ML20073R681

Answers to General Interrogatories & Interrogatories on Contentions 22A,22B,75,80,83,84 & 132,first Set.Related Correspondence

ML20073R681
Person / Time
Site:	Harris
Issue date:	04/28/1983
From:	Carrow H CAROLINA POWER & LIGHT CO.
To:	Eddleman W EDDLEMAN, W.
Shared Package
ML20073R677	List: ML20073R675 ML20073R681 ML20073R690 ML20073R697
References
ISSUANCES-OL, NUDOCS 8305040485
Download: ML20073R681 (63)

Text

i arLWi.D CORRESPONDENCB UNITED STATES OF AMERICA .. .--

NUCLEAR REGULATORY CO.MMISSION 4'

.a.

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

-* 33 g -2 J'052 CAROLINA POWER & LIGHT COMPANY ) . w. .r .n a,

~*AND NORTH CAROLINA EASTERN MUNICIPAL )- "" ' '5E E5' POWER AGENCY -

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, . ) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ,.). 50-401 OL Units 1 & 2) )

)

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2 APPLICANTS' ANSWERS TO WIILLS EDDL'EMAN55 GENERAL INTERROGATORIES AND INTERROGATORIES ON CONTENTIONS 22A,22B,75,80, 83-84 AND 132 TO APPLICANTS CAROLINA POWER & LIGHT. COMPANY et al.

. . . (First Set) * ' ' - - -

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- ANSWERS TO GENERAL INT'51iddGSTORIES

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INTERROGATORY NO. Gl(a). Which cerftentions of Wells Eddlenian do Applicants agree are-now admitted in this proceeding,_MRC Docksts 50-400/401 O.L ? . . .

. _ (b). For each such contendon, provide for Kny answers to interrogatories by Wells -

Eddleman which Applicants have ' previously qr presently received (except those suspended by Board order, if any),- the following information:

(c). ..Please state the name, present or last k1 Town address, and present or last known employer of each person whom Applicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) upon whom Applicants relied (ciher than their attorneys)in making such answer.- -

(d). please identify all facts concerning which each such person identified in response to Gl(c)(1) above has first-hand knowledge. - . _

(e). please identify all facts and/or documen'st upon which each person identified in response to Gl(c)(2) above relied in providing information to respond to the interrogatory, . including the parts of such documents relied upon.

(f). Please identify any oth,er docufneht(s) thed or relied upon 5[ Applicants in responding to the interrogatory "

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(g). Please state which specific fac .each . document, identified in response to Gl(e) and Gl(f) above, supports, in the opinion-cr belief or Applicants, or..whichApplicants allege such document supports. _ _

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s (h). Please state specifically vihat information each person idbdtified in response to Gl(c)(!) or Gl(c)(2) above provided to or' for Applicants' affiant in answering the ~

interrogatory. If any of this information is not, documented, pleise identify it as _

! " undocumented"in responding to this-section of GeneralInterrogatory Gl. ' .

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. s 8305040485 830428 -

PDR ADOCK 05000400 --

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ANSWER G1(a). The contentions of Intervenor Eddleman which are admitted in this proceeding are set forth in Applicants' " Admitted Contentions" dated January 21, 1983. Note that Contention 15 is pending reconsiderationpy the-Board.

(b). The answe'rs to General Interrogatories herein are restricted to the interrogatories set forth in Wells Eddleman's "First'Set"' of' interrogatories' on Contentions 22A, 22B, 75, 80, 83-84 and 132. ,

A nswers to General Interrogatories

_ relating to Contentions 41, 45 and 65 will be provided in a separate response to interrogatories related to those contentions. =

(c). The answer to this interrogatory islcontained in Attachment A attached hereto. ._

, (d). The answer to iljis interrogatoryis. contained in Attachment A at,tached

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(e). All such facts or documents relied upon by those individuals identified in

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Attachment A are indicated within each response to'the specific interrogatoriesTon the

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con'tentions. -

(f). See Answer Gl(e). .

(g). Applicants have indicated which specific facts are supported by the documents identified, within each response to -the specific-interrogatories on the

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contentions. ,

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(h). The answer to this interrogatory is! contained in Attachment A attached

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hereto. -

INTERROGATORY NO G2(a). Please state the name, presentmor last known

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address, title (if any), and present or last known , employer, and economic interest

. _. . (shareholde3 bondholder, contractor, employee, etc.) if any (beyond expert or other witness fees) such person holds in Applicants.or any- of them, for each person you intend or expect to call as an expert witness or a witness in this proceeding, if such information has not previously been supplied, o'has changed sin ~ce such information was last supplied to Wells Eddleman. This applies to -Eddleman and Joint Contentions as admitted or stipulated by Applicants. .

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(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 possibility of such person's testifying for Applicants, if.you have contacted such person.

(d). Please statg the subject matter,. separately.for eacit contention as to.which each such person is expected to' testify, which each such [ Arson is expected to testify to.

(e). Please identify all documents or parts thereof upon which each such witness lg expected to, plans to, or will rely, in testifying or in preparing testimony.' ,

ANSWER G2(a). The Applicants do not know!at this time'which, if any, expert or other witnesses they expect to call in this proceeding. -When and if Applicants identify such witnesses, Applicants will sGpplement this response in a timely manner.

(b). See answer G2(a).- . i -

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(c). See answer G2(a). -

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(d). See answer G2(a). -

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(e). See answer G2(a). '

INTERROGATORY NO. G3(a). Please idenlify.any other 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 provides, and identifying ,wherein such source.that infymation is to be found.

(b). Please ide'ntify any other source (s) of idforiItation not previously li$entified upon which any witness identified under G2 above, or other witness, has used in preparing testimony or exhibits' or ' extid ets.to use in testiinony or exhibits, identifying for each such source the witness who is expected to use it, and the part or part(s) of such source (if applicable) which are expected to be used, and, if not previously stated, the fact (s) or

. subject matter (or both) to.which such source relates. ..

l l ANSWER G3(a). Applicants have identified all such other sources of information, if any, within each response to the specific interrogatories set forth herein. .

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(b). See Answer G2(a).. _

l INTERR'OGATORY NO. G4(a). Please identify all documents, and which pages or I

sections thereof Applicants intend or, expect _to usein cross-examination of any witness I

,,_,;._ call in this hearing. For each such witness, please. provide on a timely basislASAP near

' or durin172arings) a list of all such' docume'nts, the subject matter Applic' ants believe they relate to and make the document (s) available for inspection and copying as soon as l possible after Applicants decide or form intent to use such documen,t in cross-

! examination. __ _

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(b). Please identify any undocumented information Applicahts intend to use in l cross-examination of each such witness'for m'E. -

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ANSWER G4(a). Applicants have not at this time identified which documents, if any, they intend to use in cross-examination of Mr. Eddleman's witnesses. Mr. Eddleman a,

has yet to identify any. witnesses which he intends to call to, testify. Thus, it would be impossible for Applicants to answer this interrogatory at this time. ' However, at such thne as Mr. Eddleman provides Applicants with the names of his proposed witnesses and and when and if Appilcants identify documents to tk used'in cross examination of.such witnesses, Applicants will supplement this response in a tienely manner.

(b). See Answer G4(a) above. -The same would apply as to undocumented Information, if any. . .

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' INTERROGATORY NO. G5(a). For each contenlien Applicants state or admit is an admitted Eddleman contention undbr Gl(a) above,-or an admitted joint intervenor contention please state whether Applicants havp available to them experts, and information, on the subject matter of the contentipn. -

(b). If the answer to (a) above is other than a'ffirmative, state whether Applicants expect to be able to obtain expertise in the subject _ matter, and information on it, and if not, why not. . ..

. ANSWER G5(a). Applican.ts,have available to them experts and information on the.

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subject matter of each contention referred to herein.

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(b). Not a'pplicabIs.' .

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[ NOTE: There was no Interrogatory G6J , ,

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INTERROGATORY 'NO. O-7. Please identify all'docuInents which Applicants plan, expect or intend to offer as exhibits (other than for cross-examination) with respect

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to each Eddleman contention admitted which is included in your current response to Gl(a) in this proceeding. -

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

- ANSWER G-7. The Applicants have not at t,his time identified wfilch documents, if~any, therintend to offer as exhibits as to any admitted Eddleman conter[tions in this proceeding. When and if Applicants identify _ such exhibits, Applicants .will, supplement

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this response in a timely manner. - x 7

INTERROGATORY NO. G-8. Pl~ ease iUcntify all other information, not identified in response to the above generalinterrogatories, that Applicants rely on or use or plan or expect to use in preparing testimonf, or-in conducting crosr-examination, or in preparing e e w.

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exhibits, for this proceeding, with respect to each Eddleman contention and joint contention which is admitted in this proceeding and on which discovery is currently open or on which discovery has been open under the schedule laidput by the Board 3-10-83.

Please state for each such item of information th4 contention and subject matter to which it relates. -

ANSWER ,G-8. The Applicants have not at this tim,e identified any "other information" that they plan to ese -in preparing ;testirirony, or in conducting cross-examination, or in preparing eichibits for th'is proc.eeding with regard to any admitted Eddleman contentions. To the extent this-interrogatory seeks information beyond the scope of the answer provided, i,t is objee,ted to, as being overly broad, irrelevant,

- burdensome, and seeking protected or privileged ir3 ormation. f ANSWERS TO INTERROGATORIES ON CONTENTION 22A INTERROGATO_RY NO. 22A-1(a). Have Appliennts m,ade any study _or calculation of nuclear fuel transport costs, uranium yellowcake transport costs, UF 6 transport costs, or other transport costs in connection with the-delivery of nuclear fuel to (1) their ~

existing nuclear plants; or (2) the Shearon Harris nucle ..-

~ar plant? -

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(b). Have Applicants any information as to the cost of transporting spent' fuel (1) from Brunswick to Harris, (2) frplrr Robinson to Hairr.is; (3) from Robinson 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. s accounting records) and list all cost cornponents includ~ed 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 5? Please state the discount rate used, the nominal dollar amounts for fuel in each of the ten years 198P9fe, sad all sources and calculations used to derive

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. the annual nominal dollar amounts. W ow these wbre used. Please i.dentify all pages of such data sources used, and wW V'd; 9 them.

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(e). Was an escalation ate w in the calculation requested in (d) above? If so, what was that rate? Please als6 state all assumptions, calculations 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.- .

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(f). Has CP&L estimated c6st of trinsporting any spent fuel from Harris to~any other reactor site, or to an AFR?- ,

(g). If the answer to (f) above is affirmative, state Wbat cost was estimated, how the estimate was made (including all data sources used), and state the cost p'er assembly transported, or per reactor-year of operation.-

(h). How does CP&L co,mpute the cos.t of nuclear fuel (or its c[omponent costs) to which carrying charges are appli_ed? Please show the calculation (used for ER Amendment 5 and identify all data sources used in making it. . .

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(1). If any assumption, calculation or data source in (h) above differs from the computation of nuclear fuel costs to which carrying charges apply that is used in rate

- cases before (a) FERC; (b) the NC Utilities Commissiog (NCUC); or (c) the South Carolina Public Service Commission, or any of these, please state for each such i difference (1) what the difference is; (2) howit is computqd; (3)-the dollar amount of such

' difference if not given earlier; (4) the amount of this difference for 1 year's operation of Harris 1.

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(j). .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 charge rates used by CP&L (a) in its latest rate increase applications to FERC, the NCUC, and the SCPSC; or (b) in the rates approved for CP&L b.y FERC, the NCUC or the SCPSC in

- CP&L's last rate case before each such body, please state ^those rates also.

(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 kWh,in the ER, particularly Tables 8.1.1-2 and 8.2.1-2? If the conversion is made in' any. Other way, state-how the costs are

_ converted into mills per kWh and all basis and calculations from which such costs were derived. . _.

(1). Are tilere any expenses or costs asso'ciat'et! with nuclear fuel that are not ingluded in ER_ Amendment 5 (e'.g. in the Tables-i6 p~ art k above) whigh .qtre charged. to ratepayers under CP&L's current rates as set by th'e NCUC? by FERC? by SCPSC? If so, for each Commission, state what those costs are,-and give equivalence in mills /kwh for each such cost. - -

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, (m). How does CP&L charge co-Applicant NCEMPA for nuclear fuel?

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(n). How does CP&L charge co-Applicant 'NCEMPA for carrying charges on nuclear fuel?

(o). How does CP&L plan to char'ge NCEMPA for nuclear waste disposal?

(p). For each response to m,n, and o aboverplease state hoir the method differs (if7t 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 inethod, if any, for each item.

(q). Have Applicants inc1'uded any_ cost' s '.of low-level waste disposal in the' computations of ER Table 8.2.1-2? If so, what costs?

(r). Have Applicants included any costs 'of low-level waste disposal in the computations underlying ER Table 8.1.1-2? If so, what costs, and how are they included, please state this including all basis and calculations.. ~

. - - . . (sh_Jre th4re other costs of low-leyb waste disposal not included ~in'the ER for either Table referred to in q and r:above? If so, please state what costs, from sources derived, and why they were not included. .-

h (t). Are there any low-level 14aste disposal costs'not included irt the tables referred to in q and r above, which are being charged by CP&L or.NEEMPA or both to

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their ratepayers in any jurisdictions? If so, please state which costs, which Table they .

are not included in' (or Tables), the amount of -the costs, and their equivalent in mills /kWh. This applies to costs -froJp ' existing CP&L nuclear plants, sand all cost

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components of nuclear waste disposal for low-level waste, which are not included in the above Tables.

