ML20069L156

General Interrogatories & Interrogatories on Contentions 29, 37B,64f & 67 (Second Set).Related Correspondence

ML20069L156
Person / Time
Site:	Harris
Issue date:	04/22/1983
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
References
ISSUANCES-OL, NUDOCS 8304280057
Download: ML20069L156 (26)

Text

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ahM CORRESPONnDn UNITED STATES OF AMERICA .

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NUCLEAR BEGULATORY COMMISSION '83 FM 26 K0:17

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BEFORE THE ATOMIC SAFETY AND LICENSING BOIED } iT vlenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of

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

Units 1 ani 2) )

)

Wells Eddleman's General Interrogatories 6pd XJfBn/8fbud to Applicants Carolina Power & Light et al. gegbhea5 27j.7/8 g f agf QJ, (Se.Co& Set)

Under 10 CPR 2.7h0, 2.7k1 and the Board's 9-22-82 Memorandun and Order, Wells Eddleman recuests Applicants to answer seearately l and fully in writing, under oath or affirmation, each of the following interrogatories, and to nroduce a nermit inscection and conying of the original' or best copy of all docunent's identified in resconse to interrogato"ies as set forth below. .

l These interrogatories are intended to be continuing in nature,

! and I recuest each answer to be oromotly sucalemented o" anended as acurooriate under 10 CFR P.714d(e), should CPA L, NCFMPA, .any other

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or any contractor or consultant to any, some or all cf those, Apolicant,Aor any emnloyee of any or some or all of them, or any n@@ individual acting on behalf of any or some of all of them, obtain two.

EO or create any n6w or differing information responsive to these 080 (wMtt("Them" refe=s to the preceding list!ng(s))

3 ex general interrogatoriel\ The reauest for oroduction

. of documents-80 is also continuing and reauests Anolicants to eroduce cromntly if 88 g .

not innediately any additional documents the Aunlicants and others no .

03Q 0 acting on their behalf or employed by them, as listed in the crevious

2 sentence, obtain which are responsive to the request (s) for uroduction of documents below.

Where identification .of a document is reonested, clease briefly

., describe the document (e.g. book, notebook, letter, memo, recort,

- notes, transcript, minutes, test data, log, etc. ) and provide the following information as aunlicable: document name, title, number, author (s), date of writing or of publication or both, addressee, date aonroved, by whom annroved, and the name and address of the eersens haing normal custody of tha document, and name and address of any person other than the preceding having actual cossession of the document. When identifying documents in resconse to these interroEatories and recuests, please state the nortion or nortions of the document (e.g. sections, chadars, pages, lines) upon which Apolicants rely or which Apnlicants swear or affirm is/are resnonsive to the acolicable interrogatory or veouest.

DEFINITIONS herein:

" Harris", " Harris Plant", "SENPP", or " plant" where not soecified otherwise, all mean the Shearon Harris Muclear Power Plant.

"Apolicants" means all of the persons, emoloyees, consultants, contractors and cornorations as listed in the first sentence of the second paragraph on page 1 of this. document, above.

"FSA9" means the Harris Final Safety Analysis Secort.

4 "ER" means the Harris Environmental Penort.

" Document ($" means all writings and records of everv tvoe, including electronic and ccmnuter records, in the nossession, control or custody of Annlicants or any individual (s) acting on Anolicarts' behalf, including, but not linited to: venorts, books, memoranda, corresnondence, notes, ninutes, nannhlets, leaflets, magazines, 1

articles, surveys, naps, bulletins, chotogranhs, sneeches, transcrints,

, ,. ,c.-. - - , . , , , . .,_ , - - _ . _ - - , . -

_3 voice rocordings, comnutor urintouts, information storsd in connutors or connuter veripheral devices such as disks, drums, etc., voice recordings, microfilm, microfiche and all other writinEs or ncordings of any kind (s); and cooles of any of the nreceding even though the

\ ortE inal(s) are not in the possession of Aeolicants or in their custody or control. Docunent(s) shall be deened to be within the any control of Acclicants or individual'sl acting on their behalf if they have ownershin, nossession, or custody of the document (s) or a cony thereof, or have the right to secure the docu ent(s) of a cooy thereof, from ary nerson or nublic or "rivate entity havirr phvsfcal nossessfrn thereof.

Eech definitf on El ven above anolies within all other definitions above.

G S N EhA G IQUT & k Ob0 Y G1 (a) Which contentions of Wells Eddleman do Apnlicants agree are now admitted in this creceeding, N"C Dockets 50-4'00/401 0.L.?

(b) for each such contentien, provide f or any answers to interrog-stories by Wells Eddleman which Auplicants have previously or cresently received (except those suspended by Board oraer, if any), the following information:

(c) Please state the nane, present or last known address, and oresens l

or last known encloyer of each person whom Applicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) uoon whom Apnlicants rolled ( other than their attorneys) in making such answer.

(d) olease identify all facts concerning which each such nerson 15antified in resconse to G1(c)(1) above has first-hand knowledF e.

(e) please identify all facts and/or documents ucon which each nerson identified in resconse to G1(c)(2) above relied in oro#iding information to resoond'to the interrogatory, including the carts of such docunents relied ucon.

w (eIt2A af&

(f) Please identify any other document (s) used/by A licants in resco'ndinE to the interrogatory.

(g) Please state which specific fact aach docunent, identified N in resuonse to G1(e) and GL(f) above, sunports, in the coinion or belief of Acolicants, or which Annlicants allege such docunent supoorts.

(h) Please state specifically what information each person identified in restonse to G1(c)(1) or G1(c)(2) above orovided to or for Anplicants ' affiant in answering the interrogatory. If any of this information is not docunented, clease identify it as "undocunented" in resnonding to this section of General Interrogato"y G1.

G2. a)?leasestateJhenane, present or last known address, title (if any), and oresent or last known anoloyer, and ecenonic interest (shareholder, bondholder, contractor, emoloyee, etc. ) if or other any.(beyond expert witness fees) such nerson holds in Aunlicants or exnect on anv of then, for . each nerson you intend to call as an_ exoert witness or a witness in this proceeding, if such information has not ureviously been supnlied, or has changed since such information was last supplied, to Wells Eddlenan. This ann 11es to Eddlemen and Joint a st culated by Aonlicants.

(b).Contentions as admitted'Otentfon Please identify each co regarding which each such person is expected to testify.

(c) Please state when you first contacted each such nerson with regard to the possibility of such nerson's testifying for

'Aonlicants, if you have contacted such nerson.

(d) Please state the subject matter, separately for each contention as to which each such person is expected to testify, which each such person is exnected to testify to.

(e) Please identify all docunents or carts thareof uuon which each such witness is expected to, ulans to, or will rely, in testifying or in preparing testinony.

5 G3(a) Please identify any other source (s) of information which Applicants have used to resnond to any intevrogatory identified under G1 above, stating for each such source the interrogatory to which it relates, and. what information it nrovides, and identifying- ,

where in such source that information is to be found.

(b) Please identify any other sourceh)of information not urevicusly identified upon which any witness identified under G2 above, or or exhibits other witness, has used in urenaring -testinenp/, or exnects to use

- in testimony or exhibits, identifying for each such source the witness who is expected to use it, and the nart or part(s) of such so urce (if applicable) which are expected to be used, and, if not (or both) ,

ureviously stated, dhe fact (s) or subject matter to which such source relates.

and which

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G4(a) please identify all documents,quages or sections thereof A"nlicante intend or exneet tn .use in cross-examination of any

witness I call in this hearing. For each such witness, please orovide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject natter Aeolicants believe they i relate to, and nake the document (s) available for inspection l

form intent and copying as soon as possible after Anplicants decide or IFt und to use such document in cross-exanination.

(b) please identify any undocumented information Applicants intend to use in cross-examination of each such witness for me.

G5 (a) for each contention Apolicants state or admit is an f -

i admitted Eddleman contention under G1(a) above, or an admitted joint intervenor contention, please state whether Auplicants i

have available to them experts, and information, on the subject matter of the contention.

(b) If the answer to (a) above is other U2an affirmative, state whether Aoplicants exoect to be able to obtain exnertise in the subject matter, and information on it, and if not, why not.

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G-7(a) Please identify all documents which Applicancs plan, exnect or a intend to offer as exhibits (other than for cross-examination) with respect to each Eddleman contention admitted in this proceeding which (i) is included in your current'resnonse to G1(a), or (ii) is the s

subject.of interrogatories in this set; please state for which contention or contentions each exhibit will be or is expected to be offered.

(b) Please identify all documents which Auplicants plan, expect or

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intend to use in cross-examination of any other narties' witnesses or joint intervenor witness in this proceeding, with resnect to (1) Eddleman contentions identified under G-7(a)(1) (or G1-(a))

above, or any other Eddleman conte $ tion which is the subject of inter-rogatories in thie set; (ii) each Joint contention now admitted in this proceeding; (iii) per our agreenent of h-8-83, each contention of each other party to this proceeding which is currently adnitted.

