ML20071E628
| ML20071E628 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/03/1983 |
| From: | Wilson R WILSON, R. |
| To: | CAROLINA POWER & LIGHT CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8303140269 | |
| Download: ML20071E628 (6) | |
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ra.AICD connE:;P0XDCiCa UNITED STATES OF AMERICA
/f{,yp NUCLEAR REGULATORY COMMISSION N'il? ll A10:25 ATOMIC SAFETY AND LICENSING BOARD
^5r BEFORE ADMINISTRATIVE JUDGES Glenn 0. Bright Dr. James H. Carpenter James L. Kelley, Chairman 3 March 1983 in the Matter of CAROLINA POWER & LIGHT COMPANY Docket Nos.
50-400 OL' AND NORTH CAROLINA MUNICIPAL POWER 50-401 OL AGENCY NO. 3 (Shearon Harris Nuclear Power Plant, Units I and 2)
RESPONSE TO APPLICANTS' INTERR0GATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Answers To General interrogatories 1 (a)
I relied on no one.
(b)
See I(a)
(c)
See I(a) 2,(a)
No one provided information.
I relied on no one.
(b)
See 2(a) 3 (a)
I have not selected any expert witnesses yet.
(b)
See 3(a)
(c)
See 3(a) 4 (a)
I used only the FSAR and ER except the reference in response 1 (b) - 1 (a)
(b)
See 4(a)
(c)
See 4(a) 5 (a) (b)
See 4(a) 6 (a) (b)
None 7 (a) See 4(a) 8303140269 030303 PDR ADOCK 05000400 vse;
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Answers to, Interrogatories on Specific Contentions 1(a) - l(a)
My contention is that the ER does not define the extent and impact of chlorine dispersal.
(b)
See f(a)
(c) (d)
I have pointed out that the ER neglects to address a specific effluent and environmental impact of the operation of the Harris plant.
I have made no further allegations and therefore at this point have done no analysis myself.
l(a) - 2(a)
See I A-1(c)(d) above (b)
See 2(a) above (c)
See 2(a) above (d)
See f (a) - (c) (d) above lla) - 3(a) The NPDES permit is for wastewater discharges. My contention deals with vapor effluent.
(b)
See 3(a)
(c)
See 3(a) 1(a) - 4(a)
See 1(a)-(c)(d) above (b)
See 4(a)
(c)
See 4(a) l(a) - S The text of the ER refered to Reference S.3-4-4 by Larson.
lhere was no citation at the end of that section. My point is that this citation is deleted.
l(b) - 1(a)
My contention is that chlororganic compounds dispersed in cooling towers vapor may be toxic to the surrounding biosphere.
(b)
Chlororganic compounds are formed in chlorinated cooling water.
(Jolley, R'.L.', W.W. Pi tts, F.G. Taylor, S.J. Hartmann and G. Jones, Jr. In: Water Chlorination:
Enviromental Impact and Health Effects, Jolley, R.L., H. Corchev, D. H. Hamilton (eds). Proceeding of a conference October 30 - Nov. 4,1977)
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Chlororganic Compounds may be toxic directly, through behavioral effects, and
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through mutagenesis.
. Jolley, R.L., G. Jones, W.W.Pitts, J.E. Thompson Chlorina-tion of Organics in Cooling Waters and Process Effluents.
In:
Symposium pro-ceedings cited above.)
(c)
See f (a) - 1(c)(d) l(c) - 1(a) My contention is that sulphuric acid and hydrogen peroxide may be toxic to the surrounding biosphere.
(b) See 1(a) - 1(c)(d)
(c) See (b)
(d) See (b) 1(d) - 1(a) My contention is that "other chemicals" (words from ER) including biocides could be toxic to the biosphere, (b)
See l(a) - l(c)(d)
(c)
See (b)
(d)
See-(b) 1(e)-1 ft did not seem reasonable that'one small creek could replace the water i
lost through cooling tower evaporation for 2-unit operation.
I have done no numerical analysis.
l(e) - 2(a)
It is widely known that the Cape Fear has many industrial waste inputs as well as municipal sewage inputs.
(b)
I have not analyzed the composition of the river.
l(e) - 3(a)
Yes (b)
See 1(e) - I above.
