
l
- 1. A-1-190-1-CC-H- 600 4/E 36. A-1-190-1-CT-H- 299 5/D
- 2. 602 5/D 37. 300 4/C
- 3. 612 3/C 38. 304 2/3
- 4. ~6 35 4/D 39. 309 7/D
- 5. 636 2/B 40. 312 8/E
- 6. 641 3/D s 41. 331 7/D
- 7. 644 5/E 42. 337 4/B
- 8. 1148 4/E 43. 338 8/E
- 9. 1153 8/I 44. 358 6/D
- 10. 1156 4/E 45. 359 5/C
- 11. 1157 5/F 46. 360 8/F
- 12. 1158 2/C 47. 423 4/C
- 13. 1159 5/F 48. 424 6/E
- 14. . 1269 2/B 49. 427 4/C
- 15. 1271 2/B 50. 430 3/B
- 16. 1272 2/B -
- 51. 432 3/B
- 17. 1277 2/B 52. 433 4/C
- 18. 1283 3/C 53. 434 6/E
- 19. A-1-190-1-CH-H- 70 4/E 54. 438 3/B
- 20. 71 1/B 55. 440 4/C
- 21. 72 2/C 56. 442 3/B
- 22. 91 1/B 57. 446 3/5
- 23. 92 1/B 58. 447 3/B 24 . A-1-190-1-CT-H- 224 6/C 59. 449 3/B
- 25. 227 5/C 60. 451 3/B
~
- 26. 247 5/D 61. 459 10/H
- 27. 269 6/C 62. 460 8/F
- 28. 270 5/C 63. 462 6/D
- 29. 277 8/E 64. 464 7/E
- 30. 278 6/D 65. 466 5/C
- 31. 279 5/C 66. 468 5/C
- 32. 280 6/D 67. 469 5/C
- 33. 282 7/D 68. 470 6/D
- 34. 283 6/D 69 471 6/D
- 35. 298 8/F 70. 472 8/F l
l J
C ' 71..,A-1-190-1-CT-H- 474 6/D 106. A-1-190-1-PD-E- 53 1/B
- 72. 476 5/C 107. 54 1/B
- 73. 477 6/D 108. SS 1/3
- 74. 479 5/C 109. 56 1/B
- 75. 480 6/D 110. -
59 2/C
- 76. 481 5/C 111. 63 1/B
- 77. 482 6/D 112. 65 1/B
- 78. 483 5/C s 113. 67 1/B
- 79. 486 6/D 114. 69 2/C
- 80. 797 0/A 115. 71 3/D
. 81. A-1-190-1-CX-H- 96 2/C 116. 72 1/B
- 82. A-1-190-1-FP-H- 256 1/B 117. 73 3/D
- 83. A-1-190-1-PD-H- 5 2/C 118. 74 3/D
- 84. 6 2/C 119. 75 1/B
- 85. 7 1/B 120. 76 2/C
- 86. 8 1/B 121. ,
77 1/B
- 87. 9 1/B 122. 78 2/C
- 88. 10 2/C 123. 81 1/B
{
- 89. 13 4/E 124. 82 2/C
- 90. 14 1/B 125. 83 1/3
- 91. 29 1/B 126. 84 3/D
- 92. 35 2/C 127. 86 4/E
- 93. 37 2/C 128. 87 1/B
- 94. 40 0/A 129. 88 2/C
- 95. 42 2/C 130. 89 1/B
- 96. 43 2/C 131. 91 0/A
- 97. 44 4/F 132. 92 1/B
- 98. 45 2/C 133. 97 1/B
- 99. 46 2/C 134. 98 1/B' 100. 47 2/C 135. 102 2/C 101. 48 2/C 136. 103 2/C 102. 49 0/A 137. 104 2/C p 103. 50 2/C 138. 105 1/B 104. 51 1/B 139. 107 4/E 105. 52 1/B 140. 109 O/A
, _g-141.' A-1-190-1-PD-H- 111 2/C 176. A-3-216-1-PD-H- 341 4/E 14 2. 112 2/C 177. 345 1/B 143. 113 1/B 178. 352 1/B ,
144. 115 1/B 179. 367 1/B 145 A-1-190-1-RH-H- 15 7/D 180. 368 0/A 146. 16 4/D 181. 369 1/B 147. 17 3/B 182. 370 0/A 148. 25 7/E 183. 371 2/C 149 26 5/D 184. 489 1/B 1 150. 33 5/C 185. 490 1/B 151. 35 6/D _ 186. 491 0/A 152. 45 7/E 187. 492 1/B 153. 53 0/A 188. 493 1/B 154. 55 6/D 189 4 94 2/C 155. 57 .6/B 190. 495 1/3 156. 60 7/D 191. -' 496 3/D 157. 62 7/C . 192. 565 1/B 158. 63 13/J i~ 193. 567 2/C 159 64 7/D 194. 569 O/A 160. A-3-216-1-CT-H- 208 3/C 195. 570 0/A 161. 209 0/A 196. 571 2/C 162. 211 0/A 197. 572 1/B 163. 213 0/A 198. 576 2/C 164. 214 0/A 199. 577 0/A 165. 216 0/A 200. 578 1/B 166. 249 3/D 201. 615 0/A 167. 250 1/B 202. 616 1/B 168. 252 3/C 203. 617 0/A 169. 253 2/B 204. 619 4/E 170. 254 2/B 205. 620 5/F 171. - 257 3/C 206. 621 0/A 172. 274 5/E 207. 622 0/A 173. A-3-216-1-FP-H- 246 1/B 208. 623 1/B 174. 270 1/B 209. 627 0,' A 175. A-3-216-1-PD-H- 339 3/D 210. 628 0/A
, w " 211.' A-3-216-1-PD-H- 629 1/B 246. A-3-216-1-SW-H- 362 4/C 212. 630 1/B 247. 364 2/B l
213. 631 4/E 248. 366 1/B 214. 633 3/D 249. 368 2/3 l 1 215. 634 3/D 250. 370 5 216. 635 1/3 251. 372 3/C
- 217. 636 1/B 252. 374 4/B 218. 637 4/E 253, 378 4/B 219. 639 1/B 254. 379 3/C 220. 640 1/B 255. 380 3/C 221. 641 1/B 256. 381 3/C 222. 642 0/A 257. 382 3/C 223. 643 4/E 258. 384 3/C 224. 645 4/E 259. 385 3/C 225. 647 2/C 260. 386 3/C
~
226. 648 2/C 261. 387 3/C 227. 649 1/B . 262. 388 3/C 228. 650 2/C i 263. 391 3/C 229. 652 4/E 264. 392 3/C 230. 689 0/A 265. 393 3/C 231. 690 1/B 266. 394 3/C 232. 691 0/A 267. 398 0/A 233. 692 1/B 268. 400 0/A 234. 693 0/A 269 4 04 0/A - 235. 694 1/B 270. 406 1/B 236. 695 1/3 271. 410 1/B 237. 696 0/A 272 412 2/B 238. 697 4/E 273. 448 3/C 239. 1132 3/D 274. 452 3/C 240. 1134 2/C 275. 454 2/B 24 1. 1135 3/D 276. 455 2/B 242. 2086 1/B 277. 456 3/C 243. 2092 0/A 278. 458 2/B 244. A-3-216-1-SW-U - 359 2/B 279. 459 2/B 245. 360 2/B 280. 460 3/C
' 281.* A-3-216-1-SW-H- 462 2/B 316. A-3-216-1-SW-H- 906 1/B 282. 463 2/B 317. 907 1/B 283. 464 3/C 318. 908 1/B 284. 466 2/B 319. 927 1/B 285. 467 2/B 320. 923 1/B 286. 468 2/B 321. 929 1/3 287. 471 3/C 322. 930 1/3 288. 475 3/C 323. 932 1/B 289. 517 3/C 324. 934 1/B 290. 519 4/D 325. 935 1/B 291. 521 3/C 326. 936 1/B 292. 528 6/F 327. 943 2/C 293. 529 4/D 328 947 1/3 294. 530 3/C 329. 952 2/C 295. 531 4/C 330. 953 2/C 296. 532 ,4/C 331. 959 1/B 297. 533 4/C . 332. 960 1/B 298. 5" 333. 534 '4/C 978 2/C 299. 535 4/C 334. 979 4/E 300. 536 4/C 335. 982 4/E 301. 537 4/C 336. 991 2/C 302. 538 4/C 337. 1176 3/D 303. 539 5/D 338. 1177 1/B 304. 540 2/B 339 1181 1/B 305. 545 4/D 340. 1183 1/B ' 306. 608 3/C 341. 1184 1/B 307. 893 1/B 342. 1186 1/B' 308. 895 2/C 343. 1201 3/D 309. 897 1/B 344. 1203 2/C 310. 899 1/B 345. A-4-216-1-CT-H- 259 5/E 311. 901 1/B 34 6. 260 ~ 4/D 312. 902 2/C 347. 261 4/D 313. 903 1/3 348. 262 4/D 314. 904 1/B 349 203 2/B 315. 905 1/B 350. A-4-216-1-PD-H- 307 2/C i t 1
cq-351 A-4-216-1-PD-H- 317 0/A 386. A-4-216-2-SW-H- 596 3/B 352. 319 4/E 387. 598 4/B 353. 320 1/B 388. 602 3/B 354. 321 4/E 389. 603 3/B 355. 735 2/C 390. 604 4/C 356. 736 1/B 391. 605 4/C 357. A-4-216-1-SW-H- 419 6/E 392. 1876 1/B 358. 420 2/B 393. 1878 0/A 359. 422 4/C ,394. F-1-216-1-FP-H-1075 1/B 360. 424 2/B 395. 1077 2/C 361. 477 4/C 396. 1079 1/B 362.. 479 3/B 397. 1080 1/B 363. 484 3/B 398. 1081 1/B 364. 487 4/E 399 1082 1/B 365. 489 5/C 400. 1084 2/C
~
366. 547 5/D 401. 1085 1/B 367. 568 6/B - 402. 1086 1/B 368. 570 7/E 403. 1088 2/C 369. 572 4/C 404. 1090 1/B 370. 581 3/B 405. F-2-216-1-FP-H-1114 2/C 371. 583 3/B 406. 1125 2/C 372. 585 3/B 407. 1127 2/C 373. A-4-216-2-CT-H- 641 2/B 408. 1129 2/C 374. 643 1/A 409. 1131 2/C 375. A-4-216-2-PD-H- 228 1/B 410. A-2-236-1-AF-H- 83 '4/E 376. A-4-216-2-SW-H- 425 4/C 411. 85 2/C 377. 552 4/C 412. 109 1/B' 378. 554 4/C 413. 114 3/D l 379. 556 4/C 414. 118 3/D 380r 563 3/B 415. 119 2/C ( 381. 565 2/B 416. 120 1/B l 382. 576 3/B 417. 129 2/C 383. 578 4/C 418. 133 2/C 384. 589 3/B 419. 134 2/C 385. 595 4/C 420. 135 1/B l l I l
2/C 456. A-2-236-1-CC-H- 374 2/C 421. 'A-2 -236-1-AF-H- 138 1/i4 3/D 457. 473 5/F 422. 1/B 458. 483 3/D 4 423. A-2-236-1-BD-H- 131 132 1/3 459. 662 3/D 424. 139 2/C 460. 663 2/C 425. 142 1/B 461. 665 2/C 426. 0/A 462 667 2/C 427. A-2-236-1-BR-H- 467 468 O/A 463. 668 2/C 428. 1553 0/A 464. 669 3/D 429. 1554 0/A 465 670 1/3. 430. 1555 0/A 466. 671 4/E 431. 432. 1556 0/A 467 672 4/E 433. 1557 0/A 468. 673 4/E 1558 0/A 469 677 1/B 434. 1559 0/A 470. 678 2/C 435. 1560 0/A 471. 877 2/C 436. A-2-236-1-CC-H- 89 2/C 472. 878 1/B 437. 90 1/B 473 880 2/C 438. ~ 439. 91 2/C
- 474. DELETE 92 3/D 475. 887 1/B 440.
441. 93 5/F 476. 888 4/E 442. 94 2/C 477. 889 2/C 443. 95 2/C 478. 891 2/C 444. 97 2/C 479 892 2/C 98 2/C 480. 893 2/C 445. 446. 99 3/D 481. 894 1/3 100 6/G 482. 896 2/C 447. , , 448. 101 4/E 483 900 3/D 449. 102 5/F 484. 902 2/C 105 3/D 485. 903 1/B 450. 451. 107 2/C 486. 905 1/B 452. 110 2/C 487. 906 4/E 453. 111 1/B 488. 908 4/E 454. 112 2/C 489. 909 2/C 455. 113 1/B 490. 910 1/B
- Rev. 1, 05/27/81
491. A-2-236-1-CC-H- 91.'. 4/E 525. A-2-23'6-1-CC-H-1562 0/A 492 - 9.*_3 2/C 527, 1564 0/A 493. 014 2/C 528. 1566 0/A 494 916 3/D 529. 1576 0/A 495. 918 4/E 530. 1583 0/A 496. 919 5/F 531. 1584 1/B 497. 920 2/C 532. 1587 0/A 498. 922 1/B 533. 1598 1/B 499. 942 4/E 534. 1599 O/A 500, 943 2/C 535. 1601 0/A 501. 944 3/D 536. 1603 2/C 502. 945 4/E 537. 1604 0/A 503. 947 5/F 538. A-2-236-1-CE-H- 11 0/A 504, 948 3/D 539. 14 2/C 505. 949 1/B
- 540. DELETE 506. 952 4/E 541. 18 3/D 507. 958 2/C 5'2. 21 1/B 508. 965 4/E .
