ML20072N324

Joint Intervenors Response to First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20072N324
Person / Time
Site:	Harris
Issue date:	03/29/1983
From:	Payne M EDELSTEIN & PAYNE, KUDZU ALLIANCE
To:	CAROLINA POWER & LIGHT CO.
Shared Package
ML20072N309	List: ML20072N305 ML20072N324
References
ISSUANCES-OL, NUDOCS 8304010507
Download: ML20072N324 (17)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '83 Ep m . , g BEFOREThlEATOMICSAFETYANDLICENSINGBOARD In the Matter of P.

CAROLINA POITER & LIGHT ~ )

COMPAh7 AND NORTH CAROLINA )

EASTERN MUNICIPAL POWER AGENCY ) Docket Nos. 50-400 OL -

(Shearon Harris Nuclear Power 50-401 OL Plant, Units 1 and 2) )

JOINT INTERVENORS RESPONSE TO APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION Or DOCUMENTS TO JOINT INTERVENORS (FIRST SET)

Joint Intervenors hereby serve their Answers to Applicants' First Set of Interrogatories.

GENERAL INTERROGATORIE'S 1(a). State the name, present or last known address, an'd present or last known employer of each person known to Joint Intervenors to have first-hand knowledge of'the facts alleged, and upon which Joint Intervenors relied in formulating allega-tions, in each of the contentions which are the subject of this I.

set of interrogatories.

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@P .ioint Intervenors know of no such persons at this ' time .,-

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mg (b). Identify those facts,concerning which each such o

t 8d 00 person has first-hand knowledge.

, -a i 04 (c). State the specific allegation in each contention om

@@owhich Joint Intervenors contend such facts support.

2(c). Stato the nema, present . cur last known address, and present or last employer of each person,'other than affiant, who provided information upon which Joint Intervenors relied in answering each interrogatory herein.

The representatives of the Joint Intervenosr discussed these interrogatoriss. The only other person who assisted in answering these interrogatories was David Martin, Physics Department, North Carolina State .

University. Raleigh, North Carolina.

(b). Identily all such information which was provided

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by each such person ana the specific interrogatory response in which such information is contained.

r General discussions End advice.

6 3(a). State the name, address, title, employer and educational and professional qualifications of each person Joint Intervenors intend to call as an expert witness or a witness relating to any contention which is the subject of this set of interrogatories.

At this time Joint Intervenors have made no arrangements for an expert witness on these contentions.

(b). Identify the contention (s) regarding which each such person is expected to testify. ,,.

(c). State the subject matter to which each such person is expected to testify.

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, 4(c'). Idantify nil documents in Joi.nt Intervenors' possession, custody or control, including all relevant page citations, pertaining to the subject matter of, and upon which Joint Intervenors relied in formulating allegations in each contention which is the subject of this set of interrogatories.

Joint Intervenors relied on the FSAR and contentions of intervenors in othe' licensing proceedings , particularly the Ca tawba proceeding.

(b). Identify the contention (s) te which each such document relates.

Contentions IV, V, and VI.

(c). State the specific allegation in each contention which Joint Intervenors contend each document supports.

While these documents suggested the formulation of the contentions, it probably cannot be said that any of them 3 directly " supports" the contention.

5(a). Identify all documents in Joint Intervenors' possession, custody or control, including all relevant page citations, upon which you relied in answering each -

interrogatory herein.

Joint Intervenors have neither possession, nor control of any documents , other than relevant portions of the FSAR.

(b). Identify the specific interrogatory response (s) to '

l which ekch'such document relates.

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. .6(n). Idantify cny othar courco of information, not previously identified in response to Interrogatory 2 or 5, which was used in answering the interrogatories set forth herein.

None.

(b). Identify the specific interrogatory response (s) to which each such source d,1 information relates.

7(a). Identify all documents which Joint Intervenors intend tp offer as exhibits during this proceeding to suppert the contentiens which are the subject of this set of interroga-tories or which Jcint Intervenore intend to use during cross-examinatica of witnesses presented by Applicancs and/or the NRC Staff on each contention which is the subjecr of this set of interrogatories. .