Please identify for each such document the witnesses, or witness, and all contentions with resnect to whom (or which) that document is planned, expected, or intended to be offered or used.

(c) Please identify which of the documents identiSed in response (i) to (b) above will be offevad into evidence by Aunlicants, and (ii)'

which of the sane documents Aunlicants expect to offer into evidence or intend to offer as evidence or exhibits in this nroceeding.

G8 (a) Please identify, for each Eddlenan contention which is I the subject of this or an earlier set of interrogatories, all inforna-tion not previously identified which was (i) used or relied on in preparation of Anplicants' resnonses to that contention and all contentions superseded by it (per transcrint of July 1982 special prehearing conference, the Board's Sentember 1962 order adn'ttting cohtentions, or stipulation by Applicants or W.E.), with respect to any fnets alleged therein, identifying for each such fact the specific source (s) of information used or relied unon.

G-8(b) Please identify all persons who supplied information relied on or used in Applicants' response to each contention for which information a

is requested in G -8(a) above. (ii) Please identify for each such person what information was supplied, and with respect to which conten-each iten of tion (s) EkKk information supplied was used. (iii) Please state all known qualifications of each such nerson with respect to the subject matter of the xxximatina each contention for which that person supolied information.

G-9(a)Please identify all information not identified in resnonse to the above general interrogatories, including all documents, which Applicantsrelyonorftendtouseinnakingtheircaseorcarrying their burden of proof in this proceeding, :..._. . with respect (1) to each Eddleman contention which is the subject of this or an earlier set of Eddleman interrogatories to Apolicants; (ii) with resnect to each joint contention on which discovery is now open under the Board's March 1983 order, or on which discovery has been open under said order establishing a discovery schedule. (The phrase "or on which discovery has been open" is intended to keen this interrogatory current and continuing for information and documents which Auplicants rely on or form intent to use af ter the formal close of discovery.

I interpret Applicants' continuing interrogatories to aunly continuously from their date of subnission to me, and I intend these to apply likewise.)

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l l

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l

. 8-Eddleman intsrrogatoriss to Applicants (2d set, 1st round).. Pleass note that

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the general interrogatories supplied with the first set are continuing, as writt en,_

andapplytobonthons as discovery on then comes open under the Board's 3-10 8S3 order; however I am supplying a copy.of the general interrogatories (revised per my 4 8-83 discussion with Applicants' attorneys 0"Neill and Carrow) at Applicants' request here "because (they) don't like to compare documents" and intend to continue to do so, assuning thereby that the general interrogatories and first group of ass other interrogatories on a given contention together comprise the "first round" under that order. I therefore assume responses to the general interrogatories in a set are not due until the responses to given other interrogatories (first group on a given contention) are due, and hereby grant that tine to Applicants to respond even if I should inadvertently fail to insert the general interrogatories in any future set of interrogatories. Please note that nothing here affects or impairs the continuing effectiveness of my general or other interrogatories to Applicants.

FURTHER INTERROGATORIES (2d set, 1st round, environmental contentions and those on which Applicants seek summary disposition):

N4as used below, " monitor" includes the meanings " detector" and " detection 29-1(a)fPleaseidentifyallradioiodinemonitorsatHarriswhichwill device" continuously sample levels of any radioactive isotope of iodine, or any combination

. of such isotopes, which is located (i) on the upstream side of any filter or l device which is designed, or claimed by Applicants, to remove radiciodines from a gas or air stream at the Harris plant; (ii) directly on the downstream. side of any such filter or device per (i) above; (iii) on the downstream side of any such filter or device per (i) above before such stream of gas or air (including any contaminants and radioactive materials) merges or mixes with any other vent, duct, room, space or other stream or source of air or gas which originates within the Harris plant containment, spent fuel building, auxiliary building, l

or other area into which the FSAR or ER contemplates or states that radio-iodines can be present during normal operation (including by leaks or accidental transport which does not cause the plant to cease operation); (iv) at any other point downstress of any such filter or device per (i) above but before the release of the air or gas stream (including any contaminants or radioactive material it may include) to the environnent; (v) located outside any enclosure or building or vent at Harris but within 10 meters of any designated release point for radiciodines per the FSAR or Fat as currently reviseda (vi) loc.T,ed more than 10m but low t,han 140 h from any designated release point per (v) above.

.( @.) located more than 188 meters from any designated rdlesse point per (v) above; (viii) located between t,Wo OP Acre such designated release points per (v) above or within 100 meters of more than one release point, giving for each such continuously sanpling monitor its distance from each release point it is within 100 neters of; (ix) located outside the exclusion ' area foi Harris; '

(x)' located at the boundarynof the Harris exclusion area.

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. I 29-1(b) Please identify all radioiiodine monitors or samplers at Harris i in each of the locations (i) through (x) as stated in (a) above which l (i) provide e provide conti,ontinuous nuous sampling sampling but mustbut becannot manually beread; read(iii) centinuously; provide (ii) continuous-sampling but cannotube read without removal of a sample from the monitor or sampler; (iv) sample less than continuously, giving the time periods or pattern of sampling for each; (v) are read other than i continuously, providing the method and schedule of reading for each; (vi) provide readouts other than on a continuous basis, stating for each to what places, displays, computers or other equipment the readings are provided, or the data from such monitor or sampler is provided, and the schedule on which it is provided, and the minimum and =n4=_, schedules on which such readout ~or data is checkedby a human being (and which person is to do that, by job description or title if names unknown); (vii) provide other than continuous sampling and are read less often than (na) once per hour; (bb) once per shift (6, 8 or other designated number of hours per shift, stating the nunber of hours in each shift and the title or identity of the person to read same and whether plant procedures require such person to make such reading); (cc) once per day (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), stating the title or identity of the

> person designated to read same and whether Harris plant procedures require such person to make such reading; (dd) once per week; (ee) once per month: (ff) once per quarter; (gg) once per r; (hh) once per refueling cycle, stating the expected length of such re ng cycle; (33) less often than once per year or once per fefueling cycle, a s ing the time interval specified for such reading, and giving fon each of (dd) through (jj) above the information at who (name or job title) is designated by Harris plant procedures to make the reading, and whether the procedures require such person to make such reading within the time stated.

(viii) for each nerson (or job title) stated or listed in response to (vii) above (and all parts or any part thereof), state what the level of radio-iodine reading is at which that person must take additional action, and what action plant procedures require that person to take if the radioiodine reading is at or above that level. (viii-aa) If there is more than one level of radio-iodine reading at which a person making or checking the reading (per vii above's answers you have provided) would have to take a different action, please specify each such action and the =4n4=m level of radiciodine reading that requires such action.

(c) for each radiciodine monitor or sampler (or other radiciodine detector) identified in response to any part(s) or (b) or (a) or both above, please state (i) whether Applicants have independently determined the accuracy of such device, monitor, sampler or detector : (ii) if response to (i) above is affirmative for any such thing, state exactly how the test was done,what the acceptance criteria were, whether the acceptance criteria were established before, during or after the test, who established the &cceptance criteria, the method of the test, who conducted the test, and the qualifications of each person who conducted the test or established acceptance criteria for such test to perform such work or make such test or determine such criteria; and to' identify all documents which include the method (s), acceptance criteria, l lab notes, results of such test, limits of accuracy of the test itself, limits of accuracy of the equipment used, calibration of the equipment used, assay of any radioactive material used in the test, calibration of any equipment teed in assaying the material used in the test, or potential for error in the test as designed or as conducted, including any deviations from the protocol or parocedure for the test which actually occurred during, before or after the test. (iii) If response to (i) above is other than affirmative, please state whether Applicants have any information on the testing of each nonitor identified I

i --. . . . . . , - _. _ _ _ _ _ _ _ _ _ _ _ __ _ ____

9 in response to ary part(s0 of (a) or (b)'above for accuracy (aa) under laboratory conditions, (bb) under plant operating conditions at any other nuclear plant besides Ha_rris, (cc) under other conditions, specifying such other conditions, giving this xmaps infornation for each such monitor, detector, sampler or device.

(d) for each monitor, detector,' sampler or device identified in-response to (c)(iii) above, please give all information requested for an affirmative response to (c)(1) above, which is requested in (c)(ii) 2 above, for each such device, monitor, detector or sampler on which someone other than Applicants has performed accuracy tests.