543, 22 1/B 509. 967 5/F :- 544. 25 1/B 510, 968 3/D 545. A-2-236-1-CH-H- 166 O/A 511, 969 4/E 546. 168 O/A 512. 976 2/C 547. 169 1/B VotD 513. 1211 1/B 548. 170 2/C 514. 1213 O/A VOID 549. 171 1/B 515. 1216 O/A 550. 176 0/A 516. 1218 0/A 551. 177 1/B 517. 1220 2/C 552. 181 4/E 518. 1222 O/A 552A. 193 0/A VOID 519. 1224 1/B 553. 194 O/A VOID 520, 1247 0/A 554. 195 1/B 521. 1310 0/A 555. 201 1/B 522. 1312 0/A 556. 203 1/B 523, 1326 0/A 557. 204 1/B 524. 1557 O/A 558. 205 1/B 525. 1560 0/A 559. 206 1/B 560. 207 1/B i l
- Rev. 1, 05/27/81 l
. _g_
~~
561. A-2-236-1-CH-H- 208 1/B 596. A-2-236-1-FP-H- 735 1/B 562 249 5/B 597. 736 1/B 563. A-2-236-1-CS-H- 8 5/D 598. 737 1/B 564. A-2-236-1-CX-H- 228 0/A 599. 738 1/B 565. 229 1/3 600. 739 0/A 566. 248 3/D 601. , 749 2/C 567. 249 3/D 602. 757 1/B 568. 391 3/D 603. 761 1/B 569. 397 3/C 6 04 . 790 1/B 570. 400 0/A 605. 791 1/B 571. 423 1/B VOID 606. 792 2/C 572. 424 1/B VOID 607. 793 3/D 573. 425 1/B 608. 794 2/C 574. 426 1/B VOID 609 795 1/B 575. 427 1/B VOID 610. 799 2/C
~
576. 432 1/B 611. 800 3/D 577. 433 1/B . 612. 801 3/D 5" 578. 437 1/B 613. 803 3/D 579. 438 2/C 614. 8 04 3/D 580. 442 1/B 615. 805 1/B 581. 446 1/B 616. 806 2/C 582. A-2-236-1-DW-H- 79 O/A 617. 882 2/C 583. - 81 1/B 618. 884 0/A 584. A-2-236-1-FP-H- 525 1/B VOID 619. 886 0/A 585. 526 1/B 620. 888 1/B 586. 527 O/A 621. 890 0/A 587. 533 1/B 622. 894 0/A 588. 626 0/A 623. 896 1/B 589. 629 O/A 624. 899 0/A 590. 729 1/B 625. 900 0/A 591. 730 1/B 626. 901 0/A 592. 731 0/A 627. 908 O/A 593. 732 1/B 628 911 0/A 594. 733 2/C 629. 912 .0/A 595. 734 1/B 630. 913 0/A
. e 631. A-2-236-1-FP-H- 921 0/A 666. A-2-236-1-FM-H- 228 0/A 632. 924 0/A 667. 229 0/A 633. A-2-236-1-PD-H-1502 0/A 668. A-2-236-1-RH-H- 166 2/C 634. 1503 0/A 669 174 4/E 635. 1504 1/B 670. 183 3/D 636. 1505 1/3 671. 199 1/B 637. 1506 0/A 672. A-2-236-1-SW-H- 345 0/A 638. 1507 0/A 673. 346 0/A 639. 1508 0/A 674. 354 0/A 640. 1509 O/A 675 355 2/C 641. 1516 0/A 676. 433 0/A 642. 1518 0/A 677. 441 0/A 643. 1520 1/B 678. 442 0/A 644. 1522 1/B 679. 443 0/A 645. A-2-236-1-PM-H- 185 0/A 680. 444 0/A 646. 187 O/A 681. ,
445 0/A 647. 189 0/A . 682. 446 1/B 648. 191 1/B b 683. 507 2/C 649. 196 0/A 684. 509 2/C 650. 197 1/3 685. 510 2/C 651. . 198 0/A 686. 511 2/C 652. 200 0/A 687. 512 2/C 653. 201 0/A 688. 513 2/C 654. 209 0/A 689. 515 3/D 655. 213 1/B 690. 961 1/B 656. 216 0/A 691. 1207 1/B 657. 217 0/A 692. 1231 3/D 658. 218 0/A 693. 1235 2/C-659. 220 0/A 694. 1237 1/B 660. 221 0/A 695. 1239 1/B 661. 222 0/A 696. 1241. 4/E 662. 223 0/A 697. 1242 3/D 663. 224 0/A 698. 1244 1/B 664. 225 0/A 699. 1245 1/B 665. 227 0/A 700. 1254 2/C l
_gg._ l
.. 1 701. A-2-236-1-S'4-H-1258 4/E 736. A-3-236-1-BD-H- 338 2/C j 702. 1454 1/B 737, 339 2/C 203. 1458 3/D 738. A-3-236-1-CC-H- 340 5/F 704. 1431 1/B 739. 341 5/F 705. 1453 1/B 740. 342 6/G 706. 1485 0/A 741. 344 6/G 707. 1533 2/C 74 2. 346 4/E 708. 1537 2/C 743. 348 3/D 709. 1540 3/D 744. 34 9 4/E VOID 710. A-3-236-1-AF-H- 149 1/B 745. 368 2/C 711. 151 2/C 746. 375 1/B 712. 153 2/C 747. 378 2/C 713. 160 1/B 748. 379 1/B 714. 161 2/C 749. 380 1/B 715. A-3-236-1-BD-B- 144 0/A 750. 381 2/C 716. 146 3/D 751. 384 1/B 717. 147 1/B -
752. 385 2/C 718. 148 2/C 753. 386 1/B 719. 149 1/B 754. 387 2/C 720. 150 1/B 755. 388 2/C 721. 151 2/C '756. 391 5/F 722. 155 1/B 757. 393 4/E 723. 157 3/D 758. 397 3/D 724. 160 3/D 759. 401 2/C 725. 162 3/D 760. 402 5/F 726. 192 2/3 761. 4 04 1/B 727. 193 2/B 762. 464 4/E 728. 199 2/B 763. 469 4/E 729, 203 2/B 764. 471 3/D 730. 204 2/B 765. 4 74 2/C 731. 205 3/C 766. 475 1/3 732. 231 2/B 767. 476 2/C 733. 232 2/B 768. 479 3/D 734. 233 4/D 769 484 3/D 735. 242- 2/B 770. 485 2/C
-gg_
771. A-3-236-1-CC-H- 488. 3/D 806. A-3-236-1-CC-H-110's 4/E 772. 490 4/E 807. 1190 2/C 773. 492 5/F 808. 1192 2/C 774. 494 2/C 809. 1193 4/E 775. 497 3/D 810. 1194 3/D 776. 499 3/D 811. 1232 0/A 777. 501 2/C 812. 1321 0/A 778. 502 3/D 813. 1572 2/C 779 508 2/C 814. 1580 1/B 780. 509 2/C 815. 1581 2/C 781. 510 2/C 816. 1583 0/A 782. 511 4/C 817. 1600 0/A 783. 512 3/D 818. A-3-236-1-CE-H- 4 1/B 784. 926 2/C 819. 6 2/C 785. 927 3/D 820. - 7 4/E-
~
'786. 929 3/D 821. 8 2/C 787. 931 1/B . 822. ,
302 1/B 5" A-3-236-1-CH-H- 144 0/A 788. 932 4/E 823. 789 936 0/A 824. 145 0/A 790. 938 2/C 825. 147 0/A 791. 978 1/B 826. 151 1/B 792. 980 1/B 827. 273 0 793. 982 1/B 828. 279 3/D 794. . 983 1/B 829. 281 1/B 795 984 1/B 830. 284 2/C 796. 985 2/C 831. 307 1/B 797. 986 3/D 832. 311 0/A 798. 989 1/B 833. 364 0/A 799. 1011 1/B 834. 365 1/B 800. 1016 2/C 835. --366~~ 0/A 801. 1017 1/B 836. 367 2/C 802. 1058 1/A 837. 368 0/A 803. 1062 1/A 838. 369 1/B VOID , 8 04 . 1064 2/B 839, 370 1/B VOID i 805. 1188 2/C 840. 390 1/B i I
841. A-3-236-1-CH-H- 392 0/A VOID 876. A-3-236-1-FP-H- 649 2/C 842. 415 0/A 877. 650 2/C 843. 420 0/A VOID 878. 651 2/C 844. 422 1/3 879 652 2/C , 845. 425 1/B 880. 653 2/C 846. 426 0/A 881. A-3-236-1-MS-H- 408 2/C 847. 429 2/C 882. 409 1/B 848. A-3-236-1-CX-H- 290 2/C e83. 444 1/B 849. 362 2/B 884. A-3-236-1-SW-H-1195 1/B 850. 364 4/E 885. 1199 1/B VOID 851. 370 3/D 886. 1262 4/E 852. 374 4/E 887. 1253 2/C 853. 378 4/E 888. 1264 2/C 854. 380 2/C 889 1265 2/C 855. A-3-236-1-DW-H- 83 0/A 890. 1266 '1/B 856. 84 O/A 891. 1269 1/B 857. A-3-236-1-F?-H- 508 1/B - 892. 1270 1/B 858. 509 0/A 893. 1291 0/A 859. 511 1/B 894. 1292 0/A 860. 512 1/B 895. 1293 2/C 861. 513 3/D 896. 1294 1/B 862. 514 O/A 897, 1295 3/D 863. 515 1/B 898. 1296 1/B 864. 516 1/B 899. 157.4 1/B 865. 518 2/C 900. 1607 5/C 866. 519 1/B 901. W-5-236-1-WG-H- 386 2/C 867. 538 0/A 902. 387 2/C 868. 542 2/C 903. 392 2/C. 869. 545 1/B 904. 393 2/C 870. 546 0/A 905. 406 1/B 871. 604 2/C 906. 407 0/A 872. 639 2/C 907. 408 2/C 873. 640 3/D 908. 409 2/C 874. 641 2/C 909. 411 2/C 875. 648 2/C 910. 414 1/B
911. W-5-236-1-WG-H- 415 0/A 946. W-5-236-1-WG-H- 520 2/C 912, 416 2/C 947. 521 3/D 913. 417 2/C 948. 523 1/B 914. 422 1/B 949. 525 1/B 915. 423 2/C 950. 527 2/C 916. 424 2/C 951. 529 3/D 917. 438 2/C 952. 533 0/A 918. 444 0/A 953. 536 0/A 919. 445 0/A 954. 538 2/C 920. 446 1/B 955. 541 3/D 921. 447 1/B 956 542 2/C 922. 450 4/E 957. 557 1/B 923. 451 2/C 958. 565 1/B 924. 455 0/A 959 566 2/C 925. 457 1/B 960. , 567 2/C 926. 462 2/C 961. 570 2/C 927. 463 '2/C '. 962. 571 2/C 928. 467 2/C 963. 580 1/B 929. 470 2/C 964. 581 1/B 930. 471 2/C 965> 582 1/B' 931. 474 3/D 966. 583 1/B 932. 475 0/A 967. 585 1/B 933. 476. 2/C 968. 598 4/E 934. 477 3/D 969 599 2/C 935. 482 3/D 970. 600 2/C 936. , 485 1/B 971. s 601 3/D l 937. 490 1/B 972. 610 2/C l 938. 491 1/B 973. 620 3/D l 939. 510 1/3 974. 621 2/C j l 940. 511 1/B 975. 627 2/C 94 1. 512 1/B 976. 1065 2/C ! 94 2. 513 1/B 977. 1066 2/C 94 3 . 515 1/3 978. 1067 2/C , 944. 518 2/C 979. W-5-236-1-WL-H-2192 1/B 945. 519 2/C 980. 2196 1/B 1
981.W-6-236-1-WG-H- 628 1/3 1016. A-5-236-1-CC-H- 463 2/C 982. 630 2/C 1017. A-5-236-1-SW-H- 4 95 2/C 983. 633 0/A 1018. 496 0/A 984. 639 1/B 1019. 503 0/A 1 985. 669 3/D 1020. 505 0/A 986. 670 4/E 1021. 1346 0/A 987. 672 4/E 1022. 1653 0/A 988. 680 1/B 1023. A-5-236-2-EW-H- 786 O/A 989. 681 1/3 1024. 787 0/A 990. 682 1/B 1025 F-1-236-1-SF-H- 879 2/C 991.- 683 1/B 1026. 890 1/B 992. 691 1/B 102'< . 902 4/E 993. 692 1/B 1028. 910 1/B 994. 693 2/C 1029 916 1/B 995. 705 2/C 1030. T-i-240-1-SW-H- 265 f/G 996. 710 2/C 1031. 266 5/F 997. 711 1/B 1032. 267 5/F 998. 712 3/D 1033. 268 5/C
~
999. 717 2/C 1034. 269 5/F 1000. 723 2/C 1035. 270 5/F 1001. 729 3/D 1036. 271 5/F 1002. 731 3/D 1037. 272 5/F 1003. 732 3/D 1038. 274 6/G 1004. 733 2/C 1039. 275 5/F 1005. 734 3/D 1040. 276 5/F 1006. 735 3/D 1041. 277 5/F 1007. 739 2/C 1042. 278 5/F 1008. 750 0/A 1043. 279 5/F
- 1009. 752 0/A VOID 1044. 280 5/F 1010. 759 2/C 1045. 281 5/F 1011. 762 3/D 1046. 283 6/G 1012. 763 2/C 1047. 284 5/F 1013. 767 2/C 1048. 285 4/E 1014. 771 3/D 1049. 286 5/F 1015. A-5-236-1-CC-H- 352 4/E 1050. 287 5/F 1
- Rev. 1, 05/27/81
'. -G@-
"1051. T-2-240-1-SW-H- 288 5/E 1052. 289 5/F 1053. 290 5/F 1054. . 291 5/F 1055, 292 9/K 1056. 293 8/J 1057. 294 8/J 1058. 295 8/J 1059. 296 8/J 1060. 297 8/J 1061. 298 8/J 1062. 299 8/J 1063. 300 8/J 1064. 301 5/F 1 1065. 317 4/E 1066. 323 5/F 1067. 325 5/F ,
1068. 331 8/J b~ 1069. 332 6/G 1070. 333 7/H 1071. 334 6/G 1072. 335 6/G 1073. 336 6/G 1074. 337 6/G
~
1075. 338 6/G 1076. 339 6/G 1077. 815 7/H 1078. TK-1-236-1-PM-H-289 0/A 1079. 292 1/B 1080. 293 1/B 1081. 294 1/B 1082. 295 1[B 1083. 293 1/B 1084. 300 2/C 1085. 301 1/B 1086. 302 1/B
EXHIBIT NO. 4
~
HVAC HANGER INSFECTION STATUS P.EINSPECTION 85 Duct Hangers Reinspected 81 Hangers rejected 2 Determined to have engineering problems 2 Hangers tacked RESOLUTIONS 41 Hangers accepted by waivers 40 Hangers reworked a f.. I 1 I
9 EXHIBIT 5 ELECTRICAL HANGERS REINSPECTION STATUS
- 298 - Total cable tray & conduit hangers inspected
- 268 - Rejected hangers
- 17 - Accepted hangers
- 13 - Hangers with engineering problems RESOLUTION OF THE
- 268 REJECTED HANGERS
- 154 - Hangers accepted by PW or FCR
- 19 - Hangers accepted by field rework
- 95 - Hangers accepted by combination of field rework and PW's or FCR's t
- Rev. 1, 05/27/81
EXHIBIT NO. 6 '
.. '. REINSPECTION LIST OF HVAC DUCT SEISMIC SUFFORTS RA3 190 ELEV.
F-1930 F-1011 F-1933 F-1931 F-1012 F-1016 F-1013 I F-1000 F-1014 F-1001 F-1002 F-1008 F-1004 F-1009 F-1934 F-1005 F-1200 F-1203 F-1201 f RAB 236 ELEV._ , F-1098 F-1090 ", F-1926 F-1956 F-1291 F-1092 F-1927 F-1292 F-1093 F-1928 F-1101 F-1094 F-1929 F-1100 F-1095 F-1950 F-1099 F-1096 F-1951 F-1123 F-1097 F-1102 F-1086 F-1108 F-1952 F-1087 F-1109 F-1953
~
F-1088 F-ll10 F-1954 F-1089 F-1111 F-1955 EMDRAC Drawings 1364-12756 Rev. 5, 1364-16318 Rev. 1, 1364-16319 Rev. 1, 1364-16320 Rev. 2 were used by QA to perform the reinspection on the above hangers.
, (continu:d) HVAC DUCT SEISMIC SUPPORTS RAB 247 ELEV. l F-1696 F-1297 F-1703 F-1103 F-1483 F-1704 F-1104 F-1486 F-1305 F-1298 F-1300 F-1494 F-1105 F-1699 F-1707 F-1904 F-1303 F-1304 F-1301 F-1905 F-1307 F-1702 F-1901 F-1495 F-1489 F-1491 F-1708 F-1490 F 1906 F-1309 .
F-1501 F-1711 5.. TOTAL HANGERS: 85 I
. w.e:o u gg y REI3SPECTION LIST OF CABLE TRE. & CONDUIT SUPPORT HANGER
- 1. 7C21-EC2328 25. 7042-ED2351-2
- 2. 7041-ED2326 27. 7042-ED2351-3
- 3. 7021-HC2301 ,
- 28. 7041-CD2311
- 4. 7021-EC2327 29 7041-ED2312
- 5. 7041-RD2315 30. 7041-ED2313
- 6. 7021-EC2353-1 31. 7041-ED2314
- 7. 7021-EC2352 32. 7041-ED2315
- 8. 7021-EC2353-2 33. 7041-ED2316
- 9. 7041-ED2324 - Sect. R 34. 7041-ED2319
- 10. 7041-ED2324 35. 7041-ED2322
- 11. 7041-ED2312 j
'_ 36. 7041-ED2333
- 12. 7041-ED2325 ,
- 37. 7041-ED2321
- 13. 7041-CD2310 38. 7041-ED2308-1
- 14. 7041-CD2308 39. 7041-ED2307-1
- 15. 7041-ED2323 40. 7041-ED2307-2
- 16. 7041-ED2328 41. 7,041-ED2308-2
- 17. 7041-ED2328 - Sect. 42. 7041-CD2309
- 18. 7041-ED2320 - Sect. H 43. 7041-ED2310
- 19. 7041-ED2320 ,
- 44. 7042-HD2365
- 20. 7041-ED2302 45 7041-ED2303-1
- 21. 7041-ED2301-2 46. 7041-ED2303-2
- 22. 7041-ED2301-1 47. 7041-ED2304 l
2 'J . 7042-ED2358-3 48. 7041-ED2306 - Sect. E
- 24. 7042-CD2364 49. 7041-ED2306 - Sect. F
< 25. 7042-ED2351-1 50. 7041-EC2339
-R-
gl. 7,021-EC2323 76. 7041-ED2309
- 52. 7021-EC2317 77. 7041-ED2311
- 53. 7021-EC2322
- 78. DELETE
- 54. 7021-HC2307 79 7042-ED2365 -
- 55. 7021-HC2306 80. 7042-CD2369 3
- 56. 7021-HC2303
- 81. DELETE
- 57. 7021-HC2302 82. 7021-EC2325
- 58. 7021-EC2326-2 83. 7042-ED2380
- 59. 7021-EC2341
- 84. DELETE
- 60. 7021-EC2326-1 85. 7042-HD2370
- 61. 7042-ED2356 86. 7042-CD2363
- 62. 7042-ED2357-1 87. 7042-ED2358-1
- 63. 7042-ED2357-2 88. 7042-ED2358-2 f
- 64. DELETE '
- 89. DELETE
- 65. 7042-E02375 -
- 90. DELETE
- 66. 7042-CD2365
- 91. DELETE
- 67. 7042-ED2373
- 92. DELETE
- 68. 7042-ED2352
- 93. DELETE
- 69. 7042-ED2366 . 94 . 7042-ED2353
- 70. 7042-ED2379 95. 7042-CD2366
- 71. 7041-ED2305-1
- 96. DELETE l 72. 7041-ED2305-2
- 97. DELETE
- 73. 7041-ED2305-3
- 98. DELETE
- 74. 7041-ED2306-1
- 99. DELETE
! 75. 7041-ED2306-2
- 100. DELETE
- Rev.1, 05/27/81 q r. . .
