ML20072K022

First Set of Interrogatories & Interrogatories on Contentions 22A,22B,41,45,65,75,80,83 & 84.Certificate of Svc Encl.Related Correspondence

ML20072K022
Person / Time
Site:	Harris
Issue date:	03/21/1983
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
Shared Package
ML20072K025	List: ML20072K022 ML20072K040
References
ISSUANCES-OL, NUDOCS 8303300334
Download: ML20072K022 (33)

Text

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D&* ~l50 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'83 M 25 C12iO4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of

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Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al.

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50 401 OL (Shearon Harris Nuclear Power Plant,

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Units 1 ani 2)

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Wells Eddleman's General Interrogatories 6pd XJf6n/M5fN6 "M to Apolicants Carolina Power & Li ht et al.

(wMties Z2(224 E

yf /,6 95 gpd (First Set) ql f

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Under 10 CFR 2.7h0, 2.7h1 and the Board's 9-22-82 Memorandun and Order, Wells Eddleman reouest6 Applicants to answer seuarately i

and fully in writing, under oath or affirmation, each of the following interrogatories, and to nroduce a'nermit insuection and conying of the original or best copy of all document's identified in resnonse to interrogato-ies as set forth below.

These interrogatories are intended to be continuing in nature, and I recuest each answer to be nromutly suurlemented or anended as anurouriate under 10 CFR P.7h0(e), should CFA L, NCFMDA,.any other om or any contractor or consultant to any, some or all cf those, yQ Apolicant,por any emnloyee of any or sone or all of them, or any

! MO 88 individual acting on behalf.of any or some of all of them, obtain

'o y

or create any new or differing information resconsive to these og

(#nM4"Them" refe"s to the oreceding list $ ng(s))

8a generalinterrogatorieg\\

The recuest for production of documents-S#

og is also continuing and recuests Aonlicants to eroduce Dromotly if ma.o not innediately any additional documents the Auelicants and others acting on their behalf or employed by them, as listed in the orevious 1

d 2

ocntanco, obtain which era rosponsive to the recuast(s) for nroduction of documents below.

Whers identification of a document is reauested, niease briefly describe the document (e.g. book, notebook, letter, memo, renort, notes, transcript, minutes, test data,-log, etc.) and provide the following information as anulicable: document name, title, number, author (s), date of writing or of cublication or both, addressee, date annroved, by whom annroved, and the name and address of the oersens hfing normal custody ec the document, and name and address

- of any uerson o'dher than the preceding having actual nossession of the dccument.

When identifying documents in resconse to these interroEatories and recuests, please state the nortion. or nortions of the docunent (e.g. sections, chaders, pages, lines) uron which Apolicants rely or which Aonlicants swecr or affirm is/are restensive to the arolicable interrogatory or vecuest.

DEFINITIONS herein:

" Harris", " Harris Plant", "SHNPP", or'" plant" where not snecified

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otherwise, all mean the Shearon Harris nuclear Power Plant.

"Annlicants" neans all of the persons, emuloyees, consultants, contractors and cornorations as listed in the first sentence of the-second paragraph on page 1 of this document, above.

"FSAP" means the Harris Final Safety Analysis Decort.

"EP," means the Harris Environmental Deacrt.

"Eccumen($" means all writings and records of everv tree, includinE electronic and ccmauter records, in the nossessien, control or custody of Annlicants or any individual (s) acting on Anelicarts' behalf, including, but not linited to: reuorts, books, menoranda, correspondence, notes, ninutes, nannhlets, leaflets, magazines,

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

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voice recordings, com7utsr urintouto, information stored in connutara or comnuter neripheral devices such as disks, drums, etc., voice recordings, microfilm, microfiche and all other writings or ncordings of any kind (s); and cocies'of any of the nreceding even though the original (s) are not in the possession of Auclicants or in their custody or control.

Document (s) shall be deemed to be within the any control of Anelicants or individualfsl acting on their behalf if they have ownershin, nossession, or custody of the document (s) or a cony thereof, or have the r'.ght to secure the docu-ent(s) of a cooy thereof, from any nerson or nublic or "rivate entity havirg phvsical cosseas'en thereof.

Each definit? on given above a,nlies within all other definitions above.

G6/ CA.SL /CC/4 RD66 TD8 O.

d G1 (a) Which contentiens of Wells Eddleman do Applicants agree are now admitted in this croceeding, N"O Dockets 50-400/401 0.L.?

(b) for each such contenticn, provids f or any ansvers to interrog-stor.ies by Wells E4dleman which Aeolicants have previously or tresently received (except thor.e suspended by Board order, if any), the following info'rmation:

(c) Please state the name, present or last known address, and cresen%

or last known ennleyer of each Derson whom Acclicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) uuon whom Apnlicants relied (

other than their attorneys) in making such answer.

(d) niease identify all facts concerning which each such eerson ikantified in resconse to G1(c )(1) above has first-hand knowled e.

F (e) olease identify all facts and/or documents uuon which each 1

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nenson identified in resconse to G1(c)(2) above relied in cro#iding information to respond to the interrogatory, including the earts of such docunents relied ucon.

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u-ngI(Ed afmd (f) Please identify any other document (s) used/by A licants in. responding to the interrogatory.

(g) Please state which specific fact each docunent, identified in resnonse to G1(e) and GL(f) above, sunports, in the ouinion er belief of Acclicants, or which Aonlicants allege such docunent supeorts.

(h) Please state scecifically what information each nerson identified in resuonse to G1(c)(1) or G1(c)(2) above nrovided to l

or for Anplicants' affiant in answering the interrogatory.

If any of thds information is not docunented, clease identify it as

" undocumented" in resnonding to this section of General Interrogato~y G1.

G2. a';? lease state the nane, present or last knowr address, title (if any), and present or last known annloyer, and ocenonic interest (shareholder, bondholder, contractor, encloyee, ete,~) if or other any (beyond expert witness fees) such person holds in Arnlicants or e::pect on anv of them, for. each nerson you intend to call cs nn. exnert witness or a witness in this proceeding, if such informe. tion has not nreviously been supnlied, or has changed since s.uch information was l ast supplied, to Wells Eddlenan.

This sunlies to Eddlenen '

and Joint Contentions as admitted,or sticulated by Acolicants.

(b). Please identify each contention regarding which each such person is expected to testify.

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(c)

Please state when you first contacted each such person with regard to the nossibility of such nerson's t'estifying for Acolicants, if you hqve contacted such Derson.

(d)

Please state the subject natter, 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 thereof ueon which each such witness is expected to, olans to, or will rely, in testifying or l'n preparing testimony.

_5 G3(a) Please identify any othe'r source (s) of information which Applicants have used to respond to any interrogatory identified under G1 above, stating for each such source the interrogatory to which it relates, and what information it urovides, and identifying whewe in such source that information is to be found.

(b) Please identify any other source @of information not urevicusly identified upon which any witness identified under G2 above, or or exhibits other witness, has used in urecaring testinen /, or exnects to use in testimony or exhibits, identifying for each such source the witness who is expected to use it, and the eart or part(s) of such (if applicable) which are expected to be used, and, if not so urce (or both) creviously stated, the fact (s) or subject matter to which such source relates.

and which Gh(s) please identify all documents,goages or sections thereof A-olicants intend or exneet to use in cross-examination of any witness I call in this hearing.

For each such witness, clease trovide on a timely basis (ASAP near er during hearings) a list of all such documents, the subject natter Aeolicants believe they relate to, and nake the document (s) available for inspection form intent and cocying as soon as possible after Auplicants decide or tytwre to use such document in cross-examination.

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

G5 (a) for each centention Apnlicants state or admit is an admitted Eddleman contention under G1(a) above, or an admitted joint intervenor contention, please state whether toplicants have available to them experts,;and information, on the subject matter of the contention.

(b) If the answer to (a) above is other dian affirmative, state whether Auplicants expect to be able to obtain exoertise in the subject matter, and information on it, and if not, why not.

eq, G-7.

F1cnce id;ntify all documants which Apnlic nts plan, expect or intend to offer as exhibits (other than for cross-examination) with respect to each Eddleman contention admitted which is included in your current resnonse to G-1(a), in this proceeding.

For each such document, specify the contention and the subject matter to which it relates.

G-6.

Please identify all other information, not identified in i

response to the above general interrogatories, that Applicants rely en or use or plan or expect to use in nrecaring testimony, or in conducting cross-examination, or in preparing exhibits, fcv this proceeding, with respect to eLch Eddleman contention and Joint centention which is admitted in this croceeding and on which li?covery is curreetly open or on which discovery has been cuen under the schedule laid out by the 3 card 3-10-83 Please state for each such item of information the contention and subject matted to wh!t h it relates.

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Interrogatories to Applicants on~ contentions.they are conducting discovery of me 1

on : specific interrogatories on contentions as listed below:

22A-1 x (a) Have applicants made any study or calculation of nuclear fuel transport costs, uranium yellowcake transport costs, UF6 transport costs, or other transport costs in connee, ion with the delivery of nuclear fuel to t

(1) their existing nuclear plants; or (2) the Shearon Harris nuclear plant?

(b) Have Applicants any information as to the cost of transporting spent fuel (1) from Brunsivick to Harris; (2) from Robinson To Harris; (3) from Robinsen to Brunswick?

(c) If the answers to any parts of (a) and (b) above is yes or affirmative, please state for each such part, the cost and the basis on which it is estimated or known (e.g. accounting records) and list all cost components included in that cost and the source (s) of information for each such component.

(d) How do Applicants calculate the average fuel cost for Harris in Table 8.1.1 2 of ER Amendment 57 Please state the discount rate used, the nominal dollar amounts for fuel in each of the ten years 1986-95, and all sources and calculations used to derive the annual ncminal dollar amounts, and how these were used. Please identify all nages of such data sources used, & what info's on them.

(e) Was an escalation rate used in the calculation requested in (d) above?

If so, what was that ratei Please alsc state all assumptions, calculations l

and data sources used in deriving that rate. Please identify pages of all such data sources which were relied upon and what information comes from them.