~ (e) what is the maximum level of contamination known to Applicants to have been found.in or on any radiation m9n6 tor, detector, sampler or other device for detecting radiciodines, identified in response to the above interrogatories or any part thereof, during plant operations at any site other than Harris? (i) what contaminants were involved -- which nuclides in what amounts or concentrations? (ii) how did these contaminants get

.to such monitor. Please note that this interrogatory applies to the same type and the same model of monitor, detector, sampler or other device for detecting radioiodines which is planned to be used at Harris.

(f) At what pages of the FSAR, in what anendments, have Applicants provided (1) the information promised in item 3 of page TMI 61 of the FSAR

as current 5-14-82; (ii) the information for item IV, p. TMI 63 of the FSAR as referenced in (i) above, for steam generator safety relief valet, PORV, atmospheric steam dump valves, and release points of secondary steam from

. the auxiliary feedwater pump turbine, which is promised in the last paragraph on page EC 63; (iii) information concerning any other radiciodine release points or potential release points identified by Applicants or NRC staff or others since the EE Appendix to the FSAR was drafted; (iv) information conerning any other radioiodine release points or potential release points currently known to Applicants in the Harris plant (aa) as designed (bb) as built to date or currently. If any such information is not now in the FSAR, please identify that information, for items i, ii, iii, iv or any or all of thec Pbovec l_

(g) identify the model number, type, manufacturer, and cost of each radiciodine monitor, detector, sampler or device for detection which is

included in (i) the FSAR per response to (f) above, or (ii) the responses to (a),(b),(c) or (d) above, which Applicants plan or expect to install, or have installed, at Harris, stating at what location and for what purpose such monitor, detector, sampler or device is installed or will be installed. (iii) for each such item, state whether CP&L or Applicants or their contractors or subcontractors are in possession of the item (monitor, detector, sa r.pler, or other radioiodine detection device).

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(h) Are Applicants able to sample every release fro the condensate vacuum p:u:p effluent (ii) the atmospheric steam dump valves -- each one, (iii) the steam generator safety relief valves, (iv) the power operated relief valves.

(v) the AFN pump turbine potential release points, (vi) the other c potential or actual radiciodine release points identified in ' (f)(iii) or (iv) above, (aa) continuously for radiciodinest (bb) for (i) through (vi) above,

other than continuously for radiciodines, stating how and how often such sample will be taken, and how nany samples can be taken simultaneously and how many persons are required to take each such sanple and how those persons will be shielded fro. radioactivity. (ce) please identify, for each

. release point in (i) through (vi) above, which nonsampling monitors or detectors will be used at Harris for each such point, whether such device (s) are mobile

• a aa a e at"$hr $ n 'm!hheEsEEapgb gcg {

, othsr 29-1(j) (aia is not used due to possible confusion with makpart parts)

(i) identify all documents in the possession of Applicants which give actual or estimated radiciodine release rates or total amounts (per year or otherwise) for operatir4 nuclear power plants, particularly VC Sumner, North Anna 1, North Anna 2, Robinson 2, Brunswick 1, and Brunswick 2. (ii) if known to Applicants, please state for each plant for which Applicants possess av data on radioiodine releases, whether the monitoring of radioiodines for that plant is continuous at all points of release, including for F7ds every point of release identified in, or in response to, a v part of (h) above; (iii) please, if known to Applicants, state the accubacy and testing for accuracy which each radioiodine monitor, detector, sampler or other device at any i plant listed in (i) above or identified in response to (i) or (ii) above has been during the entire time.for which Applicants have radiciodine release data for that plant,.or a v part thereof, specifying such part of such time, u

' providing all this information for each plant; (iv) If answer to any part (i),(11),(111) or subpart above is other than affirmative, please so state, giving a v basis for such answer, and steting which questions or parts of questions above Applicants do not know the answer to.

29-1(k)(i)Have Applicants performed any tests of (aa) vole thyroids (bb) i mouse thyroids (ce) rabbit thyroids (dd) deer thyroids (ee) sheep thyroids (ff) cattle thyroids (gg) human thyroids (hh) thyroid glands of any other species, stating which species, in order to establish baseline or background levels of radiciodine around and at the Harris plant site? (ii) If answer to any part of (1) above is affirmative, please state who performed the tests, when, what that person's qualifications were to perform uch test, whebe the organisms whose thyroids were tested came from (location and distance-from plant site; within the plant site, distance from the nearest release point identified either in FSAR pages TMI 60 through -63, ot other telease point identified in response to any part of (h) above), what test was done, the method of such test (or tests), the qquipment used in each such test, its calibration, derivation of background couhts, sampling technique (s),

counting equipment used, how long the counting was done for for both samples and background counts, when the sample counts were performed, when the back-ground counts were performed, all results of such tests, identify all documents, lab notes, data sheets, data recordings, printouts, and other records of each such test, and explain why the method (s) or test (s) used were selected.

(iii) do Applicants know if anyone else has performed tests on the thyroids of.'any species inquired about in (i) above within 50 miles of the Harris site (aa) prior to 1970 (bb) prior to 1974 (oconee plant operation) (cc) prior to 1975 (Brunswick 2 operation) (dd0 perior to 1977 (Branswick 1) (ee) prior to 1981 (McGuire 1 operation; (ff) after 1-1-81; (gg) after 12-1-81, (iv) if response to a v part of (iii) above is affirmative, identify such person and state if known, what tests were done by that person and when. If the data of tests done by any person known to Applicants to have tested thyroids of any species within 50 miles of Harris is unknown, please identify the person and say that the date of the tests is not known.

(v) Do Applicants have a position as to whether radiciodine levels in thyroids are an appropriate measure of radiciodine levels to which organisms in the environment are exposed? (vi) If answer to (v) is affirmative, please state *zzk Applicants' position. (vii) Do Applicants know whether a v other electric utility has taken a position concerning whether radiciodine levels in thyroids are anappropriatemeasureofradioiodinelevlestowhichhumansand/orotherorganisms in the environment are exposed. (viii) If answer to (vii) is affirmative, please identify each such electric utility *and state its position or identify any document in which such position is stated.

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29-1(n) Do Applictnts possass any data as to the amount of radiciodinss detected in the environment within 50 miles of (1) their Brunuswick plants (aa) on land (bb) in rivers (cc) in the ocean (dd) elsewhere within 50 miles

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of 3:unswick plants; (ii) within 50 miles of the HB Robinson plant; (iii) within 50 miles of the vc Summer nuclear plant; (iv) within 50 miles of the North Anna nuclear plants; (v) within 50 miles of any Westinghouse PWR plant not inquired about above in (ii), (iii) or.c(ts$; (vi) within 50 miles of any power plant which uses the same types or models of radiciodine monitors '

which Applicants plan to (or have installed) install at Harris? (vii)

If the answer to any of parts (i) through (tvi) above is affirmative, please state the identity of the plant, identify the data Applicants possess, and identify an documents Applicants possess which contains such data.

29-1(n) Do Applicants know whether the same (i) types (ii) nodels (iii) series (iv) design of ra detection device %ggipdpinedaimonitor (bb) detector (ce) sampler (dd) othe (yy) outside the US? For each response to the above 4 by 4 by 2 element set of questions, if the response is affirmative, please identify each power

.p(lant including and which detectors monitors, type, model, series, or and samplers) design is used of radiciodine there. detection de The insertions in the third line of this interrogatory reads "used or to be used at Harris" and fonows the word " device" in that line. That should clatify the question, as it is not clear the insertion will be readable otherwise.

29-1(o) Do Applicants know of any operating nuclear power plant (i) in the US, (ii) outside the US, for which every possible release point for radio-iodines is continuously monitored? (iii) if answer to (i) or (ii) above is affirmative, please identify such plant and an documents in possession of Applicants which confirm or support such answer; (iv) if Applicants answer to either (i) or (ii) above is negative, have Applicants inquired as to this natter of continuous radiciodine monitoring at all possible release points for any nuclear plant?

-(v) If answer to (i) above is other than affirmative, please answer question l (iv) above also, if answer not already given. (vi) please list every utility or power plant for which Applicants have inquired about radiciodine monitoring at, in any way, since March 28, 1979. (vii) for each plant or utility listed in response to (vi) above, please state the inquiry made, how nade, when gr,4de, by whom3made, and the answer or response received, identifying all documents which contain such inquiry or response or were supplied in response to such inquiry.

