ML20071H108

First Set of Interrogatories on Contentions Iii,Iv & V. Certificate of Svc Encl.Related Correspondence

ML20071H108
Person / Time
Site:	Harris
Issue date:	05/16/1983
From:	Payne M EDELSTEIN & PAYNE, KUDZU ALLIANCE
To:	CAROLINA POWER & LIGHT CO.
References
ISSUANCES-OL, NUDOCS 8305240507
Download: ML20071H108 (15)

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UNITED STATES OF AMERICA 9,Q%"'ED NUCLEAR REGULATORY COMMISSION

'N liif 10 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD mS .54

. In the Matter of )

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CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY ) Dochet Nos. 50-400-OL

) 50-401 OL (Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

JOINT INTERVENORS' INTERROGATORIES TO APPLICANTS ON CONTENTIONS III, IV, AND V (FIRST SET)

Pursuant to 10 CFR 2.740b and 2.741 and to the Atomic Safety and Licensing Board's " Memorandum and Order" of September 22, 1982, Kudzu Alliance , CCNC, CHAhGE & Wells Eddleman hereby request that the Applicants answer separately and fully in writing, and under oath or affirmation, each of the following interrogatories, and produce and permit inspection and copying of the original or best i

l copy of all documents identified in the responses to the inter-rogatories below.

Under the Commission's Rules of Practice, answers or objections to these interrogatories must be served within 14 days after service of the interrogatories , responses or objections to the request for production of documents must be served within 30 days t

l after service of the request.

l These . interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate should the applicants or any individual acting on their 8305240507 830516 o PDR ADOCK 05000400 G PDR C'd

behalf obtain new or differing information concerning the responses to these interrogatories.

Terms used in these interrogatories will have the same definitions used in the Applicants' Interrogatories dated January 31, 1983.

GENERAL INTERROGATORIES Responses to these general interrogatories shall be given for each contention, along with the responses to each specific interrogatory.

1. State the name, present or last known address, and present or last known employer of each person known to the Applicants to have first-hand knowledge on which the responses are based, in each of the contentions which are the subject to this set of interrogatories.

2. Identify those facts concerning Which each such person has first-hand knowledge.

3. State the specific basis or facts which support each response.

4. State the name, present or last known address, and present or last employer of each person who provided information upon which the Applicants relied in answering each interrogatory herein.

5. Identify all such information which was provided by each i

such person and the specific interrogatory response in which such

information is contained.

l l 6. State the name, address, title, employer, and educational t

and professional qualifications of each person the Applicants intend to call as an expert witness or a witness relating to any contention j which is the , subject to this set of interrogatories.

7. Identify the contention (s) regarding Which each person in l Interrogatory 6 is expected to testify.

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8. State the subject matter to which each person in Interroga-tory 6 is expected to testify.

9. Identify all documents in Applicants' possession, custody, or control, including all relevant page citations, pertaining to the subject matter of, and upon which the Applicants relied in for-mulating responses in each contention which is the subject of this set of interrogatories.

10. State the specific response in each contention which Applicants contends each document supports ,

11. Identify all documents in Applicants' possession, custody or control, including all relevant page citations , upon which you relied in answering each interrogatory herein.

12. Identify all other sources of information, not identified in response to Interrogatories 5, 8, and 11, uhich was used in answering the interrogatories. set forth herein.

13. Identify all documents which the Applicants intend to offer as exhibits during this proceeding to refute contentions which '

are the subject of this set of interrogatories.

INTERROGATORIES ON JOINT CONTENTION III III-1.a).Please state whether any TLD's to be used at the Harris Plant are able to give continuous remote readings of radiation.

b) If any TLD is identified above, please specify where that TLD will be used at the Harris Plant, who its manufacturer is, what its range is, how often it will be read during a general emer-gency, how often it will be read during normal operating conditions, and how it wi-11 be read III-2.a) Please state wheth.er continuous recording equipment is available for pressurized ionization monitors.

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b) Please state whether remote reading equipment or computer readouts are available for pressurized ionization monitors.

c) Please state whether real time or remote readout capability is available for pressurized ionization monitors.

d) If any such capability as asked above is not available for pressurized ionization monitors, do Applicants believe that such an ability could be developed, or would be developed, if Applicants contracted for it with a maker of computer instrumentation or pressurized ionization monitors.

e) If the answer to subpart d above is other than affirmative, state in detail all facts which support your ansuer, f) If the answer to subpart d above is affirmative in any respect, please state what increase in cost might be required and what information Applicants have which supports this answer. Please identify all documents which may support this answer.