(f) Has CF&L estimated cost of transporting any spent fuel frc= Harris to any other reactor site, or to an AFR7 (g) If the answer to (f) above is affirmative, state what cost was estimated.,

how the estimate was made (including all data sources used), and state the cost l

per assembly transported, or per reactor-year of operation.

l How does CP&L compute the cost of nuclear fuel (or its component costs)

(h) to which carrying charges are applied? Please show the calculation used for ER Amendnent 5 and identify alli data sources used in making it.

(i) If any assumption, calculation or data source in (h) above differs from the ecmoutation of nuclear fuel xxrr costs to which carrying charges apply that

. cases f before (a0 FERC;( b (b) the NC Utilities commission (NCUC);

i is used in rate l

or (c) the South Carolina PublicE Service Commission, or any of these, please state for each such difference (1) what the difference is; (2) how it is com puted; j

(3) the dollar amount of such difference if not given earlier; (4) the amount l

of this difference for 1 year's operation of Harris 1.

9j) What carrying charge rate did CP&L use in computing nuclear fuel carrying charges in the Environmental Report? If this charge rate differs from the fixed enarge rates used by CP&L (a) in its latest rate increase applications to FIRC, the NCUC, and the SCPSC; or (B) in the rates approved for CP&L by FIRC, the NCUC or the SCPSC in CP&L's last rate case before each such body, please state those rates also.

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(k) what number of kilowatt-hours (per year, or plant lifetime) is used by CP&L to convert costs of nuclear fuel into costs per khh in the ER, particularly Tables 8.1.1 2 and 8.2.1 27 If the conversion is at made in any other way, state how the costs are converted into mills per khh and all basis and calcu-lations from which such costs were derived.

e 22A-1 continued (1) Are there av expenses or costs associated with nuclear fuel that are not included in ER Amendment 3 and (e.g. in the Tables in part k above) which' are charged to ratepayers under CP&L*s current rates as set by the NCUC7 by PERC7 by SCPSC7 If so, for each Commission, state what those costsare,andgiveequivalenceinmills/kwhforeachsuchcost.

(m) How does CP&L charge co-Applicant NCEMPA for nuclear fuelf (n) How does CP&L charge co-Applicant NCEMPA for carrying charges on nuclear fue17 (o) How does CP&L plant to charge NCEMPA for nuclear waste disposa17 (p) for each response to m,n, and o above, please state how the method differs (if at all) from the method used to compute the costs in the ER of these items.

Please state further the derivation of all differences in the method, if any, for,each item.

(q) Have Applicants included any costs of low-level wast.e disposal in the computations of ER Table 8.2.127 If so, what costs?

(r) Have Applicants incladed.ay costs of low-level waste disposal in the computations under3,ying ER Table 8.1.1-27 If so, what costs, and how are they included, please state this including all basis and calcuhtiens.

(s) are thche other costs cf low-level waste disposal not included in the ER for either Table referred to in o and r above? If so, please state what corts, from sources derived, and wLy they were not included.

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(t) Are there any low-level waste disposal costsu not included in the tables referred tp in q and r above, which are being charged by CP&L or NCEMPA or both to their ratepayers in any jurisdictions? If so, please state a which l

costs, which Table the;k r.re not included in (or Tables), the asunt of the costs, and their equivalent in mills /Wh. This applies to costs frcm I

existing CP&L nuclear plants, and all cost components of nuclear waste disposal for low-level waste, which are not included in the above Tables.

(u) Has the methodx of nuclear waste disposal contemplated under the NUCLEAR WASTE POLICI ACT of 1982, which CP&L references in the ER, been utilized on an industrial scale (e.g. for as much as one reactor-year's l

wor'h) of waste at a burnump equal or greater than that expected by Applicants for Harris fuel, E4-days per metric ton heavy metal or metric torn utanium'(MTU) anywhere in the United States so far? If so, what was the cost of such disposal per metric ton of heavy metal?

(v) please state or identify the MTHM of high-level waste Harris units are expected to produce at (1) 80% caoacity factor DER (2) 70% capacity factor DER (3) 60% capacity factor DER (4) 50% capacity ' factor DER (5) 40% eapacity factor DER (6) 30% CF DER (7) 20% CF DER (8) 10% CF DER.

If this amount varies between Harris 1 and Harris 2, please give it for each unit at each capacity factor stated immediately above.

(w) Are Applicants familiar wi.th the costs of compliance with 40 CFR 191 Environmental Standards for Management and Disposal of Spent Nuclear Fuel, Highp141 vel and Transuaranic Radioactive Wastes, as contained in EPA's DEIS on such, dated December 19827 l

l (x) Il not do Ap cants plan to comply with such regulations?

ty7 a ansker to w above is arfirmative l

g 1p g g y ch regulations for each, Harris unit gor eado Applican s know the year o l

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l 22A 2 l

(a) Please state exactly what estimates and values of what variables.were used in the study of. system operating costs referred to in ER section 8.1.

i For each such variable, state all assumptions and calculations used in producing the values of that variable for each year 1986-1995 (b) was a PRCHOD computer program used in making the study referred to in (a) above? If so, please provide a copy of each run used in the study.

j (c) Please state concisely exactly how the computer runs H+d in that "udy computes system operating costs from the inputs.

(d) are the assumptions about variables in other than Harris capacity factor and system load identidal in each such run? If not, state eaxactly t

which variables values differ in each run.

(e) are the variables and assumptions identified in parts a, b, c, and d above different from those CP&L used in Docket E-100 sub 41 testimony filed in November 1982 before the NC Utilities Commission (or underlying such testimony)? If so, state all differences and give any reasons known to CP&L for each such difference.

(f) was a computer program other than PROMOD used in making the study referred to in ER Amendment 5 section 8.1 and part a above? If so, please identify the program or porgrams and provide listings of them and copies of actual runs used for the 33 ame.vbent.

(g) were any computer runs made by Applicants with respect to sensitivity studies for ER Amendment 5 which were not used in preperirg that amendment?

IF so, please identify all such runs, provide a.cpies, and str.te why they wre n:t used.

(n) if any part(s) of the results of any corputec runs identified above (parts b,c,f, and g) were not used in ER Awadment 5, cleare identify those parts. The reason for g and h herein is that Dcke Power G.

did rejec.t runs and omit parts of runs in computations of aveided energy costs (systen operating costs) in Docket E-100 sub hl, and I went to be sure CP&L did not do likewise in preparing ER Amendment 5 (1).Wat reasco, if any, did CF&L have for omitting any parts of co*::puter results identified in h above from ER Amendment 5's analnis and summary? or from ti either?

(j) Has CP&L analyzed negative growth in sales on its s/ stem? Negative growth in peak demands?

(k) Do Applicants agree that system fuel savings cannot be computed without (1) a system load forecast giving hourly loads or total loads; (2) fuel cost l

estimates for units on CP&L's system ; (3) CBF. costs, both fixed and variablex l

for such units ;(4) other costs as indentified in PROMOD; by the method they used in ER Amendment 5 section 8.17 (1) If answer to k above is other than affirmative, please state exactly-how such calculation can be made without each such data item (input to PROMOD or not).

(m) Do Applicants agree that ca.ying charges on fuel inventories for both coal and nuclear fuel should be included in comparing systen operating costs with and without the Harris units?

(n) If answer to m above is other than affirmative, state why.

(o) Are any escalation rates used in estimathng costs of coal or of nuclear fuel as inputs to any calculations or computer programs identified above on Interrogatory 22A=27 If so, what are those rates, state the basis for each such rate, state where it is used and how, and state any data or sources or calculations relied upon in setting that escalation rate, for each such rate.

(p) was the Discount rate used in ER Table 8.1.1-2 about 10.88% Wat was I

M %'it? Was the discount rate used in Table 8.2.1-2 different? If so, l

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22A-3 (a) id:ntify any index cr indic':s uccd by Applicants in computing fuel costs for the Harris plant used in the ER either in (1) section 8.1; or (2) Section 8.2; or (3) elsewhere in the ER.

(b) for each index identified in a above, please state the compiler or i

source of such index, the data sources used in compiling such index, and

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the actual value of the index for each year 1965 through 1982, and each year thereafter which has transpired.

(c) state, for each index identified in a above, whether the index includes predictions of future prices or costs of any items, and if so, which items. (d) state all predictions made in each such index after 1974 for uranium costs, yellowcake costs, enrichment costs, tailings disposal cost at uranium.v.ines or millas or both, radioactive waste disposal costs for uranium mining, milling, enrichment, UT production, and fuel fabircation, giving for each prediction the year kn which it was made and the predicted values of each such cost for all future years predicted.

(e) if any index identified under a above does not include predictions, )

please so state. (f) identify precisely what portions of what indexes have been used by Applicants in preparing the estimates in each portion of the ER identified in response to (a)(1) through (a)(3) cbove, explaining exactly how each such index or portion thereof was used in preparing estimates or figures which either support figures in the ER, or azaxximind figures which appear in the ER, stating which figure ( s) each such index or portion thereof was used to compute, verify, or support.

(a)DoApplicantsrelyonanythingbayondthebasQ

/kb672 22A 4 (which is for a BWR) in preparing their de m missioning cost estimates f D :bt W~'

l Harris in the ER7 (b) If answer to (c) above is affirmttive, state all such basis and how it is included in each such estimate for which any other basis is included.

(c) If answer to (a) above is other than affirmative, do Applicar.ts possess any informatrion indicating higher decomkissioning. costs e

for a P'AR than for BWRs? (d) If answer to e above is affirmativa, what is the information, identify all documents containing it, and please siate whether or not such information is applicable to Harris.

(c) If answaer to (c) above is other than affirmative state whether Applicants believe any l

information such as is requested in e above exists.