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(u). Has the method of nuclear waste disposal contemplated under the NUCLEAR WASTE POLICY 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 worth.pf waste at a burnump equal or greater than that expected by Applicants for Harris fuel, MW-days per metric ton heavy metal or metric turn uranium (MTU) anywhere in 4e United States so far? 'If so, what was the cost of such disposal per metric ton of heavy metal? *

(v). plea,se state or identify the MTHM of high-level waste ^

Harris units .are etpected to produce at (1) 80% capacity factor DER (2) 70% capacity factor DER (3) 60%

capacity factor DER (4) 50% capacity factor DER (5) 4090-capacity factor DER (6) 30%

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CF DER (7) 20% CF DER (8) 10% CF DER.~ 1f this amount varies between Harris 1 and Harris 2, please give it for each unit at each capacity. fact,or stated immediately above.

(w). Are Applicants familiar with-the costs of compliance with 40 CFR 191 Environmental Standards for Management and Dispbsal of Spent Nuclear Fuel, High Level and Transuranic Radioactive Wastes, as contained in EPA's DEIS on such, dated December 1982? .,

(x). If not, do Applicants pkan to comply wiihfuch regulations?

(y). If answer to (w) above is affirmative, 'do Applicants know the cost of

_ _ _ _ ._ compliance with such regulation' sfor each Harris un.it for, each year of ,opetation? What is that cost? - *

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ANSWER 22A-1(a). No.

(b). Objection. The costs of transporting spent fuel from other nuclear plants to SHNPP are not included in' operating cos,ts for SHNPP nor are such costs in any way related to SHNPF nuclear-fue1 cost,s. Thus the information requested is not relevant to the issue admitted in this proceeding as Contention 22A, nor is it reasonably

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caTeulated to lead to the discovery of admissible evidence.

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(c). Not applicable. . ,

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(d). The answer to this interrogatory is, contained in Attachment B attached hereto.

(e). Escalation rates were used in developing SHNPP nuclear fuel costs by

" applying-fosecaste'd values supplie by Data-Resources, Incorporated (DRI):to existing contract formulas of the individual cos_t elements:of the nuclear fuel, cycle - U308, conversion, enrichment, and fabrication. Tables of_the forecasted escalation rates are provided at Attachment C hereto, along with the specific source and page number from which the information was obtained. _,  ; '

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(f). No. .

(g). Not applicable.

(h). Nuclear fuel costs are calculated by utilizing a nuclear fuel operating

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plan, a fuel design for e'ach reactor, and a~ set of prices'fer co%onent costs (alonk with lead times for each component and an AFUDC rate) and an industry-standard fuel cost

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computer code written by NUS Corporation, called Fuel Costs - IV. The calculation of nuclear fuel costs provided in ER Amendment 5 is set forth on Fuel Costs -IV printout.

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(From Harris ' Environmental Report Studyi all~ F 1982; see code description and user manual - N US-798.) [

(i). No SHNPP nuclear fuel costs have been-presented in these rate cases.

(j). Applicants did not compute or provide-carrying charges for nuclear fuel in the tR. The -" carrying charges" listed on Table 8.2.1-2 are inaccurately labeled.

.These costs are AFUDC costs.

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(k). For.the number of kWh used to caletilate the average fuel cost in Table

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8.1.1-2, see Applicants' ~Answey 22A-1(d). _ A lifetime levelized generation of,,

9,855,000,000 kWh for the 28 year plant life was .tised in deriving the levelized costs

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shown on Table 8'2.1-$.

(1). A portion of the net nuclear fuel investment included in the rate base is

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associated with the SHNPP requirements. The carrying cost on the nuclear fuel is approximately 14 percent of the nuclear fuel. accounts;used in _the rate base, or ~ --

$10,080,000, as ,of 12-31-82. Due to the fact that:this is not a direct fuel cost, it does

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l not lend itself ,to a mills /kWh calculation.

(m). NCEMPA owns a share of-the nuclear fuel inventory Arid pays its share

'of costs'Wl1En they occur. _.

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l (n). NCEMPA owns a-share-of-the nuciear fuel inventory, and pays its share

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of costs when they occur. -

(o). NCEMPA owns a shar~e of tie nuclear fuel inventory and pays its share -

of costs when they occur. - - --

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1 (p). NCEMPA owns a share of the nuclear fuel inventory and p1ys its share of costs when they occur.

(q). Low-level waste disposal is not included in nuclear fuel costs.

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(r). See Answer 22A-1(q).

(s) and (t). Objection. The costs of low-level waste disposal are not included

$ nuclear fuel costs. Thus the information reouested, is not relevant to the issue admitted in this proceeding as' Contention 22A nor is it reasonably calculated to lead to

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the discovery of admissible evidence.

j (u). The method of nuclear waste dis [posal contemplated under the Nuclear Waste Policy Act of 1982, to Applleants' knowledgh, has not been used on an industrial

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(v). Objection. The spent fuel /nuclea[ w'aste disposal fee is one-mil-per- .

killowatt hour as established by Section 302 of the Nuclear Waste Policy Act of 1982 and it is not based on a . unit mass such as MTHM. Tnthe information requested is not.

relevant nor is it likely to, lead to t,he discovery of relevar;t eyidence.

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(w). No. The Department of Energy haS res'ponsibility for disposal ~of spent

-nuclear fuel and- higit level.wa'ste. It is Applicants! view that compliance with this

regulation is not applicable to Applicants, and there,fo,re, Applicants have no estimate of

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the cost of compliance. -

l (x). See Answer 22A-1(w). ..

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( (y). See Answer 22A-1(w).

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INTERROGATORY NO. 22A'-2(a). Pliase state exactly what estimates and values of what variatiles were used in the study of system operating costs referred to in ER section 8.1. For each such variable, state-all assumptions and calculations used in -

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producing the values of that varjable'for each year.1986-1995. . _

(b). Was a PROMOD computer program used'in making the study referred to in (a) above? If so, please provide a copy.of each run usedTin the study. _ .

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(c). Please state concisely exactly how the computer runs used in. that study computers system operating costs from the inputs. 2 (d). Are the assumptions,about variables o(her than Harris capacity factor and

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syste.m load identical in each such run? If not, state exactly 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 Utilitie's Commission (or'uhderlying stich t'estimony)? If so, sta'te

• 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 programs and provide listings of them and copies of" actual runs used for the ER amendment. .

(g). Were any computer runs made by Applicants with respect to sensitivity studies for ER Amendment 5 which were no~ t used in preparing that amendment? If so,

please identify all such runs, provide copies, and st[ ate why they were not used.

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) (h). If any part(s) of the resI11ts of any comptber_ runs identifiea above (parts b,c,f,

- and g) were not used in ER Amendment 5, please. identify those parts. The reason for g and h herein is that Duke Power Co. did reject those and omit parts of runs in computations of avoided energy costs (system operating c2sts)in Docket E-100 sub 41 and I want to be sure GP&L did not do likewise in prepar[ng ER Ainendment 5. -

(i). What reason,if any, did CP&L have for oinitting any parts of computer results identified in h above from ER Amendment 5's analysis _and summary? or from either?

(j). Has CP&Il analyzed negative growth in sides on its system? Negative growth -

in peak demands? ., , _ _ _ ,

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y. .

(k). Do Applicahts agree that system fuel savin @ cannot be' computed without (1) a system load forecast giving hourly loads or totalloads; (2) fuel cost estimates for units on CP&L's system; (3) O&M costs, both. fixed and variable for such units; (4) other costs as identified in PROMOD; by the method they used in ER Amendment 5 section 8.1?

! (1). If answer to k above is other than affirniat'ive, please state exactly how such ~

caTeulation can be niade without each'sdeh data item (input to PIiOMOD or not).

, (m). Do Applicants agree that carrying charges on fuelinventories for both coal ~

, and nuclear fuel should be included in comparing system operating costs with and without the Harris units? .

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

(o). Are any escalation rates used in+stimating costs of coal or of nuclear fuel as

. inputs to any calculations or comput~er progfams id&ntified above on Interrogatory 22A-2? If so;-what are those rates, stat.e the basis for each such rate, state where it is used and how, and state any data or sources or calcGlations relied upon in setting that escalation rate, for each such rate. ; .

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(p). Was the Discount rate used'in ER Table _8.1.1-2 about 10.88%? What was the

! rate? Was the discount rate used in Table 8.2.1-2 different? If so, what was it?

l ANSWER 22A-2(a) through (p). Objection.; These interrogatories address the i -

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system operating cost analysis set forth in the ER and not nuclear fuel costs which are 1

the only issue addressed in Contention 22A. Interrogatories 22A-2(a) through (p) do not pose questions that are relevant to the issue admitt'ed inathis proceeding or that are reasonably calculated to' lead to the discovery of' admissible evideitee.

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INTERROGATORY NO. 22A-3(a) Identify any index or indices used by Applicants i3 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, ple.ase state the compiler or source of

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such index, the data sources used in compiling such index, and 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 aboys' whet,her the index includes predictions of future prices or costs of any items, and if so, which items.(d) State all predictions made

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in each such index after 1974 for. uranium costs,' yellowcake costs, enrichment costs, tailings disposal cost at uranium mines or mills or both,. radioactive waste dispos'al costs for uranium mining, milling enrichment, UF6 production, and fuel fabrication, giving for each prediction the year in which it was made and the predicted values of each such cost for all future years predicted. (e) if any index identifi,ed 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) above explaining exietly how each such index or portion thereof was used in preparing estimates or figureswhich either support figures in_the ER, or figures which app. ear in the ER, stating which figure (s) each such index or portion.

thereof was used to compute, verify, or support. -f- -

ANSWER 22A-3(a). The' following table lists the Th. dices'used in escalating nuclear fuel costs for the Harris Plant:

WHOLESALE PRICE INDEX -INDUSTRIAL COMMODITIES (WPIIND)

( WHOLESALE PRICE INDEX - ELECTRIC POWER (WPIO54) _

l WHOLESALE PRICE INDEX -INDUSTRIAL CHEMIGALS (WPIO61NS) '

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j WHOLESALE PRICE INDEX - MINING MACHINERY: AND EQUIP' MENT (WPIl192NS)

AVERAGE HOURLY EARNINGS, M,INING (AMEMIN5) -

AVERAGE HOURLY EARNINGS, CHEMICALS AND PRODUCTS (AHE28NS) 1 -

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. AVERAGE IiOURLY EARNINGS, PRIMARY ElETAL3 (AHE33NS) . .

. - - . - . ~

l AVERAGE HOURLY EARNINGS,, ELECTRICAL MACHINERY (AHE36NS)

< GROSS NATIONAL PRODUCT,IMPIICIT PRYCE DEFLATOIV (b). & (c). Historical data is compiled by the U. S.- Bureau of Labor l Statistics. Since the Bureau does,not produce, forec)sted values, the SHNPP nuclear fuel

~

e *-  %

l -- -

\

l  %

I - - - - .- - . - . . . . . - . _ . . , -. -

costs are based on forecasted indices provided by Data Resources, Incorporated (DRI).

(d). (e). & (f). The Data Resources, Incorpora(ed, forecasts are applied to existing contract escalation formulas of the individual cogt elements of the nuclear fuel  !

cycle - U 038, conversion, enrichment, and fabrication. These forecasted costs are input in a computer 'model which calculates nuclear fuel . costs. ' See Answer 22A-l'(e).

.  : i .

Applicants do not calculate a base fuel cost from which further escalations are applied.

See Attachment C hereto for the escalation values used to calculate the nuclear fuel costs set forth in the ER. -

INTERROGATORY NO. 22A'-4(a) Do Applibalnts rely on anything beyond the basis of NilREG/CR 0672 or NUREG/CR 0672 itself (which~is for a BWR) in preparing their decommissioning cost estimates. for Harris in the _ER? (b) If answer to (a) above is affirmative, 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') etiove is -other than affirmatiye, do

_ , Applicants possess any,information indi~cating higher decommissioning co,sts for a PWR

~ than for BWRs? (d) If answer to e above is affirmitiV ,'what is the information,~ident'ify all documents containing it, and please state whether or not such information is applicable to Harris. (e) If answer to (c) above is other than affirmative state whether Applicants believe any-informatiorrsuch as is requ6stegin c abovd exists. , ._

_ ANSWER 22A-4 (a)- thr.pygh (e). -

Objection. R These interrogatories address-

. t_

decommissioning costs and not nuclear fuel costs'which are the only issue addressed in Contention 22A. Interrogatories ~22A-4(a) through (e') do not pose questions that are relevant to the issue admitted in this proceeding or that are reas'onably calculated to lead to the discovery of admissible' evidence._ ,

INTERROGATORY NO. 22I-5 (a) Have Applicants established any reserve fund to pay the $5 million retrospective premiums for ariy existing CP&L or CP&L co-owned reactor in the event of a nuclear accident elsewhers_ in the US? (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 from 1971 through present (c) If answer to a above is other than affirmative, how does CP&L and its co-Applicants plan _10,make.such payment if it is_ required under the NRC's implementation of the Price Anderson Act, and a nuclear accident occurs at any other_US power reactor which makes such payment necessary? (d) Have Applicants paid premiums for replacement power insursnee for any existing reactors owned or co-owned by CP&L? (e) If answer to (d) above is other than affirmative, state whether any such insurance payments have beeri" approved by ths NC Utilities Commfssion in CP&L's NC retail rates and charges. (f) If answer to d above is affirfnative, state the amount of each such premium in each year any premium fo'r such insuranet was giaid, listing premium by reactor or unit and by_ year. (g) Do Applicants agree that nuclear plant replacement power insurance is a cost of operating a nuclear unit? (h) If answer to g above is other than affirmative,-explain consistency of this answer'with.. answer to (i) below: what charges for nuclear plant replacement power insurance are.now included in w

i l

CP&L's expenses allowed to be recovered in rates by (1) FERC (2) NCUC (3) SCPSC?