- 101. DELETE 126. 7021-EC2346-2 102. 697S01-9 127. 7021-EC2356 103. 697S01-10 128. 7021-EC2355
~
104. 697S01-11 129 7021-EC2305 105. 697S01-12 130. 7021-EC2338 106. 697S01-13 131. 7021-EC2304-4 107. 697S01-14 132. 7021-EC2302-1 108. 697S01-15 133. 7021-EC2345 109. 697501-16 134. 7021-EC2304-1 110. 697S01-17 135. 7021-EC2304-3 111. 697S01-18 136. 7021-EC2358-2 112. 7021-EC2304-2 137. 7021-EC2358-1 113. 7021-EC2337 138. 7021-EC2357 114. 7021-EC2346-3 'g. 139. 7021-EC2340 115. 7021-EC2360-1 .~ 140. 697S01-30 116. 7021-EC2360-2 14 1. 697S01-31 117. 7021-EC2324- 142. 697S01-32 118. 7C21-EC2302-2 143. 697S01-33 119. 7021-EC2359 144. 697S01-34 120. 7021-EC2316 145. 697S01-35 121. 7021-EC2306-1 146. 697S01-36 122. 7021-EC2306-2 147. 697S01-37 123. 7021-EC2346-1 148. 697S01-38 124. 7021-EC2348 -1 14 9. 697S01-39 125. 7021-EC2348-2 150. 697S01-40
- Rev. 1, 05/27/81
e 151. 697S01-41 176. 7026-EC2659-265 152. 697501-52 177. 7026-EC2659-270 153. 697S01-53 178. 7026-EC2659-275 154. 697S01-67 179 7026-EC2659-279 155. 697501-60 180. 7026-EC2649 156. 697S01-42 181. 7026-EC2634 157'. 697S01-43 182. 7026-EC2664-6 158. 697S01-44 183. 7026-EC2664-8 159. 697S01-45 184. 7026-EC2608-1 160. 697S01-46 185 7026-EC2608-2 161. 697S01-47 - 186. 7026-EC2601-1 162. 697S01-48 187. 7026-EC2602-3 163. 697S01-49 [. 188. 7026-EC2635 164. 697S01-50 - 189. 7026-EC2603 165. 697S01-51 190. 7026-EC2613 166. 7021-HC2309 191. 7026-EC2605 167. 7021-HC2308 192. 7026-EC2602-2 168. 7021-EC2354-3 193. 7026-EC2602-1 169. 7021-EC2354-2
- 194. DELETE 170. 7021-EC2354-1
- 195. DELETE 171. 7026-EC2638 - Sect. AE
- 196. DELETE 172. 7026-EC2638 Sect. G
- 197. DELETE 173. 7026-EC2638 - Sect. K
- 198. DELETE 174. 7026-EC2638 - Sect. M
- 199. DELETE 175. 7026-EC2641
- 200. DELETE l
l
- Rev. 1, 05/27/81 4- __ _ . . _ .
E. .
- 201. DELETE 226. 699S02-40
= 202. DELETE 227. 699S02-41
- 203. DELETE 228. 699502-44
- 204. DELETE 229. 699502-69
- 205. DELETE 230. 699S02-72
- 206. DELETE 231. 699S02-73 207. 699S02-131 232. 699S02-74 208. 699S02-130 233. 699S02-139 209 699S02-100 234. 699S02-140 210. 699S02-99 235. 699S02-141 211. 699S02-98 236. 699S02-142 212. 699502-96 237. 699S02-145 213. 699S02-95 [.. ~ 238. 699S02-146
~
214. 699S02-97 - 239. 699S02-147 215. 699S02-96 & 97 Brace 240. 699S02-18 216. 699S02-27 241. 699S02-19 217. 699S02-28 242. 699502-20 218. 699S02-29 243. 699S02-22 219. 699S02-30 244. 699S02-23 220. 699S02-31 245. 699S02-24 221. 699S02-35
- 246. 699S02-25 (" Temp. Support")
222. 699502-36 247. 699S02-26 __ 223. 699502-37 248. 699S02-21 224. 699S02-38 249. 699S02-117 225. 699302-39 250. 699S02-116
- Rev.1, 05/27/81
251. 699502-115 276. 699S02-144 252. 699502-114 277. 699502-43 253. 699502-113 278. 699S02-14 254. 699S02-112 279. 699S02-1 255. 699S02-111 & 112 280. 699S02-136 256. 699S02-111 281. 699S02-137 257. 699S02-110 282. 699S02-133 258. 699S02-109
- 283. DELETE 259. 699S02-109 & 108
- 284. DELETE 260. 699502-108 285. 699S02-143 261. 699S02-107 286. 699S02-56 262. 699S02-91 287. 699S02-50 263. 699S02-62 g . 288. 699S02-51 264. 699S02-88 - 289. 699S02-49 265. 699502-119 290. 699S02-47 266. 699502-118 291. 699S02-46 267. 699S02-L5 292. 699S02-101 & 100 268. 699S02-16 293. 699S02-101 269. 699S02-17 294. 699S02-102 270. 699S02-45
- 295 699S02-103 (" Temp. Support")
271. 699S02-48 296. 699S02-104 272. 699502-55 297 699S02-105 l 273. 699S02-54 298. 699S02-106 274. 699S02-53
- 299. DELETE 175. 699S02-52
- 300. DELETE
- Rev.1, 05/27/81
301. 7026-EC260*2-3 326. 699S02-63
- 302. DELETE 327. 699502-64 l
- 303. DELETE 328. 699S02-65
- 304. DELETE 329. 699S02-68
- 305. DELETE 330. 699S02-89 l
- 306. DELETE 331. 699S02-90 0 307. DELETE 332. 699S02-92
- 308. DELETE 333. 699S02-93
- 309. DELETE 334. 699S02-94
- 310. DELETE
- 335. DELETE
- 311. DELETE 336. 697501-7 312. 699S02-32 337. 697S01-8 313. 699S02-33 338. 697S01-22 1
314. 699S02-34 7 339. 697S01-26 3 15. 699502-57 340. 7042-ED2374 316. 699S02-58 341. 7021-EC2399 317. 699S02-75 & 61
- 342. DELETE 318, 699S02-79
- 343. DELETE 3'1 9. 699S02-81 320. 699S02-82 321. 699S02-83 322. 699S02-84
, 323. 699S02-85 ,
324. 699S00-86 325. 699S02-87
- Rev. 1, 05/27/81
~ ,, . EXHIBIT NO. 8 .
REINSPECTION FCR & PW RESOLUTIONS REQUIRED FOR HVAC, CABLE TRAY AND CONDUIT SUPPORT HANGERS ELECTRICAL HVAC PW-AS-152 Rev. 2 FCR-AS-334 Rev. 1
- PW-AS-218 Rev. 2 FCR-aS-349 Rev. 1 FCR-AS-334 Rev. 1 FCR-AS-372 Rev. 1 PW-AS-346 FCR-AS-372 Rev. 1 PW-AS-347 FCR-AS-380 PW-AS-349 Rev. 1 FCR-AS-392 Rev. 1
- FCR-AS-350 FCR-AS-446 PW-AS-354 FCR-AS-483 PW-AS-356 PW-AS-508 FCR-AS-372 Rev. 1 PW-AS-509 PW-AS-380 PW-AS-510 PW-AS-391 PW-AS-511 PW-AS-392 Rev. 1 1 c- ,
PW-AS-414 j - FCR-AS-394 FCR-AS-395 FCR-AS-396 FCR-AS-397
- PW-AS-398 PW-AS-399 PW-AS-400 PW-AS-401 PW-AS-402 PW-AS-403 PW-AS-404 FCR-AS-405 FCR-AS-414 ;
FCE-AS-436 PW-AS-440 PW-AS-441 PW-AS-442 l PW-AS-443
- Rev.1, 05/27/81
.. o se ELECTRICAL (cont'd)
PW-AS-444 DCN-560-061 PW-AS-445 DCN-560-071 PW-AS-446 DCN-560-083 PW-AS-447 DCN-650-366 PW-AS-481 DCN-560-086 FCR-AS-483
- FCR-E-042 PW-AS-489
- FCR-E-022 FCR-AS-496
- FCR-E-093 PW-AS-497
- FCR-E-083 PW-AS-499
- FCR-E-079 PW-AS-500
- DCN-650-558 PW-AS-519 PW-AS-520 PW-AS-521 PV -AS-522 PW-AS-523 <_
FCR-AS-524 PW-AS-527 , PW-AS-541 PW-AS-546 PW-AS-547 DCN-650-406 FCR-E-078 DCN-560-076 FCR-E-041 FCR-E-060 PW-AS-215 PW-AS-152 Rev. 1 FCR-AS-314 Rev. 1 ! FCR-AS-372 Rev. 1 DCN-560-026 l DCN-560-033 DCN-560-043
- Rev. 1, 05/27/S1 l
dpsM*:oq#o ~ UNITED STATES l 8 m g NUCLEAR REGULATORY COMMISSION , 3 r REGION 11
- 101 MARIETTA St., N.W.. SUITE 3100 9, , ,
e ATI.ANTA, GEORGIA 30303 g, .* . . . . [ Report Nos. 50-400/81-12, 50-401/81-12, 50-402/81-12 and 50-403/81-12 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name: Shearon Harris Docket Nos. 50-400, 50-401, 50-402 and 50-403 License Nos. CPPR-158, CPPR-159, CPPR-160 and CPPR-161 Inspection at Harris site near Raleigh, North Carolina Inspector: b- ? # N G. F. MaWietil, Senior Retfdent Inspector Data Signed Approved by: b _ C. A. Juliam,/ Acting Sectfon Chief, Division of 7[//8I Date Signed Resident and Reactor Project Inspection (
SUMMARY
- Inspection on May 20 - June 20,1981 Areas Inspected This routine, inspection involved 87 resident inspector-hours onsite in the areas of followup on previously identified items; equipment handling and storage, Units 1-4; concrete and soil, Units 1-4 and welding, Units 1-2.
Results Of the four areas inspected, no violations or deviations were identified.
,' i l'.
-. _r- - _ _ - , ,--
l REPORT DETAILS
- 1. Persons Contacted ,
Licensee Employees "S. D. Smith, Vice President, Construction
*R. M. Parsons, Site Manager
*N. J. Chiangi, Manager Engineering and Construction QA/QC
*G. L. Forehand, Director QA/QC
*A. M. Lucas, Senior Resident Engineer
*8. Seyler, Principal Civil Engineer
*0. C. Whitehead, Senior QA/QC Specialist
*L. E. James, Principal QA Engineer
*E. L. Betz, Project QA Specialist
*R. Hanford, Principal Engineer - Welding
*T. J. Wait, QA/QC Specialist Other licensee employees contacted included 30 construction craftsmen, 10 technicians and 15 office personnel.
Other Organizations ([ *W. D. Goodman, Daniel Construction Company Project Manager
*J. Kirk, Daniel Construction Company Assistant Project Manager
- Attended exit interview
- 2. Exit Interview The inspection scope and findings were summarized on May 29 and June 19, 1981, with those persons indicated in paragraph 1 above. ,
- 3. Lic'ensee Action on Previous Inspection Findings
- a. (Closed) Deficiency 400/80-17-01; 401, 402, 403/80-15-01: " Failure to minimize onsite road dust generated by routine construction activities and vehicular traffic." CP&L letter of response dated ' October 23, 1980, and RII letter to CP&L dated October 28, 1980, and results of
, telephone conversation on October 17, 1980, and subsequent observations
. by the onsite USNRC resident inspector reveals that sufficient corrective action has been taken to provide the necessary water for minimizing onsite road dust. This item is closed.
- b. (Closed) Infraction 400/80-22-01: " Failure to correctly translate and implement codes and standards for. special processes." CP&L letters of response dated December 9, 1980, and subsequent evaluations of the responses reveal 'tnat suff1ctent corrective action has been taken to provide adequate control of the installation and inspection of pipe hangers as they relate to the above listed infraction. This item is
2 l I closed; however, during subsequent RII inspections the implementation of CP&L's corrective action to avoid further noncompliances will be closely monitored.
- 4. Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragraph 7.d.
- 5. Equipment Handling and Storage Units 1-4
- a. The inspector observed the stored condition of the reactor vessel for Units 1 - 4, the steam generators for Units 1-2 and the Unit 1 pressurizer.
- b. The inspector observed portions of the receipt inspection, storage and the rigging for off-loading of emergency diesel generator engine serial number 740462643.
In the areas inspected, no violations or deviations were identified. ( 6. Concrete and Soil, Units 1-4
- a. The inspector observed portions of concrete placements being made in:
Unit 1 containment building (pour numbered 1CBXW240001); reactor auxiliary common building, (pour numbered 2RASL236009). The concrete forms were tight, clean and level. Activities pertaining to delivery time, free ' fall, consolidation and testing conformed to specification requirements, concrete placement activities were continuously monitored by inspection personnel.
- b. The inspector toured the storage areas for the concrete batch plant cement and aggregate stock piles. The inspector questioned the cleanliness of the number four stone; CP&L QA personnel ran an information only wash test (ASTM C-117) on the aggregate in question.
The results of the test indicated that the aggregate did not contain excessive clay or other aggregate particles.
- c. The inspector toured the concrete test lab and observed the stored condition of the concrete test cylinders in the curing room. A set of cylinders was randomly selected by the inspector (from pour number 2RASL236009); the documentation for the cylinders showed the correct identification and revealed acceptable compressive strength test results.
, d. The inspector observed stil backfill operations and the test results
- for the soil being placed onto the service wacer piping located l North-West of Unit 2 containment (N2310-2355/W1755-1820).
l (
3
/
- e. The inspector observed the in process structural inspections of the main and west auxiliary dams, spillways, piezometers, settlement monuments and dam outlet channel. The inspections were conducted by the design engineer (EBASCO) and CP&L representatives for compliance with Regulatory Guide 1.127 and ESASCO specification CAR-SH-CH-24.
In' the areas inspected, no violations or deviations were identified.
- 7. Welding - Units 1 and 2
- a. The inspector observed the inspections and the as found conditions for the following weld joints:
(1) 1-SW-521-FW-1776 (observed fit-up) (2) 5-FP-101-SW-1 (observed final visual) (3) 1-BR-136 cW-486 (observed purge) (4) 2-SC-1-FW-16 (observed final visual) (5) 2-SC-1-FW-12 (observed final visual)
- b. The inspector participated in a site inspection conducted by another RII inspector; the inspection involved: observation of in process ASME Section III, Class two and three welds; observation of class 1E cable
, tray supports and observation of as found condition of structural welds. The results of the inspection are documented in RII reports numbered 50-400, 401, 402, 403/81-11.
- c. The inspector selected ten controlled documents which were being utilized by craft personnel for the installation of electrical class 1E
! raceway supports. The documents were found to be of the most current revisions and contained sufficient details required to conduct the installations. -
1 ( d. The inspector observed the as found condition of stud welds which were installed for the purpose of fastening class 1E conduit pull boxes into their support brackets (boxes numbered B 141558, 8141458, B139758 and
, B1537S8). The inspector questioned site CP&L engineering and inspection personnel concerning the type fasteners to be utilized to fasten the conduit pull boxes to the installed studs. As a result; the inspector was not shown nor could site CP&L personnel provide the design information (drawing or specification) to be followed in
~
selecting and installing the fasteners (nuts) for Class 1E seismic I mounted conduit pull boxes. This is an unresolved item l (50-400/81-12-01).
. 1
\. In the areas inspected, no violations or deviations were identified.