22A-5 (a) Have Applicants established any reserve fund to pay theM $5 million retrospective premiums for any existing CP&L or CP&L co-owned reactor in the event of a nuclear accident elsewhere in the US7 (b) If answer to a above is affirmative, please state each reactor's reserve fund, and the amount in it at the end of each year fron 1971 through present (c) If answer to a above is other than affirmative, how does CP&L and its co-Applicants plan to make such payment if it is required under the NRC's implementation of the Price-Anderson Act, and a nuclear accident occurs at ary other US power reactor which nakes such payment necessary? (d) Have Applicants paid premiums for replacement power insurance for any existing reactors owned or co-owned by CP&L7 (e) If answer to (d) above is other than affirmative, state whether any such insurance payments have been approved by the NC Utilities Commmission in CP&L"s NC retail rates and charges. (f) If answer to d above is affirmative, state the amount of each such premium in each year any premium for such insurance was paid, listing premium by reactor or unit and by year. (g)

Do Applicants agree that nuclar plant replacement power insurance is a cost of operating a nuclear unit? (hl If answer to g above is other than affirmative, explain consistency of this answer with answer to (i) below: (i) what charges for nuclear plant replacement power insurance are now included in CP&L's expenses allowed to be recovered in rates by (1) FERC (2) NCUC (3) SCPSC7 I

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o 22A 6(m) ER c:ction 5 8 st:tes ths sits specific dacommissicning ostimatas suggest CP&L reactors may have decommissioning costs higher than those shown in that section of the ER. Do Apblicants still agree this may be truet (b) Do Applicants agree with the ER statement that these costs for Harris are "certainly within an order of magnitude" of those shown? (c) Do Applicants understand "an order of magnitude" as used in the ER and in b above, to mean "a factor of 10"?

(d) If not, what do Applicants say it means (that phrase quoted first in c above).

(e) Identify all site-specific studies of decommissioning CP&L's (1) Robinson 2 unit (2) Brunswick 1 unit (3) Brunswick 2 unit (4) Harris 1 unit (5) Harris 2 units (6) Harris 3 or 4 unit or both, of which Applicants are aware.

(f) State which of the studies identified under e above, Applicants possess a copy of. (g) State the total cost of decommissioning (1) Harris 1 (2) Harris 2 (3) Harris 3 or 4 or both, as shown in each such study for which a cost for decommissioning any of these units is given. (h)mState the total cost of deco.missioning (1) Robinson 2, (2) Brunswick 1 (3) Brunswick 2 given in a g cx each site specific study id.entified in a response to the above interrogatories. (i) If not stated above, give,all years of constant dollars, inflation rates, discount rates, and cost escalation rates used in preparing each reactor decommissioning estimate given in a response to the above interrogatories, particularly g and b above, stating also any contingency amounts or percentage included in each such estimate.

22A.7(a) Do Apclicants believe that if radiation exposure linits for internal or external radiatiers exposure u were lovered from their presently allowed value4,ma that O&M costs for the Harris plant would increase as a consequence?

(b) If answer to a above is other than affirmative, state ind detail the basis l

for your answer. (c) If answer to a above is affirmative, has CP&L done any study of such cost increases for (1) a 50% reduction in external exposure limits (2) a 90% reduction in external exposure limits,(3) a 50% reduction in internal exposure limits (4) a 90% reduction in internal exposure limits or (5) ~any other specific or unspecified reduction in either or both such limits?

i (d) If anwer to e above is affirmative, please identify each such study, i

its basis includi;g all documents it is based upon (or which were used in prepating it), name the preparer (s) of the study, state their qualifications to nake such study, and state what increase (percentage, dollar, mills /kWh, or other) in 022 costs for Harris or other nuclear plant (specify which).

(e) Are Applicants in possession of any study or studies or documents on the matters inquired into under (c) above, which was not a study performed by CP&L7 (f) If answer to e above is affirmative, please state the information requested in both e and d above, inclusive, for each such study or docu=e:it.

22-A 8(a) Identify all *d==+d indices by Data Resources International which Applicants use to a estimate nuclear fuel carrying charges in the ER.

(b) give the value of each such index for each year 1965-82 and to present; (c) give all predictions of future values of such index nade after 1-1-70, for each such index. (d) If not already given above, give the values (list then) of each index for which a prediction was identified in response to e above, for each year 1971-82 and to present. (e) Explain in detail how each such index identified above in response to a,b,c, or d was or is used by Applicants to compute the carrying charge listed in the ER for nuclear fuel, including all other assumptions, levelization, die unt, escalation, and tak other rates used in making such computation, and identify all work papers on which such computations were performed by Applicants for ER A.endment 5

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II SPECIPIC INTERROGATORIES'TO CP&L RE EDDLLM N 83-84

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hf or had made 83-84 (1) (a) Has CP&L ever made/any study of (or studies of) er given any consideration to, the formation of carcinogedh chemicals as the result of disebarges of chemicals from the Shearon Harris Nuclear Power Plant?

(b) If your answer to (a) above is yes, please identify those studies (all of them), the date of each, title, author (s),

qualifications of the author (s), employer of the author (s) if other than CP&L, and, if the studies do not fully describe their methodology, concisely describe the methodology used in each.

(c) If there.are ne studies, state consisely what consideration CP&L has given to this issue, and on what date each such consideration was made.

If dates are not known, please specify tach what is known, if amjthiag,about when/ uch consideration was mada.

(d) If your auswer to (a) abave is ro, will GP&L admit that the SHNPF will d3.acharge chsticals into ite lake, where boating, swimming and fishing are planned to be allowed or encouraged, which chemicals can by themselves or through teactions, become carcinogenic or be carcinogenic?

(e) for each chemical CP&L plans to discharge from SENPP into water, please state whether CP&L believes the chemical is a carcinogen.

(f) for each chemical CP&L plans to discharge from SHNPP into water, please state whether CP&L believes that chemical can react with other chemicals CP&L plans to discharge, to form carcinogens or a carcinogen.

(g) for each chemical CP&L plans to discharge from SENFP into I

water, please state whether that daemical can react with other chemicals found in the Cape Fear River, or discharged

(

l from indu9 trial er othnr courceo,into the Cape Fcar Rivtr, to form any carcinogen or carcinogens.

(h) If your answer, for any of the chemicals involved above, to any or all of the intarrogatories (e), (f) and (g) above is No, please state for each such answert (i) any specific studies of the chemical or reaction producti which CF&L relies upon in stating the chemical is not a carcinogen; (ii) (where anplicable) all reaction owoducts CP&L believes can be formed on will ba formad by each such chemical once discharged; (iii) for each such reaction oroduet, any specific study or studies of that chemical which CP&L reliers on for the statement that each such chemical is not a carcinogen; (iv) Nhy CP&L believes that the reaction products of (h)(ii) above l

are the eniy ones that can or will be forned.

(j)..Is CP&L aware of any studies of crgante chemicals found (y

in the waters /of the Haw River?

(ii) of the Jordan Lake?

(iii) of the Cape Fear River above the Ehrris plant intake, or any other tributarfes thereof? (iv) of Buckhorn Cresk?

(v) White Oak Creek?

(v's) please state for each such study identified in ' response to of(y) j(i),(ii),TIIi) or (iv/ a(bove the date, author (s), method (s), chemicals searched or tested for, title, source, and whether the study is in CP&L's possession or Applicants' possession.

(k) is CDALsware of any studies of metals and their salts found in the waters of (i) the Haw River? (ii) the Joraan Lake? (iii) the Cape Fear Riber above the Harris plant intake, or any other tributary thereof other than the Haw?

(iv) Buckhorn Creek?

(v) White Oak Creek?

(vi) please state for each such study identified in responde to k(i) or (ii) or (iii) or (iv) or (v) above the date, author (s), method (s),

chemicals searched or tested for, title, so urc e, and whether the study is in Anplicants' nossession.

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1 (1) for occh cnd sysry enreinogon idnntified abova by CP&L, please state (i) the maximum concentration factor thereof in algae, in baeteria, in benthic organisms, in each predator feeding on any of the preceding, in fish, crabs, shrimp, oysters, and other conmercial species; and in any species of fish caught for soort or food in either the Cape Fear River, the Harris lake (when it is opened for fishing, assuning it is),

l or fishing /she11 fishing areas near the mouth of the Cape Fear, i.e.

within 50 to 75 miles thereof.

(,t i ) farm.ammb-maraxmrax=== d==== =m+d =nH M =dreha ver @==mxataka what dose ('s) in which organisms have been found to increase rates of cancer, specifying the cancer (s) the rate of which is increased, if known.

(iii) tu whether CP&L believes there is any level or concentra-tion of such carcinogen below which it cannot induce cancer.

l l

(iv) if any anaver to 1(111) above its Yes, please state in full l

the basis for such celief, identifying any studT (chapter and pages),

expert (s), publication (s$ (chapter and pages) or other persons or anything else relied upon to support that belief by Applicants.

(m) Do Applicants agree that chemicals discharged from the SHNPP, either individually, in interaction with each other forming reaction products, or in reaction with other chemicals in the Cape Fear River, l

can cause cancer?

(ob other than affirmative)

(n) If your answer to (m) above is No,/please state fully any bas ~is for your answer not already stated Kha in resuonse to the above interrogatories, and identify which of the above responses, if any, are part of the basis of such answer.

(o) if your answer to (m) abbve is Yes, or sone affirmation that I

the answer may be yes, ha.- CP&L studied the magnitude of such carcinogenic effects over the exuected lifetime of SHFP?

I

(p) plaasa stato the dato, typo of study, author (s) or parscns who made the study, method (s) of the study, all facts and authorities which the study or those who made it relied upon (citing specific facts,'pages of books, etc), and whether the study is in CP&L's possession.

(q) If your answer to (o) above is other than affirmative, please state whether CP&L or Applicants presently plan to make any study whatsoever of this matter, and state when such study is expected to be made.

(r) Imxm2&L, rum are Applicants aware of any NRC staff studies l

of the carcinogenicity of discharges of chemicals fron nuclear plants l

or any nucleev nlant?

Please list all such studios of which Ano11 cents are aware.

(s)

Are Applicants aware of any contention (s) con. ernir.g

. carcinogenic effects of non=rsdioactive chemicals emitted from any nuclear plant into water, in any other proceeding (s) before the.NRC ta at present? ~ If so, please identify such proceu' ling ar.d state whether Applicants possess the wording of the contention, or any document stating the contention (s).

(t) other than the chemicals listed in the ER f'or discharge from the Harris plant into water, are all other chemicals to be used at the Harris site identified in the ER?

Where?

l (u) If any chenical to be used at the Harris site is not identified each such chemical

'n the ER, please identify /it and state the maximum quantity thereof wl:ich (1) is expected to be at the site at any time, and (ii) will be allowed on the site at any time, if there is a limit, for each.