ANSWER 22A-5(a) through (i). Objection. These interrogatories address insurance 4

costs and not nuclear f,uel costs which are the only issue addressed in Contention 22A.

Interrogatories 22A-5(a) through (i) do not pose questions that are relevant to the' issue admitted in this proceeding or that are reasonably calculated to lead to the discovery of admissible evidence.  !

INTERROGATORY NO. 22A-6(a) ER section 5.8 states that site specific decommissioning estimates suggest CP&L reactors may have decommissioning costs higher than those shown in that section of tFe ERs Do Applicants still agree this may be true? (b) Do Applicants agree with the ER statemer.t 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 abov.e, 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-(l)-Robinson 2 unit (2) Brunswick 1 unit (3) Brunswick 2 unit (4) Harris I 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 th,e -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 i cost for decommissioning any of these units is'given. (h) State the totalarost of decommissioning (1) . Robinson 2, f2) Brunswick I, .13). Brunswick 2 given in each site-specific study identified in response to the above interrogatories. (i) If not stated above, -

' give all years of constant dollarsiinflation rates, discount rates, and cost escalation..

I rates used in preparing'eacf1 rea'etof decommissioning e~ stimate given in respons_e to the above interrogatories,. particularly g and h above, stating also any contingency amounts or percentage included.in each such estimate.

ANSWER 22A-6 (a) through (1). Objection. These interrogatories address decommissioning costs and.not nuclear, fuel costs whii:h are the only issue addressed in

~

Contention 22A. Interrogatories 22A-6(a)-through-(i) do not pose questions that are

~

~

relevant to the issue admitted in this proceeding or that are reasonably calculated to lead to the discovery of admissible evidence. _

( INTERROGATORY NO. 22A-7(a) Do Applicants believe that if radiation exposure

' limits for internal or externar radiation exposure 'were lowered from ~their presently allowed values, that O&M costs foFthe Harris plant would increase as a consequence?

""(b) If answer to a above is other than affirmativef state in detail the basis 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) 1L90% r. eduction in external exposure limits, (3) a 50% reduction in internal exposure limits (4) a 90%

reduction in internal exposure limits or (5) any ,ther-specific o or unspecified reduction in either or both such limits? (d) If ansser to e above'is affirmative, pl' ease identify each such study, its basis. including all doedments'it is based upon (or which were used in preparing it), name the preparer (s) of the; study, state their qualifi~ cations to make such study, and state what increase (percentage, dollar, mills /kwh, or other) in O&M costs for

- ~

4  %

x

,- - , _ ~ - , . . - . , - , - - - . - - - . - - - - - --

Harris or oth:r nuclear plant (specify which). .(e) Ara Applicants in possession of cny study or studies or documents on the matters inquired into under (c) above, which was not a study performed by CP&L? (f) If answer to e above is affirmative, please state the information requested in both c and d above, inclusive, for each such study or document.

.a.

ANSWER 22A-7(a) through (f). Objection. The,se interrogatories address, O&M costs and not nuclear fuel costs which are the only issue addressed in Contention 22A.

Interrogatories 22A-7(a) through (f) do not pose questions that are relevant to the issue admitted in this proceeding or that are reasonably calculafed to' lead to the discovery of admissible evidence. -

+

INTERROGATORY NO. 22A-8(a) - Identi,fy all indices by Data Resources International which Applicants use to 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 made after.1-1-70, for each such index. (d) If not already given above, give the values (list them)'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, discount, escalati'on,.and other rates used.in making such computation, and identify all work papers on which such computations were performed by Applicants for ER Amendment 5. -

ANSWER 22A-8(a) through (e). See Answer to-E2A-1(j). __

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ANSWERh TO IN'F$RROGATORIES ON 60NTENTION 22B

~

. INTERROGATORY NO. 22B-1(a). Who prepared ER Amendment 2's section dealing with Harris costs and benefits for only 2 onits.as opposed to 2 [ sic] units? Please

~

list all such preparers and which sections they prepared, most particularly the preparer of the estimate of Harris operating payroll (or prepare _rs).

~ ~ ~

(b). Is there any other amendment or update to the' Harr'is ER in which CP&L has estimated that the operating payroll for 2 Harris units would be different than the payroll estimated for 4 units in the original ER? .If so, please identify each such update

~ ~

or amendment, and where such different estimate appears, and state who prepared each such estimate. - -

(c). D,escribe 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)r-Explain why the same. number .was used for, Harris operating' p'ayroll for 2 units as was used for 4 units in the earlier ER, in ER Amendinent 2. State every basis for such explanation.  ;

.?

(e). Identify the numbers of personnel to_be employed at the Harris site to operate 2 units, and how this number' differs from the number needed to operate 4 units

~ ' -

in the original ER. ,

d =

- e

. - - s

i I (f). identify the numbtr of p rsonnel at CP&L headquarters required to covsr 2 1-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 4 units.

2 (g). identify the numbers of contract laborers neededdo maintain and take care of outages on 2 Harris units, and the number required for 4 units.

(h). state whether the salaries of any personnel enumerated under e, f, or g'above will be different because there 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 requiremsnts 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 ara added under it, and why such

! number of personnel is required, and why a larger number is not required, and why no

smaller number is adequate to'c5mply with~each spch NRC regulation. If the number of

. personnel needed to comply with each or any such regulation is not specified in that

~~

regulation, please state all bases mot previously identified upon which CP&L bases the ~

number of persons required at each Harris unit to coinply with that re'gulation.

(j). For each NRC regulation identified under 4 above, state exactly how many additional personnel at CP&L's general offices or,other sit.es not including the Harris plant, will be required to comply with that regulation. State all bases for such number, e including reasons why any less personnel would not.b,e enough, and why 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 CPetl; compute this number for each -

regulation, to achieve cornpliance,with it? For, each reg, why is any lesser number not-enough? E . .

_. (1). Are there any other. NRC regulations not identified above which add to the number of perso~nnel' required 'for Harris operation 4n 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. .

~ ~ '

l ANSWER 22B-1(a). Applicants understand that the' first question should read:

"Who prepared ER Amendment' 2's-section dealing with Harris costs and benefits for only 2 units as opposed to 4_ units?" Applicants' resp'onse to this question and all other

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interrogatories, relating to Contention 22B iirestricted to operating payroll costs, which is the subject of Contention 22B. The answer to t,he first question is "no'one", because

• the origfn# projected lifetime operating payroll of,$653 million (32-year life for 4 units as established in the original Eli) was not-updated in I Amendment 2,to .the ,ER (Section

./

8.1.2) to reflect two units. Applican'ts understanp why there may be some confusion regarding the scope of informatio6 reflectsd in the ER subsequent to Amendment 2. _

^

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Certain, but not all information in ER Section B was amend d to take into ace:unt the cancellation of Units 3 and 4. For example, a table was added in Amendment 2 which showed construction and operating payroll through Unit 2 start-up (1989) only. This table

~ ~

did reflect two units oitly, and was provided in respons'eto'a request from NRC[ Staff.

However, the projected operating payroll expense for two units (28 years) was not

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provided in-Section 8.2.1 until Amendment' 5 to -thIe ER. The projections set forth in

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Amendment 5 were based on 1982 estimates. - .

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(b). Only ER Amendment 5. See Answer 22B 1(a).

(c). The operating payroll estimate i[ncluded in the O&M cost estimates as set forth in ER Amendment 5 included estimates 6f all Company and contract' payroll costs. These costs were projected for each year-of-the life of the SHNPP and then discounfed at 10.883 percent. to 1986 dollars._ The result of this calculation is approximately $615 million. These calculations an h inputs used t erein are found in -

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work papers maintained by CP&L's, Planning and Coord1 nation Department.

c- __

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(d). See Answer. 22B-1,(a). , _ _. . - ..

(e). Appli~ cants' current estimate of theiotal number of personnel needed to

~ operate ,2 units at the SHNPP is between 1100 and 1200 (including Operations and Maintenance, Quality Assurance, Engineering, Training, On-Site Nuclear Safety, Contract Security, and Janitorial personnel). 5pplicants 'do'not have a comparable comprehensive estimate for ~ 4 units. However, the estimate f_or operations and maintenance is approximately 630 personnel for 2 units, which may be compared to

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Applicants'last estimate of 900 personnel for 4 units.

(f). Applicants did not make a separatp detailed estimat'e of the number of

~ ^ CP&L headquarters personnel required to support ,2 units at the SHNPP. ' Applicants' estimate of operating payroll, which includ'es headquarters personnel, was based on

.)

Applicants' experience at CP&L's othe,r Westingilouse PWR (Robinson Unit No. 2). ,

(g). Applicants havi 6ot e'itimated separately the contract labor _

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, ^ et  %

rsquir2ments for outage support for 2 units. Applicants' current estimate of the additional personnel required on site for a significant outage is approximately 500 personnel. This would be a combination of contract and CP&L personnel and reflects the

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support requirements for an octage at one unit only. 'A plica'n'ts would not expe,ct the personnel requirements for a 4 unit plant to be significantly different per unit per 4

outage. Applicants have no such estimate for 4 units. -

(h). Applicants b'elieve that the fact that SHNPP will operate as a 2-unit s

plant'versus a 4-unit plant will not affect individual salaries, but will affect only the number of personnel required. )

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(i). Applicants' esti_ mate of operating payroll was not 'erived d in a' manner that isolated such detail. Based on CP&L's experience-in operating Robinson Unit No. 2, Applica'nts' estimate did take into account general N.RC regulations and those regulations

. . y. . .

applicable to similar PWR units.

~~

(j). See Answer 22B-1.(i). . . -

(k). See Answer 22B-J(i). .- .. .

u . .

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(1). See A'nswer 22B-1(i).

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INTERROGATDRY' NO'. 22. B-2, Please slate-all estimates of Harris operating payroll Applicants have prepared since January 1,1977, stating for each the date therof, the numbers of Harris site, central office, other no.n-llarris site (CP&L) and (non CP&L) cQDtract laborers required, and how. the total payroll estimate is computed from these numbers, including any cost escalation rates, salary escalation rates, wage escalation rates, or discount rates used therein, and whe.ther 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 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 requirc.c!. -

ANSWE'R 22B-2. There have been no other estimates of operating payroll other

_ than those used in the Environmental' Report filings.' ' . .

INTERROGATORY NO. 22B-3. Plea'se sta{e any es'timates of Harris operating payroll filed in NC Utilities Commission-docket -E 2 sub 203, which. requires annual reports on the Harris plant, and when such estimates were filed therein.

ANSWER 22B-3. No SHNPP o'perating payroll estimates haveteen filed in North

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Carolina Utilities Commission Docket . , ..

E-2rSub 203..[. . ~

e **  %

1 INTERROGATORY NO. 22 B-4. If the same indices used by Applicants to estimate future payroll costs for Harris in the current ER had been used to estimate

, those costs based only on data pre-1977, how accurately would each such index have predicted CP&L's actual labor costs or unit labor costs for contract laborers, for salaried Harris site personnel, f,or Brunswick plant operating personnelt and for non-nuclear plant support personnel (central office and non'-central offiedt for the Company's Brunswick and Robinson plants as of (a) 1980 (b) 1981 and (c) 1982 (using data on annual unit la'bor or salary costs, as appropriate for each such category of personnel during each year indicated. - .

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ANSWER 22B-4. Objection. This informati6n is not readily available. Providing such information would require research and calculations which are not permissible

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discovery requests.

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INTERROGATORY NO. 223-5. Supply the-actual values of all indices used by Applicants in estimating future Harris payroll for each year 1960 t'hrough 1982', for all

- years *for which each such index is available. -

ANSWER 22B-5. Applicants operating payroll e timate is not based on indices but

- * ~ '

_~

- :- rather on the actual experiences at CP&L's RobinsorpUnit No 2. - -- .

INTERROGATORY NO. 22 B-6. Has any reguirement of NRC resulted in a need for higher salaries, for for more higher-salaried personnel, or for better trained personnel who can be expected to require higher salaries at- the Harris plants since the - -

construction permit was-issued for Harris on 1-2_7 78? . .

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ANSWER 22B-6'. ' Applicants have no specific data to support such a statement but

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I)elieve that generally' increased nucleac regulation has-resulted in higher salaries.

INTERROGATORY NO. 22 B-7.- If answer to 2_2 B-6 is affirmative, state for each sush requirement the additional personnel, higher salaries, number of higher salaried l personnel, number of better qualified personnel, and totalimpact on operating payroll (as t estimated or actual) for (a); 4 Harris units; and (b) 2 Harris units, for each such l requirement identified under B-6 above. - .

ANSWER 22B-7. See Answer 22B-G.