By " dispersed" I meant spread as vapor or aerosol i
in the cooling towers' plume.
i l(e) - 4(a)
I contend that the Cape Fear water, if dispersed, could be toxic to the bio ~ sphere.
(b)
See l(a) - 1(c)(d)
(c)
See (b) i
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1(f) - 1(a) As I stoted in the fIrst Prehearing Conference Page i1I my concern is that routine operation of the plant might require more water tnan could be provided by Buckhorn Creek flow. The Reservoir Reanalysis has confirmed that concern.
The point of my contention is that Cape Fear water will be used and that contention 1(e) mus t therefore be addressed.
(b)
See I(e) - I above (c)
See 1(a) 1(f) - 2(a)
I contend that there may be times when Cape Fear River Water may be necessary to prevent unacceptably low water level in the main reservoir.
(b)
See I(e) - 1 above I(f) - 3(a)
No (c)
I clarified my concern in the First Prehearing Conference Page 111.
l(f) - 4(a)
No (c)
I made no mention of the loss of service of cooling towers scenario.
1(f) - 5(a)
No (c)
I made no mention of the Main Reservoir as a back up cooling reservoir.
1(f) - 6(a)
No (c)
It is irrelevant to my contentions.
l(f) - 7(a)
I contend that the method of calculation is not displayed and therefore cannot be evaluated.
l(t) - 0 There is no documentation of the comparison of rainfall in the Buckhorn Creek watershed and the Middle Creek watershed.
The " synthesized" estimate of Buck-horn Creek flow (90 cfs), based on Middle Creek estimates, differed from tne measured flow for the period 1973-1977 (79 cfs).by 12%.
1(f) - 9(a) Their equivalence has not been documented.
(b)
I have not analyzed this question myself.
I(f) - 10 See above only.
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l(f) - II(a)
See 1(c)-1 and f (f)-1(a),
l (f) - 12 1 do not know the frequency with which water will be used from Cape Fear rivers Response To Request For Production Of Documents The document referred to in Respon'se f (b) -l(a) is available at the North Carolina State University Library.
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UNITED SfATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of CAROLINA POWER & LIGHT C0. Et al.
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Dockets $0-400 Shearon Harris Nuclear Power Plant, Units I and 2
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and 50-401 0.L.
CERTIFICATE OF SERVICE I hereby certify that copies of RESPONSE TO APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS HAVE Been served this f day of March 198 3, by deposi t in the US Mail, fi rst-class pos tage prepaid, upon all parties whose names are listed below, except those whose names are marked with an asterisk, for whom service was accomplished by Judges James Kelly, Glen Bright and James Carpenter (I copy each)
Atomic Safety and Licensing Board US Nuclear Regulatory Commission Wells Eddleman Washington, DC 20555 718-A Iredell St.
George F. Irowbridge (attorney for Applicants)
Shaw, P i t tman, Pot ts, & Trowb ri dge Phyllis Lotchin, PH.D.
1800 M. St. NW 108 Bridle Run Washington,0C 20036 Chapel Hill, N. C. 27514 Of fice of the Executive Legal Director Dan Read At tn Dockets 50-400/401 0.L.
CHANGE /ELP USNRC Box 524 Washington, DC 20555 Chapel Hill, N. C.
27514 Of fice of the Secretary Pat & Slater Newman Docketing and Service Station CANP Attn Dockets 50-400/401 0.L.
2309 Weymoutn court USNRC Haleigh, N. C.
27612 Washington, DC 20555.l3 copies)
Ruthanne G. Miller, Esq.
John Runkle Atomic Safety and Licensing Board Pac CCNC U.S. Nuclear Regulatory Commission 307 Granville Rd.
Washington, D.C.
20555 Chapel Hill', N. C. 27514 Deborah Greenblatt, Esq.
Travis Pa'yne 1634 Crest Rd.
Edelstein & Payne Raleigh, N. C. 27606 Box 12643 Raleigh, N.C. 27605 Bradley W. Jones, Esq.
U.S. Nuclear Regulatory Commission p
Region Il Certified by 101 Marrietta Street Atlanta, GA 30303
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