(v) Do Applicants believe that other chemicals, listed in the ER of identified in response to (u) above, can be spilled or leak into l

l or be washed into the Harris lake?

(w) If your answer to (v) above is other than affirmative, please state in full the basis for your answer.

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Is 223-1(a) Who prepared ER Amendment 2's.section dealing with Harris costs and benefits for only 2 units as opposet to 2 units? P Please list an such preparers and which sections they prepared, most particularly the preparer of the. estimate of Harris optrating payren (or preparers).

(b) Is there any other amendment or Lpdate to the Harris ER in which CPE

),gestimated that the operating payroll for 2 Harris units would be different Dian the payroll estimated for 4 units in the original ER7 If so, please identify each such update or amendment, and where such different estimate appears, and k state who prepared each such estimate.

(c) Describe in detail any calculations or computations done for 2 units as opposed to 4 units in computing operating payroll for Harris in each amendment identified in response to a and/or b above.

(d) Explain why the same number was used for Harris operating payroll for 2eunits as was used for 4 units in the earlier ER, in ER Amendment 2.

State every basis for suchx explanation.

J (e) identify the enumbers of personnel to be empl&yed at the Harris site te operate 2 units, and how this number differs from the nunber needed to operate 4 units in the original ER.

(f) identify the number of personnel at CPE headquarters required to cover 2 units at Harris, and explain why this number is the same or different (if it is) from the number of CP&L general office personnel required for h units l

(g) identify the numbers of contract laborers neced to maintain and take j

care of oatages on 2 Earris units, ar.d urp the number required for 4 units.

(h) state whether the salaries of any personnel enumerated under e,f, er g above will be different because theire are 2 units at Harris, and not 4.

(i) State exactly how many additional personnel are required to operate 2 Harris units under new regulatory requirements enacted by the NRC since the Harris CP was issued. For each such regulation which Applicants believe adds required personnel, state which regulation, and how many personnel per unit are added under it, and why such number of personnel is required, and why a' l

larger number is not required, and whey no x smaller number is adequate to comply with each such NRC regulation. If the number of personnel needed to comply with each or any such regulation is nat specified in that regulation, please state all bases not previously identified upon which CPE bases the number of persons required at each Harris unit to comply with that regulation.

(j) For each NRC regulation identified under i above, state exactly how many additional personnel at CPE*s general offices or other sites not including the Harris plant,will be required to comply with that regulation. State all i

ba'ses for such number, including reasons why any less personnel would not be enough, and whym any larger number is not required, with respect to each such regulation.

(k) how many additional contract laborers are required at Harris for each regulation identified under i above? How did CPE compute this number for each regulation, to achieve compliance with it? For each reg, why is any lesser nuggt 7 (1) Are there any other NRC regulations not identified above which add to the number of personnel required for Harris operation in any way? If so, state which regulation (for each such) and exactly how many personnel each requires, and why any, lesser number is insufficient and why any more are not required.

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I 22-B.2: P1sasa state all estimatss of H*rris' operating payroll Applicants have prepared since January 1, 1977, stating for each the date thereof, the numbers of Harris site, central office, other non-Harris site (CPSL) and (non-CP&L) contract labroers required, and how the total payroll estimate is compated from these numbers, including any cost escalation rates, salary escalation rates, wage escalation rates, or discount rates used therein, and whether the estimate was incorporated into the FSAR or the PSAR or filed with the NRC or any other regulatory body (identify any such body for each x estimate). Please state for each such estimate whether 2 or 4 units or some other number of units were used in preparing the estimate, and how the number of units affects the number of personnel required.

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22-L 3: Please state any estimates of Harris operating payroll filed in NC Utilities Commission docket E-z2 sub 203, which requires annual reports on the Harris plant, and when such estimates were filed therein.

22-b 4; If the same indices used by Applicants to estimate future payroll cost; for Harris in the current IR had been used to estimate those costs based only on data pre-1977, how accurately woula each such index have predicted CP&L's actual labor costs cr unit labor costs for contract laborers, for salared Harris site personnel, for Brunswick plant operating personnel, and for non-naclear plant support personnel (central office and non-central-office) l for the Company's Brunswick and Robinson plants as of (a) 1980 (b) 1981 and (c0 t

1932 (using data on annual unit labor or salary costs, as appropriate,for l

each such category of personnel during L 7---i J'- i-each year indicated.

i 22-B-5 supply the actual values or all indices used by Applicants in estimating future Harris payroll for each year 1960 through 1982, for all years for which each such index is available.

f 22-3-6 Has any requirement of NRC rasalted in a need for higher salaries, or for more higher-salaried personnel, or for batter trained personnel who can be expected to require higher salaries, at the Harris plants since the Contstruction permit was issued for Harris on 1 27-787 22-B-7 If answer to 22-B 6 is affirmative, state for each such requirement the additional personnel, higher salaries, humber of higher salaried personnel, number of better qualified personnel, and total i= pact on operating payroll (as estinated or actual) for (a) h Harris units; and (b) 2 Harris units, for each such requirement identified under B-6 'above.

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h5-1(a) What NRC reports, regulatory gu' ides, or staff technical positic?r.s or ru1~es have Applicants used in preparing their analysis of water hamer (th' respect

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to the Harris plant? Please list each such report and its NRC identifying number and date, and what pages or sections Applicants used, andx.

(b) If your answer to a above is none, do Applicants concede the va'lidity of Eddleman 45 is proved?

(c) If there are any reports, guides, staff technical petitions or rules CP&L or Applicant did use with respect to water hamer at Harris, please. state:(for esch):

l 1.

Whether it was used in the design of the plant originany,. and if so how.

2.

Whether it was used in redesign cr updating the design of the plant, an d if so when and how.

3 Exactly what reports, guides, N#,C rdles, and staff positions Applicants believe they are in fun compliance with with respect ti water' hammer at Harrist 4

Exactly what information in each such rule,' report, guide or position identifted in c3 above is what Applicants contend they comply funy with? -

i 5

For each such compliance claimed in c84 above, please state succinctly all facts, analysis, or expert opin&on (identyifying 'the eppert(s) wtGse opinion-it is ) that Applicants contend support their po:sition.

6. dtate exactly e at items or parts'of anything identified in a above it do Applicants believe they are not yet in fun compliance with?

7 Is NRC stin to issue further guidance on Task A-1 Water Hanner under its schedule in NUREG-06067 If so, state what guidance and when it is due.

State for each such guidance whether Applicants are assured they have complied with l

an its requirements.

i B. For every noncompliance or less than fun compliance identified under c6 or c7 above, state the extent of the noncompliance and what CP&L is doing.to comply (if nothing, please say so) with applicable guidance, rules, etc (per a above) and when, if ever, Applicants expect to achieve fun compliance.

9.

For each noncompliance in 8 above where Applicants expect to achieve i

fun compliance in the future, please state an significant factors or occurrences e,

now known to Applicants which would or could delay such full compliance.

10. To the extent that noncompliances are identified in respect to water j

hammer above, do Applicants concede that Eddleman 45.is correct in its claimst l

Please so state for each noncompliance if not an are included in your answer to 1

the preceding sentence.

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(d) Describe specificany what transients Applicants believe can cause watePhansiers 3

in the Shearon Harris Nuclear Power Plant, and where those water hammers can occur J

(which sections of piping, etc.) and the location of such.

difor each such, please state:

1. Exactly how leaks in such section(s) win be detected on a continuous basis or otherwise inspected for, and how assurance is had that an sich,1saks wini be sru gxy hammer promptly identified, for each such section or location where a water can occur.

i 2 Will the Harris plant be shut down if a leak or other evidence indicates a water hammer is possible in this section or sections of pipe or other areaf If not, please state why not.

3 What tests win detect steam voids or slugs inside the pipes, at all times?

there instruments in these section(s) and each such section to detect I

4 kAre steam voids or condensate buildup or water slugs continucusly?

5 If answer to h d4 is affirmative, identify an such and their reliability and testing.

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6 if Answer to d4 is not affirmative for an places a waterx=humsw hammer NrsfMe a$aS*rs$sfIf lbaN!$ahrkiNEl h*c[t anS$yNiNS 'IN ap*d E ts E

have not performed such analysis, please so state.

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45-1 d continued 1

7' Please state for each section identified in 4 above or any part of 4 above the frequency of visual inspection by operators (a) during operation; (b) during shutdown for refueling (c) during ag other shutdown (d) during

- accidents which isolate containment, which is assured by procedures or plant technical specifications.

8 Please state for each section to which 2 d7 above applies, how far the inspector will be from each part of each such section, what level of i-lighting is aussured, and what minimum level of leak can and will be visually detected from that distance, for each required visual inspection, (and state whether such conditions of visual inspection are incorporated into any CP&L procedure in its 1 Robinson nuclear plant, its Brunswick plant, 4

or for the Harris plant).

Please state an analysis and calculations made to determine the allertness of inspectors, au checklists of what they win inspects for leaks that can indicate water hammer, an calculations and analysis showing what inspectors can see, and identify any section of the pipe of other device in which water hammer can occur which is not visible during inspection rounds in each of the situations in d7a,b..c, and d above.

i 9 Please describe exactly how the Harris inspection program will detect possible precursors to water hamer, the formation of slugs, voids, and leaks, and conditions where valve closure could cause water hammer, or valve opening could.

Please answer this for an possible water hammer events under 45-1 d above.

10 Please provide the results of any analysis of water hammer events done by Applicants which take into account possible failures in the inspection programs described above in your responses re Eddleman 45 in this set of interrogatories, future set,(continuing basis: respond when interrogatories are answered or orany/analysisisdone,reasonablypromptly).

study (e) Describe any means used in Harris design to isolate the shock wave of a water hammer from air and water lines used in control systems to safety-related equipment, feedwater and 1 AFW systems, etc.

(f) Have Applicants analyzed or studied the effect of water hammer on other i

systems such as air and water control lines at an? If so, what have they studied, with what results, based on what information?

(g) Have Applicants analyzed the water hammer resulting at McGuire nuclear station on restart after a shutdown on or about December 2 or 3,1981, which caused that plant's electrical generator to be flooded? If so, what were the results of this study or analysis as to whether such an event could occur at Harrist (h) Have Applicants analyzed water hammer events at other Westinghouse FWRs at all? If so, identify an such analyses and na make copies available.