29-1(p)Please state exactly how Applicants derived their revised iodine source term conveyed to NRC Staff, including (i) whether there was any change in assumed core inventory of radiciodines in naking this revision (ii) if andswer to (i) above is affirmative, the exact changes made, and all reasons for making such changes, and all documents, experts, opinions and other infor-nation relied upon in making such change; (iii) whether there was any(change in 'the transfer of radiciodines assuned in revising the source term; iv)

If answer to iii is affirmative, what changes were nade, why, all reasons for nakit.g each such change, and an documents, experts, opinions and other information that were used in making each such change (v) the derivation.of the core inven-tory of radiciodines, and an experiments, analyses, calculations, and other basis of such core inventory that are known to Applicants for radiciodines; (vi) any assunptions about radiciodines used in deriving Applicants' source term which is currently being used in this case, which have not been identified above, stating for each who made the assunption or computation, and the full

!' basis for such assu.ption; (vii) all other facts used in deriving the radio-iodine terms (each of then) in the source term currently in use in this case.

i 29-1(q) (i) Do !.pplicants hava t v information conearning the brsakdown of or any failure of filters or other devices used to renove radioiodines from any nuclear power p lantz's effluent streams prior to release into the environment; (ii) If answer to i is affirmative, please state such information

+ and identify an documents.in possession of Applicants which contain such information; (iii) Do Applicants have any information on the failure of sealers or gaskets in connection with any failure or breakdown identified in (i) above?

(iv) If answer to (iii) is affirmative, please identify an such information s and all documents containing it, and state such information succinctly.

- (v) what is the exact limit on radiciodine releases for each isotope of iodine during normal operation of the Harris plant per (aa) technical speci'i-cations as proposed by Applicants (bb) technical specifications propased by NRC (ccQ license condition Applicants plan or expect to accede to; (dd) plant procedures; (eeQ please state which limits identified above are enforceable by NRC; (ff) please state any other limit for each radiciodine isotope, or all radioiiodine isotopes togehter, for emissions from the Harris plant, which Applicants believe of know win apply to Harris, in curies per year or any other appropriate measure in which such limit is expressed.

29-1(r)(1) please list the contribution to the Harris source term for each radioiodineisotopefromeachreleasepotg.identifiedabove, including an those mentioned in pages TMI-60 through TMI 63 of the FSA:. as it stood 5-14-82, and all those additional release pathways identified in response to interrogatory (f)(iv) above or otherwise known to Applicants at present.

(ii) for each pathway (ie. pathway passing xk through a release point inquired about in (i) above) for which the amount of radiciodine passing through that point is not kr.own for any radiciodine isotppe, please list that isotope and state that Applicants do not know the anount of (iso 6 ope) released throggh that poiht or pathway. e.g. EApplicants do not know that atount of I-129 released through atmospheric steam dump valve 7" (if that is the case).

(iii) please list all io nne isotopes not identified in the Harris source term (iv) please list an isotopes of eleaents other than iodine, which are produced in nuclear fission or expected to be produced by the Harris core, which decay in any proportion into radioiodine isotopes. (2 v) for each isotope listed in response fo (iv) above please state the halflife of the decay into radio-iodine (aaQ directly (bb)into any other isotope which eventually decays into a radioactive isotope of iodine, and please state the proportion of H R decays identified above (for each such decay) that (cc) result in a rddioiodine isotope, or (dd) result in an isotope which decays further by one or more steps into a rddioiodine, in any p[oportion. (vi) please identify which of the isotopes identified in response To (iv) above will be released from Harris, stating which are in the current Harris source term and which are not.

29-1(s) please identify an (i) gaskets (ii) seals (iii) falexible mounting or TO N material (iv) other mounting material (v) other components, which are useddn M (orm to seal) the air strea .s at Harris which may contain or are expected to contain radiciodines, or which are adjacent to any traps, filters, or other

! devices for removing radiciodines from Harris gaseous effluents, which are

! made of (aa) polyethyL ene, (bb) polyvinyl chloride (PVC) (ce) ethylene

' propylene rubb er (dd) neoprene (ee) crosslinked polyolefin material (ff) chloroprene (gg) ch;.lorosulfonated polyethylene.

l 29-1(t) identify (i) an conponents identified in response to (s) above for whikch Applicants have performed any analysis of (aa) swelling (bb) embrittlement (ce) reduzced elasticity (dd) reduced tensile strength (ee) oxidation (ff) oxidation in conjunction with radiation and heat (fgg) swelling associated with heat, radiation, (and to radiciodines jj) diffusion reduced oxygen rate of (hh) untake ofinmoisture radioiodines (ii) ermeability such mater ial.

an d ossess which rovide any analysis of the above g )any magcum erl gt g gicah in )p(s) above, wit respect to any matter in (1) above.

29 2(a) Pluso specify tha accuracy of t@ wind spesd indicator ussd to collect meteorological data at the Harris tower for use in the ER snd

' licensing of the Harris phant. (b) please state when such accuracy was last tested, and how, and what.the accuracy was at (i( wind speed below 1 mph; (ii) wind speed 1 4 mph (iii) wind speed 5-9 mph (iv4 wind speed 10 14 mph (v) wind speed 15-19 mph (vi) wind speed 20-24 mph (vii) wind speed 25 29 mph, (viii) wind speed 30-39 mph, (ix) wind speed 40 49 mph (x) wind speed 50 mph and over; (xi) any other specific wind speed at which accuracy was tested. Please

' give the accuracy as determined, whether that is in percent, plus or minus speed, of however it was determined, in whatever units accuracy was determined.

(c) please state when such accuracy (per (a) above) was first tested, by whom, by what method, and what the results were, including responses to items (i) through (xi) of (b) above for this first test. (d) please identify all documents which incorporate data or results of tests inquired about in a,b, or e above.

(e) please state how the accuracy of the wind direction indicator at the Harris site has been tested, and when, and what accuracy was determined for it, at an times of testing of its accuracy since such indicator began operating.

(f) if more than one wind direction indicator, or more than one wind spped indicator, has been used for Harris meteorological data, please answer all

^ parts and subparts of a through e above for each such indicator, identifying the indicator and its time in use (starting and ending date and time) if such information is not already given above.

(g) Please state all sources of meteor & logical data in possessions of CP&L other than Harris tower weather data, which were used by Applicants in computing or estimating radiciodine concentrations in the environment during Harris operation.

(h) please identify an documents in Applicants possession which give the time,

' amount, duration, intensity, or other information concerning rainfan or: a snowfall or other ;;ecipitation for any loottion or locations within 50 miles of the Harris plant, indicating for each the year and date such information begings, the location, the method by which the data was collected, and any determinination of the accuracy of such data dich Applicants have made.

($j) Please identify any data Applicants possess on the actual diffusion pattern of (aa)I-131 particles (bb) I-129 particles (cc) other radiciodine particles

~

l (dd) organic iodine (ee) nonradioactive iodine particles (ff) non radioactive l

hypoiodous acids (gg) other forms of iodine around the Harris plant. Please identify all documents in which such data is contained and state how and when and by Won such data was conected, including methods used and percent of iodine released that was traced, and any data showing the distribution of iodine in (gg) air (hh) soil (ii) water (jj) buildings (kk) crops (n) forage or pasture (nm) grass (nn) other stopping points, e.g. cars, residences, schools, etc.

that resulted.

(k) Please identify any studies of the actual diffusion of (i) gaseous iodine (ii) air (iii) other gases, which Applicants have performed at the Harris plant, of (iv) which Applicants are aware of at any nuclear or other power plant.

(v) please identifynall documents which contain the results or methods of such study for each such study, W ich Applicants possess or are aware of.

(1)Please identify any actual tests of diffusion of (i) iodine as a gas (ii) i iodine particles (iii) organic $odine (iv) HOI (v) other iodine compounds which have been conducted (vi) from any release point of the Harris plant identified in response to interrogatory 29-1 above, or inquired about in interrogatory 29-1, e.g. at (f) therein, stating for each test whether the iodine was radioactive or not, and if radioactive , dat isotopes and what amounts were released. (vii) please identify an documents in which the methods of any tests, the results of any tests, or accounts or records of any test identified in response to items in (1) above (i thru vi or any of them) are contained, who performed the tests, who set the criteria for the test, who chose the method of the test, when the test was done, and who ordered the test.

~ . . ,

s I _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ __

15-29-3(a0 Is the sourca term identified in response to 29-1(p) above the ona used to derive the values for expected concentrations of radiciodines in the cooling tower blowdown (Table 5 2.2 3a) or main reservoir (Table 5 2.2.-3b)

(ER) for Harris? (b) If answer to a is affirmative, is it for both or just one, and which one) (c) Is any of the concentration of radiciodines Applicants project for the reservoir or for the cooling tower blowdown due to atmospheric transport of radiciodines? (d) If answer to e is affirmative, please state exactly how much radiciodine which has been in the air before ending in the (i) resrvoir (reservoir) and (ii) cocling tower blowdown. (e) identify all other release pathways or mechanisms whereby radioiodine can get into (i) the Harris reservoir, or. (ii) the cooling water circulating through the cooling towers, stating for each an assumptions that affect Applicants estinate of the radio-iodine released in each pathway, the reasons and data which support those assumptions, and the amount Applicants estimate will leak out through each such pathway (iii) for all radiciodines together . . (iv) for each radio-active iodine isotope.