INTERROGATORIES ON JOINT CONTENTION IV IV-1. For each monitor or dosimeter that is to be employed at the Shearon Harris Plant , for any purpose, please state the following information:

a) The manufacturer or manufacturers of such monitors or dosimeters, including their address.

b) The number of each such monitors or dosimeters.

c) The accuracy of each such monitor or dosimeter together with a concise statement of how that accuracy was determined; whether the Applicahts determined it or someone else determined it; what the qualifications of the person who made this determination of accuracy of this dosimeter were; when this determination of dosimeter accuracy was made; what the accuracy is in plus or minus percent, or percent 4_

over and percent under for each of the following types of radiation: '

(i) Gamma belon lmev (ii) Gamma 1-10mev (iii) Gamma above 10mev (iv) Beta below 100 key (v) Beta 100-1000 kev (vi) Beta 1000-10000 kev (vii) Beta 10000-100000 kev (viii) Beta 1000000-1000000000 kev (ix) Beta above 1000000000 key (x) Alpha, specifying what energy ranges each dosimeter is sensitive to alpha radiation.

(xi) Neutrons , specifying what energy ranges each dosimeter is sensitive to neutron radiation.

(xii)

Protons , specifying what energy ranges each dosimeter is sensitive to proton radiation.

(xiii)

Any other radiations to which each dosimeter is sensitive.

t For each such sensitivity range listed above, please provide a list of all documents which establish such sensitivity range.

!. State whether each such document is in Applicants possession.

} Provide the names of the persons who prepared such document, l a lis t l of their qualifications if known to Applicants for preparing such 1

document, the date such document was prepared, and whether the

! exact same dosimeter as referenced in the FSAR or in the answers to other sections of this interrogatory above was used in the test- '

ing that is re5erenced in each such document for each dosimeter 3 5

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IV-2.

FSAR 12.5.3.6.2, internal radiation exposure assessment, states that "whole body counting and/or bio asse techniques are used to compare the quantity of radioactive material present in the body to that quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform airborne concentration specified in Appendix B, Table 1, Column 1 of 10 CFR 20". Please state:

a) Whether Applicants agree that this sentence appears as quoted ~above in the FSAR.

b) Whether Applicants consider such a dose that would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at the uniform airborne concentration maximum limits specified in Appendix B, Table 1, Column 1 of 10 CFR 20 are acceptable under ALARA.

c) If your answer to subpart b) above is other than affir-mative, please state what maximum level of radioactive material present in the body is acceptable to applicants for any employee at the Harris plant.

d) State the maximum and average error of whole body counting for each radionuclide which is listed in Appendix B. Table 1, Column 1, of 10 CFR 20 for the equipment to be used at the Shearon Harris 4

Plant.

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e)

Identify the manufacturer and provide a complete description of all equipment used for whole body counting, including its ability to detect radiation from each nuclide listed in Appendix B, Table 1 ,

Column 1, of 10 CFR 20 subpart 6. 5.

f) For each nuclide listed in response to subparts above, S

please state th E maximum and average error of the equipment to be a e

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used at Harris for whole body counting with respect to the following  :.

nuclide concentrations: e fr

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(i) At the maximum level which would result from exposure for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at the maximum uniform airborne concentration specified in Appendix B , Table 1, Column 1,10 CFR 20.

(ii) At 50% of that value.

(iii) At 10% of that value.

j (iv) At 1% of that value.

(v) At 0.1% of that value.

g) Explain, for each nuclide identified in response to j subparts above, exactly how the concentration in the body that would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at the

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uniform airborne concentration specified in Appendix B, Tab 1 1, Column 1, 10 CFR 20 was determined, and exactly who, among Applicants staff, has made this calculation; or, if it has not been made, who will make it. Give the steps in calculating it including any assump-tions used and any references used. Please identify all documents or references used in making this calculation. Please state the qualifications of the person who will make or has made the calcula-l tion, and identify all other documents which contain such calculation j or which support such calculation which are in Applicants possession.

IV-3. Please state the radiation exposure which is recorded in the records of Applicants for each person who has ever worked at the Robinson Plant, the Brunswick Plant , or at any other nuclear l

power plant which was or is owned in part or whole by Carolina Power

& Light Company or North Carolina Eastern Municipal Power Agency.

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If you consider that supplying this information with the name of l each individual would violate any privacy consideration, please state precisely whit privacy consideration is involved and give a unique l

number to each individual and supply the information related to that 7

}j3 2 individual in all subparts of this interrogatory below with reference jjj Et to that number assigned uniquely to each individual .