ANSWERS TO INTERROGATORIES ON CONTENTIONS 75

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INTERROGATORY NO'. 75-1(a) Please litt every instance of' Asiatic clams (corbicula sp or others) living.in cTndensers or cooling water systems at nuclear power

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plants, of- which Applicants are aware, giving for each the date of disco 9ery of such clams, the extent of fouling by such clams if any for ('l) condenser (2) RHR heat exchanger (3) other systems needed to shuLdown a reactor safely,,by. dissipating heat ~

therefrom. (b) Identify each such instan_ce 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 exchangers, specifying the type of other heat exchahger involved, and

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identifying each such instance with the nuclei plant at which it oc_ curred. (c) Are any of ~

the instances listed in response to a_above.outside the United States.~(d) If answer to c .

. . .. . ~

"6

is other than affirmative, h ve Applicants any information on such instances of corbicula or other asiatic clams living in nuclear plants outside 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 aware, and give for each such instance all information requested in a, b, c, and d above. 4 ANSWERS 75-1(a)(1), (2), and (3). Applicants are swarE oT instances of Corbicula fluminea (Asiatic clam) at three nuclear power plants: Arkansas Nuclear One (ANO) Unit 1!, September 1980; TVA Browns Ferry Unit 1, October,1974; and TVA Nuclear Unit, ,

Muscle Shoals, Alabama 1971. _ Details of t!)ese ins}tances are provided in the following

^

documents which Applicants will make available at the corporate offices of CP&L for viewing and copying by Wells Eddleman at his reqdbst:

2 ANO Unit 2 NhC IE Bull'etin 81$03., " Flow Blockage of -

Cooling Water 15 Safe.ty System Components by Asiatic

. Clams _and Musselsf' ,

~ ~ ~ ~ ~

Browns Ferry Unit l Goss L. B., J. M. daEs'on, N. B. Flora,'B. G. Isom', C."

Gooch, S. A. Murrag, C. G. Burton, and W. S. Bain.

, 1979. Control .- Studies on Corbicula for Steam-flectric g- - _

Gerierating Plan ts."- - -In Proceedings of the . First '

^

International C_orbicula Symposium, J. Britton, ed.

October 13-15, 1977. Fort Worth Texas. Pp. 139-151.

TYA Muscle Shoals Unit I,som, Billy G.1971. Evaluatio5 and Control of Macro-

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i invertebrate Nuisance Organisms in Freshwater Industrial Supply Systems. Midwest Benthological Society. l'9th Annual Meeting. University of Notre

(

- Dame, Indiana.

March 24-26, 1971r Unpublished

' ' '~

- - - . - -.-. manuscript. I3 pp. - ' !

(b)(1) through (5). All hetails, if_any, of these instances of which Applicants are aware are contained in the documents listedin Answer 7[-1(a). s.

3 . -

i (c). No. - - -

_ _ .- _ 1 en *  %

19 - - -

N. *

(d). No. .

(e). All details, if any, of these instances of which Applicants are aware are contained in the documents listed in Answer 75-1(a). 5 I

! INTERROGATORY ' NO.- 75-2(a). Do Applican'tm liavi' any means to detect corbucula (siel sp or other clams or mollusks in the Harris cooling lake and auxiliary cooling lake? (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 minimuni size of, clam it (1) can detect and (2) will be 99% or more assured of detecting. (c) Is any means identified above able to identify corbicula larvae? (d): If answer. to e above is affirmative, state how each such means does so and the sampling frequency and sample size used $p do so.

l ANSWER 75-2(a). Yes. However it should be noted that Corbicula fluminea is the only known freshwater mollusk preJent in U.S. drainage systems capable of biofouling, if at all; condensers or cooling water systems at nuclearliower plants. All other mollusks commonly associated with biofouling are lirnited [to marine or brackish water

.- environments. Marine mollusks cannot survive a freshwater environment and.do not present any biofouling potential at SHNPP. -

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(b)(1) and (2). The CIS &L routine biolo[al monitoring program willAetect -

Corbicula fluminea. This' programTincludes the qu'arterdcollection of triplicate samples'

from a deep and a shallow -

area at five locations in the main and auxiliary reservoirs 1

including one location near each of the two intake structures. Samples of Corbicula j fluminea will be collected by staff biologists frodi CP&L's Environmental Technology Section. Sample collection is performed by using a limnological grab or dredge sampling device designed for the collection of bottom or'sedimerit-dwelling  : organisms. The

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minimum size of clams these methods cantetect is approximately 1 mm. If 1 mm or larger clams are present in samples, Applicants are assured of detecting them by laboratory quality control programsr *

( -

(c). Yes. -

}

(d). Clams in the approximate 1 mm size class pre const"dered to be larvae; j _ s

therefore, methods set forth in Answer 75-2(b) will detect larvae. -

3

! INTERROGATORY NO. 75-3(a) Describe c6mpletely any systems and measures l --

- -_ . - _ _ . . . . _ . - - - . _ - - . - _ _ - _ _ _ - - - , - _ . - - _ - _ . . . . - . - - , _ _ _ _ _ _ . _ , _ _ _ - - _ ~ . . _ _ - , . - _ _ _

_. _ _ ~. _ _ -

i Applicants us to protect the main condenser et 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 alloy is used, specify each; and give the manufacturer of Q1 materials made from each aluminum bronze alloy in the Harris condensers. (c) identify all points at which each j aluminum bronze alloy identified in (b) above touchw anymther 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) If not stated in response to e above, describe particularly the ground conta.ct of.each grounding arrangement or system or device identified in e above. (e) Has CP&L or any of its subcontractors for Harris analyzed deterioration of gound contact for any ground contact identified in response to (d) above? (f) If answer to (e) is' affirmative describe each such analysis and identify all documents used in preparing such analysis, ickentify any document 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. .

. ANSWERS 75-3(a) through (f). During a, meeting held among Wells Eddleman, Intervenor, John O'Neill and Hill Carrow, attorney's for Applicants, on Friday, April 8,

_ _ 1983, Mr. Eddleman indicated that the corrosion hft,as,asking about in Int _errogatory,75-3 was that specifically caused by attachment of Corbicula fluminea (or other mollusks if any) to condenser walls or surfaces. As.such, hs'gfated in Asswer 75-2(a), Corbicula ._

_fluminea is the only mollusk cappble of biofouling,,if at'all, the Shearon Harris Nuclear

- .~ .

~

Power Plant condensers and Corbicule fluminea does not attach to any surfaces.

Therefore, no corrosion of ~ the condsnser surfaces ~~will occur due to attachment of Corbicula fluminea and Interrogatory subparts as to condenser alloys and grounding are

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not relevant. _ _

INTERROGATORY NO. 75-4 (a) Do Appli'e ants believe that corbicula sp living in the Harris condenser would cause noticeable pressdre changes on the water side of that condenser? (b)-If answer to a above is affirmativh, describe any such changes and the minimum number of corbicula required to make such a change at the minimum detectable level, and how such minimum detectable pressure change is noted, and how if at all Harris procedures will alert personnel _seeing such a pressure change to the possible presence of corbicula. (c) If there are any other things that can cause pressur [ sic]

- - - . changes.oLihe sa'me magnitude identified in.part~ a or b above, other tha~n:corbicula in the condenser, list all such things"or conditions and explain how each is distinguished from corbicula and how this will be done at Harris. (d) What measures precisely have Applicants taken with respect to pressure efianges,' air leaks or other e' vents that could damage the Harris condenser? (e) Fcr each such measure,jidentified in d_above, state how the presence of corbicula in the condenser Icould affect it,- particularly if the condenser were fouled with very large number of living or dead corbicula. For purposes of this question, a very large number of.corbicula is a number that could affect the (1)

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l. . - .

cfficiency of the condenstr in condensing steam at full load, or (2) the integrity of the condenser, or (3) a partial blockage or total blockage of the condenser or a part of it, or (4) any of the measures identified in (d) above.

ANSWER 75-4(a). No. Applicants do not believe CoJbicula would be able to live in the " water" side of the condenser. - -

g - - - -

(b). Not applicalile.

-+ .(c). 'Not applicable. No pressure changes are identified.

(d). No specific , measures have been taken other than design and

_ construction of the condenser for high reliability and opeability. The design is for a 40 year life span and takes into account all credible phmt transients.

(e). See Answer 75-4(a). Dead Corbihtda passing into the. Circulating Water System would be of such small size that they sill, pass through the condenser due to water flow and will have no effee.t on it.

ANSWERS TO INTERROGATORIES'ON' CONTENTION'80 ~ ~

~

INTERROGATORY NO. 80-1-(a). Are Applicants aware of any studies of mixing of air or water in the lee of nuclear plant structuref~or,other ~ power plant structures? . _

(b) If answer to (a) above is affirmative, identify each such study, stating wheriit was done, by whom, what their qual,K.ications were, an~d,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 identified in (b) above and those used in preparing the Harris ER?,(d)._If answer to (c) above is affirmative, identify each such study and provide for each such study all the informaflon 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. (g) Have Applicants conducted any studies of disp.ersion of radionuclides in the environment not identified above, or are any reports or documents not identified above, which treat dispersion of -

radionuclides from nuclear power plants in air or'wster, in Applicants' possession? (h) If

~

answer to (g) above is affirmative, identify each such study, report or document and give for each the information requested.under (b) above; and state when Applicants acquired the document or report (if known) if they didn'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 of Applicants' knowledge. _ .

-. _ A,liSEER 80-1 (a). Yes. - _. ,  :

(b).

Title:

" Atmospheric Diffusion: A-Study of the Dispersion of Windborne

~-

Material from Industrial and Other Sources." -

1 -

2 -

When: 1974. . . -

.~ : .. .

~.

_722 -

2

By Whom: Fr:nk Pasquill, D. Sc., Meteorological Office, Br:cknsil, Berkshire, England Qualifications: Dr. Pasquill has worked in the research part of the Meteorological Office since 1937 and has become recognized internationally as 3a leading authority in the field of atmospheric dispersion. He obtained- a- First Class. Honours degree in Physics at Durham University and was later awarded an M. Sc. (1949) and a D. Sc. (1950).

. Possess a copy:'Yes. .

~

Title:

NOAA Technical Memorandum ERL ARL-69l" Rancho Seco Building Wake Effects

~

^

_ on Atmospheric Diffusion."

~

When: November 1977. ~

- By Whom: G. E. Start (et al.)7 National' Ocesitic and Atmospheric Administration, Environmental Research Laboratory, Air Resourchs_ Lab _ oratory, Idaho Falls, Idaho.