At this time, Joint Intervenors have identified no such documents .

(b). Identify the contention (s) to which each document relates and the particular page citations applicable to each .

contention. ,

INTERROGATORIES ON JOINT CONTENTION IV (TLDs)

IV-1(a). Describe in detail the additional personnel

- radiation exposure monitoring instruments (including range, sensi.tivity and qualifications) which Joint Intervenors contend are n(cessary in order to assure the p.otection of worker

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safety and health at the Harris Plant.

Joint Intervenors are still attempting to gather the l detailed information sufficient to answer this interrogatory.

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- (b)* Stato in datnil all facts which support J'oint Intervenors' contention that the instruments identified in the answer to the preceding interrogatory are necessary.

IV-2(a). Do Joint Intervenors contend that thermolumines-cent dosimeters ("TLDs") are inadequate to measure cumulative radiation doses as required by 10 C.F.R. Part 20?

i' Yes. .

(b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this i allegation.

Plus or minua 33% is to inaccurate to assure cocpliance with each such limit, and also ALAF)..

(c). If the answer to Interrogatory IV-2(a) is other than affirmative, explain in detail how your response is consistent with the allegations set fcrth ir. Joint Contention .

IV. '

IV-3(a). Do Joint Intervenors contend that portable pressurized ionization monitors are capable of measuring cumulative radiation doses as required by 10 C.F.R. Part 20? ,

Yes , if they have appropriate output recording equipment and are used continuously.

(b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this

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allegation.

Joint Intervenors are currently pursuing dis covery on this, t

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, (c). If tha cnawar to Interrogstory IV-3(a) is 'other than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention

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IV.

f?S E' As discussed in FSAR 55 12.5.3.2.2.2 and IV-4(a).

12.5.3.6.1.1, self-reading dosimeters will be utilized, as necessary, for both s ecific job exposure evaluations and to indicate current individual exposure status. Do Joint Intervenors contend that these self-reading dosimeters do not provide workers with a real-time radiation expcsura menitoring capability?

The FSAR does not describe the accuracy of, or the output from these self-reading dosireters. If, in fact, the output is an easily interpreted analog or digital form, they cay

. provide sufficient real-time conitoring. It is also necessary that the self-reading dosimeters be located on the individual's body at or near the point or points of maximum exposure.

'b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this ,

allegation.

(c). If the answer to Interrogatory IV-4(a) is other than affirmative, explain in detail how your response is

- . consistent with the allegations set forth in Joint Contention IV..

I.V-5(a). Do Joint Intervenors contend that the s' self-reading dosimeters, discussed in FSAR 55 12.5.3.2.2.2 and 12.5.3.6.1.1, are inadequate to assure worker safety and health in radiation hazard areas?

See answer-to interrogatory number IV-4(a).

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(b). If tha cnawar to tha pracacding intprrogntory is affirmative, state in detail all facts which support this cliegation.

(c). If the- answer to Interrogatory IV-5(a) is other than affirmative, explain in detail how your response is

• consistent with the allegations set forth in Joint Contention e' ,

IV. .

IV-6(a).

Do Joint Intervenors contend that the monitoring ranges of the self-reading dosimeters, described in FSAR

$ 12.5.2.1.7.4, are inadequate to protect uprker safety and health?

No, the ranges listed in the FSAR seem appropriate.

(b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this all'egation.

is other (c). If the answer to Interrogatory IV-6(a) .

t'han affirmative, explain in detail how your recponse is consistent with the allegations set forth in Joint Contention IV.

The fact that the monitoring ranges listed in the FSAR may be appropriate, in no way offers an assurance that the self-reading dosimeters will actually be capable of accurately measuring radiation in the ranges listed in the FSAR.

IV-7(a). Do Joint Intervenors contend that the self* reading dosimeters, discussed in FSAR 66 12.5.3.,2.2.2,a'nd 12.5.3.6.1.1, are inadequate to corroborate the exposures indicated by TLDs?