1 0 < l o ' 440.49 Provice a discussion of mechods used to insure taat tnE EC; system . (6.3) is placed and maintained in a wate'r filled concition to preclude tne / effects or water hammer, ' Rosponse :
, ECCS piptng is designed such that normal systoa operatio,n and testing assures that the systems remain water-filled to preclude ,
~
the effects of water hammer. Interfaces with normally _ pressurized non-ECCS systems preclude a lose of water from SCCS systems. Leakage from ECCS systems through valve packing, pump
- seals. etc., will be detected by a number of methods including: 1) normal operator rounds, 2) performance during testing, 3) the plant leak reduction inspection peogram, 4) various sump level alarms, 5) decreasing water levels in various tanks. Should significant leakage be discovered, where an introduction of air into the system could have occurred, provisions have been made in the system design to permit raf tlling and venting of the affected components or piping following repair to the sourca of leakage.
4 e t l [
00LKETED U'34RC January 31, 1983
'83 FEB -3 P2 52 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ^ ^ T ?
a:S . u '.'. . M;Of BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
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 and 2) ) APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR CHANGE (FIRST SET) Pursuant to 10 C.F.R. SS 2.740b and 2.741 and to the Atomic Safety and Licensing Board's " Memorandum and Order (Reflecting Decisions Made Following Prohearing Conference)" of September 22, 1982, Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that Intervenor Chapel Hill Anti-Nuclear Group / Environmental Law Project (" CHANGE") answer separately and fully in writing, and under oath or affirmation, each of the following interroga-tories, and produce and permit inspection and copying of the original or best copy of all documents identified in the response to interrogatories below. l
l Under_the Commission's Rules of Practice, answers or objections-to these interrogatories must be served within 14 days after service of the interrogatories; responses or objections to the request for production of documents must be served within 30 days after service of the request. These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. S 2.740(e), should CHANGE or any individual acting on its behalf obtain any new or differing information responsive to these interroga-tories. The request for production of documents is also continuing in nature and CHANGE must produce immediately any additional documents CHANGE, or any individual acting on its behalf, obtains which are responsive to the request, in accordance with the provisions of 10 C.F.R. $ 2.740(e). Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, tran-script, report, handwritten notes, test data) and provide the following iniormation as applicable: Document name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person or persons having possession of the document. Also state the portion or portions of the document (whether sec-tion (s), chapter (s), or page(s)) upon which you rely. 1
Definitions. As used hereinafter, the following defini-tions shall apply: The "ER" is-the Environmental Report - Operating License Stage for the Shearon Harris Nuclear Power Plant, as amended. The "FSAR" is the Final Safety Analysis Report for the Shearon Harris Nuclear Power Plant, as amended.
" Applicants" is intended to encompass Carolina Power &
Light Co., North Carolina Eastern Municipal Power Agency and their contractors for the Harris-Plant.
" Document (s)" means all writings and records of every type in the possession, control or custody of CHANGE or any individual acting on its behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings and all other writings or recordings of any kind; " document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody, or control of CHANGE, a document shall be deemed to be within the " control" of CHANGE or any individual acting on its behalf if they have ownership, possession or custody of the document or copy thereof, or have the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.
f
General Interrogatories 1(a). State the name, present or last known address, and present or last known employer of each person known to CHANGE to have first-hand knowledge of the facts alleged, and upon which CHANGE relied in formulating allegations, in each of the contentions which are the subject of this set of interroga-tories. (b). Identify those facts concerning which each such person has first-hand knowledge. (c). State the specific allegation in each contention which CHANGE contends such facts support. 2(a). State the name, present or last known address, and present or last employer of each person, other than affiant, who provided information upon which CHANGE relied in answering each interrogatory herein. (b). Identify all such information which was provided by each such person and the specific interrogatory response in which such information is contained. 3(a). State the name, address, title, employer and educational and professional qualifications of each person CHANGE intends to call as an expert witness or a witness relating to any contention which is the subject of this set of interrogatories.
l l (b). Identify the contention (s) regarding which each such person is expected to testify. (c). State the subject matter to which each such person is expected to testify. 4(a). Identify all documents in CHANGE's possession, custody or control, including all relevant page citations, pertaining to the subject matter of, and upon which CHANGE relied in formulating allegations in each contention which is the subject of this set of interrogatories. (b). Identify the contention (s) to which each such document relates. (c). State the specific allegation in each contention which CHANGE contends each document supports. 5(a). Identify all documents in CHANGE's possession, custody or control, including all relevant page citations, upon which CHANGE relied in answering each interrogatory herein. (b). Identify the specific interrogatory response (s) to which each such document relates. 6(a). Identify any other source of information, not previously identified in response to Interrogatory 2 or 5, which was used in answering the interrogatories set forth herein. i
(b). Identify the specific interrogatory response (s) to which each such source of information relates. 7(a). Identify all documents which CHANGE intends to offer as exhibits during this proceeding to support the contentions which are the subject of this set of interroga-tories or which CHANGE intends to use during cross-examination of witnesses presented by Applicants and/or the NRC Staff on each contention which is the subject of this set of interroga-tories. (b). Identify the contention (s) to which each document relates and the particular page citations applicable to each contention. Interrogatories on Contention 44 (Reactor Vessel Level Instrumentation System) 44-1. Westinghouse has developed a Reactor Vessel Level Instrumentation System ("RVLIS"), suitable for installation in operating plants and plants under construction, to meet the f recommendation of Item II.F.2 of NUREG-0737 (TMI Action Plan) for additional instrumentation to detect inadequate core cooling. The RVLIS is designed to provide a relatively simple and straight forward means to monitor the water level in the reactor vessel, and serves to provide additional information to ; the operator during accident conditions. The RVLIS utilizes l l differential pressure (d/p) measuring devices to indicate water l l
level and relative void content of the circulating primary j coolant system fluid. The NRC Staff's review, which accepts the Westinghouse RVLIS, is reported in NUREG/CR-2628. If Applicants commit to install the Westinghouse RVLIS at SHNPP, is your Contention 44 satisfied? If not, explain in detail the basia for the answer. 44-2. If Applicants commit to install the Westinghouse RVLIS at SHNPP, will CHANGE voluntarily withdraw Contention 44? If not, explain in detail the basis for the answer. Interrogatories on Contention 79(c) ~(Regulatory Costs) 79(c)-1. Section 8.2.2.1.a of the ER (Amend. 5) contains estimates of the regulatory costs, at both the state and federal levels, associated with the Harris Plant. Does the provision of this information in the ER satisfy your Contention 79(c)? If not, explain in detail the basis for the answer. 79(c)-2. If the answer to the preceding interrogatory is affirmative, will CHANGE voluntarily withdraw Contention 79(c)? If not, explain in detail the basis for the answer. REQUEST FOR PRODUCTION OF DOCUMENTS Applicants request that CHANGE respond in writing to this request for production of documents and produce the original or best copy of each of the documents identified or described in
the answers to each of the above interrogatories at a place mutually convenient to the parties. Respectfully submitted, George F. Trowbridge, P.C. Thomas A. Baxter, P.C. John H. O'Neill, Jr. SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W. Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 26602 (919) 836-7707 DATED: January 31, 1983 I ( ___
r y v - 000gifD t%m JangrYEn2 1"9g2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In'the Matter of )
)
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 and 2) ) APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO JOINT INTERVENORS (FIRST SET) Pursuant to 10 C.F.R. SS 2.740b and 2.741 and to the Atomic Safety and Licensing Board's " Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference)" of September 22, 1982, Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that Joint Intervenors (CHANGE, CCNC, Kudzu Alliance and Wells Eddleman) answer separately and fully in writing, and under oath or affirmation, each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identified in the responses to interrogatories below. In accordance with informal discussions held among the parties, Applicants request that Joint I
l Intervenors serve a single, consolidated set of answers and responses to these discovery requests. Under the Commission's Rules of Practice, answers or objections to these interrogatories must be served within 14 days after service of the interrogatories; responses or objections to the request for production of documents must be served within 30 days after service of the request. These interrogatories are intended to be continuing in
- nature, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. 5 2.740(e),
should Joint Intervenors or any individual acting on their behalf obtain any new or differing information responsive to these interrogatories. The request for production of documents is also continuing in nature and Joint Intervenors must produce immediately any additional documents they, or any individual acting on their behalf, obtain which are responsive to the request, in accordance with the provisions of 10 C.F.R. f 2.740(e). Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, tran-script, report, handwritten notes, test data) and provide the following information as applicable: Document name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person or persons having possession of the document. Also i _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ . . . . _ _ _ . -
state the portion or portions of the document (whether section(s), chapter (s), or page(s)) upon which Joint Intervenors rely. Definitions. As used hereinafter, the following defini-tions shall apply: The "ER" is the Environmental Report - Operating License Stage for the Shearon Harris Nuclear Power Plant, as amended. The "FSAR" is the Final Safety Analysis Report for the Shearon Harris Nuclear Power Plant, as amended.
" Applicants" is intended to encompass Carolina Power &
Light Co., North Carolina Eastern Municipal Power Agency and the'.r contractors for the Harris Plant.
" Joint Intervenors" in intended to encompass the following organizations and individuals, jointly and severally: Chapel Hill Anti-Nuclear Group Effort, the Environmental Law Project, the Conservation Council of North Carolina and the Kudzu Alliance, as organizations, their members, and their represen-tatives, and Mr. Wells Eddleman.
" Document (s)" means all writings and records of every type in the possession, control or custody of Joint Intervenors or any individual acting on their behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings and all other writings or recordings of any
kind; " document (s)" shall also mean copies of documents even thougn the originals thereof are not in the possession, custody, or control of Joint Intervenors, a document shall be deemed to be within the " control" of Joint Intervenors or any individual acting on their behalf if they have ownership, possession or custody of the document or copy thereof, or have the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof. GENERAL INTERROGATORIES 1(a). State the name, present or last known address, and present or last known employer of each person known to Joint Intervenors to have first-hand knowledge of the facts alleged, and upon which Joint Intervenors relied in formulating allega-tions, in each of the contentions which are the subject of this set of interrogatories. (b). Identify those facts concerning which each such person has first-hand knowledge. (c). State the specific allegation in each contention which Joint Intervenors contend such facts support. 2(a). State the name, present or last known address, and present or last employer nf each person, other than affiant, who provided information upon which Joint Intervenors relied in answering each interrogatory herein. t L
(b). Identify all such information which was provided by each such person and the specif.c interrogatory response in which such information is contained. 3(a). State the name, address, title, employer and educational and professional qualifications of each person Joint'Intervenors intend to call as an expert witness or a witness relating to any contention which is the subject of this set of interrogatories. (b). Identify the contention (s) regarding which each such person is expected to testify. (c). State the subject matter to which each such person is expected to testify. 4(a). Identify all documents in Joint Intervenors' possession, custody or control, including all relevant page citations, pertaining to the subject matter of, and upon which Joint Intervenors relied in formulating allegations in each contention which is the subject of this set of interrogatories. (b). Identify the contention (s) to which each such document relates. (c). State the specific allegation in each contention which Joint Intervenors contend each document supports. 5(a). Identify all documents in Joint Intervenors' possession, custody or control, including all relevant page
citations, upon which you relied in answering each interrogatory herein. (b). Identify the specific interrogatory response (s) to which each such document relates. 6(a). Identify any other source of information, not previously identified in response to Interrogatory 2 or 5,
- which was used in answering the interrogatories set forth herein.
(b). Identify the specific interrogatory response (s) to which each such source of information relates. 7(a). Identify all documents which Joint Intervenors I intend to offer as exhibits during this proceeding to support the contentions which are the subject of this set of interroga- , i tories or which Joint Intervenors intend to use during cross-examination of witnesses presented by Applicants and/or the NRC Staff on each contention which is the subject of this set of interrogatories. I (b). Identify the contention (s) to which each document relates and the particular page citations applicable to each contention. 1
\
l 1 INTERROGATORIES ON JOINT CONTENTION IV (TLDs) l IV-1(a). Describe in detail the additional personnel radiation exposure monitoring instruments (including range, sensitivity and qualifications) which Joint Intervenors contend are necessary in order to assure the protection of worker safety and health at the Harris Plant. (b). State in detail all facts which support Joint Intervenors' contention that the instruments identified in the answer to the preceding interrogatory are necessary. IV-2(a). Do Joint Intervenors contend that thermolumines-cent dosimeters ("TLDs") are inadequate to measure cumulative radiation doses as required by 10 C.F.R. Part 20? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to Interrogatory IV-2(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention IV. IV-3(a). Do Joint Intervenors contend that portable pressurized ionization monitors are capable of measuring cumulative radiation doses as required by 10 C.F.R. Part 2O? J
(b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to Interrogatory IV-3(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth-in Joint Contention IV. IV-4(a). As discussed in FSAR SS 12.5.3.2.2.2 and 12.5.3.6.1.1, self-reading dosimeters will be utilized, as necessary, for both specific job exposure evaluations and to indicate current individual exposure status. Do Joint Intervenors contend that these self-reading dosimeters do not provide workers with a real-time radiation exposure monitoring capability? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to Interrogatory IV-4(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention l IV. IV-5(a). Do Joint Intervenors contend that the self-reading dosimeters, discussed in FSAR $$ 12.5.3.2.2.2 and 12.5.3.6.1.1, are inadequate to assure worker safety and health in radiation hazard areas?
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, 1 (b). If the answer to the preceeding interrogatory is . l affirmative, state in detail all facts which support this ' allegation. (c). If the answer to Interrogatory IV-5(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention IV. IV-6(a). De Joint Intervenors contend that the monitoring ranges of the self-reading dosimeters, described in FSAR S 12.5.2.1.7.4, are inadequate to protect worker safety and health? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to Interrogatory IV-6(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention IV. IV-7(a). Do Joint Intervenors contend that the self-reading dosimeters, discussed in FSAR SS 12.5.3.2.2.2 and 12.5.3.6.1.1, are inadequate to corroborate the exposures indicated by TLDs? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. _g.
l (c). If the answer to Interrogatory IV-7(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention IV. INTERROGATORIES ON JOINT CONTENTION V (AIR MONITORS AND SAMPLERS) V-1(a). Would a commitment by Applicants to meet the provisions of NRC Regulatory Guide 8.25 (relevant pages attached hereto as Appendix 1) regarding calibration frequency satisfy Joint Intervenors' concerns with respect to the issue of the frequency at which the continuous air monitors and portable air samplers will be calibrated? (b). If the answer to the preceding interrogatory is negative, state in detail the basis for Joint Intervenors' disagreement with the Regulatory Guide 8.25 provisions regarding calibration frequency. (c). If the answer to Interrogatory V-1(a) is affirma-tive, will Joint Intervenors voluntarily withdraw Joint Contention V? If not, explain in detail the basis for the answer. V-2(a). If the answer to Interrogatory V-1(a) is nega-tive, identify the frequency at which Joint Intervenors contend that the portable air samplers and continuous air monitors must be calibrated.