(1).Have Applicants in their possession anymother studies of water hammer not identified above? If so, please identify each such and make all those not from NRC available for inspection and copying.

(j) Exactly how do Applicants propose to keep all systems abutting or feeding the ECCS fun of water at au times?

Please state a succinct but full reply to this.

(k) Exactly how do Applicants verify that an such systems in j above are full of water at an times? Please state for each means of verification whether or not it is automatic, continuous, or requires manual or visual effort. If it is not automatic, state what human effort is required to do it and when and at 1

what frequency it win be done.

State also an procedures requirEng any of t$te when 1t.g It EIris.

If it is not co tinuousi st i

e preced and how often.

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f-INTERROGATORIES TO APPLICANTS RE EDDLDIAN 41 41-1(a) Please identify every person who has ever inspected at least-one pipe hanger weld at the Harris plant, to Applicants' knowledge. If privacy considerations would in your view preclude disclosure of the identification of any such person, list each person by a unique number (E.G. W,1d inspector fl, Pipe Hanger Inspector !13).

(b) for each person identified in a above, state what qualifications if any that person had as a weld inspector when hired, what tests in welding inspection she or he passed before or after hiring for the Harris plant, the time between passing any such test and the date of hiring, whether Applicants possess the results of such test, the requirements of such test (or questions on it),

l any other content or nature of such test or tests, and any other information Applicants have about the qualification of such person to inspec t welds.

(c) for each person identified in a above, state whether the person was able to read welding blueprints, including size, type, width, penetration, sidef length, method, and other welding blueprint symbols. For any person for whom he the answer to any of the preceding matters in this part c or an of them is yes, state exactly how and when App 1tcants verified each such fact or ability, and whether a record of such verification is still in Applicants' possession.

lue (d)Stateexactlyhowtheweldingsymbosg$rints,ificationsforpipehanger a d spec welds as put together by Applicants' design personnel were checked before the pipe hangers were welded. State also if anyone on-site checked thtse matters, and if so, who checked each such welding specification and when, identifying the qualifications of an persons who checked these welding specifications, blueprints and symbols, and whether they were adjudged by such person to be correct or not.

(e) for each such symbol, welding bludprint or specification judged in-correct, state when corrective action was taken and what corrective action was taken. State also if this was before or after the welding was done.

(f) Satate what percentage of pipe hangers r r were required to be inspected under Applicants QA program prior to the NRC inspector's identification of the defective welds on 3 September 1980. If there was no percentager required, how was the number or percentage of welds to be inspected determined!

(g) hhat percenta e of pipe hangers were required to be inspected by Applicants' QA p ogram prior to 93/19807 installed prior to 9/ge of pipe hangers actuany had been inspected, of t h) what percenta3/80,asof9/3/807 hhat percentage of pipe hangers in j

stalled had been inspected prior to 1-1-807 Prior to 1-1-797 If none, so satate.

(i) hhat percentage of pipe hanger welds had actually been inspected at Harrispriorto9/3/80s,ofthoseinstanedandweldedbythatdate? Of those welded by 9/30/80 but not instaned? Of those instaned by 1-1 80, what percentage or number had been inspected by 1-1807 (j)whatpercentagedefedtiveweldshadbeenidentifiedasof(1)9/3/80; (2) 1-1-80; (3) 1-1-79 anong the welds on pipe handers (a) instaned by that date, for each date; (b) welded by that date, for each date, but not installed.

(k) do Applicants possess the records of weld inspections for an welds at the Harris plant on pipe hangers? Win they make these available for inspection and copying?

(1) d identify every person who welded a pipe hanger that has been installed at the Shearon Harris plant at any time.

(m) form each such person, state the date hired, the date discharged if the person has been discharged, the date of resignation or leaving work if resigned or 1cid off, and the qualifications in welding Applicants established each such person had when hired. State any additional training each such person received.in welding while employed byM Applicants (including their contractors and subcontractors, etc) and what welding tests or welding qualification tests each such person passed, and when, identifying all such tests passed and any tests

41-1 continued n continued the person failed, and when. State whether Applicants or thkir contractors or subcontractors possess records of such tests passed or failed. Will Applicants make the results of each such test available for inspection and copying? Did Applicants, including contractors and subcontractors, retain the specimens or test pieces welded by this personset in each welding test that person tookt If not, why not? If yes, will Applicants make the speciments and test piacos available for inspection or futther testing?

(n) For each welder identified in m above, state whether Applicants know if this person could read welding blueprints, including symbols for s)ze, length, pouxsition, penetration, groove preparation, heat treatment, undercut allowable, type of electrode required, sim, current setting and type (DC or AC). If yes, how do Applicants know this and when did they first know it.

If no, please so state.(o) Hgve Applicants e tablished who made the defective welds identified on pipe hangers at Harrist

, list for each welder identified in m above, the total number of welds s he has welded as of (1) 1-1-79 (2) 1 80 (3) 9-3 80 (4) 1-1 61 (5) 1-1-82 and as of the end of each calendar year after 1982, on pipe hangers; the number of such pipe hanger welds which had been inspected as of each date (1-1-79 etc)d; the number of such welds which had been found defective (a) as of each such date (b) in any reinspections after 9-3 80 (c) (p is above, handwritten in) : If Applicants don"t know who made the defective pipe hanger welds, will they admit their QA program is inadequate in ithat respect?

(r) where any welders discharged due to making defective pipe hangerz welds atHarrispriorto9/3/807 Identify each such welder.

(s) were any welders discharged due to making defective pipe hanger welds atHarrisafter9/3/807 Identi.fy each such welder.

,(t) were any weld inspectors other than those identified in the report (Revision 1, dated 11 June 1981 on Weld symbol errors and misapplication of weld on Bergen-Paherson pipe hangers) discharged by CP&L due to failure to catch defective ipia:Ar= e h pipe hanger welds after 9/3/807 (u) were any inspectors discharged for failing to catch errors in pipe hange r welds at Harris prior to 9/3/80; (v) Identify all such inspectors who are included under items t and u above, l

discharged for failure to detect pipe hanger weld defects.

(w) were any persons discharged who had checked the weld specifications on l

pipe hangers at Harris prior to 9/3/80, for failure to detect errors in such!

Identify all such persons.

(x) Were any persons discha ged or disciplined who had checked the weld specifications on pipe hangers at Harris, if such discharge or discipline occurred after9/3/80oronthatdate? Identify all such persons.

(y) Do Applicants possess irformation detailing every error in pipe hanger welds which they have so far detected at Harris? If yes, will they nake this information available for inspection and copying?

(z) Do Applicants possess any information detailing errors in weld specifientions, inspection of welds, or welding of pipe hangers at Harris which is not included in their June 11, 1981 revision 1 final report to NRC7 '.:111 they make that information g availabale for inspection and copyingt 41 2 Please answer parts a through z of 41-1 above, limiting your answers to welds on Bergen Paerson pipe hangers of Seismic Class I, i.e. interpreting the word " welds" in each part of 41-1 interrogatory to mean " welds on Bergen-Pderson pipe hangers for Seismic Category I3"

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41-3(a) were all pipe hangers at Harris reinspected after 9/3/807 If not, how many weren't?(b)For every pipe hanger rejected as a result of reinspection please identify a

the exact uma defect (s) it had in its welds, where these defects were located, z and how they ware identified. (c) were any such defects, for each hanger, unable to be seen on previous inspections?

(d) for each such hanger, state who resinspected it, how long they took to reinspect it, and whether they stated all defects in writing (e) for each such rejection oxf a hanger in b above, identify and produce all field change requests, requests for permanent waiver, and field rework orders issued with respect to it.

(f) for each hanger in e above, state what a review of the field work orders, field change request, or request d for pernanent waiver was done, and the date of each such field work order, field change request (FCR) or permanent waiver re.iuest( P%') and the date each such was approved. If any such FCR or PW request was denied, or any field work order nodified for this hanger, so state, and explain fully, for each hanger covered by this interrogatory.

414(a) Did CP&L QA or QC inspect any drawings of pipe hanger welds, as sent out by Bergen-Patterson or otherwise, before the welding was done according to those drawings, before 9/3/807 (b) If answer to a above is affirmative, what fraction of the drawings received at the Harris site were inspected? Of those inspected, how nany were found to have errors, unclear details or missing details?

(c) does Applicants' QA/QC retain records of any such inspections made,#11sted in response to a or b above, of pipe hanger welddrawingsreceivedat$arrispriorto9/3/807 If so, will Applicants make all such records available for inspection and copying?

(d) Does Applicants' QA/QC program now inspect every drawing for pipe hanger welds received from Sergen Patterson? (e) If answer to d is affir=ative, when was this begun? Is it a formal policy? Does it apply to drawings of other safety-related a welding, e.g. that on embeds? (f) If answer to d above is other than affirnative, state how nany ~or what percentage of drawings of pipe hanger weldsreceivedhavebeeninspectedsince9/3/80,andthetotalnumberofsuch drawings received at the Harris site since 9/3/80; (g) list all persons who re-viewedpipehangerdrawingsatHarrispriorto9/3/80andstateeach'squalifi-cations for such work; (h) list all persons not listed above who reviewed pipehangerdrawingsatHarrisafteroron9/3/80,andthequalificationsof each for such work; (i) list all persons under g above who are no longer at Harris, giving last known address for each; (j) are weld drawing reviews for pipe hangers independently checked at Harris now on a routine basis by two or more persons? (k) If answer to j above is other than affirmative, state what additional review, if any, is being made to check the review of pipe hanger weld drawings received at Harris, or to see how well the review is done.