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Joint -Interv:nors havs insufficient informttion cbout -

the self-reading dosimaters at this time with which to formulate an answer. The FSAR says'they are used for

'diff.erent types of radiation than the TLDs.

(b). If the answer to the preceding interrogatory is offirmative, state in detail all facts which support this allegation. '

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(c). If the ans.wer to Interrogatory IV-7(a) is other than affirmative, expl:ain in detail how your response is consisten,t with the allegations cet fcrth in Joint Contention

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IV.

INTERROCAIORIES ON Jo1NT CONTENTIOli V

( AIR Mol!ITORS rds*D S A.'QpERS) ,

V-1(a). Would a commitment by Applicants to meet the provisions of NRC Regulatory Guide 8.25 (relevant pages

- attached hereto as Appendix 1) regarding calibration frequency sa,tisfy' Joint Intervenors' concerns with respect to the issue of the frequency at which the continuous air monitors and port,able air samplers will be calibrated? ,

Probably not.

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(b). If the answer to the preceding interrogatory is negative, state in detail the basis for Joint Intervenors'

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disagreement with the Regulatory Guide 8.25 provisions regarding calibration frequency.

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ALRA requires minimization of exposure. Monitoring accuracy is necessary to provide assurances that ALARA will be achieved. Calibrations every sixth month are insuffi'cient to, assure this.

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(c). If the cnewar to Interrogatory V-1(a) is affirmm-tive, will Joint Intervenors voluntarily withdraw Joint Contention V? If not, explain in detail the basis for the cnswer.

V-2(a). If the answer to Interrogatory V-1(a) is nega-tive, identify the frequency at which Joint Intervenors contend -

P that thepertableairsahplersandcontinuousairmonitorsmust be calibrated.

One month, unless the drif t of any monitor is more than plus or minus 5% after one month; in which case more frequent calibration should be required.

(b). Stat e in detail all facts which support Joint Interveners' contention that the portable air samplers and continuous air monitors must be calibrated at the frequency identified ~in.the answer to the preceding interrogatory.

To be assured of maintaining plus or minus 5% accuracy, frequent calibration is required.

V-3(a). Do Joint Intervenors contend that the portable nir samplers and continuous air monitors are required to be accubate within plus or minus 5%?

Yes.

(b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this

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allegation.

A1 ARA requires them to be as accurate as possible.

Plus or minus 5% is an appropriate range and reasonably achievable, i 9

in othsr (c). If tha en; war to Intarrogatory V-3(c) than affirmative, explain in detail how your response is consistent with the allegations set forth in Joint Contention V.

V-4(a). Do Joint Intervenors contend that NRC Regulatory Guide 8.25 is inadequate.in allowing for a cumulative error in .

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airflow calibrations of less than 20%?

Yes.

(b). If the answer to the preceding interrcgatory is affirmative, state in detail all facts which support this allegation.

See response to interrogatory number V-3(b)

(c). If the answer to Interrogtory V-4(a) is other than affirmative, explain in detail how your response is

- consistent with the allegations set forth in Joint Contention V; .

INTERROGATORIES ON JOINT CONTENTION VI (RADIATION DETECTION AND MONITORING)

VI-1. FSAR $ 11.5.2.5 describes the types of radiation ,

detectors to be used in the Harris Plant Radiation Monitoring System ("RMS"). With respect to each detector type identified therein, identify any alleged inadequacies of the detector type in question.

h fficient

, Joint Intervenors are still attempting to gat er su .-

information to provide .a specific response with respect" to each detector type.

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VI-2(a). Do Joint Intervanors centsnd that the allegnd inadequacies identified in the answer to the preceding inter-rogatory will prevent the RMS from carrying out its intended function?

Not determined yet (see response to interrogatory number VI-1); however, the. wiring and computer hardward and soft- -

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ware employed in the RMS could prevent it from carrying out its intended function regardless of the detectors. (See TSAR Section 11. 5 . 2 . 3 .1)'

(b). If the answer the the preceding interrogatory is state in detail all facts which support rhis 4

affirmative,

. allegation. .