(b). State in detail all facts which support Joint Intervenors' contention that the portable air samplers and continuous air monitors must be calibrated at the frequency identified in the answer to the preceding interrogatory. V-3(a). Do Joint Intervenors contend that the portable air samplers and continuous air monitors are required to be accurate within plus or minus 5%? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to Interrogatory V-3(a) is other l than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention V. V-4(a). Do Joint Intervenors contend that NRC Regulatory Guide 8.25 is inadequate in allowing for a cumulative error in airflow calibrations of less than 20%? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to Interrogtory V-4(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention l l V. INTERROGATORIES ON JOINT CONTENTION VI (RADIATION DETECTION AND MONITORING) VI-1. FSAR 5 11.5.2.5 describes the types of radiation detectors to be used in the Harris Plant Radiation Monitoring System ("RMS"). With respect to each detector type identified therein, identify any alleged inadequacies of the detector type in question. VI-2(a). Do Joint Intervenors contend that the alleged inadequacies identified in the answer to the preceding inter-rogatory will prevent the RMS from carrying out its intended function? f (b). If the answer the the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to Interrogatory VI-2(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention VI. VI-3(a). FSAR S 11.5.2. also identifies the types and amounts of radiation which will be monitored by each type of detector. Do Joint Intervenors contend that other specific radionuclides must be identified and monitored by the RMS? (b). If the answer to the preceding interrogatory is affirmative, identify each specific additional radionuclide l 1
which Joint Intervenors contend must be identified and monitored by the RMS. (c). For each specific radionuclide identified in the answer to the preceding interrogatory, state (1). the basis for Joint Intervenors' conten-tion that such radionuclides must be identified and monitored; and (ii). the additional protective actions which could be undertaken based upon knowledge of the concentration and/or release of each such radionuclide beyond those actions which would be initiated based on information derived from the RMS as currently designed. VI-4(a). FSAR S 11.5.2.7 describes the Process and Effluent Radiological Monitors, monitor locations and associa-ted read-outs and alarms. Do Joint Intervenors contend that additional monitors are required in order to determine process and effluent radiological concentrations and/or releases? (b). If the answer to the preceding interrogatory is affirmative, identify the type and proposed location of the additional monitors which Joint Intervenors contend are required. (c). State in detail all factr which support Joint Intervenors' contention that the additional monitors identified in the answer to the preceding interrogatory are required. r I l (d). If the answer to Interrogatory VI-4(a) is other i than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention VI. l VI-5(a). Do Joint Intervenors contend that the read-outs and alarms associated with the Process and Effluent Radiological Monitors are inadequate? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to Interrogatory VI-5(a) is affirmative, identify the additional read-outs and alarms for the Process and Effluent Radiological Monitors which Joint Intervenors contend are required. (d). If the answer to Interrogatory VI-5(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention VI. VI-6(a). FSAR $ 12.3.4.1 describes the Area Radiation Monitoring System, monitor locations and associated read-outs l and alarms. Do Joint Intervenors contend that the Area Radiation Monitoring System is inadequate to accomplish its intended purposes, as set out in FSAR f 12.3.4.1.1? l
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(b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to Interrogatory VI-6(a) is affirmative, describe in detail all modifications to the Area Radiation Monitoring System which Joint Intervenors contend are required. (d). If the answer to Interrogatory VI-6(a) is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention VI. VI-7(a). FSAR 5 12.3.4.2 describes the Airborne Radiation Monitoring System, monitor locations and associated read-outs and alarms. Do Joint Intervenors contend that the Airborne Radiation Monitoring System is inadequate to accomplish its intended purposes, as set out in FSAR S 12.3.4.2.1? (b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this allegation. (c). If the answer to Interrogatory VI-7(a) is affirmative, describe in detail all modifications to the Airborne Radiation Monitoring System which Joint Intervenors contend are necessary.
(d). If the answer to Interrogatory VI-7(a) is other 4 than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention VI. REQUEST FOR PRODUCTION OF DOCUMENTS Applicants request that Joint Intervenors respond in writing to this request for production of documents and produce the original or best copy of each of the documents identified or described in the answers to each of the above interroga-tories at a place mutua'lly convenient to the parties. Respectfully submitted, George F. Trowbridge, P.C. Thomas A. Baxter, P.C. John H. O'Neill, Jr. SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W. Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 26602 (919) 736-7707 Dated: January 31, 1983 I I
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# :gr% August 1980 U.S. NUCLEAR REGULATORY COMMISSION (M w */
o.***. REGULATORYdUf0E" OFFICE OF STANDARDS DEVELOPMENT REGULATORY GUIDE 8.25 (Task OH 905-41 CAllBRATION AND ERROR LIMITS OF AIR SAMPLING INSTRUMENTS FOR TOTAL VOLUME OF AIR SAMPLED A. INTRODUCTION IV of this manualprovide sources of published, recommended, or standard methods;a summary of recommended standard Paragraph (a)(3) of Q 20.103," Exposure of Individuals to methods; and a listing of calibration instruments and their Concentrations of Radioactive Materialsin Air in Restricted suppliers. Areas," of 10 CFR Part 20, " Standards for Protection Against Radiation," requires that licensees use suitable This guide supplements the instructions in this manual measurements of concentrations of radioactive materialsin by adding guidance for frequency of calibration, for accept-air for detecting and evaluating airborne radioactivity in able error limits in volume measurement, and for documen-restricted areas. In addition, paragraph (c)(4) of 20.106, tation.
" Radioactivity in Effluents to Unrestricted Areas," requires that licensees provide information as to the highest concen-tration of eaJ1 radionuclide in an unrestricted area, a C. REGULATORY POSITION procedure that in many cases requires air monitoring beyond the restricted area. This guide identifies methods acceptable to the NRC staff for calibrating air sampling 'Ilic publication entitled " Air Sampling Instruments for instruments for total volume of air sampled and provides Evaluation of Atmospheric Contaminants,"I Sth Edition, guidance for ensuring that volumes of air sampled are 1978, provides guidance on total air sample volume calibra-known within certain limits. tion methods acceptable to the NRC staff, as supplemented below:
B. DISCUSSION
- 1. FREQUENCY OF CALIBRATION In order to accurately assess the air concentration of radioactive materials in a given location, the volume of air A licensee committed to a reutine or emergency air sampled as well as the quantity of contaminant in the sampling program should perform an acceptable calibration sample must be determined. Accurate determination of the of all airflow or volume metering devices at least once every volume of air sampled requires standard, reproducible, 6 months, with the exception of permanently installed and frequent calibration of the air metering devices that are cifluent monitors.2 Special calibrations should be performed used with air sampling instruments. at any time there is reason to believe that the operating characteristics of a metering device have been changed, by The American Conference of Governmental Industrial repair or alteration, or whenever system performance is flygienists has published a manual entitled " Air Sampling observed to have changed significantly. Routine instrument Instruments for Evaluation of Atmospheric Contaminants,"3 maintenance should be performed as recommended by the 5th Edition,1978. Part II, Section I, " Calibration of Air manufacturer. Primary or secondary standard instruments Sampi ag Instruments," of this manual provides instructions used to calibrate air sampling instnanents should be inspected for acceptable methods of calibrating air volume and frequently for consistency of performance.
flow rate metering devices. In particular, Tables II,III, and 2 See NUREG-o472," Radiological Efnuent Technical Specifica. 3 tions for PWRs " July 1979, and NUREG-0473, " Radiological Copies are available from the American Conference of Govern. Efnuent Technical Specifications for BWRs," July 1979, which mental Industrial Hygienists, P.O. Box 1937, Cincinnati, Ohio 4 s 2ol. specify calibration at least once every la months. USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Comrnission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 Regulatory Guides are issued to describe and make avaHable to the Attention: Docketing and Service Branch, pubite methods acceptable to the N R C staff of implementing specific parts of the Commission's regulations, to delineate tech. The gulde; are issued in the following ten broad divisions: niques used by the staff in evaluating specific problems or postu. lated accidents or to provide guidance to appilcants. Regulatory 1. Power Reactors 6. Products Guldes are noi substitutes for regulations, and compilance with 2. Research and Test Reactors 7. Transportation them is not required. Methods and solutions different from those set 3. Fuels and Materials Facilities 8. Occupational Health out in the guides will be acceptable if they provide a basis for the 4. Environmental and Siting 9. Antitrust and Financial Review findings requ6 site to the issuance or continuance of a permit or 5. Materials and Plant Protection lo. General license by the Commission. Copies of issued guides may be purchased at the current Government Comments and suggestions for improvements in these guides are Printing Office price. A subscription service for future guides in spe. encouraged at all times, and guides will be revised, as appropriate, cific divisions is available througn the Government Printing Office. to accommodate comments and to reflect new information or information on the subscription service and current GPO prices may cuperience. This guide was revised as a result of substantive com. De ootained by writing the U.S. Nuclear Regulatory Commission, ments received from the public and additional staff review, wasn6ngton, D.C. 20555 Attention: Publications Sales Manager.
, .' r the determination of total volume,is less than 20 percent.
- 2. ERRORLIMIT FORMEASUREMENTOF AIRSAMPLE This analysis assumes a linear change in the flow rate across VOLUME the sample collector during the sampling period when flow Most methods of calibrating airflow or air volume metering rate meters are used. In turn, this assumption allows simple devices require direct comparison to a primary or secondary averaging of the initial and final flow rates for a single sample.
standard instrument to determine a calibration curve or a correction factor. An example of a primary standard is a spirometer that measures total' air volume directly with high if there are significant differences in pressure and temper-ature between the calibration site and the sampling site, precision by liquid displacement. An example of a secondary standard is a wet-test meter that has been calibrated against appropriate corrections should be made using the ideal gas a primary standard. Primary atandards are usually accurate laws as discussed in the previously described manual. to within 1 percent and secondary standards to within 2 A sample calculation of the most probable value of the percent. cumulative error in total volume measured is as follows:If The significant errors associated with determining the accuracies of the scale reading, the calibration factor, and total air volume sampled are: sample time are +4,2, and I percent,respectively,and there are no other significant sources of error, the cumulative E: The error in determining the calibration factor, error would be: e (An acceptable estimate is the percent error associated with the standard instrument used in Ey = [4 2 + 22 , g j 2% = 4.58% or N 5% the calibration.)3
- 3. DOCUMENTATION OF CALIBRATION OF AIR E,: Intrinsic error in reading the meter scale. (An METERING DEVICES acceptable estimate is the percent equivalent of one-half of the smallest scale division compared to The licensee should maintain records of all routine and the scale reading.) special calibrations of airflow or volume metering devices, including the primary or secondary standard used, method E: The percent error in measurement of sampling employed, and estimates of accuracy of the calibrated t
time that should be kept within 1 percent. metering devices. Allinstruments should be clearly labeled as to the date and results of tl:e most recent calibration and E:y The most probable value of the cumulative percent should include the appropriate correction factors to be used, error in the determination of the total air volume sampled. D. IMPLEMENTATION Eycan be calculated from the following equation pro-vided there are no additional significant sources of errors: The purpose of this section is to provide information to applicants and licensees regarding the NRC staff's plans for 2 using this regulatory guide. Ey = [E2+E2+E3% Air sampling instruments, including those personal Except in those cases in which an applicant or licensee (lapel) samplers that have flow rate meters, should have proposes an acceptable alternative method for complying flow rate or total volume metering devices calibrated so with @20.103 and 20.106 of the Commission's regula-that the most probable value of the cumulative error Ey ,in tions, the staff will use the method described herein in the evaluation of ongoing and proposed air monitoring pro-Erams after November 15,1980. 3The calibration factor should be based on two kinds of deter. minations. First, correction factors should be determined at several If an applicant or licensee wishes to use the method e trectN'n' f!ctoYs"h !uld bY deterNiNd whiWa'dus n w ra es upscale and again while adjusting !)ow rates downscale and the two described in this regulatory guide on or before November 15, sets of data should be compared. Second, subsequent calibrations 1980, the pertinent portions of the application or the should compare the new correction factors to those determined during the previous calibration. If observed differences are signif* licensee's performance will be evaluated on the basis of icant compared to the overall volume error timit of 2o percent, an this guide. additional error term should be included in the calculation above. O 8.25-2
s I VALUF/ IMPACT STATEMENT
- 1. PROPOSED ACTION availability of acceptable calibration methods suitable for adoption in their programs.
1.1 Description . 1.3.3 Industry Many NRC licensees are required to maintain radiation and contamination survey programs, including air sampling, The value to industry in providing guidance on air' l t3 assess concentrations of airborne radionuclides. Regula- volume calibration procedures consists of the probable tory concentration values are specified in Appendix B to improvement in worker protection from more accurate 10 CFR Part 20. The proposed action is to provide guidance assessment of airborne radioactive material hazards. The far improving air sampling procedures in the form of impacts include equipment and manpower costs that do not receptable methods of calibrating air sampling instruments appear to be excessive in view of the proposed acceptable f r determining total volume of air sampled, frequency of methods and frequency of calibration requirements. The calibration, and documentation procedures. Measurement staff estimates the initial cost of an acceptable calibration of the total volume is required in the calculation of the system to be less than 3300 and approximate man-power concentration. requirements to be I to 2 man-hours per year per instrument. 1.2 Need for Proposed Action 1.3.4 Workers In order to accurately characterize the air quality of a For the workers, the values of improved air monitoring working environment, the volume of air sampled as well as include more accurate assessments of the quality of the the quantity of contaminant must be determined. Accurate working environment and a probable reduction in internal assessment of the quantity of air sampled requires frequent radiation exposure. Recent staff discussion with union calibration of air metering devices by standard, reproducible representatives indicates that there is anincreasing concern methods. To assess internal exposure resulting from airborne about exposure to airborne radioactive material on the part radioactive material and to evaluate working conditions, of workers in the industry. Continued NRC efforts to 9 ac.::ptable standard calibration and measurement methods must be developed. The Office of Nuclear Materials Safety increase our understanding of this aspect of radiation hazard and to improve monitoring and control of airborne and Safeguards requested the Office of Standards Develop- radioactivity is essential, ment to accelerate the schedule for issuing guidance to NRC licensees on acceptable methods for total volume 1.3.5 Public calibration and measurement. Environmental monitoring to assess the release of 1.3 Value/ Impact of Proposed Action radioactive materials in the vicinity of NRC-licensed facil-ities includes air sampling. Calibration procedures for 1.3.1 NRC Operations low-flow-rate, continuous air sampling instmments will be included. The public will benefit from increased reliability Acceptable methods for calibrating air sampling instru- of environmental measurements. ments provide additional criteria for inspection and enforce-ment of NRC radiation protection regulations. Increased 1.4 Decision accuracy in assessing airborne radioactive material concen-trations would provide a more reliable data base for develop- The NRC should develop and provide guidance on ing additional regulatory action to contrd and reduce acceptable total air volume calibration methods for those internal radiation exposure. Impacts of the development of types of radiological air sampling instruments used by guidance as described include task completion manpower licensees. cost, estimated to be 0.3 man-year, and printing costs of approximately 3300.
- 2. TECHNICAL APPROACH 1.3.2 Other Government Agencies The action proposed here is to provide guidance on Coordination with several governmental agencies (e.g., acceptable memods of calibrating airflow and air volume NBS, OSIIA, EPA) has been necessary to ensure consistency metering devices on radiological air samplers. Survey in cases where respective regulatory and monitoring func- programs and, where appropriate, air monitoring programs tions interface. Agreement States whoselicensingregulations are required of many NRC licensees. It is our intent that include air sampling requirements may benefit by the acceptable methods of air volume calibration be a required
{4 8.25-3
. T camp:nent cflicensee m nit: ring procedures. There are no regulatory guide could reference existing and acceptable technical alternatives to providing this guidance, standard calibration methods or adequately describe calibra-tion procedures acceptable to the NRC staff. The staff does
- 3. PROCEDURAL APPROACH not consider that revision of any existing regulatory guides could provide the objectives proposed here.
3.1 Procedural Alternatives 3.3 Decision on Procedural Approach The proposed action, to publish guidance on calibration procedures for radiological air sampling instruments, could The staff concludes that a regulatory guide adopting be accomplished by several methods: publishing an NRC acceptable methods for total air volume calibration for regulation requiring that specific calibration procedures be radiological air sampling instruments should be published. used by all licensees; preparing or revising a regulatory guide (based on the existing paragraph 20.201(b) of 10 CFR 4. STATUTORY CONSIDERATIONS Part 20) that would provide an acceptable method for calibration; developing an ANSI standard on calibration 4.1 NRC Regulatory Authority procedures that could be endorsed by a new regulatory
'giiide; or publishing a NUREG report or a branch position Paragraph 20.201(b) of 10 CFR Part 20 establishes alegal paper. requirement that each licensee make or cause to be made such surveys as may be necessary for him to comply with the 3.2 Value/ Impact of Procedural Alternatives regulations. The NRC is thur authorized to provide criteria for acceptable survey methodology, including calibration of An NRCregulation establishes generallegalrequirements, instrumentation.
is more costly and time consuming to prepare, and is not an appropriate vehicle for the specific and narrow objective pro- 4.2 Need for NEPA Statement posed here. One advantage is that a regulation legally requires compliance, in general, this approach is not considered cost The action proposed here is no't considered to constitute effective in view of the objective of the proposed action. a major addition or change and would entail no effect on the environment. The staff does not believe that an environ-ANSIstandards are generally intended as technical mental impact statement is necessary. treatments of broad areas of concern toindustry. An ANSI standard concerning all aspects of an acceptable monitoring 5. RELATIONSHIP'IV OTHER EXISTING OR PROPOSED program would be appropriate but beyond the narrower REGULATIONS OR POLICIES objective proposed here. Developing an ANSI standard and an endorsing regulatory guide might require several years Several regulatory guides concerning health physics and would be costly. This approach is not considered cost surveys at various types of NRC-licensed facilities such as effective in view of the proposed objective. Regulatory Guide 8.21," Health Physics Surveys for Bypro-duct Material at NRC-Licensed Processing and Manufactur-A NUREGreport would be an appropriate vehicle for ing Plants," are in preparation. These guides would appro-reporting on technical studies of various methods of calibrat- priately reference the guide proposed here. In addition, ing air samplers. Regulatory guidance, however, is not guides such as Regulatory Guide 1.70, " Standard Format established through publication of a NUREG report. and Content of Safety Analysis Reports for Nuclear Power Since this proposal includes establishing an acceptable Plants," will include a commitment to acceptable air method for compliance with required surveying programs, a sampler calibration procedures. When next revised, these NUREG report is not considered suitable. guides should include cross-references to this guide as an d acceptable element of a licensee's monitoring program. Branch porition statements are intended as interim measures to be used when animmediate responseis required. The proposed guide is consistent with Regulatory They are usually superseded when a more permanent mode Guide 8.8,"Information Relevant to Ensuring That Occupa-
. of guidance is developed. tional Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable." When next revised, Regula-A regulatoryguide can be prepared at reasonable cost tory Guide 8.8 should include a cross-reference to this guide.
within a reasonable time period. A regulatory guide can establish acceptable criteria for compliance with a regulatory 6.