(f)~ Please identify all documents which Applicants rely on or have used

- in making c_alculations er in answering the questions above re radiciodine release from Harris to (1) cooling tower blowduown, (ii) the main reservoir, (iii) cooling tower circulating water, stating how each wgs used and what facts in each were relied upon.

(g) Please identify all other information, expert opinion, or other facts not identified in response to any of (a) through (f) above which Applicants rely on or use in estimating radiciodine releases to the (1) reservoir, (ii) ~

cooling tower circulating water (iii) cooling tower blowdown.

(h) what amount or curies of radiciodines do Applicants project will be released from the cooling towers at Harris other than by blowdown?

(j) do Applicants plan to monitor the cooling towers for radiciodines?

(k) If answer to (j) above is other than affirmative, please state all reasons for your answer.

(1) what effect does moisture in the cooling towers have on Applicants' ability to monitor radiciodines inside the cooling towers or in their release to the atmosphere? (iii do Applicants have any instruments capable of detecting radiciodinesinthenoistair/ vapor /dropletmixtobefoundinsidethecooling towers? (iii) do Applicants have any instruments capable of neasuring radio-iodines at the top of the cooling tower (s)? (iv) please identify each such instrument, state how its accuracy varies with moisture as humidity and as water droplets, identify any tests substantiating such statements re accuracy variation with humidity and exposure to water droplets, for any instrument

' which is inquired about in (ii) or (iii) above and all such instruments.

(m)(i)Does the release of liquid radioactive waste into the main reservoir

. at Harris count in Applicants estimates of radioiodine in the reservoir 7 (ii) If response to (i) above is affirmative, please state how much radio-iodine, for each iodine isotope, is expected to be released into the reservoir as liquid (aa) per year (bb) over the operating life of one Harris unit (ce) over the operating life of 2 Harris units, as estimated by Applicants . (iii)

Identify all documents and calculations and assumptions nade by Applicants in producing the information supplied in response to (ii) above, stating who made the calculations and assumptions, and what the basis of each assumption is, identifying also any documbnts which support the basis of each assumption.

(iv) do the responses to (ii) and (iii) above use the same source term Applicants identified and answered with respect to in Interrogatory 2901(p) above?

(v) If response to (iv) is other than affirmative, identify what source term was used and give its complete derivation. (vi) If not already identified in response to (i) through (v) above, state all radiciodine pathways' to the

' (aa) main reservoir (bb) cooling tower which Applicants have identified in

- - their analysis of radiciodine releases. - . . ,

, . - . . , . - . . , - . _ - - - . - - - , - . . - _ _ . . . . . - . . . - . . _ , _.c. . - _ . - -- -

--r

29-3(n) (i) please identify all docunents which give - _ - (aa) test data, or (bb) operational data for nuclear power . plants of PW tyce . cpd Westinghouse,NSSS (cc) or operational data for other PBS, or (DD) operational data,for BWRs, showing the amount or percentage of each radiciodine isotope which is trapped by (ee) the liquid radwaste processing system to be used at Harris, or a substantiany equivalent systen (ff) the filters or radio-iodine absorbers or traps to be used at Harris (gg) the substantial equivalent of such filters (hh) the substantial equivalent of such absorbers (jj) the substantial x equivalent of such traps.

(ii) please state for each document identified in response to (i) above how the radiciodine concentration was measured for each isotope (aa) before and (bb) after going through the radiciodine absorption device or systen used (as described in i (ee) through . _ _ (jj) above or otherwise, noting what other absorption device or system was used if it is not one of those in (i) above).

(iii) please state the calibratnion method used, how long before the test it was used, and the accuracy found, for each device used to measure the radiciodine concentrations inquired about in (ii) above. If you don *t know, please so state.

(oMDoesCP&Lpossessacopyofeachdocumentwhichdescribestheexact method CF&L used to calculate concentrations of radionuclides in the main Harris reservoir? (ii) If response to (1) is other than affirmative, please list each document which describes such method and state whether Applicants possess a copy of it. (iii) If response to (i) above is affirnative, please list each such docunent. (iv) please state how the method inquired about in (i) above was determined to be Applicable to the Harris reservoir, and what limita-tions the method has, if any. (v)please state whether CP&L or Applicants have done any study of the actual stratification or actual degree of annual turnover in the Harris reservoir. (vi) if answer to (v) is affirmative, please identify each such study, who did it, when, any documents which (aa) request the study, (bb) plan the study (ccQ include field notes or data from the study (dd) an results of the study (ee) all data collected from such study.

(vii) Have Applicants done or had done any dye-tracer or other tracer study of the Harris reservoir and cirulation of water in it? (viii) If answer to (vii) is affirmative, answer all parts of (vi) above for each such study, and please also state what method, if any, was used to simulate Harris plant water with-drawals and discharges in operation in such study, including the actual withdrawals and discharges of water m'ade, or any assumptions involved in such l simulation, for the study.

l (ix) was any dye tracer study or other emprirical study of Harris reservoir used by Applicants with respect to radiciodine level computations for the ER?

' (x) If answer to (ix) is affirmative, please identify ~any such studynnot already identified in response to the above cuestions, and state for each all the information requested in (vi) above. Wherever information in (vi) is requested with respect to any answer other than that to (v), the language about (v) being affirmative which is contained in the text of (vi) above should be ignored.

l SW (p)(1) Have Applicants peformed any4 analysis or experinents as to the chemical interactions or reactions or (aa) elemental iodine (bb) organic iodine (cc)

HOI (dd) other iodine compounds in either (ee) the Harris cooling tower system, or (ff) the Harris reservoir? (ii) If answer to (i)(ee) or (i)(ff) above is affirmative, please identify any such study, analysis or experiment, state who did it, when, who ordered it, the methods used, identify all documents requesting the study, planning it, giving the nethodology used, stating the field notes or lab notes from such study, workpapers from the study or analysis or experinent, or which give the results of such study, analysis or experinent

- of the data used or collected in such st M y analysis or experiment., ,

1__-__._---

29-3(p) continuid each

.(iii) please state exactly how the results of av experinent, study or analysis

. identified in response to (ii) above affects the concentration of radiciodine in (aa) the Harris cooling tower blowdown (bb) the Harris reservoir (cc) the air above' the cooling towers when they are in use (dd) the air over the HARRIS reservoir, or air moving across the meservoir surface (ee) bottom sediment at Harris reservoir or in it.

(iv) please identify any studies Applicants have performed of radiciodine uptake of algae or aquatic weeds in the Harris reservoir or downstrea, of it, including all docunents that request or contain the results of such studies.

.(v) please identify any other studies of radiciodine uptake by algae which ,

Applicants rely on in their analysis ofradioiodine doses to humans from Harris.

(vi) please identify all information or studies on the water / air - aquatic weed -

waterfowl - human pathway for radiciodine uptake which Applicants have used or rely on for Harris. (vii) for each study identified in (v) or (vi) above i please state who did it, when, whether Applicants have any documents that contain the study, whether Applicants have any documents that contain the results, and identify all documents containing information requested in this subsection (vii$

as well as information recuested in (v) or (vi) above.

(viii) please identify any information concerning iodine concentrations in food chains beginning with algae upon which Applicants rely in computing or estimating radiciodine doses to humans. Please provide all information in the second and third lines (1st and 2d full lines ) of vii above for all information identified in response to this subsection.

29 4(a) Do Applicants consider a site emergency at Harris to be included in

" normal operation"? (b) Do Applicants consider a general emergency at Harris tobeincludedin"normaloperation"?(c)DoAp/plicantsconsiderasitealert at Harris to be included in " normal operation" (d) Do Applicants consider

" normal operation" at Harris to include all conditions which are not defined by NRC as emergency situations on one of the 4 levels (up to general emergency)?

(e) what is the ==v4=m condenser 1.eakage possible at Harris in " normal operation"? ,

(f) what is the maximum primary-t secondary system leakage at Harris that is normal operation? (g) what is the(maximum primary to secondary leakag for which the plant can continue to operate (i) h*+hMy indefinitely (ii) for more than one week (iii) for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (iv) for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (v) for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (vi) for 24 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (vn) for l'ess than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />? (g viii) please state any power limitations that apply to the responses to (i) through (vii) or any of them. (h) what is the maximum radiciodine level in ptimary coolant allowed at Harris in normal operation? (j) Is there any level of radiciodine or of any isotope of iodine in Harris primary coolant that requises or forces the plant to be shut down, by rule, procedure, or otherwisef (k) If answer to j above is affirmative, please state each such level that may require the Harris plant to shut down, giving the highest such level which requires plant 3: shutdown (i) by NRC regulation (ii) by plant operating license condition (iii) by plant operating procedure (iv) utherwise.