If none, so state. If there is a prodicedure or QA/QC requirement for how many l

such drawings willan be rechecked, state it and when it was established, and statehowifatallitwaschangedafter9/3/80;(1)ifanswertojabove is affirmative, state how many drawings have been reinspected, and identify all such drawings of pipe hanger welds on which missing, unclear or wrong symbols or instruction were war found upon review, and the total number of such i

I dramwings found to contain a errors upon reinspection. (n) state the qualifications for inspecting such drawings, and the identity of, each person at the Harris site who re-inspects or chseks initial inspection of pipe hanger weld drawings re-l ceived at Herris. (n) provide the infornation requested in n above for all persons who have reinspected at least one drawing at Harris of pipe hanger welds,after9/3/80,ifnotalreadygivenabove.(o)statewhenpipehanger weld drawings were first double-checked at Harris and when such drawings were fftstt triple checked at Harris, if ever; 'and the percentage of errars found

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hi-5(a) State whether welders working at Harris had cny instructicns, pricr td 9 3 80, on what to do if a weld drawing was unclear, unreadable, or in obvious errorf (b) If answer to a above is affirmative, state the exact in-structions, whether written or cral, and the dates in effect. State also whether' Applica,nts know if each welder working on pipe hangers knew of each such instruc-i tion. (c) If answer to a above is other than affirmative, did QA/QC know of the non-existence of such instructions?

(d) Name every welder who worked on pipe hangers at Harris who identified an unclear or missing detail or instruction on a pipe hanger veld blueprint to a superior (foreman, etc) or QA/QC person at Harris prior to 9/3/80, and state the date f on which s/he did it, and what action was taken with respect to mag such blueptinte for each such

. / blueprint. (e) If no action was taken under (d) above for any report, or l

if CPE cannot docu.ent the action, so state; otherwise, provide all documenta-tion of act6ons taken on such identification of unclear or missing detail or instruction on a pipe hanger weld blueprint prior to 9/3/80, for inspection and copying. (f) state whether any welders at Harris made defective pipe hanger welds after going through Applicants' welder training program. Ig) if answer to f above is affirmative, state name of each such welder, and number of l

defective pipe hanger welds s/he made; state also if such welder has been discharged for making defective welds. (g) identify all welders, inspectors, and QA/QC personnel who worked on pipe hanger welds or inspected same or l

blueprints for same at Harris prior to 9/3/80 and state for each whether CPE to read weld blueprints properly prior to had verified that person's ability % failure rate for pipe hanger welds e uka I

9/3/80.(h)statewhetherthe127 l

shown on Exhibit 1 to CPE's 6-1181 letter to NRC re pipe hanger welds is acceptable to CP&L QA/QC at Harris; (1) state exactly how many weld drawings have been returned to the Site Mechanical Unit under the policy of-returning such when it is not possible to weld the hanger exactly as drawn due to physical limitations or drawing errors; (j) for each weld drawing which was returned due to the reasons set forth in i above, since 9/3/80, state I

i exactly what was done to resolve the problem and document all such resolution l

by identifying all documents which show or contribute to such resolution or approve such resolution; (k) state whether any permanent waivers have been l

I granted for sank any weld for which a drawing has been returned to the Site Mechanical Unit for the reason (s) set forth in i above or any of them, and for each such permanent waiver, state the basis therefor and any engineering rationale undestlying it, and state who granted the waiver or approved it.

(1) identify any drawings pointed out to the Site Mechanical. engineering unit QC personnel due to such defects as identified or listed in i above; by QA or state for each the resolution of the problem.

41 6 Answer all questions and all f Interrogatories 41-3, 41 4, 41-5 above, inclusive, with respect to (parts oa) Bergen-Patterson pipe hange HVAC pkys hangers only (c) Cable tray and electrical condusit hangers only (d) has any such analysis been done for non-seismic-category-I hangers of any kind at Harris, as is asked about in 41-3, 4 4, er 41-5 above, or any such reinspections madef Identify all persons retrained in welding, blueprint reading, or 41-7 inspection re pipe hangers or other supports by CPE since 9/3/80 and when each such person was retrained, for how long, using what curriculum and materials (produce same for inspection and copying), and state what tjests if lany were given to each such person during or after such training to determine the effect of such training (or for any other purpose) and what the results of those tests were for that person, for each such person.

i 41-8 Identify all welds made by rsons iisted in 41-7 bove resinse which have been found to be defecNye in anynway since t$e per on w s r tra listing for each su,ch person all such defective welds.

s

~ to 41 Identify any inspe etions made by'any person identified in response 41-9 7 above whith have-'been reinspected since 9-3 80 after such person was retrained in inspection. For each such re-inspection, state if av i defect,s were found in a v welds inspected. State also the number of such defective welds found upon reinspection, and the total number of welds reinspected, for each such person who has been retrained in inspection since 9-3-80.- 41-10 State exactly what was taught re blueprint reading and weld symbol identificatio, to whoa, since 9/3/80 as described in item 2 on page 2 under " corrective action in CP&L's 6-11-81 kRMRR to NRC re pipe hanger defects and the report attached to such letter, at p.2 also of this report attached to the 6-11-81 letter. PLEASE NOTE: Wnere 6-n-81 letter is referred to abee, the report attached to it is meant, in all interrogatories on Eddleman 41. 41-U Please list each pipe hanger defect, HVAC hanger defect, or cable tray or conduit hanger defect identified since CP&L made its rev. 1 report on pipe hanger defects on 6-11-81, at the Harris plant. For.each such, please state when it was found, by whom, and whether it is mentioned in av NRC inspection reports, and if so, which reports, of what date, by whom. INTERROGATORIES re Eddleman 65 . Gre-e.r 65-1(a) Please state how the quality of concretefor each pour in th[elh mat, containment walls, and auxiliary building and fuel building (spent fuel pool) was assessed by Applicants and whether samples of the mix have been retained by Applicants for each such pour. (b) For each pour ixxx in each area identified in a above (or listed by me in that interrogatory) please state the date(s) of the pour, the supervisor (s) of that pour, the time (s0 in which the Mar toch 4AP And Weth4P A 00n0rsti %AteMent lep6Pt.or equiValeht,ined extsh fbr. sueb pour, and whether a sanple or samples of such pour was rett by Applicants, and identyify each such sample. (c) state for each such pour the nature and extent of an inspections made during and after the pour to detect voids or honeycombing in the pour; (d)x state for each such pour or for the area of concrete that pour emplaced, whether Applicants, Daniel or anyone else has conducted ultrasonic inspection to assess the extent of voids or honeyconbing in the pour. (e) whenever an answer to (d) above is affirmative for any pour or area, state the results of such inspection, and identify all docunents and records of such ultrasonic inspection. (f) identify all docunents describing the infornation requested in (c)mabove. (g) for an inspections listed in d or e above, state what measures, if any, were taken to distinguish the passage of sound through contrete from the passage of sound through rebar or other metal emplaced in the concrete, including trumplates and embeds. (h) identify any instances of honeycomking or voids in any pour in the Harris (1) base mat (2) containment wall (a,3) auxiliary building walls (3) containment ceiling (4) fuel building or spent fuel pool wan s which Applicants have so far identified. (1) state for each such instance . identified in response to h above when the honeycombing or void was discovered, exsactly what corrective actions if any were taken for it, what the results of such corrective measures wert) how those results were established, who verified the results, who took the corrective measures, and identify all documents showing how the corrective measures were planned, carried out, and inspected or tested for results. (j) for each instance of honeycombing or voids identified above in response to any part of this i interrogatory, sta.te (1) the weakentnr effect of the honeycombing or voids before correction, if known, and (2) f.he weakening effect of such honeycommbing or voids after correction, if known, and how such effect was calculated and

s 65-1(j) continued whattheweakeningeffectisintermsofthestrengbofthewallorbasemat

involved, the gripping of concrete on the rebar in such portian or area or pour, the si$ngth and integrity of embeds and trumplates placed in such portion, area or pour, and how such weakening effect was calculated and whether it has E N cN Ne*h W yc N ng*brioE we$e N dS" 65-2(a) To knowledge of Applicants, including their contractor DansIl Inter-h national, is it true that (1 the base mat poured in December 1977 at Wolf Creek has approximately 50 percent of its concrete test containers for the base mat pour failing (of having failed) to meet strength of 5000 psi, (2) that 5000 psi is the specified strength for test containers from this pour, (3) that the concrete used in the pour was purchased from a company that supplied Daniel with a mix for=ulated intended for use in ditch linings and box culverts on highways, (4) that such concrete was used in the base mat pour at WoII Creek, and/6r (5) that such contarete is not approved for a highway surface, but only for non-safety-related mud slabs and fin concrete only. (b) Identify au Dan &fl documents, and an other documents in Applicants' possession, which relate tb the facts inquired about in (a) above.

6503(a) At the woII Creek, callaway, and Farley plants, state (1)what modifica-tions to design and structures at each were required by (a) NRC (bY) Daniel (c) the utility, after discovery of defects in concrete emplaced in the base mat l or in other parts of the plant structure including the spent fuel and auxiliary buildings, wheverer defects in concrete have so far been discovered; (2) the identity of all documents requesting such modifications, whether the modifica. tions were made or not, which came to Danie.1 International; (3) any response Daniel made to any documents requesting such modifications as asked for in (2) l preceding this subsection of this interrogatory; (4) any documents TdRRn Daniel used, or created, in response to such requests, other than responses, including design of modifications, and an work papers relating to such design, please identify, and state whether Danniel stin possesses sames- (5) identify an reports of work done in such modifications made as identified in a(1) above, and state whether Daneil possesses same; (6) identify any defects found in modification work done as stated in response to a(1) above. (b) Identify a n repairs made to concrete in the base mat, and containment walls, at each plant: Callaway, Wofif Creek, and Farley, after discovery of and defects therein, whether such defects were found by Daniel or others, identifying who found the defects when they were found, and when the concrete foux.d defective was originally poured, and stating when repairs were begun, and when completed. (c) answer every item in 65-1(a) through (j) above with respect to (1) the Callaway plant (2) the Wolf Creek Plant (3) the Farley plant, substituting the name of each plant listed here for"(SHNPP) Harris" in my interrogatory 65-1 wherever it occurs, and substituting Daniel for ? Applicants" wherever the word " Applicants" appears in my interrogatory 65-1, throughout. 65 4 (a) Identify an documents in which the rebar design of the Harris base mat (as it was when the base mate concrete was poured, are given. (b)is base If answer to a) is none, identify all documents partiany describing the Harr l mat rebard structure before the base mat was poured; (c) Identify all docu-I