SUMMARY
AND CONCLUSIONS requirement and,if incorporation into a license is requested, l is subject to inspection and enforcement. In summary, it is proposed that a regulatory guide be published for the purpose of providing guidance on accept-Developmert of a regulatory guide allowsextensiveinput able methods of calibrating radiological air sampling instru-from all segments of the nuclearindustry and the public. A ments for total volume of air sampled. O 8.25-4
DOCKETED Lwc January 31, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -
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BEFORE THE ATCMIC 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 )
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(Shearon Harris Nuclear Power ) Plant, Units 1 and 2) ) ; APPLICANTS' INTERROGATORIES . AND REQUEST FOR PRODUCTION OF DOCUMENTS TO CGNSERVATION COUNCIL OF NORTH CAROLINA (FIRST SET) Pursuant to 10 C.F.R. 55 2.740b and 2.741 and to the Atomic Safety and Licensing Board's " Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference)" of September 22, 1982, Carolina Power & Light Company and North Carolina Eastern Municipa'l Power Agency hereby request that the Conservation Council of North Carolina ("CCNC") answer separa-tey and fully in writing, and under oath or affirmation, each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identified in the responses to interrogatories below. Under the Commission's Rules of Practice, answers or objections to these interrogatories must be served within 14 days after service of the interrogatories; responses or
'4 objections to the request for production of documents must be served within 30 days after service of the request. l
)
These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. $ 2.740(e), should CCNC cr any individual acting on its behalf obtain any new or differing information responsive to these interroga-tories. The request for production of documents is also continuing in nature and CCNC must produce immediately any additional documents it, or any individual acting on its behalf, obtains which are responsive to the request, in accordance with the provisions of 10 C.F.R. $ 2.740(e). Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, tran-script, report, handwritten notes, test data) and provide the following information as applicable: Document name, title, number, author, date of publicati.on and publisher, addressee, date written or approved, and the name and address of the person or persons having possession of the document. Also state the portion or portions of the document (whether sec-tion (s), chapter (s), or page(s)) upon which Joint Intervenors rely. Definitions. As used hereinafter, the following defini-tions shall apply: The "ER" is the Environmental Report - Operating License Stage for the Shearon Harris Nuclear Power Plant, as amended.
The "FSAR" is the Final Safety Analysis Report for the Shearon Harris Nuclear Power Plant, as amended.
" Applicants" is intended to encompass Carolina Power &
Light Co., North Carolina Eastern Municipal Power Agency and their contractors for the Harris Plant.
" Document (s)" means all writings and records of every type in the possession, control or custody of CCNC or any individual acting on its behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings and all other writings or recordings of any kind; " document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody, or control of CCNC a document shall be deemed to be within the " control" of CCNC or any individual acting on its behalf if CCNC or such individual has ownership, possession or custody of the document or copy thereof, or has the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.
GENERAL INTERROGATORIES 1(a). State the name, present or last known address, and present or last known employer of each person known to CCNC to have first-hand knowledge of the facts alleged, and upon which
b CCNC relied in formulating allegations, in each of the contentions which are the subject of this set of interroga-tories. (b). Identify those facts concerning which each such person has first-hand knowledge. (c). State _the specific allegation in each contention which Joint Intervenors contend such facts support. 2(a). State the name, present or last known address, and present or last employer of each person, other than affiant, who provided information upon which CCNC relied in answering each interrogatory herein. (b). Identify all such information which was provided 1 by each such person and the specific interrogatory response in which such information is contained. 3(a). State the name, address, title, employer and I educational and professional qualifications of each person CCNC intends to call as an expert witness or a witness relating to any contention which is the subject of this set of interroga-tories. (b). Identify the contention (s) regarding which each such person is expected to testify. (c). State the subject matter to which each such person is expected to testify.
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5 4(a). Identify all documents in Joint Intervenors' possession, custody or control, including all relevant page citations, pertaining to the subject matter of, and upon which I' CCNC relied in formulating allegations in each contention which is the subject of this set of interrogatories. (b). Identify the contention (s) to which each such document relates. (c). State the specific allegation in each contention which CCNC contends each document supports. . 5(a). Identify all documents in CCNC's possession, i custody or control, including all relevant page citations, upon which you relied in answering each interrogatory herein. (b). Identify the specific interrogatory response (s) to which each such document relates. 6(a). Identify any other source of information, not previously identified in response to Interrogatory 2 or 5, which was used in answering the interrogatories set forth herein. (b). Identify the specific interrogatory response (s) to which each such source of information relates. 7(a). Identify all documents which CCNC intends to offer as exhibits during this proceeding to support the contentions which are the subject of this set of interrogatories or which CCNC intends to use during cross-examination of witnesses l l
presented by Applicants and/or the NRC Staff on each contention . which is the subject of this set of interrogatories. (b). Identify the contention (s) to which each document relates and the particular page citations appli~ cable to each contention. i INTERROGATORIES ON CONTENTION 12 (JORDAN DAM BREAK)_ 1 12-1 (a). Do you contend that Applicants failed to analyze dam failures or possible failure of the Shearon Harris Nuclear Plant Main Reservoir Dam (hereinafter " Main Dam")? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that Applicants failed to analyze dam failures or possible failure of the Main Dam. (c). If the answer to (a) above is negative, do you contend Applicants' analysis is inadequate? If so, explain in detail the basis for your contention. 12-2. State in detail all the facts which support your allegation that a break in Jordan Lake Dam would result in a flood greater than the probable maximum flood used by Applicants to determine the effects of high water upon the site. 12-3. State in detail all the facts which support your allegation that a break in Jordan Lake Dam would result in the existing Buckhorn Dam being carried away.
o i 12-4 (a). Do you contend that there are deficiencies associated with construction of the Main Dam? (b). If the answer to the preceding interrogatory is l' i affirmative, state in detail all the facts which support your allegation that there are deficiencies associated with con-4 struction of the Main Dam. (c). If the answer to (a) above is other than affirmative', explain in detail how your response is consistent with the allegation set forth in Contention 12. I 12-5 (a). Do you contend that the Auxiliary Reservoir is i insufficient to provide adequate cooling capacity to safely , shut down both reactors? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that the Auxiliary Reservoir is insufficient to provide adequate cooling capacity to safely shut down both reactors. (c). If the answer to (a) abo-e j a other than affirmative, explain in detail how yew
- r* sponse is consistent with the allegation set forth in Cs e .e:9.t . <,a 1 2 .
12-6 (a). Do you contend that the differences in eleva-tion between the Cape Fear River bank and the Main Dam crest is insufficient to preclude any effects on the' Main Dam o. E?rris Reservoir of a flood resulting from a break in Jordan Lake Dam?
I* i , (b). If the answer to the preceding interrogatory is l t affirmative, state in detail all the facts which support your allegation that the differences in elevation between the Cape Fear River bank and the Main Dam crest is insufficient to preclude any effects on the Main Dam or Harris Reservoir of a l flood resulting from a break in Jordan Lake Dam. (c). If the answer to (a) above is other than i affirmative, explain in detail how your response is consistent with the allegation set forth in Contention 12. INTERROGATORIES ON CONTENTION 14 (HYDRILLA VERTICILLATA) 14-1 (a). Do you contend that hydrilla verticillata (hereinafter hydrilla) will be introduced into the Shearon Harris Nuclear Plant reservoir? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your ! I allegation that hydrilla will be introduced into the Shearon Harris Nuclear Plant reservoir. (c). If the answer to (a) above i other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contentien 14. 14-2 (a). Do you contend that mesh traveling screens through which cooling tower makeup water must pass are inadequate to prevent hydrilla from clogging intake valves? i (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your l
e 6 allegation that mesh traveling screens through which cooling tower makeup water must pass are inadequate to prevent hydrilla from clogging intake valves. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 14. 14-3 (a). Do you contend that makeup water. intake valves clogged by hydrilla provide insufficient amounts of water to cool down both reactors? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that makeup water intake valves clogged by hydrilla provide insufficient amounts of water to cool down both reactors. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 14. 14-4 (a). Do you contend that hydrilla will clog other parts of the Harris Plant cooling system? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that hydrilla will clog other parts of the Harris Plant cooling system. Your answer shou.- include, but not be limited to, a detailed listing of those p wtions of the cooling system you allege will be clogged by hydrilla. _9_
(c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 14. 14-5 (a). Do you contend that Applicants have failed to consider the possibility that hydrilla, among other obstruc-tions, could clog the intake structure and have failed to design against such an occurence? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that Applicants have failed to consider the possi-bility that hydrilla, among other obstructions, could clog the intake structure and have failed to design against such oCCurence. I (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention 14. 1 l 14-6 ( 't ) . Do you contend that hydrilla could become ) established in water at the depth of 30 feet or greater? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that hydrilla could become established in water at the depth of 30 feet. 14-7 (a). Do you contend that hydrilla could become established in water continually traveling at a velocity of 0.4 l feet per second or greater? l
(b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that hydrilla could become established in water continually traveling at a velocity of 0.4 feet per second. 14-8 (a). Do you contend that hydrilla will be carried by currents from other parts of Harris Reservoir to the vicinity of the water intake structure? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that hydrilla will be carried by' currents from other parts of Harris Reservoir to the vicinity of the water intake structure. (c). If the answer to (a) above is other than affirmative, state in detail how you contend hydrilla will be carried to the vicinity of the water intake structure. REQUEST FOR PRODUCTION OF DOCUMENTS Applicants request that CCNC respond in writing to this request for production of documents and produce the original or best copy of each of the documents identified or described
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i A .a in the answers to each of the above interrogatories, at a place mutually convenient to the parties. Respectfully submitted, . George F. Trowbridg'e , P.C. Thomas A. Baxter, P.C. John H. O'Neill, Jr. SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W. Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 26602 (919) 836-7707 DATED: January 31, 1983
a 00LKETED U'P:RC January 31, 1983
'83 FER -3 P2 :52 UNITED STATES OF AMERICA NUCLEAR REOULATORY COMMISSION gr -
BEFORE THE ATOMIC SAFETY AND LICINSING BOARD In the Matter of )
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CAROLINA POWER & LIGHT COMPANY ) AND NORTH CAROLINA EASTERN ) - Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL
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(Shearon Harris Nuclear Power ) Plant, Units 1 and 2) ) APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR RICHARD D. WILSON (FIRST SET) Pursuant to 10 C.F.R. 55 2 740b and 2.741 and to the Atomic Safety and Licensing Board's " Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference)" of September 22, 1982, Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that Intervenor Richard D. Wilson answer separately and fully in writing, and under oath or affirmation, each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identified in the response to interrogatories below. l l Under the Commission's Rules of Practice, answers or objections to these interrogatories must be served within 14 L ,_ -= ~ . . . _ . . _ _ _ . , - . , _ . _ . - 5
l i days after service of the interrogatories; responses or objections to the request for production of documents must be served within 30 days after service of the request. These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. 5 2.740(e), should you or any individual acting on your behalf obtain any new or differing information responsive to these interroga-tories. The request for production of documents is also continuing in nature and you must produce immediately any additional documents you or any individual acting on your behalf, obtain which are responsive to the request, in accord-ance with the provisions of 10 C.F.R. 5 2.740(e). Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, tran-script, report, handwritten notes, test data) and provide the following information as applicable: Document name, title, number, author,.date of publication and publisher, addressee, date written or approved, and the name and address of the person or persons having possession of the document. Also state the portion or portions of the document (whether sec- [. tion (s), chapter (s), or page(s)) upon which you rely. Definitions. As used hereinafter, the following defini-tions shall apply: The "ER" is the Environmental Report - Operating License Stage for the Shearon Harris Nuclear Power Plant, as amended. 5
4 l The "FSAR" is the Final Safety Analysis Report for the Shearon Harris Nuclear Power Plant, as amended.
" Applicants" is intended to encompass Carolina Power &
Light Co., North Carolina Eastern Municipal Power Agency and their contractors for the Harris Plant.
" Document (s)" means all writings and records of every type in the possession, control or custody of Richard D. Wilson or any individual acting on his behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts', books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings and all other writings or recordings of any kind;
" document (s)" shall also mean copies of documents even though-the originals thereof are not in the possession, custody, or control of Richard D. Wilson; a document shall be deemed to be within the " control" of Richard D. Wilson or any individual acting on his behalf if he has ownership, possession or custody of the document or copy therenf, or has the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.
General Interrogatories 1(a). State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the facts alleged, and upon which you relied in formulating allegations, in each of the 1 l .
contentions which are the subject of this set of interrogatories. (b). Identify those facts concerning which each such person has first-hand knowledge. (c). State the specific allegation in each contention which you contend such facts support. 2(a). State the name, present or last known address, and present or last employer cf each person, other than affiant, who provided information upon which you relied in answering each interrogatory herein. (b). Identify all such information which was provided by each such person and the specific interrogatory response in which such information is contained. 3(a). State the name, address, title, employer and educational and professional qualifications of each person you intend to call as an expert witness or a witness relating to any contention which is the subject of this set of interroga- - tories. (b). Identify the contention (s) regarding which each
- such person is expected to testify.
(c). State the subject matter to which each such person is expected to testify. 4(a). Identify all documents in your possession, custody or control, including all relevant page citations, pertaining
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I to the subject matter of, and upon which you relied in formulating allegations in each contention which is the subject of this set of interrogatories. (b). Identify the contention (s) to which each such document relates. (c). State the specific allegation in each contention which you contend each document supports. 5(a). Identify all documents in your possession, custody or control, including all relevant page citations, upon which your relied in answering each interrogatory herein. (b). Identify the specific interrogatory respenae(s) to which each such document relates. 6(a). Identify any other source of information, not previously identified in'rusponse to Interrogatory 2 or 5, which was used in answering the interrogatories set forth herein.
-(b) . Identify the specific interrogatory response (s) to which each such source of information relates.
7(a). Identify c.'.1 documents which you intend to offer as exhibits during this proceeding to support the contentions 5hich are the subject of this set of interrogatories or which you intend to use during cross-examination of witnesses presented by Applicants and/or the NRC Staff on each contention i which is the subject of this set of interrogatories. l
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I (b). Identify the contention (s) to which each document relates and the particular page citations applicable to each contention. Interrogatories on Contention I(a) I(a)-1(a). Do you contend that the use of a chlorination system as described in Section 3.4.2.4 of the ER which would require 3-5 ppm chlorine and which would operate for two 30-minute cylces per day would result in chlorine dispersal into the atmosphere with a resulting adverse impact upon the biosphere surrounding the Harris plant? i (b). If the answer to the preceding interrogatory is. affirmative, state in detail all the facts which support your allegation that use of a chlorination system as described in Section 3.4.2.4 of the ER which would require 3-5 ppm chlorine and which would operate for two ,30-minute cycles per day would result in chlorine disperal into the atmosphere with a resulting adverse impact upon the biosphere surrounding the Harris plant. (c). If not contained in your answer to (b) above, please identify specifically the nature and extent of chlorine dispersal which allegedly would occur; the compounds; the threshold concentration at which these compounds can adversely affect the environment; the nature of the adverse impact that you allege would occur; and the components of the biosphere which you allege would be affectoc.. Describe in detail the
basis for your answer, including an identification of any assumptions employed. (d). If the answer to (a) above is other than affirmative, explain-in detail how your response is consistent with the allegations set forth in Contention I(a). I(a)-2(a). Do you contend that the use of such a chlorin-ation system at a frequency greater than two 30-minute cycles per day would result in chlorine dispersal into the atmosphere with a resulting adverse impact upon the biosphere surrounding the Harris plant? (b). If the answer to the preceding interrogatory is affirmative, state in detail all of the facts which support your allegation that use of such a chlorination system at a frequency greater than two 30-minute cycles per day would result in chlorine dispersal into the atmosphere surrounding the Harris plant. (c). If not contained in your answer to (b) above,
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please state the frequency of chlorine usage which you allege would result in an adverse impact upon surrounding biosphere; the nature and extent of chlorine dispersal which allegedly would occur; the nature of the adverse impact which allegedly would occur; and the components of the biosphere which alleg-edly would be adversely affected. (d). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention I (a).