~

Qualifications: (unknown). .

~~~ '- ^ ' ~ ' " ~ '

Possess a copy: Yes. ~ -

~

Title:

" Dispersion in the Wake of a ModelIndustriItl-Complex" NUREG-0373. _

-t ,

When: February 1978.

By Whom: R. V. Hatcher (et ~al.), prepared for* NRC, Division of Reactor Safety l

Research, by Colorado State. University, Department,of Civil Engineering, Fort Collins, Colorado, 80523.

Qtralifications: (Unknown).- ,

- - ~ ~~

Possess a copy: Yes.

Title:

NOAA Technical Memorandum ERL ARL-9[1, "EOCR Building Wake Effects on Atmospheric Diffusion." -

When: November 1980. -

-m_ .By Whoa G. E*. Start (et &l.), Nation ~al Oceanic and Atmospheric A~ddlinistration, Environmental Research Laboratory, Air _ Resources Laboratory, Idaho Falls, Idaho.

Qualifications: (Unknown). - -

^ '

Possess a copy: Yes. . . --

e o e g e6 * '

g N  %

i 23 - - -

Title:

" Wind Tunnel Study of Ges Disp:rsion near a Cubicle Model Building,"

i NUREG/CR-2395 RB. 1 When: March 1982. 2 By Whom: Wen-Whai Li, R.N. Meroney, J.A. Peterka, Erepared for NRC, Division of Health, Siting and Waste Management, Office of Nuclear Regulatory Research, by Colorado State ilniversity, Department of Civil. Engineering,' Fort Collins, Colorado,

~

80523. .

Qualifications: (Unknown).

Possess a copy: Yes.

Title:

" Building Effects on Effluent Dispe'rsion [ rom, Roof Vents at Nuclear Power

^

Plants." _ _

~

When: 1980. . .

~ ~

~

By Whom: R. H.. Thuillier, R. L. Mancuso, prepaie'd 'for the Electric' P5wer R4 search Institute, 3412 Hillview Avenue, Palo Alto, California294304, by SRI International, 233 Ravenswood Avenue, Menlo Park, California,94025. -

., ,._ u .

Qualifications: (unknown).

~

_ ~' -

Possess a copy: Yes. - . . .

Title:

" Dispersion in the Vicinity of Buildings."

Wifen: 1981.

~

l _ .

i By Whom: R. P. Hosker, Jr., Air Resources, At,mospherie Turbulence and Diffusion Laboratory, National Oceanic and Atmospheric Administration, Oak Ridge, Tennessee, 37830.

Qualifications: (unknown). -

_ - . ~

~

-- - Possess 4. copy: Yes.

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l --

Title:

" Meteorology and Atomic En_ergy." .__ .

When: July 1968. - -

s By Who.n: D. H. Slade, Air- Resources Laboratory, Environmental Services se  %

l N

Administraticn, United Statss Department cf Commerce, Washingtsn, D. C.

Qualifications: (Unkno.wn).

Possess a copy: Yes. a,

Title:

NOAA TechnicaI Memorandum ERL ARL'-84, RB,79t6,'"Ififfusion Near Buildi,ngs as Determined from Atmospheric Tracer Experiments," NUREG/CR-1394.

Then: September 1980. .

By Whom: J. F. Sagendorf, N.R. Ricks, G. E. Stari, C. R. Dickson, prepared for NRC, Division of Reactor Safety Research, Office of Nuclear Regulatory Research, by the National Oceanic and Atmospheric Administration] Air Resources Laboratory, Field

~

Research Office, Idaho Falls, Idaho, 83401.  ; ' - ~

Qualifications: (Unknown). --

Possess'a copy: Yes. .- .

_ .1 ' -

[

Title:

" Nuclear Power Plant Building Wake E fects on Atmosph ric Diffusion:

~

Simulation in Wind Tunnel." , ..~.

f ,_

When: June 1981. ., , , _ _ .. . _ ..

l

.- ~

By Whom: K. M. Kotiiari, R. N. NIeroney, J. A. Petehk'a, prepared for the Electric Power

'Research Institute, 3'412 'Hillview Avenue, Palo' Alte, California, 94304, by Colorado State University, Fluid Dynamics and Diffusion Laboratory, Department of Civil Engineering, Fort Collins, Colorado, 80523.

Qualifications: (Unknown). -

Possess a copy: Yes. .

Title:

"Radionuclide Accumulation'in a Readtor Cooling Lake."

j When: July 1976.

~'

' By Whome-R. L. Shearin, R. J. Lyon, U. S. Environmental Protection Agency, Office of Radiation Programs, Eastern Enrivonmental Railiation Facility, _P.. O., Box 3009,

./

~

Montgomery, Alabama,36109. ,

Qualifications: R. L. Shearin: B". S. Phyiics, M,.S.P.H. Radiological Health,1 year_

- ~

l .

l '

l _.

x

professional training in meteorology, 2 y:crs post graduate study in Environmental Engineering Science,15 years professional experience.

R. J. Lyon: B. S. Chemistry, M. S. Radiochemistry,18' yearsprofessional experience.

' ~' ^ - ' '

Possess a copy: Yes. -

?.

(e). Yes.

^

~*

-(d).

Title:

" Meteorology and Atomic Energy."

When: July 1968. . .

By Whom: David H. Slade, Air Resources Laboratory, Environmental Services Administration, United States Department of Coihmerce, Washington, D. C.

. . -~

Possess a copy: Yes.

Title:

" Radiological Surveillance Studies at ' a. Pressurized Water Nuclear Power Reactof." - -

When: August 1971.

By Whom: B. Kahn, R. L. Blanchard, H. E. Kolde,'HlL. Krieger, S. Gold, W. L' Brinck, W. J. Averett, D. B.., Smith, A. Martin, U. _S. Env.ironmental Protection Agencyn _ _

~

Radiochemistry and ~ Nuclear Engineering Branch,' National Environmental Research i

~

• ' Center, Cincinnati, Ohio, 45268. . .

Qualifications: (Unknown). . .

~ ' ~ ~

Possess a copy: Ye's. -

Title:

"A Radiological Environs Study at a Fuel Fabrication Facility,"_ EPA-520/5-77-004.

When: October 1978. .

By Whom: R. L. Lyon, R. L. She~arin, J. AT Broadway, U. S. Environmental Protection i

Agency, Office of Radiation Programs, Eastern Environmental Radiation Facility, P. O.

~ " Box 3009,+fontgomery, Alabama, 36109. ,- -

17 Qualifications: R. L. Shearin: B. S.. Physics, M.S.P.H. Radiologgal. Health,1 year

/

professional training in meteorology ~ 2 years post-graduate study in Environmental Engineering Science,15 years professional experience.

_ q& e. O l . ,

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l =

l .. .

x i

R. J. Lyon: B. S. Chemistry, M.S. Rcdiochemistry,18 years professional experi:nes.

J. A. Broadway: Ph.D. Nuclear Engineering.

Possess a copy: Yes. 2 The following papers were presented at the Third Symi osium i 6n Atmospheric Turf >ulence Diffusion and Air Quality held October 19-22, 1976 in Raleigh, North Carolina by the

^

+A merican. Meteorological Society. ,

1. " Turbulence and Diffusion Modeling in Buoyancy Driven Mixed Layers," Otto Zeman and John L. Lumley, Pennsylvania State University, University Park, Pennsylvania.

2. "Modeling the Nocturnal Boundary Layer," Alfred K. Blackadar, Pennsylvania State University, University Park, Pennsylvania. ~  : _ ~- -

3. " Wind Flow within Forest and Crop Stands," Rodger H. Shaw, Purdue University, W.

, Lafayette, Indiana. -

- . ., ~. . .- - -

4. "A Comparative Study of Experimentally Meas' ured Atmospheric Stability and ' STAR

~

Program' Predictions," R. V. Portelli, Environment Qapada, Downsview, Ontario, Canada.

5. " Threshold Values.in Wind Speed Measurenlents,", George W. Reynolds, Tennessee

' '" ~

. ., ~,

Valley Authority, Muscle Shoals, Alabama. -

-'~ '

~6. "The Atmospheric Dispersion Model as used inJhe Reactor Safety Study, WASH-1400," Hugh W. Church, Sandia Laboratories, Albuquerque, New Mexico.

~

77 " Building Wake' Effects on Short' Stack Effluents," Alan 'H. Huber, Office of Air Quality Planning and Standards, and William H. Syder, Environmental Sciences Research Laboratory, EPA, Research Triangle Park, North Carolina.

8. " Dispersion of Vapor from LNG Spills - Simulation in a Meteorological Wind Tunnel,"

R. N. Meroney, J. E. Cermak; and D. E. Neff, Colorado State University, Fort Collins,

- Colorado.--  ; _--

9. " Characterization of Wakes' Downwind o_f Nucl~ ear Reactors," Ro,bert F. Abbey, Jr.,

.i United States Nuclear Regulatory Cominission,Vaspington, D. C. , _ .

10. " Neglect of Downstream Diffusion How Good an Assumption," G. E. Willis, l . _ > _ 1

' em  %

W -

National Crnter for Atmospheric Res: arch, Bouldtr, Colcrado, 11.

" Diffusion Under Low Windspeed Conditions near Oak Ridge, Tennessee," R Wilson, G. E. Start, C. E. Dickson, and N. R. Ricks, National Oceanic and Atm Administration, Idahb Falls,-Idaho. ~ ' .

12.

" Diffusion under Low Windspeed, Inversion Conditions," J. F. Sagendorf and C.

4 Dickson, National Oceanic and Atmospheric Administ'ation, r Idaho Falls, Idaho.

13.

" Measured Differences. in Real and- Apparent - +

Plume Parameters," P. W. N Pacific Northwest Laboratories, Battlee Memorial Institute, Richland, Washington

14. ~

" Natural Removal of Gaseous Pollutants," R. L. Kabel, Pennsylvania State

- ~_

University, University Park, Pennsylvania.

15.

"A Model for Absorption and Release or Gaseous Material by Forest Canopie

-- c- -

E. Murphy, Jr., Savannah River Laboratory, E. I, du Pont de Nemours & Co., Aike

~ , , ,

Carolina. -- ^

Posses a copy: Yes. .

~

5. -

- The following papers, a.- we,re presented.at- theJourth. Symposium on Turbulen Diffusion and Air Pollution held January 15-18i 1979 in Reno, Nevada by the Amer Meteorological Society. - - -

[ -h l "On Characteristics 'of Wind Dir'ection Fluctuations in the Surface Layer," H. A.

i

[ Panofsky and R. Lipschutz, Pennsylvania State University, University Park, Penns

~

i 2.

"Some Observations of the Along-Wind Dis}persion Parameter," R. Draxler, Air Resources Laboratory, National O'ceanic and Atmospheric Administration, Silv Maryland. r --

• _

.. 3.

I "A Statistica1 Diffusion Sodel ~for use with Variable. Wind Fields," S. R. Hanna, Atmospheric Turbulence and Diffusion-Laboratory, National Oceanic and Atmosph

.?

Administration, Silver Springs, Maryland. '

7 .

4. 'The Effects of Cross-Wind Shehr on Pluines from Elevated Sources," G. C. H

.g

Dames & Moore, Atlanta, Georgia.

5.

"The Effect of Revised Dispersion Parameters on Concentration Estim , .

Irwin, U. S. Environmental Protection Agency, ResearcitTriangle Park, .

6.

" Field Measurernents of the Benefitse o'f Increas*d Stack Height," Pau .

Pacific Northwest Laboratories, Battlee MemorialInstitute, Richland, W , .

4 7.

"M.odeling Pollutant Transfer During Daytime' Convection," Alfred K. B

~

Pennsylvania State University, University-Park, Penn Ivania.

i di _

8. " Atmospheric Turbulence and Diffusion Boundary Layer Transport Mo

~

Brookhaven National Laboratory, Upton, New York.

1

- 9. " Investigation of Turbulent Diffusion in the Extreme Lower Atmosphere

^ ,

Koper and Willy Z. Sadeh, Colorado State University 7 Fort Collins, Colorado .

10. ."Atmospherie Dispersion Research Supported byu NRC," Robert

_ . , . . . . , ., U. S. F Ab Nuclear Regulatory Commission, Washington, D, C. .

11. ~ -

"Some Parameterizations ,of the Nocturnal Beundary Layer," K.. .S. Rao an Snodgrass, Atmosphetic TurbuJence an ! Diffusion :haboratory, National

- Atmospheric Administration, Oak Ridge, Tennessee.

-- Possess a copy: Yes. -

~

~

The following papers were presented at. the Fifth Symposium on Turbulen ,

^

-Biffusion and Air' Pollution held March 9-13, 1981 in Atlanta, Georgia by the

~

Meteorological Society. -

~

)

t

1. " Stability Effects on Turbulence Struct re in the Atmospheric Surface Lay ,

M. Wilczak, University of Washington, Seattle, Washington.

_ a 2. d

"~ f,fect of F'our Stability C lassificatio6 Metho'ds on Dispersion from an Ele t

1 Source," A. E. Mitchell, Jr. and W. G. Snell,EUS Corporation, Rockville," Mary

3. /

"A Systematic Parameterization, of the Short; Term Dispersionfrom bround j ~

Sources," W. D. Ohmstede and E. B. Ste'nmark, U. S. Army Atmospheric Scien

^

\ - - - . - - - - . . - -- . - . . - .-

Labor: tory, White S:nds Missile Range, New Mexico.

4.

" Planetary Boundary Layer Flow Over a Building," U. K. Kaul, Systems Applications, Inc., San Rafael, California. 4

5. " Diffusion and Deposition of 100 Microri Particles fmm'a7oint Source at a Hhight of 92 Meters," O. Johnson, Defense Research Establishment, Suffield, Ralston, Alberta,

-+ Canada. '

~

6. " Wind Monitoring for Appli.ed Dispersion Modeling," C. R. Hodgin, Midwest Research Institute, Kansas City, Missouri.

7. " Experimental Observations of the De nden*ce of Hourly Standard Deviation of the Wind Direction on Wind Meander," M. V. Carney). Burns & McDorinel Engineering Co.,

Kansas City, Missouri. _.

8. " Laboratory Modeling of Dispersion in the Codvectivel Mixed Layer," G. E. Willis, Oregon State University, Corvallis, Oregon.

Possess a copy: Yes.

.h

~

The following papers were presented at the Sixth Symposium on Turbulence and Diffusion held March 22-25, ~ 1983 in Boston, Ma'ssachusetts by the American

' Meteorological Society. - - -

I- " Comparison of Observed and Predicted Air Concentrations Downwind'of the EOCR Reactor Complex," Charles 'W. Miller, dak Ridge National _ Laboratory, Oak Ridge, Tennessee. ,

2. "On the Variation of Turbulence within the TIBL," S. SethuRaman and D. Brinkman, Brookhaven National Laboratories, Upton, New York. ~'

. 3. "Meteocologic'al and Pollutant _ Profiles .under very Stable Conditions,'I M. L. Wesely and R. L. Coulter, Argonne National Laboratories, Illinois. ,

s

4. " Dispersion of Elevated Releases iii the Stable pundary Layer," A. Venkatram and D.

G. Strimaitis, Environmental Research and Technology, Concord, Massachusetts.

( .

m

5. "Atmosphrric Diffusion in the Mesoscala Ranga: Tha Evidence of Rectnt Plume Width Observations," F. A. Gifford, Los Alamos National Laboratory, New Mexico.

6. " Dispersion of a Buoyant Plume in a Modelled Convectiv.g Planetary Boundary Layer,"