(1) Is there a minimus or maximum level of radiciodine in the Harris condenser which would require the plant to shut down? (m) If answe- to 1 is affirmative, what is that level, and is it a maximum or a mininun? (n) what is the naximum amount of fuel or percentage of fuel that can fail (i.e. be leaking from fuel rods) at Harris (i) without the plant being shut down by NRC rille or regulation (117 Without the plant being shut down by license condition (iii) without

• the plant being shut down by CP&L rule or procedure (iv) withou'td being known to plant operators in normal operation (v) allowed in normal operation?

l

29(4) continued .

29(4) (o) please give responses to an parts of (e) through (n) above with respect to Applicants! Robinson 2 plant instead of Harris, i.e. answer all such parts with the words " Robinson 2" replacing " Harris" wherever the word " Harris

• occurs therein.

29-5(a) for each filter, trap or oth'er co=conent at Harris (or in the Harris design) which Applicants intend or expect to renove radiciodines from the effluents of the plant, please state the fonowing: (i) the maximum amount of each radiciodine isotope such component can absorb or renove from effluents, stating from which effluents radiciodine is to be removed; (ii) the maximum amount of all radiciodines together which such conponent can renove from each effluent (e.g. water, air); (iii) the exact effect of humidity on such component's ability to absorb, trap or remove radioiodines from effluents; (iv) if the effect described in response to (iii) above is different for any radioiodine isotopes, please state an such differences for each isotope compared to (aa) I-129 and (bb) to I 131; (v) y a list of an conditions known to Applicants which can or win render such component inoperable;RR

-(vi) a list of a n conditions known to Applicants which can or will prevent such component from removing radio-iodines (aa) at its full rated ability; (bb) at any level above 75% of its fun rated ability; (ce) at any level above 50% of its full rated ability; (aa) at any level above 25% of its fun rated (ee) at any level above 10%xof its full rated ability; (ff) at any level ability above 5 % of its run rated ability; (gg) at any level above 1% of its full rated ability. Fun rated ability means its normal ability (in amount, or in %,

of radiciodines passing such component or input into it or past it) to remove radiciodines. (vii$ If any of the responses to any parts of (v) or (vi) above or to (v) above or (vi) above entire, would vary with radioiodine isotope involved. please state an such variations (i) as compared to I-129; (ii) as compared to I-131. (viii) If Applicants do not have the above-requested information for any specific radiciodine isotope, or all radioisotopes, of iodine, please state an information Applicants do have, responsive to any part of (a) above, for any or an radiciodines, identifying the interrogatory to which each such answer is reponsive.

29 6(a) Are an maintenance and technical specifications and procedur k design data, related to radioiodine filters, traps, absorption or removal devices, and monitoring at Harris given in the FSAR and the ER? (b) If response to (a) is other than affirmative, please identify all documents which contain such information, detailing for 'each the information it contains which is inquired about in (a) above. (c) If response to (a) above is affirmative, please identify i

l the sections of the FSAR, and of the ER, in which su'ch information is contained, stating .and what information is contained in each (~ .e.g FSAR X.Y.1.31 contains the description of all radiciodite traps and their design)

{

(d) If response to (a) above is other than affirmative, please provide the information requested in (c) above for an data requested in (a) above which is in the FSAR or the ER. (e) Identify any other information relating to radioiodines which is in the FSAR or ER and was not requested above, stating where such information is located, in the FSAR or ER. (e.g. FSAR Y.X.1.1.1 has the radioiodine source term, and Y.X.1.1.1 3(b) has the derivation of that source term, for an radiciodine isotopes).

(f) please describe all nounting or sealing gaskets, frames, and devices to

- be used in connection with (i) radioiodine-absorbing filters (ii) other I

devices used to remove or trap gaseous or liquid radioiodines (or radioiodine l

particulates) from effluent strests (air or liquids or other material moving tow ard or to a discharge point, directly or indiurectly) at Harris, giving l

the fonowing information for each: (iii) the material and manufacturer, (iv) l the dinensions (v) the mounting or attachment of such gasket, frame of device, (vi) what it is mounted tuon, or in, or attached to (vii) if it is not attached w w,-wy -,e - -- - -- w.* y g- -- - -+.+ ,m,

. _ .=.

29-6(f) continued please describe how it is kept in place, what it rests on, and how it may be remove,d; (vii) what parts of it are in contact with effluents, giving dimensions and describing which parts are in contact, if any; if none, so state; (viii) whether Applicants have determined the (aa) maximum, (bb) typical or. average (ce) mininum radiation exposure to which such nounting, or sealing gasket, frame or device will be exposed in normal Harris operation; (ix) whether Applicants have determined or know the (aa) maximun (bb) normal or average, (cc) minimum concentration of (xx) oxygen (yy) nitrogen (zzt) water, (ww) particulates to which such device win be or is expected to be exposed in normal- Harris operation; (x) For each such device being described in response to this interrogatory (f) and its parts above, please give each determination which Applicants have nade or know, which was inquired about in (ix) above.

(xi) Have Applicants done any study of embrittlement of gaskets or seals in the Harris plant due to exposure to (aa) radiation (bb) oxygen (cc) both radiation and oxygen (dd) radiation at doses below or equal to those stated for any component or device in response to (x) above? .

(xii) If answer to any part of (xi) above is affirmative for any device.or component, then for each such device or component please identify (aa) an documents con-cerning the study or containing the results, or methods, or records of such study; (bb) the authors of each such document identified in response to (aa) above; (cc) the qualifications of each such author; (dd) an instruments or equipment used in such study; (ee) which docuents contain the results of the study; (ff$ what uncertainty was determined to be in those results.

(xiii) what the design life of such component, device, gasket or sealing device is; (xiv) what schedule such component, device, gasket, or sealing device win be replaced on, according to Applicants' current plans; (xv) the radiation exposure to personnel involved in such replacement, per device, if Applicants have made a deternination or estimate of such exposure; (xvi) the internal and external radiation in any determination or estimate given in response to (xv) above, including which radionuclides, if any, are expected to be deposit'ed internany in any person replacing such device, (xvii) the failure rate of such seal, gasket, or mounting or sealing device estimated by Appicants; if no estimate made, so state; if actual data used to give failure rate, identify source of data and an documents containing such data; (xviii) identify all dccuments containing actual or estimated failure rate of such component, or estinated lifetine of such conponent without failure.

2" Failure" means failing to perform its function, e.g. leaking for gaskets, seals and sealing devices.

29-7(a) What is the ninimum configuration of radicio' dine absorbing, trapping or filtering devices at Harris which is anowed during nornal operation?

Please list each component or device in this configuration, and the number of each required to be operable at all times during normal operation. (B)

On what schedule is the operability of each conponent listed in response to (a) above to be verified, and by whom. (please state for each such component, including an devices and components identified in response to (a) above).

(c) who is responsible for each such verificatinn? (d) must the plant (Harris) be shut down if such verification is not nade? (e) please list an such verifi-cations which, if not made, will (1) cause the plant to be shut down; (ii) l cause the plant to be derated, giving the derating required, (iii) require the plant to be shut down; (iv) require the plant to be derated, giving thederating required. (f) please give the schedule on which each component identified in response to (a} above is to be replaced at Harris; (g) please give the schedule on which each eonponent identified in response to (a) above win be serviced,

. - stating all actions to be taken and an checks to be nade, in servicing sane.

" schedule" as used herein neans any tines (e.g. 3 times per year', during each refueling outage, before every plant startup fron cold shutdown, etc., as well as any schedule giving exact dates or approxim te dates.

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20-29-8(a) Please identify all naterials use'd in (1) radiciodine-trapping filters for use at Harris (ii) mountings of such filters (iii) gaskets or seals for such filters (iv) naintaining airtight conditions in air or gas pathways at Harris where Applicants expect that radioiodines nay or weill be present.

(b) please state which of the above materials incorporate (i) polyethylene, (ii) polyvinylchloride (PVC) (iii) chloroprene (iv) ethylene propylene rubber (v) neoprene (vi) crosslinked polyolefin naterials (vid)chlorosulfonated polyethylene (viii) any other rubber (ix) any other polyner (x) any flammable material, including any of the preceding.

(c) please state whether Applicants have determined (1) the tensile strength, (ii) the change in tensile strength when exposed to radiation and oxygen, (iii) the swelling when exposed to radiation and lower oxygen levels than 21%

(iv) the change in tensile strength when exposed to radiation and then to heat (v))the swelling when (vi the tendency exposed to crack (vii) thetospeed radiation, heat, and of oxidation at the oxygen levels below 21%

temperatures such material is expected to be at at Harris, for each material identified in response to (a) above.