I(a)-3(a). Do you contend that the NPDES Permit for the Harris Plant issued on July 12, 1982 (attached hereto) does not adequately limit the amount of free available. chlorine and total residual chlorine which may be discharged in the blowdown from the cooling system? (b). If the answer to the preceding interrogatory is affirmative, state in detail all of the facts which support your allegation that the NPDES Permit for the Harris Plant issued on July 12, 1982 does not adequately limit the amount of free available chlorine and total residual chlorine which may be discharged in the blowdown from the cooling system. (c). If the answer to (a) abcVe is other than affirmative, explain in detail how yoce response is consistent with the allegations set forth in Contention I(a). I(a)-4(a). Do you contend that the composition of the cooling tower drift would be different from that of the cooling tower blowdown? (b). If the answer to the preceding interrogatory is affirmative, state in detail all of the facts which support your allegation that the composition of the cooling tower drift would be different from that of the cooling tower blowdown. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention I(a). ,
l l l l I l I(a)-5. Identify, by title and citation, the " critical ! reference" regarding chlorine dispersal referred to in your i contention. Interrogatories on Contention I(b) I(b)-1(a). Do you contend that chlo. organic compounds will be dispersed in the Harris plant cooling tower evaporation and will be toxic to the biosphere surrounding the Harris i plant? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that chlororganic compounds will be dispersed in cooling tower evaporation and will be toxic to the biosphere surrounding the Harris plant. (c). If not contained in your answer to (b) above, please identify the types and amounts of chlororganic compounds which allegedly would reside in the Harris Plant cooling towers; the compounds formed and the concentrations of chloror-ganics and other materials required to form these compounds; the threshold concentration at which these compounds can adversely affect the environment; the nature and extent of dispersal which allegedly would occur; the adverse components l of the biosphere surrounding the Harris plant which allegedly I would be affected. State in detail the basis for your answer, and identify any assumptions employed. _9_
(d). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention I(b). Interrogatories on Contention I(c) I(c)-1(a). Do you contend that sulphuric acid and hydrogen peroxide which may be added as a cooling tower treatment to correct PH would be toxic to the biosphere surrounding the Harris Plant? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that sulphuric acid and hydrogen peroxide which may be added as cooling tower treatment to correct PH would be toxic to the biosphere surrounding the Harris Plant. (c). If not contained in your answer to (b) above, please identify the nature and amounts of dispersals which allegedly would occur; the components of the surrounding biosphere which allegedly would suffer adverse affects; and the nature of those adverse affects. (d). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention I(c). Interrogatories on Contention I(d) I(d)-1(a). Do you contend that biocides other than chlorine which might be added to the Harris Plant cooling tower water will be toxic to the biosphere?
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(b). If the answer to the preceding interrogatory is affirmative, please state in detail all the facts which support your allegation that biocides other than chlorine which might be added to the Harris Plant cooling tower water will be toxic to the biosphere in the concentrations normally associa-ted with treating cooling tower water systems. t (c). If not contained in your answer to (b) above, please identify the nature and quantities of the biocides which you allege would be toxic to the biosphere if added to the cooling tower water; the compounds formed and the concentration , of other biocides along with other materials required to form these compounds; the threshold concentration at which these compounds can adversely affect the environment; the components of the biosphere which would suffer adverse effects and the nature of those adverse affects. State in detail the basis for your answer, and identify any assumptions employed. 1 (d). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention I(d). Interrogatories on Contention I(e) I(e)-1. State in detail all the facts which support your allegation that large amounts of water will frequently be pumped from the Cape Fear River into the Main Harris Reservoir. I(e)-2(a). State in detail all the facts which support your allegation that this water as pumped from the Cape Fear River will be heavily contaminated by upstream manufacturing and textile effluents. (b). If not contained in your answer to (a) above, please provide a breakdown by type of all alleged contaminants, amount (percentage) of each such contaminant, and the source (s) of each such contaminant at the intake point of the Cape Fear River makeup water pump station. I(e)-3(a). Do you contend that large volumes of contami-nated water will be dispersed from the Harris Plant cooling towers? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that large volumes of contaminated water will be dispersed from the Harris Plant cooling towers. Your answer should include, but not be limit ,d to, what is meant by your use of the word " dispersed" in such allegation. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegatiori1 set forth in Contention I(e). I(e)-4(a). If the answer to I(e)-3(a) is affirmative, do you contend that dispersion of contaminated water from the Harris Plant cool 2ng towers will be toxic to the bioephere? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support r your allegation that dispersion of contaminated water from the l i
e 1 Harris Plant cooling towers will be toxic to the biosphere. 1 Your answer should include, but not be limited to, a breakdown of the individual elements of the biosphere which will be affected in a toxic manner and the manner in which each will be affected. (c). If the annwer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention I(e). Interrogatories on Contention I(f) I(f)-1(a). Do you contend that, steady state water levels in the Harris Plant Main Reservoir cannot be maintained with inflow from Buckhorn Creek and makeup water from the Cape Fear River? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that steady state water levels in the Harris Plant Main reservoir cannot be maintained with inflow from Buckhorn Creek and makeup water from the Cape Fear River. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention I(f). I(f)-2(a). Do you contend that steady state water levels in the Harris Plant Main reservoir cannot be maintained without makeup water from the Cape Fear River? (b). If the answer to the preceding: interrogatory is affirmative, state in detail all the facts which support your. allegation that steady state water levels in the Harris Plant Main reservoir cannot be maintained without makeup water from the Cape Fear River. (c). If the answer to (a) above is other than-affirmative, explain in detail how your response is consistent with the allegations set forth in Contention I(f). I(f)-3(a). Do you contend there is a requirement for a steady state water level in the Main Reservoir? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support
- - your allegation that there is a requirement for a steady state water level in the Main Reservoir.
i (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Centention I(f). I(f)-4(a). Do you contend that the Main Reservoir will function as the ultimate heat sink in the event of a loss of service from the cooling towers? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support 1 j your allegation that the Main Reservoir will function as the ultimate heat sink in the event of a loss of service from the 1 , cooling towers. l
r- 3 (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention I(f). I(f)-5(a). Do you contend that the Main Reservoir is i I necessary as a backup cooling reservoir to safely shut down and cool down both reactors? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that the Main Reservoir is necessary as a backup cooling reservoir to safely shut down and cool down both reactors. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention I(f). I(f)-6(a). Do you contend that ultimate heat sink dependability requirements analysis as contained in FSAR S 2.4.11.7 is incorrect, inadequate, or flawed? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that ultimate heat sink dependability require-ments analysis as contained in FSAR S 2.4.11.7 is incorrect, inadequate, or flawed? (c). If the answer to (a) above is other than affirmative, e:tplain in detail how your response is consistent with the allegations set forth in Contention I(f). t- . I(f)-7(a). Do you contend that the estimated measure of consumptive water use is incorrectly calculated? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that the estimated measure of consumptive water use is incorrectly calculated. (c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Contention I(f). I(f)-8. State in detail all the facts which support your allegation that estimates of Buckhorn Creek flow as > contained in FSAR S 2.3.1.2.1.1 are inadequate and rest on false assumptions. I(f)-9(a). ,Do you contend that the rainfall of Buckhorn Creek watershed is not equivalent to the rainfall in Middle Creek watershed? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that the rainfall in Buckhorn Creek watershed is not equivalent to the rainfall in Middle Creek watershed, including what you believe the rainfall in 2ach watershed to be. I(f)-10. If not contained in your answers to I(f)-8 or I(f)-9(a) or (b), please list each false assumption underlying
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1 1 Applicants' estimates of Buckhorn Creek flow as contained in the FSAR, and state in detail the facts which support your allegation that each of those assumptions is false. I(f)-ll(a). Do you contend that the difference in flow between Buckhorn Creek of 79 cfs and the projected average consumptive water use of the Harris plant to be inadequate to maintain a steady state water level in the plant main reservoir? (b). If the answer to the preceding interrogatory is affirmative, state in detail all the facts which support your allegation that the difference in flow between Buckhorn Creek of 79 cfs and the projected average consumptive water use of the Harris plant to be inadequate to maintain a steady water level in the plant main reservoir. I(f)-12. State all the facts upon which you rely in support of your allegation that the~ Cape Fear River must be considered a frequent source of water for the Harris Main Reservoir. REQUEST FOR PRODUCTION OF DOC'IMENTS l Applicants request that Richard D. Wilson respond in writing to this request for production of documents and produce the original or best copy of each of the documents identified l l
or described in the answers to each of the above interroga-tories at a place mutually convenient to the parties. Respectfully submitted, George F. Trowbrfdge, P.C. Thomas A. Baxter, P.C. John H. O'Neill, Jr. SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W. Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn , CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 26602 (919) 836-7707 DATED: January 31, 1983 l
STATE OF NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES & COMMUNITY DEVELOPMENT DIVISION OF ENVIRONMENTAL MANI.GEMENT P,{ { M_ I,1 To Discharge Wastewater Under the NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Carolina Power and Light Company is hereby authorized to discharge wastewater from a facility located at Shearon Harris Nuclear Power Plant Wake County to receiving waters of Harris Reservoir on Buckhorn Creek in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, and III hereof. - This permit shall become effective July 12, 1982. This permit and the authorization to discharge shall expire at midnight on June 30, 1987.
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Signed this day of July 12,1982. b.
, Robert F. Helms fj]irector Division of $nvironmental Management By Authority of the Environmental Management Commission M1 & Il
r-VUys oV Permit No. NC OC*
, lq SUPPLEMENT TO PERMIT COVER SHEET Carolina Power and Light Company is hereby authorized to: (include only appropriate items) 1.
Enter into a contr'act for construction of wastewater treatment facilities 2. Make an outlet into Harris Reservoir on Buckhorn Creek 3. Construct and operate a fa'cilities to control pollutants from cooling i tower blowdown, sanitary sewage treatment plant, metal cleaning and low volume wastes in accordance with applicable effluent limits located at Shearon Harris Nuclear Power Plant subject to Part III, condition No. c. ' of this Permit, and 4 Discharge from said treatment works into the Harris Reservoir Buckhorn @ which is classified Class "C". O 1 . r 1 M2&I2
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- n. ( ). EFFLUENT L1HITATIONS AND MONITORING REQUIREMENTS and lasting untilexpiration During the period beginning at first discharge permittee is authorized to discharge from outfall(s) serial number (s). 001-Cooling tower blowdown to narri:
Reservoir Such discharges shall be limited and monitored by the permittee as specified beloW: Discharge Limitations Monitoring Requirements tEfflucnt Characteristics Kg/ day (lbs/ day) Other Units (Specify) Measurement ' Sample Sample Daily Avg. Daily Max. Daily Avg. Daily Max. ~ Frequency Type Locatidb Plow 1/ 30 mgd Continuous or Recorder E Pump Log Temperature 1/ 1/ 1/ 1/ Zinc aa 1.0 mg/l 1.0 mg/l 1/ Week Grab g E* Total Chromium ** 0.2 mg/l 0.2 mg/l 1/ Week Grab E* Phosphours** 5 mg/l 5 mg/l 1/ Week Grab E* Average Instantaneous Maximum O.2 mg/l 0.5 mg/l 1/ Week Multiple Grab At each tower Free available Chlorine 2/ Multiple Grab At each tower 1/ Week Total Residual Chlorine 2/ 1/ Discharge of blowdown from the cooling system shall be limited to the minimum discharge of recirculating water nec-essary for the purpose of discharging materials contained in the process, the further build-up of which would cause concentrations or amounts exceeding limits of established engineering practice. The discharge shall not result in th violation of class "C" water quality standards out' side of a mixing zone of 200 acres around the point of discharge. This mixing zone is for temperature and chlorine. The temperature within the mixing zone shall not :(1) prevent fre passage of fish around or cause fish mortality within the mixing zone;(2) result in of fensive conditions;(3) produce undesirable aquatic life or result in a dominance of nuisance species outside of the zone (4) endanger the public healt or welfare. Monitoring adequate to demonstrate compliance with the blowdown minimization, water quality standards fe, temperature outside of the mixing zone, and prohibitions within the mixing zone shall be proposed by the permittee si months prior to start-up and, upon approval of the proposal, the results submitted with the monthly monitoring report The permittee may discharge cooling water to the auxillary reservoir in compliance with Part III-E of this pj ]o 38 Permit. ] ] 2/ Neither free available chlorine nor total residual may be discharged from any unit for fore than two hours in p ,, any one day and not more than one unit in any plant discharge free available or total Pesidual chlorine at _, any one time unless the permittee can demonstrate to the Director Division of Environmental Management that f the unit in question cannot operate at or below this level of chlorination. The permittee shall record and report the times of release as a part of the monthly monitoring report. 3/ un later than three years after promulgation or July 1, 1987, whichever is earlier, Total Residual Chlorine shall not exceed a maximum concentration of 0.14 mg/l in the combined cooling tower blowdown discharge. Note: In the event tl RComginued on next game) . - _ _ _ _ _ - _ _ - _ - .
A. ( ) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - 3/ (continue'd) BAT regulations for control are promulgated in a manner inconsistent with the October 14, 1980, proposed guidelines, requirements of this paragraph shall be modified consistent with the promulhatd regulations (40 CFR 423) . There shall be no discharge of detectable amounts of materials added for corrosion inhibitition or any chemical added which contain the 129 priority pollutants.
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- Effluent prior to mixing with any other waste stream.
** Effective after July, 1983. These limitations and monitoring requirements apply only if these materials are added by the permittee.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored weekly on a grab sample of the effluent. There shall be no discharge of floating solids or visible foam in other than trace amounts.
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C A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS , During the period beginning on initiation of dischar serial numberand lasting until expiration (s). 002 semitary waste treatment permittee is authorized to discharge from outfall(s) ge Such discharges shall tse limited and monitored by the permittee as specified below: Harrisplant reservoir discimrge to on Buch.arn Discharge Limitations Monitoring Requirements Cre.:: iffluent Characteristics Kg/ day (lbs/ day) Other Units (Specify) Measurement Sample Sample i Daily Avg. Daily Max. Daily Avg. Daily Max. Frequency Type Locatio'n f lo,r 0.05 MGD O.075 MGD 'gp gg g g Recorder I or E
,0D 30 mg/l 45 mg/l Monthly Composite E
- S 30 mg/l 45 mg/l Quarterly Composite 'E I I-Influent, E-Effluent REEE C go s_ "
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. .E *O standard units nor greater then 9.0 standard units [,
The pH shall not be less than 6.0 ' and shall be monitored monthly on a grab sample of the ef fluent. .) aa
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w .. s A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS . and lasting until expiration , During ihe period beginning upon initiation or discharge pennittee is authorized to discharge from outfall(s) serial number (s). 003 metal cleaning wastesto discharged Such discharges shall be limited and monitored by the permittee as specified below: liarris Reservoir on Buckhora Cg ~ Monitoring Requirements Discharge Limitations Ef fluent Characteristics Other Units (Specify) Measurement Sample Samp[ Kg/ day (lbs/ day) Daily Avg. Daily Max. Frequency Type Loca+1 Dail9 Avg. Daily Max. During discharge EN Flow 0.8 37 30 mg/l 100 mg/l Daily during , E (Quantities of pollutants discharge Grab If discharged shall not exceed the quantity obtained by 15 mg/l 20 mg/l Daily during Gil & Grease multiplying the flow of discharge Grab If metal cleaning wastes generated timas the con- 1.0 mg/l 1.0 mg/l Daily during Copi>ct , Total centrations listed to the discharge Grab if right.) 1.0 mg/l 1.0 mg/l Daily during Iron, Toi.a1 discharge Grab ]?
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*Ef fluent prior to mixing with any other waste stream 1/ Conanensurate with treatment system installed
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.EF, The pH shall not be less than 6:0 standard units nor greater than 90 standard units and shall be monitored daily during discharge on a grab sample of the etfluent. * '
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( ). A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS j During theNjweriod beginning upon initiation of discharge and lasting until expiration i permittee is authorized to discharge from outfall(s) serial number (s). 004 low volume wastes dischargea l Such discharges shall be limited and monitored by the pennittee as specified below: to narris I Reservoir on Buckhorn Creek Discharge Limitstions Monitoring Requirements iffluent Characteristics Kg/ day (lbs/ day) Other Units (Specify) Measurement taple Sample Daily Avg. Daily Max. Daily Avg. Daily itax. Frequency Type Loca t' Flow 1.5 MGD 1/ 1/ 1/ 568(1251) Weekly Grab TSS 170(375) Effluer) Weekly Grab , Ea Oil f. Grease 85(187) 113(250) 1/ Commensurate with treatment system installed
- Effluent prior to mixing with any other waste stream
; Low volume wastes shall mean but not all inclusive, taken collectively as if from one source, wastewater from wet scrubber air pollution control system, ion exchange, water treater systems, water treatment evaporator -
blowdown, laboratory and sampling streams, floor drainage, cooling tower basin cleaning wastes, blowdown from rec,irculating hguse service water systems, and steam generator blowdown. Prior to Start-up of Unit #2, quantity limitations shall be one-half of the limitations shown. o2 og o.