G. E. Willis, Oregon State University, Corvallis, Oregon.% ~ -'

Possess a copy: Yes.

. (e). 'Yes. -

(f). " Meteorology and Atomic Energy.", This text provides a description of precipitation scavenging and a computational methodology for its determination.

"A Radiological Environs Study at}a Fuel Fabrication Facility." This

^

document provides test results of actual field rdeasured data at -a fuel fabrication facility. '. _

" Radiological Surveillance _ Studies at _a P'ressurized Water Nuclear-Power

- .- ~

Reactor." In this document results of field sampl'es are presented where actual snow

~ ~

samples were analyzed and evaluated. ,

(g). Yes. .

(h). Applicants have 'no't conducted any' studies of radionuclide atmospheric dispersion not identified above at the H,arris facility. Applicants conducted many studies

( to ensure compliance with 10 C.F.R. Part 50 Appendix I at the Brunswick and Robinson plghts. These documents will be made available for inspection for a reasonable period of

~ '

time. (See Applicants' Response to Request, f,or Production of- Documents filed -

contemporaneously). .

There are hundreds of papers, reports and articles in Applicants' possession which may deal in part with dispersion of radionuclides in the environment; These documents

~

- will be.made avail'able for insp~ecti,on for a reason ~able period of time. (See Applicants' Response to Request for Production _of Documents filed contemporaneously.)

INTERROGATORY NO. 80-2(a) Do Applicants believe their models1used in the ER can model rainout? (b) If answer to (a) above is affirmative, explain how in detail.

~^

,- ; _ 31 - -

. _. . ~

4 e e

e

~, __

f f .

(c) If cnswtr to (a) above is affirmative, state whether the modal has been applied to each situation described in page 42 of Eddleman response to Applicants' First Set of Interrogatories. (d) If answer to (c) is affirmative for any such situation or scenario,

describe whether that scenario used the most limited. assumptions possible for the area around the Harris plant. If so, state what those assumption + were, what the radiological health and environment,al effects were, and what radiation doses would be delivered, stating also what release (sorice term at release pointTor each radionuclide released into the air) and of what duration was assumed in making the application of the model to each such scenario or situation identified in (c) above.

J 4 '

~ ANSWER 80-2(a). No. -

(b). Not applicable.- -

s

~

(c). Not applicabic. , _,

(d). Not applicable.

[

~

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INTERROGATORY NO. 80-3(a) What is the regulatory Guide ~1.XXX referred to

- in the ER .section 6.l? (b) Is'this the same as either Regulatory Guide 1.109 or Regulatory Guide 1.113? (c) Ho'w, 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 computel runs, were d6ne in preparing _the ER (5.2 and etc.) using dispersion models described in ER-6.1, by whom, when, and what were their individuarqualifications to do such study, computer runs, or modeling? (e) Do Applicants possess copies of each study, computer run, or model identified in (d) ab.ove? (f) If answer to (e) above is affirmative, identify each such study, run or model of.which a copy is retained, stating who did it and when if not stated above. (g) If answer t~o (e) above is negative for any

~~

such study or run or model,,so state. .- g- -

ANSWER 80-3(a). This has now been ~ renamed by the Nuclear Regulatory Commission Staff as Ifegul'atoFy~ Guide 1.145. -

(b). No. ..

~

(c). Regulatory Guides 1.'109,1.113 and 1.145 were utilized to make an

~

evaluation of compliance with 10 C.F.R. Part 50 Appendix I.. .

Specifically, Regulatory Guide 1.109 was utilized to make the,long-term average _

idispersion computation that is part of the ac$ident evaluation.

~

Regulatory Guide 1.145' was_, utilized to co[npute the accident ifumber used in -

T

- prepaririffaTorst case condition analysis. ,

(d). A series of computer- runs was made to generate. the atmospheric

~ .i

~

l dispersion analysis described in ER 6.1,. These are rperred to collectively as'the "SHNPP short and long term dispersion analysis; usihg the. data base, 1976-1979." They were

. . ' .}

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32 - .

_. _ _ - - _ _ _ _ _ - - - - - . - ~. __. . _ - _ .

conducted by B. D. McFeaters, CP&L Project Seicntist (Motcorologist) during the Spring of 1980. Mr. McFeaters has a B.S. degree in Meteorology from Pennsylvania State University and has been actively conducting metorological dispersion analyses for the past 11 years,7 of whidh have been at CP&C. ' ~

-~'

(e). Yes.

• +

. (f). The "SHNPP short and long term accident analysis using the data base 1976-1979." Study conducted by B. D. McFeaters during the Spring of 1980.

+

(g). Not Applicable.

ANSWERS TO INTERROGATORIES *ON CONTENTION 83/84 INTERROGATORY NO. 83I 84 (1)(a)." Has bP&L or Applicants ever made or had made any study of (or studies of) or given any'corisideration to, the formation of carcinogenic chemicals as the result of discharges of ohemicals from the Shearon Harris Nuclear Power Plant? , . ,

s_ '. (b). If your answer to (a) above is yes, plekse. 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 methodologyused in each. . . , .

(c). If there are no studies, state consisely.what . consideration CP&L has given to.

-this issue, and on what date eachTsuch consideratiort WRg made. 'If dates are not known, please specify what isicnown,1f anything, about when 'each such consideration was made.

(d). If your answet= to (a) above is no, .will .CP&L admit that the SHNPP will discharge chemicals into its lake, where boating, swimming and fishing are planned to be allowed or encouraged, which chemicals can by the,ms, elves or through reactions, become carcinogenic or be carcinogenic? ., . ..

(e). For each chemical CP&L plans-to discharge from SHNPP 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 i

stae whether CP'&L believes that chemical can react with other chemcials CP&L plans to discharge, to form carcinogens or a carcinogen.

(g). For each chemical CP&L plans-to discharge from SHNPF fnto water, please

-* state whether that chemical can ' react with other chemicals found in the. Cape Fear River, or-discharged from industrial or other sources into the Cape Fear River, to form l any carcinogen or carcinogens. ,

(h). If your answer, for any~of the chemicals involve 51above,To kny~ or all of the interrogatories (e), (f) and (g) above liii No, plEase_ state for each such answer: (i) any specific studies of the chemical or rbaction product which CP&L relies upon in stating the chemical is not a carcinog'eni(ii) (where applicable) all reaction products CP&L believes can be formed or will be, formed by each sdeh chemical on~ce discharged; (iii) for

~.

~ '

l ..

x

etch such reaction product, any specific study,or studies cf that chemic:1 which CP&L

' relies on for the statement that each such chemical is not a carcinogen; (iv) why CP&L believes that the reaction products of (h) (ii) above are the only ones that can or will be formed.

a, )

(j). Is CP&L aware of any studies or organic chemicals found in the waters (i) of the Haw River, (ii) of the Jordan Lake, (iii) of the Cape Feraf River above the' Harris plant intake, or any other tributaries thereof, (iv) of Buckhorn Creek, (v) of White Oak ,

Creek? (vi) please state for each such study identified in response to (j)(1),(ii),(iii),(iv),

or (v) above the date, author (s), method (s), chemicals seareped .or tested for, title,

$ource, and whether the study is in CP&L's possession or 4pplicants' possession.

. . ~ *

~

(k). Is CP&L aware of any studies of. metals and their salts found in the waters of (i) the Haw River, (ii) the Jordan Lake, (iii) the Ca[pe Fgar River above the Harris plant intake, or any other tributary thereof other than the Haw, (iv) Buckhorn Creek, (v) White j Oak Creek? (vi) please state for each such study identified in response to (k)(i) or (ii) or  :'

l (iii) or (iv) or (v) above the date, author (s), method (s), chemicals searched or tested for, title, source, and whether the study is in Applicants! possession.

. (1). For each and every carcinogen identif,ied above by CP&L, please state (i) the i

maximum concentration factor. thereof in algae, in bacteria, in benthic organisms, in each predator feeding on any of the preceding, in fish, crabs, shrimp, oysters, and other i

commercial species; and in any species of fish caught f'or sport or food in either the Cape

_ -_ F. ear River, the Har.ris Lake (when ~it is opened .for fishing, assuming it is), or fishing /shellfishing areas near the mouth of the Cape Fear, i. e. within 50 to 75 miles thereof. -

e ,

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(ii). What dose (s) in which organisms have'b'e e}i found to increase rates of cancer, . - ,

specifying the cancer (s),the rate of which is increased, if known.

(iii). Whether CP&L believes there isi. hy l'evel or concentration of such carcinogen below which it cannot induce cancer.

(iv). if any answer to (1) (iii) above is Yes, please state in full the basis for such belief, identifying any study (chapter. and pages), expert (s), publication (s) (chapter and i

pages) or other persons or anything else relied upon'to support that belief by Applicants.

j.

~

(m). Do Applicants agree that chemicals. discharged from the SHNPP, either L individually, in interaction with each other forming reaction products, or in reaction with other chemicals in the Cape Fear River, can cause cancer? -

~

i --

(n). If your answer to (m) above is No, (or hther. than affirmative), please state fully any basis for your answer not already stated in response 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 (rn) a ve is Yes, or rne affirmation that the answer may be Yes, has CP&L studied the magnitude of such carcinogenic effects over the expected l

lifetime of SHNPP? _ . . _  : , .

(p). Please state the date, type of study; author (s) or persons who mad.e 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

_ ~

. s W .

CP&L's poss:ssion.

(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. '

.s (r). Are Applietmts aware of any NRC staff sledies 6f the carcinogenicity of discharges of chemicals from nuclear plants or any nuclear plant? Please list all such studies of which Applicants are aware.

+

(s). . Are Applicants aware of any contention (s) cortcernin'g concinogenic effects of i

non-radioactive chemicals emitted from any nuclear plant into water, in any.other proceeding (s) before the NRC at present? .If so, please identify such proceeding and state whether Applicants possess the wording of ths.cordention, or any document stating the contention (s).

(t). Other than the chemicals listed in theTR for discharge from the Harris plant into the water, are all other cheLnicals to be used at the Harris site identified in the ER? Where? -

(u). If any chemical to.be used at the Harris _ site is not identified in the ER, please identify each such chemical and state the. max' mum quantity therof which (i) is expected to be at.the site at any. time, and (ii) will.be al. lowed on the site at any time, if

_ there is a limit, for each. ~

i _ ,, .. .. .

(v). Do Applicants believe that other chemicals, listed in the ER or identified in response to (u) above, can be spilled or leak into or b,'e]yashed into Harris lake? ~

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

~

ANSWER 83-84 (1)(a). No.

(b). Not applicable. '

(c).

Discharges from the Shearon Harris Plant will' meet the permitted

~

discharge restrictions imposed by federal and state law.

(d). All discharges of chemicals f'roin SHNPP will meet the applicable federal and state limi.ts as to species, quantity and concentration imposed by law or regulation. No discharged chemical, by itself, is known to be carcinogenic in the

,. __ _ . ~ . .

i

. concentration which is allowed,to be discharged. As is true with virtually,all chemicals

-. . ~

~ 3-when exposed to the properly selected specific reactant (s), under the precise physical and

. _ _~~ .

chemical conditions (temperature, pressure, sunlight, pH, Eh, agitation,,etc.) necessary for a reaction or a specific succession of separate reactions, it is theoretically possible e g a g eG * '

- ~

l e

I to produen virtually any other chemical. ,

(e). In as much as current federal and state laws and regulations prohibit the discharge of substances in concentrations which are kngwn to be carcinogenic, no carcinogen will be dischbrged from SHNPP. - '

(f). Applicants are not aware of any combination of the chemicals ttischarged from'SHNPP into water that can react to form careiriogens or a carcinogen.

(g). Applicants have not conduc.ted, or' caused to be conducted, any studies

^

concerning the synergistic effects of chemicals discharged from SHNPP with chemicals found or suspected to be in the Cape Fear River. }

(h). Applicants' beli'ef that no cher$ical is discharged from SHNPP in carcinogenic concentrations rests upon the expert opinion (s) that.are the basis for federal and state discharge standards. -