(d) please state whether Applicants have analyzed the effect of fires at Harris on the oxygen concentrations to which each of the materials identified in .

response to (a) above are exposed. (e) for each material for which your response to (d) is other than affirnative, please state any information in possession of Applicants, not already identified in response to other interrogatories, which gives for that material.any of the properties (or characteristics, if you will) listed as (i) through (viii under (c) ab'ove; including the identification of each document containing information, which of the things listed as (i) through (vii) of (c) above it contains, on what page, who wrote it, and when.

(f) for each material for which your response to (d) above is affirmative, please state whether Applicants have any off the information about the properties (i) through (vii) of (c) above. (g) Identify which infornation, and all documents containing that information, Applicants possess, for a each affirmative response to (e) above for each material.

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37-B 1(a) Please identify or list an diseases which Applicants have estinated the increased incidence of due to operation of the Harris plant, including those which have been specifically calculated for increased incidense *Mm+rm for which Applicants have calculated there win be no increase.

- (b)-identify, for each such disease, (i) all documents wherein such estimate or calculation was made, (ii) all docunents and information relied upon by Applicants in naking such calculation or estimate, (iii) who made the calculation and state when such calculation or estinate was made, and who made'the esti: ate (if not already stated), (iv) any estimate known to Applicants for (aa) the increased incidence of such dfease due to Harris operation (bb) the value of any number, factor or relationship used in making Applicants' calculation or estimate, (cc) any other information. relative to the increased incidence of such disease due to external or internal radiation er radionuclides, which (for (aa) through (cc) or. any of them) is higher than the Applicants' calculation, estimate, of any number, factor or relationship used in making such calculatica or estimate, of which would increase Applicants' estimate if it were used in making such

,- calculation or estimate.

- (c) Please identify an information in the possession of Applicants which alleges or states that Mt2 (aa) NRC (bb) BEIR-III or the BEIR Committee (cc)

Applicants (dd) EPA (ee) NRC nodels (ff) Applicants' models or calculations:

(gg) underestimate radiation exposure to (i) hu-an beings or a human being; (ii) anirals (iii) g food crops (iv)s air (v) water,within 50 miles of Harris, or in connection with operation of any other nuclear power plant, (hh) underestimate the incidence of any dissease due to exposure to radiantion or any radioactive material listed in 10 CFR 20 and its appendices.

.(d) pisase list an diseases for which any information was identified under (c)(hh) above, n

37-B 2(a) For each document identified thus far by Wells Eddleman in response

' to Applicants interrogatories concerning Eddleman contention 37 3, please state (i) whether Applicants possessed a copy of such document before Eddlenan made same available to them (or, for documents not made available by Eddleman, whether Applicants possessed a copy of same before Eddleman*s responses to i

interrogatories, kunx in which he identifies such document, were received by

- Applicants); (ii) whether Applicants have made any analysis or study of such document; (iii) for an affirmative responses to (ii), and each of them, who made the study, when, who ordered the study (if anyone), the results of such study, the identity of an documents containing the results of such study, and whatsher Applicants intend to offer such study into evidence, in this proceeding (iv) for au responses to (ii) above which are other than affirmative, whether Applicants possess any study, response, critique, or analysis of such document made by anyone else other than Applicants; (v) for an affirmative responses to (iv), please state the information requested for affirmative responses to (ii) in (iii) above: e.g. who made this study,- responase, critique, or analysis, when, etc, including whether Applicants plan to offer such study, response, critique or analysis into evidence in this proceeding.

37-E(3)(a) Please list an diseases and other health effects (including deaths) which Applicants, in their ER, have considered or mentioned. (b) Please state which, if any of the dhiseases and healtypffects identified in response to (a) above Applicants believe can be caused bf tadiation (ii) radioactive material i emitted from the Harris plant. (c) please state if Applicants considered radiciodine doses to fetu ses in their ER. (d) If response to (c)'is affirmative,

! .please state at what pageTs) such doses were considered.

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(7(30(3) e) hease continued list all diseases Applicants believe can be (i) caused by radiation, (ii) contributed to by exposure to radiation (iii) contributed to by exposure to low-level radiation (iv) caused by exposure to low-level radiation (v) made more severe by exposure to low-level radiation (vi) made more severe by exposure to radiation. (f) For each' disease listed in response to (e) above for which Applicants have not made an analysis of the increased incidence of such disease to be expected due to the operation of the Harris units, please state an reasons, facts, and opinions held by Applicants to support their not having made such analysis in the ER. (g) please list all genetic defects and genetic diseases which Applicants believe CANNOT be caused by exposure to radiation in'(i) one parent (ii) both parents (iii) any ancestor.

(h) please list or define all diseases which Applicants believe CANNOT be caused by radiation. (j) please list or define any disease not heretofore identified which ? Applicants believe can be caused by radiation. (k) for each disease listed or defined in response to (g) or (h) above (or both). please state the basis of Applicants' belief that such disease CANNOT be caused by radiation,

' including all documents, experts, and information relied upon by Applicants in forming, supporting, holding or maintaining that belief.

37(BQ (4)(a)For each disease which Applicants have above stated can be caused by radiation, in response to any interrogatory above, please state whether Applicants believe (1) that such disease can occura among persons within 50 miles of the Harris site (ii) that the victims of such disease undergo pain and/orsuffering(iii)thatifanyonediesofsuchdisease,thatpersonwill have undergone pain and/or suffering (iv) that if anyone lives with this disease chronically active, that such person will undergo pain and/or suffering (v) that if anyone lives kith this disease active, that person may have expenses related to (aa) treatment of the disease (bb) pain relief (cc) maintenance of one's person due to incapacitation caused by the disease.

(b) please list all forms of mental retardation which Applicants believe CANNOT bem caused by radiation, or define all such forms of retardation.

(c) p& ease state the basis for Applicants' belief that each such disease identified

, in response to (b) above cannot be caused by radiation.

(d) please Hst any forms of mental retardation Applicants believe CAN be caused by radiation. (e) please provide the information requested in (a) above ("please I

state whether Applicants believe (i) ..... disease.") for each form of mental retardation identified in response to (d) above.

64-1(a) please list every valve on the IF-300 series spent fuel shipping cask owned by Carolina Power & Light Company (b) please identify all documents in which the seating nechanism of any such valve is shown or described (c) please identify for each such valve, all documents which describe the valve, which Applicants possess or which are known by Applicants to be on file with NRC.

(d) please identify all documents which list or describe the materials of each valve identified in response to (a) above. (e) please identify the chemical constituents of each raterial which is incorporated in each valve identified in response to (a) above. (f) please identify all fluorocarbon components of each valve in the IF-300 series spent fuel shipping cask owned by Applicants (or by CP#L).

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-23 64-2(a) Please state all reasons why the IF-500 series casks are no longer used to ship fasi spent nuclear fuel with water. (b) please state whether Applicants ar,e aware of any finding that valves on the IF-300 series casks (i) would not (ii)might not reseat after opening; (c) please sT, ate all 4 conditions under which Applicants believe the values on the IF-300 cask would open (i) when the cask contains a full amount of water as coolant (ii) when the cask is used " dry"; (d) please state the maxinum tenperature of spent fuel which a dry IF-300 series cask can handle safely; (e) please 3

state the maximum spent fuel heat generation, in watts thermal, EUs per hour, of other units of heat generatinn, which CPE's IF-300 series cask can handle (i) for a trip of up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (ii) for a trip of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (iii) for a trip of up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (iv) for a trip of up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (v) for holding such fuel within the cask indefinitely. Please also stat _ethe temperature outside the cask which is assumed in your answers to each of (i) through (v) above, and the maximum temperature outside the cask for which each such statements (your answers to (i) through (v) above ) remain valid. '

(f) please state the exact basis, and all calculations, which support your answers to each part of (e) above. (g) please identify all documents you rely

' on for answers to each part of (e) above. (h) please state whether CPE has shipped fuel dry in the cask CPE owns (spent fuel).

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64-3(a) Is CPE*s spent fuel shipping casks equipped withhnstruments or gauges which (i) continuously measure the temperature ins 1.de the cask (ii) continuously measure the pressure inside the cask (iii) can constinuously measure the air pressure inside the cask (iv) can measuure the temperature . ,

inside the cask on demand (whenever you request a reading) (v) can measure the pressure inside the cask on demand (vSi) measure the temperature of the spent fuel inside the cask (aa) directly (bb) indizrectly; (vii) measure

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the pressure inside the cask in any way (viii) measure the a tenperature inside the cask in any way? (b) If your response to.any part of (a) above is affirmative, please state for each part for which your answer is affirmative, what instrument is used, where it is located on or in the cask, what its' accuracy is, whether this accuracy has been measured in the tine since the cask began service, whether and how this accuracy is affected by radiation inside- the cask, or particles of radioactivity inside the cask; whether this accuracy is affected by the use of air, rather than water, as the " filling" of the cask around the spent fuel; whether this accuracy is affected by thernal circulation of air inside the cask, and if so, how, and the identification of all documents in which the information requested above in (b) is contained.