(c). If the answer to Interregatory VI-2(a) is other than affirmative, explain in detail how your response is con'sistent with the allegations set forth in Joint Contention VI.

VI-3(a). FSAR 5 11.5.2. also identifies the types and amounts of radiation which will be monitored by each type of .

detector. Do Joint Intervenors contend that other specific radionuclides must be identified and monitored by the RMS?

Joint Intervenors contend that FSAR section 11.5.2 does not describe the radionudides for monitoring readouts except for iodine and . Other than 1-131 and Cs-137, this section of the FSAR does not identify . specific .-

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' r a'dionuclides .

(b). If the answer to.the preceding interrogatory is affirmative, identify each specific additional radionuclide which Joint Intervenors contend must be identified and monitored by the RMS. j 11

All those not identified in FSAR section 11.'3.2 which are listed in 10 CFR 20, Appendix B. .

(c). For each specific radionuclide identified in the cnswer to the preceding interrogatory, state (1). the basis for Joint Intervenors' conten- ,

tion that such radionuclides must be identifiedYand monitored; and 'c, '

i 10 CFR Part 20 limits exposure to the public and to employees .

(ii). the additional protective actions which could be undertaken based upon knowledge of the concentration and/or release of each such radionuclide beyond those actions which would be initiated based on informatien derived from the RMS as currently designed.

These must be based on the particular radionuclide and plant

. conditions, consistent with ALARA.

3 VI-4 ( a ) .- FSAR 5 11.5.2.7 describes the. Process and Effluent' Radiological Monitors, monitor locations and associa-ted read-outs and alarms. Do Joint Intervenors contend that ,

cdditional monitors are required in order to determine process.

and effluent radiological concentrations and/or releases?

Yes. 7 (b). If the answer to the preceding interrogatory,is

- affirmative, identify the type and proposed location of the additional monitors which Joint Intervenors contend are regairbd. .

At this time, Joint Intervenors have not completed their analysis of the Process in Effluent Radiological Monitors.

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(c). Stata in datail all fcets which cupport' Joint Intervenors' contention that the additional monitors identified in the answer to the preceding interrogatory are required.

(d). If the answer to Interrogatory VI-4(a) is other than affirmative, explain in detail how your respense is consistent with the allegations set forth in Joint Contention

~VI.  ;,,

VI-5(a). Do Joint Intervenors contend that the read-outs and alarms associated with th'e Process and Effluent

• Radiological Monitors are inadequate?

No, the alarms seem loud enough, and the LED readouts seem able to be read.

(b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this all6gation.

(c). If the answer to Interrogatory VI-5(a) is affirmative," identify the additional read-outs and alarms for the' Process and Effluent Radiological Monitors which Joint Intervenors contend are required.

(d). If the answer to Interrogatory VI-5(a) is other; than affirmative, explain in detail how your response is con.sistent with the allegations set forth in Joint Contention VI.

The readouts and alarms on each individual monitor appear gppropriate.

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daccribaa th9 Aron Rcdiction.

VI-6(n). FSAR 5 12.3.4.1 Monitoring Sys' tem, monitor locations and associated rend-outs and alarms. Do Joint Intervenors contend that the Area Radiation Monitoring System is inadequate to accomplish its intended purposes, as set out in FSAR 5 12.3.4.1.1?

Yes.

(b). Iftheapswertotheprecedinginterrogatoryis ,

this affirmative, state in detail all facts which support allegation. '

The accuracy of radiation records is not specified, not

.The information radionuclides identified (FSAR p. 12.3.4-1).

for radiation surveys is not specified (FSAR p.12.3.4-2) .

The micro-processo:'s can only withstand 1,000 rads, so long 12.3.4-4). ,

term post-LOCA monitoring is not assured.(FSAR p.

The locations of monitors do not(FSAR assure detection of a p . 12.3. 4-1 and

' movements of radioactivity % the plant

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(c). If the answer to Interrogatory VI-6(a) is affirmative, describe in detail all modifications to the Area Radiation Monitoring System which Joint Intervenors. contend'are required.