(j)(i) through (v). CP&L has conducted' water chemistry studies of the Cape Fear River and White Oak Creek.

(vi). CP&I4 conducts such studies annually and will make copies thereof, u -

~'

available for review by Mr. Eddlernan at his request.

(k)(1) through (v).--CP&L has conducted water chemistry studies of the Cape Fear River and White Oak Creek.

~~

(vi). CP&L conducts such studies annually and will make ' copies thereof

' ~

available for review by Mr. Eddleman at his request., - ~

(1)(i) through (iv). Not applicable.__

(m). No. See Answer 83-84(1)(e)~

(n). See Answer 83-84(1)(h). -- - -

-- ~(o). N'ot applicable". ,

'2 (p). Not applicable. _ ._  : , .

(q). Although the answG~r to (o) above is o>ther than affirmative, the Applicants' response to (o) does not recognize a carcinogenisis problem as implied in

-s

~

. s

- - -3 6 - -

~ --

-- .-_ -- _ -. - =- ,

question (q) and therefore no plan to study "this matter" has been made or is expected to be made.

(r). Applicants are not aware of any such studieg.

(s). Applicants are-not aware of any such conAention(s). '

(t). All chemicals, other than those which are regulated by federal and/or state discharge limitations, are not listed in the ER, nor are they required to be so listed.

(u)(1) and (ii). It is impossible to, predict and q::antify the presence on site of

~

- all chemicals to be used at the Harris site. This would Eclude such ordinary substances as cleaning fluids, vehicle fuel, and paint. The ER addresses only chemicals which are of environmental concern due to their expected dis h'arge, and are therefore controlled by applicable regulations and permits. '. _

(v). .Obviously, scenarios _ can be p,ost'dlated that would result .in the

~ . , . . .. . . .. .. .

introduction of chemicals into the Harris reservoir system; however, substances that are controlled by regulations are the subject, where .necessary, of Spill Prevention,~ Control and Countermeasures Plans (SPCC) which are adequate to reduce risks to' levels acceptable to the appropriate regulatory agencies.

~

(w). See Answer 83-84(1)(v). -

INTERROGATORY NO. X83/841-(a) Please list every chemical to be discharged from the Harris plant into the cooling tower CWS; give for each the' amount in pounds per yEhr, 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 CWS. (b) Please list every chemical to be discharged from the CWS into the Harris cooling lake at any time, to Applicants' knowledge, giving for each the maximum amount tot eb discharged in. pounds per year and gram moles per year. (c) Please state the maximum concentration at which chlorine is injected or will-be injected into the CWS 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 Harris CWS. (f) If there is more than one such point, identify each and state the maximum concentration at which-chlorine will be injected at each. (g) If not already given above, state.the maximum concentration of the

- chlorine.before injection at each such point _ identified in response to (e) or (f) above. (h)

Please state the maximum concentration of-hydrzine kept in storage for Harris, as nov' planned. (i) Please state the maximuni and' average concentration of hydrazine befert injection into the CWS, RCS, and ~ secondary water at Harrjs; pleastr state-the form ir which ammonia is held for use in the-Harris water systems, for each such system. (j)

Please state the maximum concentration of ammonia before injection and at injection into each such system at Harris,-as now planned; please identify all points at which

. -.37 - - ~

• • =

l

emmonia will be injected into watzr at Herris, or otherwiss introduced into water et Harris, as now planned. (k) If not already s'ated t above, will any chemical identified above be introduced into water at Harris other than by injection, and, if so, please list for each such chemical the concentration before, and immedi t la e y af ter, such introduction, stating which water system, cooling lake, etc., it is planned to be  !

introduced into or will be introduced into.

ANSWER NO. X83/84-1(a).

The chemicals used in treating the Circulating Witter System are:

Chlorine (Cl2 )- 515,163 lblyr (6.6 x 106 gram-moles / year)

. Sodium Hydroxide (NaQH) -

.The" Circulating Water System ,will be maintained acidic; therefore, there will be i

no residual sodium hydroxide in the system.

~,...,

Sulfuric Acid (H2SO4 )- (924,68_5 lb/yr (4.3 x 106 gram-moles / year)

~

l. At Injection 2.Throughout the Circulating Water System C1 2 Not calculated - 0.2 - 6.9 ppm (max)

NaOH -

.50% -Not calculated -

H 2SO4 . 66* Be , ~~

22. 8 ppm .

(b). Chlorine is the only chemical to be discharged from the Circulating Water System into the Reservoir Sysfem. The maximum amount discharged is 7722 lb/yr

- h

-38 - ~

-a--- .

- r - m - - - - ,,,n.,., , .yy . ,

,q,s-.-.~,,9_ - .,___..,m_, -. .__,,.p ,, c- _w , , . . ~ -

(99,011 gram-moles).

_( c). The maximum possible concentration of chlorine that can be injected l

into the Circulating Water System is 6.9 ppm. However, theisystem is designed such that the chlorine residual ih the blowdown will be 0.2 pprh.basdtr~on an estimated 3 ppm injection.

i ..(d).'There are no time of day restrictions planned on chlorine injections.

(e). Chlorine will be injected.into .tlie Circulating Water System at the

.s Cooling Tower Intake Structure located at the base of each Cooling Tower.

(f). Not applicable.

2~ (g). See Answer X8344-1(c). $. _ -

i (h). The maximum concentration of'hy.drazine stored at the Harris site is a 35% solution. . ,.- ,

(i). Hydrazine will not be injected into the Harris Plant Circulating Water System. Hydrazine will be injected* into the Reactor ~ Coolant Sy. stem at the Harris Plant at a maximum and ayerage concentration of, 35%., - -

The maximum and verage a ,,

l concentration in the secondary side water systemi(M~ain Steam System)is 35% (Wet Lay-l -

up) and 10% (Normal Operation), respectively. . AmrBonia will not be injected into the Circulating Water System or the Reactor Coolant System; however, ammonia is used in _ _

tlie secondary side ~ water' system (Main Steam System). Aminonia is h' eld ready for

~ '

injection as a 10-15% aqueous solution and as a 30.%, aqueous solution in bulk storage. '

~

. _~. ,

(j). The maximum concentration of ammonia for use in the secondary side water system (Main Steam System) is 15% aqueous solution before injection and 0.15 ppm at injection. -

- A Ammonia will be injected into water at the 1 arris Plant only at the following' locations:

1. ' Condensate booster pumps ,..

2. Feedwater lines to Steam Generator A, B and C __ ,

3 -

3. Auxiliary Feedwater lines to Steam Generator A, B and C

4. Auxiliary Steam Boiler .~ r -. J '

~

. - ~

~

- 39 -

N

_ . . . , . , _ _ , ~ . . - - _ . -_

4 (k). No. ,

' INTERROGATORY NO. X83/84-2(a) Have Applicants made any studies of the formation of nonradioactive carcinogenic compounds in the chemical or water systems at Harris? (b) If answer to (a) above is affirmative, please list each such study, identify all documents used in preparing it, the date of preparation, the name(s) of the preparer (s),

the qualifications of bach preparer to do~ such studfran'd state whether Applicants possess a copy of the study. (c) Are Applicants aware of any other studies of for'mation

' of carcinogenic chemicals in the water systems of nuclear power plants? (d) If answer to (c) above is affirmative, please supply for each such study the information requested in tb) above, inclusive. (e) Have Applicants undertaken anyJtudy of earcinogenic chemicals being formed or made more carcinogenic as a result ~of int'eraction with chemicals discharged or to be discharged from Harris? (f) If answer to (e) above is other than affirmative, do Applicants agree such chemicals schedujad to be discharged from Harris, including chemicals identified in response to 83/841-(a), (b), (c) above or any other part

' of 83/841 above, can cause cancer themselves, or can interact to form carcinogenic chemicals, or can form compounds which are more carcinogenic than the precursors to such compounds, e.g. by chorinatio,n of organic or'pbenyl or dioxin or dye chemicals?

. ANSWER X83/84-2(a). No. .

(b). Not applicable. .

s_ . . (c). No. . ~.,....., . .. .

(d). Not applicable. -

• ~~ ~

~ (e). No. 3- -

- ('f). -See fnswer 83-84(1)(d). . C - ~~

INTERROGATORY NO. X83/84-3(a) Have Applicants any information as to the i

~ concentration in Cape Fear River water of (1) dioxins.(2) biphenyls (3) PCBs (4) PBBS (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 kno'wn' concentration in such water. (c)

A11swer each part of question (a)above' with respe~ct to Harris c'oolinglake water instead of Cape Fear River water. (d). Answer (b) above with respect to any affirmative answer to (c) above, giving for each the.information requested in (b) above. (e) Identify all ,

documents giving information requested in a, b, e oo.d above~. ~

ANSWER-X83/84-3(a) (1). No. _

(2). No.

, (3).- No.

l , ,- . .

(4). No. -

~

(5)~ No.

g =

1 i

(6). No. > -

s

- -4 0 - -

. , r L - -- - ---- - -- - - -- '~ ~ - - ~ ~ ' ~

(7). No.

(8). No.

(b). Not applicable. 4

• (c). . (1). No. - '

(2). No.

-+

(3). No. - ,

~

, (4). No. .

1 I

(5). No.

i (6). No.

2 (7). No.  :. . , ,

(8). No. _.

. (d). Not applicable. ,' ,

. (e). Not applicable. *

~

INTERROGATORY NO. X83/84-4(a) What nietals are present in the Jor' dan Lake water? In the sediment: (b) What 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 on average? at m'aximumT For observations made so far (d) Have Applicants any _

-information on the matters asked about in a, b.ot 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 requested in a b or e above, telling for each what information it contains.

ANSWER X83/84-4(a). Applicants have n6t studied the' chemistry of the Jordan Lake. .

(b). Not applicable. .

(c). Not applicable. -

i (d). No. -- - ' '

' ~ '

- - - . ._ __ (e). Not applicable. f -

(f). Not applicable.__  : ,

.?

INTERROGATORY NO. 83/84(5)-(a) Do Applicants believe that (1) NCl3 (2)

NHCl 2 (3) NH2Cl is a carcinogen? (b) If answer to any part of a~ above is other than affirmative, state whether Applicants believe each such compound may be a carcinogen.

, e

-41 - - ~

O" e

=. . -. - - .

l ANSWER 83/84-5(2). Applictnts do not, bellava so.

(b). Applicants do not believe so.

INTERROGATORY NO. 83/84-6(a) If not stated in answer to any other

- interrogatory in 83/84 in this set (3/21/83), please state whether Applicants have determined or can determine.how much urea'will be releassdinto the Harris Lake from

' the Harris plant? (b) If answer to a above is affirmative, or Applicants have det' ermined such amount of urea, what is it in pounds per year? (c) Do Applicants believe urea can get into the circulating water system (1) directly (2) from makeup from the lake (3) from

-+ any other source? (d) For each affirmative answer, to a,part (1, 2 or 3) of e above, please state how much urea can get into the CWS from such soorce, at maximum,in pounds per year, for each such source. (e) Have Applicants analyzed the potential for forming carcinogens from urea in (1) the Harris lake, or (2) thg Harris CWS? (f) If answer to e

^

above is affirmative, please identify each such analysis, any documents used in making such analysis, the makers of the analysis,-their qualifications to make it, the date it was made, and identify any documents in which sue!T analysis is set forth and state whether each such document is in Applicants' possession. : .

1? . ~

{ . . ANSWER X83/84-6(a). No. .

(b). Not applicable. .

(c)(1) through (3). - No.

~

(d). Not applicable. -

~ ~

(e)(1) and (2). No. - -

~

~

(f). Not ap'plicablef . .

}

INTERROGATORY NO. X83/84-7(a) Ha'd Applicants made any analysis of the effects of toxic metals or metals as carcinogens, in Cape Fear River water, as impacted by operation of the Shearon Harris plant, (1) prior to 5-14-82, (2) prior to 7-15-82, (3) to the present time, if after 7-15-82? (b) If answer to any part(s) of a above is affirmative, please state for each such analysis the maker (s) of s0ch analysis, the nature and 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, and identify all documents containing such analysis or parts of it, stating also whether Applicants possess a copy of each document identified in response to eacht iart of this interrogatory, for each such document. ,

(c). For each analysis ident fled in response' to (b) above, please state exactly what analysis was made for each metal analyzed therein, as to the effects on people through (1) drinking water (2) washing. water (3) bathing water (4) food, and/or (5) any other means. , ,

l (d). If not already ststed in response 'to (c) above, state whether e.ich such i

analysis included the effects of oRen cuts, bio-con ~ centration in food webs or chains, or l unusually sensitive individuals, or further mobilization of mptals in food or water due to i