~ 64:5 4c continued ments showing the location of embeds or trumplates in the base manbrt of the Harris plant before the concrets of the base mat was poured; (d) identify the location (state it) of any embeds or trumplates added to the Harris base mat after t'he initial concrete pour, and state for each how additional concrete or other anchoring for it was accomplished and when this was done. (e) State the minimum clearance between robars (1) side to side on the same level (2) top to bottom of one on the next higher level and (3) between all layers oft rebar in the base mat, as viewed from the top (ie. the smallest open space visible from the top of the rebar layers if one looked straight down before the concrete was poured, or inspected a blueprint showing all overlayxs of rebar from above the basemat in top view) in the Harris base mat. (f) state the average clearance between rebar in the Harris base mat for each dimension / clearance +de=*+f for which the minimum is requested in (e) above. (g) state the viscosity of concrete used in each part of the pour of the Harris base mat, if such was measured at or before the time of pouring. (h) st, ate if any voids were observed in the Harris base mat hnferaxmx during or after conrete was poured in it. (i) faumyumi identify all voids so observed, stating how each was observed and when it was first observed. (j) state all corrective action taken, if any, for each such void. 65-5(a) State whether any concrete has ever been rejected at the Harris plant site and not re-used; (b) state whether any concrete not meeting applicable standards has ever been poured in the base matet or safety related structures .at Harris to Applicants' knowledge (includes contractors and employees' knowledge). 2 (c) state the date and reason for eahh instance of rejection of concrete at Harris if the answer to (a) above is affirmative. (d) state when any pour of concrete not meeting applicable standards was observed or noted, by who=, and when it was reported, at Harris. (e) for each such pour or i>ortion i thereof, identify all corrective action taken, including analyses that Applicants contend would indicate the conctete is abic to perform what the design of the plant requires it to in terms of strength, stability, holding rebar, etc. in place (e.g. trumplates and embeds),,and when such correction or analysis was performed and by whom, and by whom it was then inspected or approved or both; if it has not been inspected or approved, so state. i Define precisely the function (s) Applicants mean, and the performance 65-6. levels expected, with respect to each requirement for strength, integrity, not cracking, ete which is required of base mats and containment walls contiining concrete, when they refer in their interrogatories on Eddleman 65 (first set) to " prevent that structure from performing its intended function". What does this phrase mean precisely and in detail? If it means different things in the different Eddleman 65 interrogatories Applicants sent 1-31-83, please define if for each such interrogatory, identifying to which interrogatory each definition applies. 65 7 State concisely the NRC requirements, rules, and guidance for the function and properties and capabilities of base mata and containments of nuclear power plants applicable to Hartis at present, as Applicants understand same, identifying all relevant numerical and other properties required expicitly or implicitly. e

v 7 bl(a) Please list every instance of Asiatie clams (corbicula sp or others) living in condensers or cooling water systems at nuclear power plants, of which i Applicants are aware, giving for each the date of discovery of such clams, the extent of fouling by such clams if any for (1) consdenser (2) FRR heat exchanger (3) other systems needed to shut down a reactor safely, by dissipating heat therefrom. (b) Identifymeach such instance in the response to a above in which clams were found in (1) intake water boxes (2) traveling screens (3) cooling towers (4) condensers (5) other heat exchangeurs, specifying the type of other heat exchanger involved, and identifying each such instance with the naclear plant at which it occurred. (c) Are any of the instances listed in response to a above outside the United States? (d) If answer to e is other than affirmative, have Applicants any information on such instances l of corbicula or other asiatic clams living in nuclear plants outriside the USA? (e) please list every instance in which dead asiatic clams were found in condensers or cooling water systems at nuclear power plants, of which Applicants are ayare, and give for saah such instance an information requested in a rb,c, and d above. 75-s2(a) Do Applicants have any means to detect corbuetla sp or other clans or mollusks in the Harris cooling lake and auxiliary cooling lake 7 (b) If your answer to a above is affirmative, list and fully describe each such means including where and with what frequency it will be used, who will do it, what the means is, how it works, and the minimum size of clam it (1) can detect and (2) win be 99% or more assured of detecting. (c) Is any means identified above able to identify oorbicula larvae? (d) If answer to e above is affirmative, state how each such means does so and the sampling frequency and sanple size used to do so. 75 3(a) Describe completely any systems and measures Applicants use to protect the main condenser at Harris from corrosion by (1) chemical means and/or (2) chemical and biochemical means in connection with organisms living in the condenser, including but not limited to corbicula sp. (species). (b) identify exactly the aluminum bronze alloy used in the Harris main condenser. If more than one such anoy is used, specify each ;and give the manufacturer of an materials made from each aluminimum bronze anoy in the Harris condensers (c) identify an points at which each aluminum bronze anoy identified in (b) above touches any other metal, and state precisely what grounding arrangements, and where located, are made for the aluminum bronze alloy, and the other metal it touches, for each such location where aluminum bronze in the Harris condenser touches any other metal. (d)w If not gated in response to e above, describe particularly the ground contact of U m grounding arrangement or system or device identified in c above; (e) Has CP&L or any of its subcontractors for Harris analyzed deterioration of ground contact for any ground contact identified in response to d absve? (f) If answer to (e) is affirmative, describe each such analysis and identify all documents used in preparing such analysis, identify av docu.ent containing the analysis, the preparer (s) and their qualification s for making such analysis, the date such analysis was made, and why the results of such analysis were not included in the FSAR or ER. 75 4(a) Do Applicants believe that ernant corbicula sp living in the Harris condenser would cause noticeable pressure changes on the water side of that condenser? (b) If answer to a above is affirmative, describe any such changes and the minimum number of corbicula required to make such a change at the minimum detectable level, and how such minimun detectable pressure change is noted, and how if at an Harris procedures win alert personnel seeing such a pressure change to the possible presence of corbicula. (c) If there are any other things that can cause pressur chan6es of the same magnitude i identified in part a or b above, other than corbicula in the condenser, list l all such things or conditions and explain how each is distinguished from corbicula

continued -27 75-p(e)this will be done ct Harris. and how (d) ht me sures precisely have Applicants takcn with raspect to pressure changes, air leaks, or other events that could damage the Harris condInarf (e) For each such measure, s identified in d above, state how the presence of corbicula in the condenser could affect it, particularly if the condenser were fouldt with very large numbers of living or dead corbicula. i l For purposes of this question, a very large number of corbicula is a number that could affect the-(1) efficiency of the condenser in condensing steam at full load, or (2) the integrity of the condenser, or (3) a partial blockage j or total blockage of the condenser or a part of it, or (4) any of the measures l l identified in (d) above. \\ 80-1(a) Are Applicants aware of any studies of mixing of air or water in ( the lee of nuclear plant structures or other power plant structures! (b) If answer to (a) above is affirmative, identify each such study, stating when it was done, by whom, what their qualifications were, and whether Applicants possess a copy of such study. (c) Are Applicants aware of any other studies of mixing and dispersion of radionuclides in the environment besides those (d) If answer identified in b above and those used in preparing the Harris ER7 to e above is affirmative, identify each such study and provide for each such j study all the infornation requested in (b) above. (e) Was rainout treated in any study identified in response to the above interrogatories a,b,c, or d?. (f) If answer to e is affirmative, state how it was treated. in each study in which it was treated, identifying the study for which each answer applies. l (g)HaveApplicantsconductedanystudiesgf,dispersionofradionuclides in the environment not identified above, orAany reports or documents not identified above, which treat dispersion of ' radionuclides from nuclear power (h) if answer to g above l plants in air or water, in Applicants" possession?is affirmativa, identify ea f the information requested under (b) above, and state when Applicants acquired ~ the document or report (if known) if theyndidn*t do the study., stating not known or " prior to (date)" in response if the date is not known, giving accurately each date requested to the best f of Applicants' knowledge. 80 2(a) Do Applicants believe their models used in the ER can model rainout? (b) If answer to (a) above is affirmative, explain how in detail, (c) if answer to a above is affirmative, state whether the model has been applied to each described in page 42 of Eddleman response to Appleants' first set situation of interrogatories. (d) If answer to e is affirmative for any such situation or scenario, describe whether that scenario used the most limiting assumptions possible for the area around the y Harris plant, if so, what those assumptions-were, what the radiological health and environmental effects were, and what radiation dant doses would be delivered, stating also what release (source tern at realease point for each radionuclide released into the air) and of what duration was assumed in making ther application of the model to each such scenario or situation identified in (c) above. 80-3(a) What is the regulatory Guide 1.XXX referred to in the ER section 6.17 (b) Is this the same as either Regulatory Guide 1.109 or Regulato y Guide 1.1137 (c) How, if at all, were any of the above-identified regulatory guides used in preparing the ER,by whom, and when, for Applicants. (d) what studies, including computer runs, were done in preparing the ER (5 2 and etc) using dispersion models described in ER 6.1, by whom, when, and what were their individual qualifications to do such study, computer runs, or modeling? (e) Do Applicants possess copies of each study, computer run, or model identified in d above? (f) If answer to e above is affirmative, identify each such studyk, run or model of which a copy is retained, statin'g who did it and when if not stated above. (g) If answer to e above is negative for any such study or run or model, so state. I - - - - - -. - ~