(c) does CPE measure the temperature of air inside its shipping cask during

" dry" shipments of spent fuelf Please state how if*not identified aber in response to the above interrogatories.

(k4(a) Please state the maximum amount of water allowed inside CPE's spent fuel cask during a " dry" shipment of spent fuel. (b) please state the m=v4== surface temperature of spent fuel which has been shipped " dry" in this cask to date. (c) please state any temperature which CPE believes (i) would (ii) could cause any valve on the CPE IF-300 spent fuel cask to (a) open (b) stick open.' (d) are any of the valves on CPE's spent fuel.

cask pressure-actuated? If so, please state the pressure at which each such valve is set to open. (e) has the opening pressure for any valve on~ CPE's spent fuel shipping cask been changed since the cask was withdrawn from " wet" g use and liriited to " dry" use? (f) if answer to (e) is affirnative, identify each such valve and the change and. original and final setting of its opening pressure. ,

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64-5(a) what naterial is used in the seals of CPE's IF-300 series cask-(hereinafter, cask, or the cask, or CPE's cask)? (b) is there any Teflon-like material used in (i) the seats of the cask (ii) the valve.s of the cask (iii)1aeals around or in valves of CPE's cask? (c) identify each such material

_ and what seal or valve it is in, how thick it is, what its dimensions are, and its shpape, for any affirmative response to (b) above, for each such valve, or seal, in the cask. (d) please identify the melting point of each raterial used in any (1) seal (ii) valve in CPE's cask. (e) please state the variation stic modulus (iii) bulk modulus (iv) hardness of (i) tensile of each naterial used in (aa)strength (ii) k'any seal (bb) any valve of the cask, stating

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which seals or valves the material is used in, with temperature, from 0 degrees F to the melting point of the material. (f) please identify any documents known to Applicants or in their possession which give any of the information requested in (e) above. (g) does any material used in (1) any seal (ii) any valve of the cask undergo a chemical breakdown or chenical reaction (aa) by itself (bb) with air (cc) with water (dd) with steam at any temperature below its melting point? (h) does any material used in (i) any seal (ii) any valve of the cask not have a melting point? (j) if the answer to (h) is affirmative for any material, please provide for that material answers to l (g)Qii) through.(dd) above, i.e. stating whether such material undergoes i any breakdown or chemical reaction without melting, by itself, with air, with water, or with steam, at any temperature.

64-6(a) Do Applicants possess a copy of a document by Pacific Northwest Laboratories entitled An Assessment of the Risk of Transporting Spent Nuclear Fuel by Truckt (b) Do Appalicants possess any documents concerning spent nuclear fuel shipping casks which refer to " Teflon valve seals"? (c) Do Applicants know if the document inquired about in (a) above refers to " Teflon valve seals"?

~(d) Do Applicants agree x that the valve seal materials used in both truck and rail spent fuel shipping casks are similar? (e)If your answer to (d) is other than affirmative, please state all differences you knew in (i) the

-content of the materials, and (ii) the physical properties of the materials, including nek1 ting point. (f) at what temperature d.o Applicants believe failure of the (i) seals (ii) valve seals on CPE;s cask would occur? (g) Is there any tenperature which kpplicants believe (i) seal x failure (ii) valve seal

' failure on their (CPE"s) cask could not occur below? (h) If answer to (g)

I is affirmative, what is that' temperature for (i) seals (ii) valve seals

! (iii) any seal (iv) each seal?

l 64-7(a) Do Applicants have any data as to the frequency of occurrence of ruptured disks in valves on IF-300 series casks? (b) Do Applicants have any I

data on seal failures in IF-300 series. casks? (c) Do Applicants have any data on whether IF-300 series casks have actually been in fires, or what temperature such . casks have reached in fires? (d) If your answer to any of a,b, or e above is affirmative, please identify all documents containing such data.

l' 64 8(a) Do Applicants have any data on actual testing of valves on the IF-300 series casks? (b) Do Applicants have anyudata on Sandia labs tests of IF-300 series casks? (c) Have If-300 series tasks ever been physically tested for i conformity with the requirements of 10 CFR 73 32,10 CFR 73 31 or 10 CFR part i 732 Appendix A or Appendix Bf (d) if answer to (c) above is affirmative, (i) l was it CPE's cask, and (ii) which requirements were physically tested ~for?

• (e) please identify all documents which ekontain informationi inquired about in parts (a) , (b), (c) and /or (d) above, stating for each what information it contains.

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. . 64-9(c) Do Applicants know if tha prossuro relist valves on CPE's cask have d ever been tested? (b) If response to (a) above is affirnative, were they tested? j when? with what resultst did av valve fail to reseat in a test? If so, which ones  :

failed to reseat? (c) Are the ASE requirements for pressure relief valves on IF-300 senies casks the .same ones that apply to stationary nuclear power. i plant ,compon4nts such as pressure a relief valves? (d) If answer to e is other than affirmative, please_ identify which sections of the ASME code apply to pressure relief valves on IF-300 series casks and which apply to pressure  ;

relief vavles in nuclear plants. (e) Do Applicants agree that pressure relief valves (i) generally (ii) in nuclear plants (iii) in spent fuel casks (iv) in IF-300 spent fuel casks (v) in CPE's saka cask, sometines stick open? t i

(f) if your answer to or for any part of (e) above is other than affirmative, state in detail the basis for your answer and all facts which support it. l 1 -

67-1 (a) Has any nuclear utility other than CPE ever been caught disposing  !

of low level radioactive waste-(i) in landfills not approved for radioactive  ;

waste disposal (ii) through' scrap dealers (iii) without proper authorization? i (b) for each part of (a) above for which your answer its affirmative, please l identify each suchs utility, (h c) Do Applicants know of any nuclear utility company d ich is doing any of the things inquired about in (a) above which hasa not yet been caught? (d) If answer to (c) is affirmative, do Applicants plan to identify such utility to the NRCf (e) If answer to (d) is other than affirmative, why nott (f) what is the identify of 7ach utility for which your

answer to (c) above is affirmative?

' 67 2(a) Did any lawyer for Applicants, or on retainer to Applicants, participate N

in ag way in drafting the " Southeast Interstate Radioactive Waste Management Compact"? (b) did any other employee of Applicants participate in ag way l\3 j in the formation or drafting of this compact? (c) did any CPE enployee have ii anything to do with the introduction of NC S,nate Bill 196 which contains ii provisions for North Carolina ratifying such compact? (d) did any CPE enployee a' or attorney on retainer to CPE or its co-Applicants (i) draft or help draft ' ~

any part of NC Senate Bill 1967 (ii) do anything to help get S nate Bill 196 introduoedf-(iii) lobby in any way for the passage of Senate Bill 1967

'(e) If response to any part(s) of (d) above is affirmative, please identify

- for each such part each person who took part in each activity. (f) hhat role, if any, did the Governor's Waste Management Board play in the negotiation, drafting, or formation of the " Southeast Interstate Radioactive Waste Management Conpact" (hereinafter, SE compact)? (g) Khat part did CPE's VP William Graham,

,- y a member of the Governor's Waste Managenent Board in NC, play in the negotiation, drafting, or formation of the SE compact?

67-3(a) Has the SE compact been ratified yet by North Carolina 7 (b) If your answer to (a) is affirmative, (1) do Applicants possess a copy of the ratified

,3 bill, appropriately certified? (ii) are there any restrictions on the use of the disposal site (aa) at present (bb) in the future for low-level i radioactive waste which that bill designates for North Carolina, for any low-level waste from Harris including (cc) resins (dd) filters (ee) trapped -

radionuclides in any form (ff) radioactive parts, including steam generators w .

or parts thereof removed from Harris (gg) control rods (hh) incere probes s ($$) other wastes designated as low-level under ERC regulationst

'67 4(a)Has CPE ever issued any memo or order at its Brunswick plant to attempt to.(i) reduce the output of low-level waste from that plant, or (ii)

, segregate " clean" materials exposed to radioactive material, for disposal other than as radioactive waste?_(b) If your answer te either part of (a) is affirmative please identify and dste such nemo or dBer (c) does CPE presently ship low-level

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radioactive waste from Brunswick to any sitet (d) identify each such site and '

b the amounts shipped (i) in 1979 (ii) in 1980,(111) in 1981 (iv) in 1982, (v) i~

p in 1983,lin cubic feet, curies, and number of shipnents.

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(e) identify all documents containing infomation inquired about in (d) above.

RIQUEST FOR p.0ITJC' ION OF DOCIIGNTS Wells Eddleman requests that Applicants 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, for inspection and copying, at a place mutually convenient to Applicants and Wells Eddleman.

f is 4-22-83 Wells Eddleman e

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