Joint Intervenors are still gathering the information necessary to fully respond to this interrogatory; however the monitors appear unable to operate accurately for ex-tended periods after LOCA.

is o,ther (d).

If the answer to Interrogatory VI-6(a) than affirmative, explain in detail how your response is t tion consistent with the allegations set forth in Joint Con en VI.

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V F-7 ( n ) . FSAR i 12.3.4.2 daccribac tha Airborno Radiction Monitoring System, monitor locations and associated read-outs and alarms. Do Joint Intervenors contend that the Airborne Radiation Monitoring System is inadequate to accomplish its intended purposes, as set out in FSAR I 12.3.4.2.17 Joint Intervenors have not yet completed their analysis of the Airborne Rad',lation Monitoring System.

(b). If the answer to the preceding interrogatory is affirmative, state in detail all facts which support this ,

allegatidn.

(c). If the answer to Interrogatory VI-7(a) is 4 . affirmative, describe in detail all modifications to the I Airborne Radiation Monitoring System which Joint Intervenors contend are necessary.

(d). If the answer to Interrogatory VI-7(a) is other than affirmative, explain in detail how your response is consistent wi'th the allegations set forth in Joint Contention VI.

REQUEST FOR PRODUCTION OF DOCUMENTS ,

Applicants requent that Joint Intervenors respond in writing to.this request for production of documents and produce the original or best copy of each of the documents identified or described in the answers to each of the above interroga-tories at a. place mutually convenient to the parties.

The only documents relied upon by Joint Intervenors are the portions of the FSAR cited by Applicants in these interrogatories , and copies of proposed contentions of r

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interv&nors in other lictnsing proceedings. If Applicants do not have access to' these documents , Joint Intervenors will provide them to Applicants.

I, M. Travis Payne, have prepared the responses to Applicants' Interrogatories to Joiiit Intervenors (First Set).

These answers are true and correct to the best of my knowledge.

This the 2 4 day of Mar ch , 19 83. .

So sworn, m /J fl . Iravis Payne g Attorney for Kudeu Alliance N

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i CERTIFICATE'0F SERVICE I hereby certify that copies of this filing were served this 27 day ofgjl983, by deposit in the United St*gtcE 31 A10:39 mail, first class , postage prepaid, or by hand-delivery,, to:

v. . .. ,

James L. Kelley Deborah Greenblatt ' 1' 7 F Atomic Safety and Licensing Board 1634 Crest Road US Nuclear Regulatory. Commission Raleigh, NC 27606 .

Washington, D.C. 2055,5

. Ruthanne G. Miller Mr. Glenn O. Bright Atomic Safety and Licensing-same addreso as above Board Panel US Nuclear Regulatory .

Dr. James H. Carpenter Commission same address as above Washington, D.C. 20555 Charles A. Barch Dr. Phyllis Lotchin Office of Executive Legal Director 108 Bridle Run US Nuclear Regulatory Commissio.1 Chapel Hill, NC 27514 Washington, D.C. 20555 Bradley W. Jones, Esq.

Docketing and Service Section US-NRC, Region II Office of the. Secretary 101 Marrietta Street US Nuclear Regulatory Commission Atlanta, GA 30303 Washington, D.C. 20555 Richard E. Jones Dr. Richard D. Wilson Vice-President and Senior Counsel 729 Hunter Street Carolina Power & Light Co.

Apex, NC 27502 P.O. Box 1551 Raleigh, NC 27602 Particia cnd Slater Newman Citizens Against Nuclear Power George F. Trowbridge 2309 Weymouth Court Shaw, Pittman, Potts & Trowbridge

.Raleigh, NC 27612 1800 M Street, N.W.

Washington, NC 20036 '

l Karen E. Long l Staff Attorney l

Public Staff - NCUC P.O. Box 991 _

Raleigh, NC 27602 h' f M s h -A

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M. Travis Payne g::7 Attorney for Kudzu Alliance j

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