=55 "5 a) State the total amount of internal radiation exposure for fjj 2M each individ,ual, identifying the plant or plants at which such ex-

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posure occurred, and the time period over which the exposure occurred

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b) State the amount of external radiation exposure for each e individual, identifying the plant or plants at which such exposure gj occurred, and the time period over which the exposure occurred j{ .

c) Has Carolina Power & Light determined the error range in plus or minus percent or plus or minus millirams or over or under k

.::4 error of such exposure for any employees?

d) If the answer to subpart c) above is affirmative for any individual, please state for that individual the accuracy of the dose measurement as stated in the records of Carolina Power Light, e) For each item of information specified above, has that information been made available to the Nuclear Regulatory Commission?

f) Has the information listed in response to each subpart of this interrogatory above been made available to the individual whose exposure was being recorded, including the error information?

g) Does Carolina Power & Light possess the last known names and addresses and telephone numbers of any individuals uho have ever worked in a temporary position at Plant? the Robinson Plant or the Brunswick h) If the answer to subpart g) is affirmative, for any indi-vidual, please identify the individual by name or number. -

1) What. measures , if any, has Carolina Power & Light taken to guard against individuals using a false name, false I.D. , or false 8

social security number in order to do temporary work under two or more names at its power plants. Please specify all such measures in detail. If any individuals have been detected by the measures stated in response to this interrogatory attempting to so be employed under two or more names in radiation work at either Robinson or Brunswick or both, please provide the particulars of when, Where, and how such individual was detected, and identify the individual.

INTERROGATORIES ON JOINT CONTENTION V V-1. a) Do Applicants believe that ALARA does not require them to have the most accurate available instrumentation for measuring radiation exposure in areas where their employees are working?

b) If the answer to subpart a) above is affirmative, please state all facts which Applicants contend support such answer and identify all documents which Applicants believe support such answer.

State whether each such document is in Applicants possession, who prepared it, when they prepared it, what their qualifications were to prepare it, and exactly how it supports Applicants answer to subpart a) above.

c) If the answer to subpart a) above is other than affirmative in any way, please state Whether Applicants have obtained the most accurate portable air samplers and continuous air monitors which are commercially available.

d) If the answer to subpart c) above is affirmative, please state for each such monitor, who the manufacturer is , hou many of them are available at Harris, What areas that monitor will ba used in, What its accuracy is, and state also the accuracy of all other monitors for air sampling or continuous air monitoring which are 9

available commerically and which do not have an error range above that of this monitor. An error range above that of the monitor means one which is larger in percentage or larger in absolute amount of radiation detected than that of the monitor which Applicants pro-pose to use at Harris.

V-2. a) Please state for each continuous air monitor and portable air monitor or portable air sampler to be used at Harris, and for each type of such monitor, exactly what frequency of inspection and

, i-calibration would suffice, in Applicants view, to assure their accuracy within plus or minus 5% at all times. If no such frequency of calibration and inspection exists, please so state.

b) What is the lowest range of error (plus or minus percent or plus and minus given amounts) which Applicants believe can be achieved for each type or each specific continuous air monitor or portable air monitor or portable air sampler to be used at Harris.

Please identify the type of air monitor or portable air sampler and the manufacturer used in response to this question.

c) What error in sampling the concentration of air with a monitor located within 10 feet of a person working in a radiation area at Shearon Harris do Applicants believe would be introduced if the persen were working closer to the radiation source than the monitor.

! d) Please state the information requested in subpart c) above r

if the person is working farther from the radiation source than the monitor- by a distance of 10 feet, j e) Please state exactly how radiation level in air varies a

with distance at Harris in each radiation working area if any specific l

relationship is known. If no such relationship is known, please state i

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whether Carolina Power & Light has any policy as to the placement of the portable air monitors and portable air samplers for radiation with respect to the air flow in a working area. Please identify all documents which contain or explain such policy, state who made the policy, what their qualifications were to make the policy , whether the policy originated with Applicants , with the NRC, with some in -

dustry group, or in some other place.

Please state further what the maximum margin of error such policy would allow with respect to the exposure or level of concentration of airborne radioactive material which would be experienced by a person working in the area as compared to that which would be detected by the portable air sampler.

If no such range has been established for error, please so state.

V-3.

With respect to tritium,the FSAR section 12.5.2.1.7.3.4 reads in its entirety as follows: "Special air s ampling. Water bubblers, dessicaant columns or cold traps are available for tritium air sampling and gas sample containers such as Marinelli containers are available for special gaseous sampling",

a) Do Applicants agree that this statement reports that section of the FSAR in full?

b) If the answer to subpart a) is other than affirmative, j please state exactly what that section of the FSAR does state.

c) Please identify each such water bubbler, dessicaant column, 8 cold traps, or das sample container referred to above, and explain how it will be used at Harris to sample the tritium levels in air in areas where personnel are working.

p d) Please state whether tritium is able to penatrate protective gear worn by personnel working in radiation areas.