132-1(a) Wat po61nts in the reactor vessel soes ths RVLIS purpourt to ' measure pressure at in order to compute its pressu e differential? Show these in plan and side view if possible. (b) how many such points are directly measured by RVLIS? (c) How does RVLIS compute the differential pressure between each pair of. points identified in response to a above? (d) what is ~ the minimu, maximum, and average error of this computation if known. (e) what are the effects, if any, of transients on tahe pressures measured RVLIS which Westinghouse or Applicants have so far analysed? and by the (f) Wat does the RVLIS use to measure pressure directly at each point identified in response to (a) above? Describe such pressurei-measuring device in detail. 132 2 (a) what is the average error of the RVLIS under (1) normal operating conditions; (2) Class 8 accident conditions (most liniting Class 8 accident); (3) Axixx Class 9 accident conditions, for any reactor in which RVLIS is now How was each such error measured? Please give each such error in instaned? percent, and in feet of water. (b) If RVLIS is not instaned in any reactor now, state, when it will be first instaned in an operating power reactor, or when it has been instaned in one if it already has. (c) specify an transients which have occurred in any reactor (power reactor) for which a RVLIS has been instaned, since the instanation of the RVLIS, and what effect each transient had on the RVLIS readings. 132-3(a) What does a RVLIS for Harris cost, instaned? (b) Are there any means of directly measuring water levels in the core of a reactor such as Harris which would cost nore than RVLIST (c) If answer to b above is affirmative, state the cost and nature of each such means, and give for each the accuracy of measuring achieved or expected to be achieved by such system, the number of points or lines verticany through the core or around it on which such measuring is done by the system, or describe any way not previously identified in which such system measures directly the water level in a reactor (PE ). Please list every chemical to be discharged from the Harris plant /83/84-1(a)into the cocling tower CdS; give for each the amount in pounds per yea i gram moles per year, and the maximum concentration of each which will be found (1) at injection (2) at any other time or place in the C'G. (b)' Please list every chemical to be discharged from the cdS into the Harris cooling lake at any time, to Applicants' knowledge, giving for each the maxi-u. amount to be discharged in pounds per year and gran moles per year. (c) Please state the maximum concentration at whichchlorine is injected or win be injected into the Cd5 at Harris; (d) please state any restrictions on time of day applied to such chlorine injections; (e) please identify the exact point at which chlorine will be injected into the ak Harris CdS; (f) if there is nere than one such poitt, identify each and state the maxinum concentration at which chlorine win be in-jected at each; (g) if anot already given above, state the maximum concentra-tion of the chlorine before injection at each such pakbinan point identified in response to e or f above; (h) please state the maximum concentration of hydrazine kept in storage for Harris, as now planned; (i) please state the maxi-i zum and average concentration of hydrazine before injection into the C45, RCS, and secondary water at Harris; please satate the form in which a-mnia is held for use in the Harris water systems, for each such system; (j) please state the maximum concentration of am onia before injection and at injection into each such system at Harris, as now planned; please identify an points at which ammonia will be injected into water at Harris, or otherwise inta o duced into water at Harris, as now planned. (k) If not already stated above, win any chemical identified above be in,troduced into water at Harris other than by injection, and, if so, please list for each such chemical the concentra-and immediately after, such introduction, stating which water tion before system, cooling lake, etc it is planned to be introduced intol or will be intro-i duced into,

,~ .. K83/84 2(a) Have Applicants nade any studies of the formation of nonradioactive carcinogenic compounds in the chemicakl or water systens at Harrist (b) If I _ answer to a above is affirmative, please list each such study, identify all documents used in preparing it, the date os preparation, the name(s) of the preparer (s), the qualifications of each paz. preparer to do such study, and state whether Applicants possess a copy of the study. (c) Are Applicants aware ) of any other studies of formation of carcinogenic chemicals in the water systens of nuclear power plants? (d) If answer to e above is affirmative, please supply for each such study the information requested in b above, inclusive. (e) Have Applicants undertaken any study of ca cinogenic chemicals being formed er nade nore carcinogenic as a mbr* result of interaction with che.icals discharged or to be discharged from Harris? (f) If answer to (e) above is I l other than affirmative, do Applicants agree such chemicals scheduled to be discharged x from Harris, including chemicals identified in response to 83/64-1(a),(b),(c) above or any other part of 83/84-1 above, can cause cancer themselves, or can interact to form carcinogenic chenicals, or can form compounds which are more carcinogenic than the precursors to such compounds, e.g. by chlorination of organic or phenyl or dioxin or dye chemicals! A83/863(a)HaveApplicantsanyinformationastotheconcentrationinCape ' Fear River water of (1) dioxins (2) biphenyls (3) PC3s (4) PS3s (5) other EPA priority pollutants (6) other known carcinogens (7) textile dyes or other dyes (8) phenolic compounds other than those inquired about above? (b) If answer to a above is affirmative, state for each the maximum known conscenix-i tration in such water; (c) Answer each part of question a above with respect to Harris cooling lake water instead of Cape Fear River water; (d) answer (b) above with respect to any affirmative answer to e above, giving for.each the information requested in b above. (e) identify all documents giving infornation requested in a,b,c, or d above. V83/844(a) Wat metals are present in the Jordan lake water? In the sediment? j - (b) Wat is the maximum concentration of each such metal so far observed? (c) what is the amount or concentration of organic matter in Jordan Lake water i on average 7 at maximum? for observations made so far. (d) Have Applicants any information on the matters asked about in a,b, or c above other than that already stated in response to those interrogatories? (e) If answer to d is affirmative, state in detail all such information and identify all documents which contain such information (f) identify all documents containing information l requested in a,b, or er above, telling for each what infornation it containes. l Do Applicants believe that (1) NC1, (2) NHC,2 (3) HH C1 is a 83/84(5)-(a) (b)Ifanswertoanypartofaabov6isotherthanaffirmative, carcinogen? state whiether Applicants believe each such compound may be a carcinogen. [83/846(a)Ifnotstatedinanswertoanyotherinterrogatoryon83/84in this set (3-11-83), please state whether Applicants have determined or can deter =ine how nuch urea will be released into the Harris lake from the Harris plant? (b) If answer to a above is affirmative or Applicants have determined such anocht of urea, what is it in pounds per year? (c) Do Applicants believe urea can get into the circulating water systen (1) directly (2) from makeup (d) for each affirmative answer to from the lake (3))from any othdr source?of can above, please state how much urea can ge a part (1,2, or 3 CWS from such source, at maxinum, in pounds per year, for each such source. in)(Have Applicants analyzed the potential for forming carcinogens fron urea (e

1) the Harris lake, e (2) the Harris CWS7 (f) If answer to e above is affirmative, please identify each such analysis, any documents used in making T,ne date it w&s made,kers of the analysis, their qualifications to make itk, such analysis the ma and identify any documents in which such analysis is set forth and state whether each such document is in Applicants' possession.

30-X83/84-7(a) Bad Applicants made any analysis of the effects of toxic metals l or metals as oarcinogens, in Cape Fear River water, as impacted by operation of the Shearon Harris plant, (1) prior to 5 k14-82 (2) prior to n 7-15 82, (b) stM AM(s) cf (3) to the present time, if after 7-15-827 If answer tog (a) above is affirmative, please state >/ cath Gw.(b C9 Mt,.;T'cthe maker s) of such analy p method of such analysis, the qualifications of the makers to prepare such analysis (for each maker), all documents relied upon in preparing each.such analysis,ab Nocunentscontainingsuchanalysisorpartsofit, stating also whether Applicants possess a copy of each document identified in response of this interrogatory, for each such docu.ent. to each part (c) For each analysis identified in response to (b) above, please state exactly what analysis was made for each netal analyzed therein, as to the through (1) drinking water (2) washing water (3) bathing effects on people na6 lc ) any other means. v '. ( 5 water (4) food.. (d) If not already stated in response to (c) above, state whether each su'ch analysis included the effects of open cuts, bio-concentration in food l webs or chaings, or unusually sensitive individuals, or fu_rther mobilization of metals in food or water due to other chemicals in such (which ot chemicals do not derive from the Shearon Harris plant). (e) Give the informath requested in (d) above for each metal in eac identified in (b) above if this information has not already been given. l Please note thete are two sets of 83/84 interrogatories, regulat and X Where the two overlap, reference to the other will suffice if it is clear and specific as to which part of which response (or which specific response to which part of another interrogatory) answers the question asked in a interrogatory. m c---

', =.. ' T REQUEST FOR PRODUCTION OF DOCUMBITS I hereby request that Applicants make availsble to me within 30 days of the date hereof (3-2P-83) for insnection and c opying cooies of edL1 documents identified in resnonse to the above hat date), and that the er r.ditiens I ret interrogatories fr then under be similar to those I an surplyirg then documents under, i.e. that I be allowed to take docunents from CP&L's offices by signing a receipt for sane, and have them cooled within 2h to h8 hours at my expense, rather than use their conyinr services, at g option. Interrogato.rie s (general, and on Eddleman 22A, 223,141,1:5, 65, 75, 80, and 83-81;) and the above reque st have been served on Apnlicants and all other parties, properly addressed, US uostage Q lSt h,, $. j prepaid, this @iikt day of March 1983 Wells Eddleman pro se l l Y / ~

UNITED STATES OF AMERICA NUCLTAR RILULATOFY COMMISSION In the matter of CAROLUA POWE". k LIGHT CO. Et al. ) Dockets 50-h00 Shearon Harris Nuclear Power Plant, Units 1 and 2 ) and 50kh01 0 L. CERTIFICATE 0F ST:RVICE Wells Eddleman's General Interrogatories I hereby certify that copies of and Interrogatories re Eddleman 22A, 223, hl, h5, 65, 75, 80, and 83-Bh ~ and veoveet Tnm ~~^An ~~ ^r ^ ~~ < ~ ~ a - H-for admissi i 2$ (first net) and reoues'1, by depos,on day of March 196 ., in j HAVE been served this the US Mail, first-class postage prepaid, upon all parties whose j names are listed below, except those whose names are arked with an asterisk, for whom service was acconplished by Judges James Kelley, Glenn Bright and James Carpenter (1 copy each) Atonic Safety and Licensirg. Board I US Nuclear Regulatory Conmission Washington DC 20555 George F. Trowbridge (attorney for Anplicants) Shaw, Pittman, Potts & Trowbridge ILuthanne G. Miller 1800 M St. NW ASLB Panel Washin6 ton, DC 20036 USNRC Washington DC 2055 5 Office of the Executive Legal Director Phyllis Lotchin, Ph.D. Attn Dacke ts 50-400/401 0 L. 108 3ridle Run USNRC Chanel Hill NC 2751h Washington DC 20555 Dan Sead Docketing and Service Section CEAl'GE/ELP Attn Docke ts 50-h00/h010.L. Box 52h Office of the Secretary Chapel Hill NC 2751h USNRC Wasuington DC 20555 Pat & Slater Newman CANP John Runkle 2309 Weynouth Court CCNC Raleigh NC 27612 307 Granville Rd Chapel Hill Ne 2751E Bradley W. Jones USNRC Region II ~Travi s Payne 101 Marietta St. Edelstein & Payne Atlanta GA 30303 Rex 126E3 i Raleigh NC 27605 Richard Wilson, M.D. Certified by

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