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mP The pil shall not be less than 6.0. standard units nor greater than 9. 0 . stanoard units and shall be monitored weekly on a grab sample of the effluent.
C a . ' A. ( ). EFFLUENT LIMITATIONS AND MONITORIl!G REQUIREHEllTS During tiiN period beginning upon initiation or d and lasting until erpiration - permittee is authorized to discharge from outfallks3harNal s se number (s). 005 PointfromSource run-o construction Such discharges shall be limited and monitored by the pennittee as specified below: Discharge Limitations Honitoring Requirements jffluent Characteristics Kg/ day (Ibs/ day) Other Units (Specify) Measurement -Sample Samp Daily Max. Loct Daily Avg. Daily Max. Daily Avg. Frequency Type t'
. int source run-off from construction is permitted iri compliance with a sedimentation and erosion control plan approved by .: 12and Quality Section of the Division of Land Resources.
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Part 1 Permit No. NC - B. SCHEDULE OF COMPLIAllCE
- 1. The permittee shall achieve compliance with the effluent limitations specified for , discharges in accordance with the following senedule:
..su Applicable.
- 2. No later than 14 calendar days following a date. identified in the above schedule of compliance, the permittee shall submit either a report of progress or, in the case of specific actions being required by identified dates, a written notice of compliance or noncompliance. In the latter case, the notice shall include the cause of noncompliance, any remedial '
actions taken, and the probability or' meeting the next scheduled requirement. 4 9 i
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- PART I Permit No. NC Act used herein means the Federal Water Pollution Control Act, As amended.
DEM used herein means the Division of Environmental Management of the Department of Natural Resources and Community Development "EMC" used herein means the North Carolina Environmental Management Commission. , C. MONITORING AND REPORTING
- 1. Representative Sampling Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge.
- 2. Reporting
- ionitoring results obtained during the previous month (s) shall be ,
summarized for each month and reported on a Monthly Monitoring Report Fom (DEM No. MR 1.0,1.1, and 1.4) postmarked no .later than the 45th day following the completed reporting period. The first report is due on
. The DEM may require reporting of additional monitoring results by written notification. Signed copies of these, and all other reports required herein, shall be submitted to the following address:
i Division of Environmental Management Water Quality Section Post Office Box 27687 Raleich, North Carolina 27611
- 3. Definitions
- a. The " daily average" discharge means the total discharge by weight during a calendar month divided by the number of days in the month that the production or commercial facility was operating. Where less -
than daily sampling is required by this permit, the daily average discharge shall be determined by the summation of all the measured daily discharges by weight divided by the number of days sampled during the calendar month when the measurements were made.
- b. The " daily maximum" discharge means the total discharge by weight during any calendar day.
- 4. Test Procedures l
Test procedures for the analysis of pollutants shall conform to The EMC regulations published pursuant to N. C. G. S. 143-215.63 et seq., The l Water and Air Quality Reporting Act, Section 304(g),13 USC 1314, of the. . Federal Water Pollution Control Act, As Amended, and Regulation 40 CFR 136. l
- 5. Recording Results l For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information: ,
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.. . PART I Permit No. NC
- a. The exact place, date, and time of sampling;
- b. The dates the snalyses were performed;
- c. The person (s) who performed the analyses;
- d. The analytical techniques or methods used; and
- e. The results of all required analyses.
- 6. Addit 1onal Monitoring by Permittee If the permittee monitors any pollutant at the . location (s) designated herein more frequently than required by this permit, using approved analytical methods as specified above, the results of such monitoring shall be included in the calculation and reporting of the values required in the Monthly Monitoring Report Form (DEM MR 1.0, 1.1, 1.4)
Such increased monitoring frequency shall also be indicated. The DEM may require more frequent monitoring or the monitoring of other pollu-tants not required in this permit by written notification.
- 7. Records Retention All records and information resulting from the monitoring activities required by this permit including all records of analyses performed and calibration and maintenance of instrumentation and recordings from continuous monitoring instrumentation snall be retained by the permittee for a minimum of three (3) years, or longer if requested by the State Division of Environmental Management or the Regional Administrator of the Environmental Protection Agency. .
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i PART n Permit No. NC A. MANAGEMENT REQUIREMENTS
- 1. Change in Discharge All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identified in this permit more frequently than or at a level in excess ::f that authorized shall constitute a violation of the permit. Any anticipated facility expansions, production increases, or process modifications which will result in new, different, or increased discharges of pollutants must be reported by submission of a new NPDES application or, if such changes will not violate the effluent limitations specified in this permit, by notice to the DEM of such changes. Following such notice, the permit may be modified to specify and limit any pollutants not previously limited.
- 2. Non compliance Notification If, for any reason, the permittee does not comply with or will be unable to comply with any effluent limitation specified in this permit, the per-mittee shall provide the Division of Environmental Management with the following information, in writing, within five (5) days of becoming aware of such condition:
- a. A description of the discharge and cause of noncompliance; and
- b. The period of noncompliance, including exact dates and times; or, if not corrected; the anticipated time the noncompliance is expected to continue, and steps being taken to reduce, eliminate and p* event
, recurrencu of the noncomplying discharge.
- 3. Facilities Operation The permittee shall at all times maintain in good working order and operate as efficiently as possible all treatment or control facilities -
or systems installed or used by the permittee to achieve compliance with the tenns and conditions of this permit.
- 4. Adverse Impact .
The permittee shall take all reasonable steps to minimize any adverse impact to navigable waters resulting from noncompliance with any effluent limitations sr'cified in this permit, including such accelerated or additional mon 12"ing as necessary to determine the nature and impact of the noncomplying oischarge. S. Bypassing Any diversion from ur bypass of facilities necessary to maintain compliance with the terms and conditions of this permit is prohibited, except (i) where l 1 M8&I7 _ _ _ _ _ _ _ _ _ _ _ I
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PART II
. Permit No. NC unavoidable to prevent loss of life or severe property damage, or (ii) where excessive storm drainage or runoff would damage any facilities necessary for compliance with the effluent limitations and prohibitions of this permit. The permittee shall promptly notify the Water Quality Section of DEM in writing of each such diversion or bypass.
- 6. Removed Substances i Solids, sludges, filter badwash, or other pollutants removed in the course of treatment'or control of wastewaters shall be disposed of in a manner such as to prevent any pollutant from such materials from entering waters of the State or navigable waters of the United States. -
- 7. Power Failures In order to maintain compliance with the effluent limitations and prohibitions of this permit, the permittee shall either:
- a. In accordance with the Schedule of Compliance contained in Part I, provide an alternative power source sufficient to operate the waste-
! water control facilities; or,if such alternative power source is not in existence, and no date for i its implementation appears in Part I,
- b. Halt, reduce or otherwise control production and/or all discharges from wastewater control facilities upon the reduction, loss, or failure of the primary source of power to said wastewater control .
facilities.
- 8. Onshore or Offshore Construction .
This permit does not authorize or approve the construction of any onshore or offshore physical structures or facilities or ths undertaking of any work in any navigable waters. t ll I8
PART II Permit No. NC S. RESPONSIBILITIES
- 1. Right of Entry The pemittee shall allow the Director of the Division of Environmental Management, the Regional Administrator, and/or their authorized represen-tatives, upon the presentations of credentials:
- a. The enter upon the pemittee's premises where an affluent source is' located or in which any records are required to be kept under the terms and conditions of this pemit; and
- b. At reasonable times to have access to and copy any records required to be kept under the terms and conditions of this pemit; to inspect any monitoring equipment or monitoring method required in this permit; and to sample any discharge of pollutants.
- 2. Transfer of Ownership or Con +rol This permit. is not transferable. In the event of any change in control or ownership of far.ilities from which the authorized discharge emanates or is contemoluted, the permittee shall notify the prospective owner or controller by letter of the existance of this permit and of the need to obtain a pemit;in the name of the prospective cwner. A copy of the letter shall he . forwarded to the Division of Environmental Management.
- 3. Availability of Reports Except for data detamined to be confidential under N. C. G. S. 143-215..
3(a)(2) or Section 308 of the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be-available for public inspection at the-offices of the Division of Environmental Management. As required by the'Act, effluent data shall not be considered confidential. Knowingly making any ' false statement on any such report may result in the imposition of criminal penalties as provided for in N. C. G. S. 143-215.6(b)(2) or in Section 309 of the Federal Act.
- 4. Permit Modification After notice and occortunity for a hearing pursuant to N. C. G. S.143-215.l(b)(2) and G. S.143-215.l(e) respectively, this permit may be modified, suspended, or revoked in whole or in part during its term for cause including, but not limited to, the following:
- a. Violation of any terms or conditions of this pemit;
- b. Obtaining this pemit by nisrepresentation or failure to disc 1cse fully all reicvant facts; or i
- c. A change in any condition that requires either a temporary or permanent reduction or elimination of the authorized discharge.
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PART II Permit No. NC
- 5. Toxic Pollutants Notwithstanding Part II, B-4 above, if a toxic effluent standard or prohibition (including any schedule of compliance specified in such effluent standard or prohibition) is established under Section 307(a) of the Act for a toxic pollutant which is present in the discharge and such standard or prohibition is more stringent than any limitation for such pollutant in this permit, this permit shall be revised or modified in accordance with the toxic effluent standard or prohibition and the pennittee so notified.
- 6. Civil and triminal Liability ~
Execot as provided in pennit conditions on " Bypassing" (Part II, A-5) and " Power Failures" (Part II, A-7), nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance pursuant to N. C. G. S. 143-215.6 or Section 309 of the Federal Act, 33 USC 1319.
- 7. Oil and Hazardous Substance Liability
[ Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject under N. C. G. S. 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321.
- 8. Property Rights .
The issuance of this permit does not convey any property rights in either - real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal ~ rights, nor any infringement of Federal, State or local laws or regulations.
- 9. Severability The provisions of this permit are severable, and if any provision of this permit, or the application of any provision of this permit to any circum-stance, is held invalid, the application of such provision to other cir-cumstances, and the remainder of this permit shall not be affected thereby.
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* . . a Parmit No. NC0039586
- 10. Expiration of Permit Permittee is not authorized to discharge after the expiration date.
In order to receive authorization to discharge beyond the expiration date, the permittee shall submit such information, forms, and fees as are required by the agency authorized to issue permics'no later than 180 days prior to the expiration date. Except as provided in N.C.G.S. 150A, any discharge without a permit after the expiration will subject the permittee to enforcement procedures as provided in N.C.G.S. 143-215.6 and 33 USC .1251 et seq. . 0 O e .
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Pcge of l Permit No. NC B. Previous Pennits All previous State water quality permits issued to this facility, whether for construction or operation or discharge, are hereby revoked by issuance of this permit. The conditions, requirements, terms, and provisions of this permit authorizing discharge under the National Pollutant Discharge E11minatien System governs discharges from this facility. C. Construction No construction of wastewater treatment facilities or additions thereto shall be begun until Final Plans anc Specifications have been submitted to the Division of Environmental Management and written approval and Authorization to Construct has been issued. If no objections to Final _ Plans and Specifications has been made by the DEM after 30 days following receipt of the plans or issuance of this permit, whichever is latter, the plans may be considered approved and construction authorized. D. Certified Operator
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Pursuant to Ehapter 90A of North Carolina General Statutes, the permittee shall employ a certified wastewater treriment plant operator in responsible charge of the wastewater *reatment fac' ities. Such operator must hold a
, certification of the grade aquivalent .o the classification assigned to the wastewater treatment facilities.
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e !* , Permit No. NC0039586 E. Heated Water Discharge to Auxillary Reservoir In order to insure that the auxillary reservoir is available for its' designed use at all times, the permittee may circulate heated water through the auxillary reservoir to prevent ice formation at any time that the surface water temperature is below 35 F provided that the surface water temperature in the auxillary reservoir is not raised more 5 F above ambient temperature and in no case is raised to more than 40 F. F. There shall be no discharge of polychlorinated biphenyls (PCB's) from this facility to the extent that this compound is not present in the facility's intake waters. G. Withdrawal from the Cape Year River - Withdrawals from the Cape Fear River, shall be limited to 257. of the flow in the river except that no withdrawals shall be made from the river when the flow is 600 cfs or less nor which will reduce the flow in the river to less __ than 600 cfs as measured at the USGS Lillington Gauge. The withdrawals shall be monitored and reported monthly on the monthly monitoring report. H. Nothing contained in this Permit shall be construed as a waiver by the Permittee of any right to a hearing it may have pursuant to State or Federal law or regulations. I. Water discharged as ba:kwash from intake screens is permitted without limitations or monitoring requirements. J. The Permittee shall submit information relative to the design, location, construction and capacity of the cooling water intake structures to demoastrate application of best technology available for minimizing adverse environmental. impact in accordance with the adopt guidelines for cooling water intake structures. This information must be submitted on or before December 31, 1982. . K. If any applicable standard or limitation is promulgated under sections 301(b) (2)(C) and (D), 304(b)(2), and 307(a)(2) and that effluent standard is more
- stringent than any effluent limitation in this permit or controls a pollutant not limited in this permit, this permit shall be promptly modified, or revoked and reissued, to conform to that effluent standard or limitatio.n.
L. Wiphin one year after start-up of the first unit,- the permittee shall analyze thd discharges serial no.s 001,003, and 004 for the priority pollutants as required by 40 CFR 122.53(d) (7) to the extent that data is still required by regulation in effect at that times. M. Should the guidelines and/or water quality standards upon which the limitations of this permit are based be revised to be less stringent, the permittee may request relaxation of the permit limits in keeping with the revised guidelines and/or standards. f
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.0 00(KETD UNITED STATES OF AMERICA "W NUCLEAR REGULATORY COMMISSION
'83 FEB -3 P2:52 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD b hiir G S V!N MANM In the 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) ) CERTIFICATE OF SERVICE
'I hereby certify that copies of " Applicants' Interrogatories and Request for Production of Documents to Joint Intervenors (First Set)," " Applicants' Interrogatories and Request for Production of Documents to Conservation Council of North Carolina (First Set) ," " Applicants' Interrogatories and Request for Production of Dc uments to Intervenor CHANGE (First Set) ," " Applicants' Interrogatories and Request for Production of Documents to Intervenor Richard D. Wilson (First Set) " and " Applicants ' Interrogatories and Request for Production of Documents to Intervenor Wells Eddleman (First Set)" were served this 31st day of January,1983, I
by deposit in the U.S. mail, first class, postage prepaid, i
) to the parties identified on the attached Service List.
i Thomas A. Baxter, P.C. l l l k I
i- 4 l- / UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i In the 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 James L. Kelley, Esquire John D. Runkle, Esquire Atanic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory C-i==4_on 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 Edelstein and Payne U.S. Nuclear Regulatory Cannission P.O. Box 12643 Washington, D.C. 20555 Raleigh, North Carolina 27605 Dr. Janes H. Carpenter Dr. Richard D. Wilson Atanic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Connission Apex, North Carolina 27502 Washington, D.C. 20555 Mr. Wells Eddleman Charles A. Barth, Esquire 718-A Iredell Street Myron Karman, Esquire Durhan, North Carolina 27705 Office of Executive IAngal Director U.S. Nuclear Regulatory Comnission Ms. Patricia T. Newnan Washington, D.C. 20555 Mr. Slater E. Neunan Citizens Against Nuclear Power Docketing and Service Section 2309 Weymouth Court Office of the Secretary Raleigh, North Carolina 27612 , U.S. Nuclear Regulatory Ccanission Washington, D.C. 20555 Richard E. Jones, Esquire
-Vice President & Senior Counsel Mr. Daniel F. Read, President Carolina Power & Light Canpany
- Chapel Hill Anti-Nuclear Group Effort P.O. Box 1551 P.O. Box 524 Raleigh, North Carolina 27602 Chapel Hill, North Carolina 27514 Dr. Phyllis Iotchin
- 108 Bridle Run Chapel Hill, North Caroli:n 27514 i
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