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e) Please state the permeability to tritium of each pro-tective device or garment, particularly air masks , protective clothing, plastic boots , and any other protective equipment worn by persons working in Harris. State the rate of diffusion of tritium through each such material or each such item of protective equipment or protective clothing.

f) Please state the maximum concentration of tritium which can be expected to enter into the breathing apparatus of any employee temporary or otherwise, working in a radiation area at the Harris Plant.

g) Please state how long it takes to determine the concentra-tion of tritium using each type of water bubbler, dessicaant column, cold trap, gas sample container and other procedure used for deter-mining tritium air concentrations in work areas at Harris , and how of ten such determinations will be made when personnel are working in any radiation area at Harris in which tritium may be present in the atmosphere.

h) Please state if tritium in liquids or in water at Harris is monitored on any regular basis, and whether Applicants have taken any steps to measure the amour.t of tritium in the drinking water system at Harris on a regular basis in case radioactive materials i are introduced into the drinking water system, particularly tritium.

If such steps are taken, please describe them.

l r V-4. a) Will Carolina Power & Light keep records of each assessment of individual exposure to airborne nuclides under 10 CFR 20.103a3, including those assessments which indicate that an individual's

, intake of radioactive material would result in less intake than l

would result from inhalation for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any one day, or for 10 t

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• e) Please state the permeability to tritium of each pro-tective device or garment, particularly air masks , protective j clothing, plastic boots, and any other protective equipment worn by i

l' persons working in Harris. State the rate of diffusion of tritium through each such material or each such item of protective equipment t- <

or protective clothing, t

f) Please state the maximum concentration of tritium which i can be expected to enter into the breathing apparatus of any employee temporary or otherwise, working in a radiation area at the Harris j Plant.

! g) Please state how long it takes to determine the concentra-tion of tritium using each type of water bubbler, dessicaant column, cold trap, gas sample container and other procedure used for deter-mining tritium air concentracions in work areas at Harris , and how i of ten such determinations will be made when personnel are working l in any radiation area at Harris in which tritium may be present in the atmosphere.

h) Please state if tritium in liquids or in water at Harris is monitored on any regular basis , and whether Applicants have tdken any steps to measure the amount of tritium in the drinking water

. system at Harris on a regular basis in case radioactive materials arc introduced into the drinking water system, particularly tritium.

If such steps are t4 ken, please describe them.

t V-4, a) Will Carolina Power & Light keep records of each assessment of individual exposure to airborne nuclides under 10 CFR 20.103a3, including those assessments which indicate that an individual's intake of ' radioactive material would result in less intake .than would result from inhalation for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any one day, or for 10

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hours in any one week, or for both, of the uniform concentration specified in Appendix B, Table 1, Column 17 b) If the response to subpart a) is negative, will any radiation ~ exposure, other than that inquired of above, not be recorded for any individual who may be exposed to radiation while working at the Shearon Harris Nuclear Power Plant?

c) If the answer to subpart b) is affirmative, please describe such exposure in detail, state how it will be excluded, identify the rules or regulations that permit it to be excluded, and indicate why Applicants believe that such exclusion is consistant with ALARA.

This the // _

day of May ,1983.

EDELSTEIN nND PAYNE Attorneys for Kudzu Alliance BY- .m g

_ ,w' , , ,i a9 M. Travis Payne 723 W. Johnson St.

f P.O. Box 12607 l Raleigh, NC 27605 (919)828-1456 l

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CERTIFICATE OF SERVICE CQ'-[;y?

I hereby been served bycertify that in deposit a copy the of the foregoinge'i,st'classdopumentSas United States Mail, fi prepaid, addressed to the parties listed below. ~ *

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. day of May, 1983.

This the /s , . .

James L. Kelley, Esquire Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. James H. Carpenter Atomic Safety and Licensing Board ,

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Charles A. Barth, Esquire Myron Karman, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Uashington, D.C. 20555 Ruthanne G. Miller, Esquire _

Atomic Safety and Licensing Board Panel

! U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Richard D. Wilson 729 Hunter Street Apex, NC 27502 Thomas A. Baxter, Esquire John H. O'Neill, Jr., Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 l r Dr. Phyllis Lotchin 108 Bridle Run Chapel- Eill, NC 27514 Bradley W. Jones , Esquire l U.S. Nuc' lear Regulatory Commission, Region II

! 101 Marietta Street i Atlanta, GA 30303 l

l Docketing and Service Section Office of the Secretary l U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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Karen L. Long, Esquire Staff Attorney, Public Staff North Carolina Utilities Commission P.O. Box 991 Raleigh, NC 27602 Hill Carrou, Esquire Carolina Power & Light Company P.O. Box 1551 Raleigh, lC 27602

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0 #l M. Travis Payne g i

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