other chemicals in such (which other-~chemeials da not derive from the Shearon Harris plant). -

w

.- =

. - - ~

e

$m

'O

(e).

Give the information recu:sted in (d) abova for each metal in each analysis identified in (b) above if this information has not already been given.

ANSWER X83/84-7 (a)(1) through (3). No.

4

' (b). Not applicable.

(c)(1) through (5). Not applicable.

• 4 (d). Not applicable. .

a (e). Not applicable.  :

Please note there are two' sets of 83/84 interiogat,gries, regular and X Where the two

~

overlap, which reference to the other will suffice if it is clear and specific as to which part of '

response (or which-specific response to which part of another interrogatory) answers the question asked in another interrogatory.

ANSWERS TO INTERROGATORIES ON CONTENTION 132 r

INTERROGATORY NO.132-1(a) What' points in the reactor vessel does the RVLIS purport to measure pressure at in order to compute,its pressure differential? Show these in plan and side view if possible. (b) 4 RVLIS? (c) How mahy such points are directly nieasured by How does RVLIS com~pute the dif{erential pressura-between each pair of points identified in response to (a) above? (d)* What is the minimum, maximum, and average error of this computation if known. (e) What are the effects, if any, of transients on the pressures measured by the. R$IS which_ Westinghouse or Applicants have so far analyzed? (f) What does the RVLIS use to measure pressure directly at each ~

point identified in r,esponse to (a) above? ~ Describe, such pressure-measuring device in

, detail. -

. , y.,

ANSWER 132-1(a). See pages 14 to 21 of NUREG/CR-2628, " Inadequate Core i Cooling Instrumentation Using Differential P'ressure for Reactor Vessel Level Measurement," Oak Ridge National Laboratory (March 1982).. Applicants will produce

~

NUREG/CR-2628 for inspection and copying in accordance with the accompanying i

Response to Request for Production of Dofumenis. ~

(b). See Answer 132-1(a). -

! . (c). See pages 21 to 37 of NUREG/CR-2628.

(d). Ses pages vii to ix and 3Nto 40 f NUREG/CR-2628

~ ~ ._ . -

(e). See pages I to 8,73 to 81- and 91 to 98 of NUREG/CR-2628.

(f). See Answer 1321(c).' 2 ' '

j i _ s 1

INTERROGATORY NO.132-2(a) What is the average error of the RVLIS under (1) i normal operating conditions, (2) Class 8 accident conditions (most limiting Class 8 ,

n

. ~

e

- _ _ - _ _ _ - . _ . _ .. -._, .---.. . . _ ~ . . - . __ _ . _ . _ - _ . _ - . - . _ . .- -- -_ _ -

cecident), (3) Clzss 9 accid:nt c:nditions, for any r:2ctor in which RVLIS is now installed? Ilow was each such error measured? Please give each such error in per cent, and in feet of water. (b) If RVLIS is not installed in any reactor now, state when it will be first installed in an operating power reactor, or when it has been installed in one if it already has. (c) Specify all transients which have occurred in any reactor '(power reactor) for which a RVLIS has been installed, since the installation of the RVLIS, and what effect each transient had on the RVLIS reidings. N ANSWER 132-2(a). Applicants are unaware of any information available regarding

-+the error range of the RVLIS under normal or. a'ecident condit!0ns at any operating reactor. Applicants understand that an uricertain[ty level of 6% was established as a target value during the design of the RVLIS (this correlponds to a deviation of plus or minus one foot for the upper range instrument anti plus or minus 2.5 feet for the narrow range instrument). Westinghouse %as evalua'ted the. I uncertainties for each component in the narrow range instrument system at 1200 psia.and has determined tha the overall uncertainty for t.he narrow range indication is plu's,yr ininus 3.9% of the level span (i.e.,

plus or minus 1.5 feet). ~

(As system pressure incFesses,' the uncer'tain'ty range a' Iso

~

increases (to plus or minus 4.6% at 2250 psia).) See NUREG/CR _2628 at 36-39. --

I'n addition to the above uncertainty evaluations ~ performed by Westingh6use, a

~. .

R'VLIS instrumentation system was installed at the SEMISCALE facility at the Idaho

. National Engineering Laboratory in order to compare the RVLIS indications with the SEMISCALE differential pressure level sensors and gamma densitometers. The SEMISCALE tests simulated various loss of coolant and loss of- forced flow conditions, and, in general, showed that the RVLIS provided a conservative estimate of vessel coolant inventory under two-phase conditions. See NUREG/CR-2628 at 49-51 and

~

Figures 12-15. I.

(b). Applicants do not know., . _

. (c). Applicants do not know.,

INTERROGATORY NO.132-3(a) What doe 5 a RVLIS for Harris cost, installed?

(b) Are there any means of directly measuring water levels in the cor.e.of a reactor such as Harris which would cost more than__RVLIS? ,(c) If answer to b above is affirmative, state the cost and nature of each,such means, -and give for each the 5ccuracy of measuring achieved or expected to be achieved by such system, the ri' umber of points or 9

. 44 .

e og

lints v ,rtic211y through the cora cr arcund it on which such ms:suring is done by the system, or describe any way not previously identified in which such system measures directly the water level in a reactor (PWR).

ANSWER 132-3(a). Approximately $1.6 million (estinyted).

(b). Applicants do not know.

'. - ~'

(c). Not applicable.

4 ,

This is the 28th day of April 1983. .

i . ,

\ . --

Oblections submitted by:

md

. Hill Carrow

, Carolina Power & Light Company

- . - . - . ,,Eost.,0ffice Box 15Al .

Raleigh, North Carolina 27602

-(919) 836-6839

~

Attorneys for Applichnts: '"3- ..

~

Thomas A. Baxter, Esquire ' s'~ -

~ ~.,M

~

John H. O'Neill, Jr., Esquire -

_Pamela H. Anderson, Esquire Shaw, Pittman, Potts tc Trowbri~dg.e .

1800 M Street, N.W.

Washington, D. C. 20038 - ~

(202) 822-1000

. Richard E. Jones, Esquire - -

l Samantha Francis Flynn, Esquire ..

~

l Carolina Power & Light Company __

- E. .

Post Office Box 1551 .

Raleigh, North Carolina 27602 -

(919) 836-6517

' * ~

M k s

I *

• i - -

~

,- 3 .. , ~

45 - ~

O l w-

ATI'ACHMENT A Mr. William M. Stocks - Answers 22A-13 (e), (h), (i), 0), (1), (m), (n),

(o) and (p); 22A-2 (m), (n) and (o); 22A-3 (a),

. (b),1c), (d), (g) and-(t)

~

411 Fayetteville Street .

Raleigh, North Carolina 27602 employed by CP&L 4

Mr. Louis H. Martin - -

Answers 22 A'-l (e), -(h), (i), 0), (1), (m), (n),

(o) and (p); 22A-2 (m), (n) and (o); 22A-3 (a),

(b), (c),jd), (e)

• and (f)

- 411 Fayetteville Street Raleigh, North Carolina 27602 - -

employed by CP&L =

2 Shirley R. Williams - Answbr's 22A-1 (e), (h), {i), 0), (1), (m), (n),

(o), and (pT; 22A-2 (m), (n) and (o); 22A-3 (a), (b), (c)t(d), (e) and (f) 411 Fayetteville Street ,

Raleigh,. North Car.olina 27602 .

._ .,_ employed by CP&L , -]~ ., , .. ,, ,

Mr. Robert K. Kunita - Answers 22 A-1 (b), (c), (f), (g), (u), (v), (w),

i (x) and (y) 411 Fayetteville Street -

~

Raleigh, North Carolina ,27602 '

employed by CP&L * - -

/

. t-.- .

Mr. Richard G. Matthews - Answ'ers 22A-2 (a) and (c) 411 Fayetteville Street . .-

Raleigh, North Carolina 27602 -

employed by CP&L Michael Ermolowich - -

Answers 22A-1 (e),'(h), (i), 0), (1), (m), (n),

l _(o) and _(p); 22A-2 (m), (n) and (o); 22 A-3 (a),

(b), (c), (d), (e) and (f) 411 Fayetteville Street -

~

Raleigh, North Carolina 27602 ~

employed by CP&L .

Dr. William T. Hogarth - Answers 75-1 75-2, 75-3, 75-4, 83/84(1),

.- __X83/84rl, X83/84-2, X83/84-3, X83/84-4,

-- 83/84-5, X83/84-6 and X83/84-7

- 4 Shearonllar.cis Ene' rgy & Envirohmental Center

^ -

-~

~

Route 1, Box 327 -

New Hiu, North CaroHna 27562 - ' ~-- ~

employed by CP&L 2 -

e =

W g 6O 9e

- ^ ~

l .

Dr. B. J. Ward -

Answers 75-1, 75-2, 75-3, X83/84-2, X83/84-3, X83/84-4,83/84-5 and X83/84-7 Shearon Harris Energy & Environmental Center Route 1, Box 327 4 New Hill, North Carolina 27562 . . . . .- .

employed by CP&L ,

Richard C. Yates -

Answers 75-1, 75-2, 75-3, X83/84-2, 4 .X83/84-3, X83/84-4,83/84-5 and X83/84-7

. Shearon Harris Energy & Environment {tl Center Route 1, Box 327 New Hill North Carolina 27562- -

employed by CP&L -

+

~ ~

Ronald S. Hobbs - Answer 3 75-1, 75-2 and 75-3 Shearon Harris Energy & Environmental Center .

Route 1, Box 327 - -

New ljill, North Carolina 27562_ -

employed by CP&L -

Leonard,S. Loflin - - -

Answbrs 75-4, X83/84-2, X83/84-3, X83/84-

- =-

4, 83/84-5, X83/84-6 and X83/84-7;~132-1,

. 132-2 and-132-3 -

Shearon Harris Nuclear Power Plant Route 1, Box 101 _ - -

New Hill, North Carolina 27562 . q -

employed by CP&L Mr.~ Phillip B. Summers', ifr! ~- Answers 83/84(1), X83/84-2, X83/84-3, X83/B4-4,83/84-5, X83/84-6 and X83/84-7 Shearon Harris Energy,& Environmental Center ,

Route 1,. Box 327 - - '

New Hill, North Carolina 27562 employed by CP&L _ .

David S. McCarthy -

• Answers 75-4, X83/84-6,132-1,132-2 and 132 Shearon Harris Nuclear Power Plant -

Route 1, Box 101 - -

New Hill, North parolina 27562 _

employed by CP&L B. L. Montague - _

Answers 22A-1 (d) and (k); 22B-1 (b), (c),

l __

'16), (e); (f), (g), (h), (i), (j), (kTand (1); 22B-2, 22B-3, 22B-4, 22B-5, 22B-6 and 22B-7 l 1~ ' '

~ 411 Faylittinille Street -

Raleigh, North Carolina 27602 _

employed by CP&L  :

?

? .-

~

l . - ~

1 - ~

~

.. ~

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B. M. Williams :- Answers 22A-1 (d) and (k); 22B-1 (b), (c),

(d), (e), (f), (g), (h), (1), (j), (k) and (1); 22B-2, 22B-3, 228-4, 22B-5, 22B-6 and 22B-7 411 Fayetteville Street 4 Raleigh, North Carolina. 27602 '

~*

empicyed by CP&L ,

R. S. Stancil - Answers 22A-1 (d) and (k); 22B-1 (b), (c),

4 .(d), (e),.(f), (g), (h),41), (j), (k) and (1); 22B-2, 22B-3, 22B-h_22B-5, 22B-6 and 22B-7 411 Fayetteville Street -

Raleigh, North Carolina 27602

• employed by CP&L -

~ ~

Mr. J. B. Alspaugh Answers 22A-1 (d) and (k); 22B-1 (b), (c),

(d), (e), (f), (g), (h), (i), (j), (k) and (1); 22B-2, 22B-3,72B-4, 22B-5, 228-6 and 22B-7

~

411 Fayetteville Street _

Raleigh, North Carolina 27602 -

employed by CP&L William Yulinski -

Answ.ers X83/84-1, X83/84-2, and X83/84-7 -

-- =-

2 World Trade Center - e.- - -- -

New York, New York 10048 _

employed by Ebasco _ - -

~ ~

Michael Farr - Answer 73'/84(1) 145 Technology Park . '.

~

Norcross, Georgia 30092 - .

employed by Envirosphere Co.

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ATTACHMENT B 4 ANSWER 22-1(d). Following is the calculation for average fuel cost for the Harris Plant:

. Fuel Cost

- Year Generation (MWlO Nominal f 1986 S*

1986 5,368,059 407973,340 40,973,340 1987 5,492,677 - 2

. 41,g70,720 , , 37,220,061 1988. 7,080,335 - 60,,478,040 49,188,975 1989 10,783,353 103,693;060 76,015,721 1990 . 10,934,696 .

110,577','160 73,148,523

- '- . 1991 10,952,678 121,-0,42,290- -72T212,486 -

1992 11,017,277 136,951,990 73,684,907

~

1993 10,972,469 , 149,735,120 -

72,660,420 1994 11,02,4,204 162,591,110 71,150,35'3 1995 11,022,D85 ". ~ 174,128J.90 68,720,510 TOTAL 94,647,833 $634,975,296

\ . . -

AVERAGE FUEL COST = $634,975,296/94,647,833 MWH

- . _ , = $6.7/MWH = 6t7 Mills /KWH Total Annual Harris Plant Gen'eration a_nd Fuel, Cost were obtained from PROMOD computer runs made for the' Harris Environmen 1 Report Studyt Fall, 1982.

~

• DISCOUNT RATE = 10.883 PERCENT.

1

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ATTACHMENT C 4 22A-1(e)

Source: DRI, Cost Forecasting Review, Second Quarter,1982 Forecasted Percentage Growth in Wholesale Price Index Page F24 Page F24 Page F31 Page F34 Industrial -Electric -

Industrial Mining Machinery Commodities Power Chemicals and Equipment Year (WPIIND) (WPIO54) .

. (PIO61NS) (WPil192NS)

- 1983 - 8.7 -10.2 . '8.5 11.8 1984 8.8 9.2 - 9.1 12.1 1985 8.2 9.3 . 8.3 9.4 1986

• 9.1 - 9.6 _ - ,

, . ' 8.7 8.2 -

1987 8.2 . 8.9 ., . ,7.7 . .. 8.9 .

1988 7.4 8.7 8.3 8.7 1989 7.1 8.7 -

8.0 8.1

~~

1990 7.0 , ,8.6 . 7.0 _ 9.i 1991 6.8 8.6 - ? 6.5 8.7 -

1992 6.6 .

8.6 - _ p.1 7.4 ~

1993 6.1

.:--[7-8 . '5.0 ' 6.2 1994 5.7

~

7.4 -

' '4.5 5.1 1995 5.6 ~

7.4 5.2 4.7 1996 5.7 ' --

6.9 -

, 5.6 5.6 1997 5.8 6.6 5.8 6.1 1998 5.7 6.6 ' '

5.5 5.3 1999 5.7 6.6 ~

5.3 '

5.9 2650 5.6 , 6.6 ~ 5.3 7.0 2001 5.6 6.6 - -

5.4 5.8 2002 5.6 6.6 . . 5.3 5.4

~

2003 5.7 6.6 __

5.2 - -

. 5.5 2004 5.7 6.6 . 5.4 4.9 2005 5.8 6.6 -

5.5 3.7 2006 5.8 6.6 5.4 4.5 2007 5.9 6.6 5.4 1.3

. ' ~ ~ -

O . e

" ** 4 b M emM

%" m P m ,

h 4 go . m

=

. g e% D d

O  %

. 4

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l 22A-1(g)

Sourec: DRI, Cost F~orecast RevieWSecond Quarter,1982 Forecasted Percentage Growth in Average Hourly Earnihes Page F25 -

Page F25 - -

Page F26 Page 26 Mining . Chemicals Primary Metals Electrical Mc. chir hal (AHEMINS) (AHE28NS)'. . (AHE33NS ) (AHE36NS)

I983 7.7 -

- 8.6 7.6 7.1 1984 11.5 8.8 7.8 7.6 1985 8.1 , 9.0 '. 8.8 7.6 1986 8.1 9.3 -

_, 8.9 - -

7.8

-1987 9.3 --

9.7 8.9 7.8 1988 7.6 9.4 . - 8.4 7.7 1989 7.5 9.5 . 8.2 7.6 1990 . 9.4 -

9.3 .' 8.1 -

7.5

__ ~ _ _ 1991 . 7.9 9. 0 .. ~ ., 8.4 .. . '7.4 1992 7.9 8.8 '

8.2 7.3 1993 7.3 8.7 - 9.0 7.1

- ~ ~

1994 7.2 8.9 7.3 7.0 1995 7.5 8.9 - c -. 7.2 6.9 1996 , 8.8 9.0 , 6.8 6.9

- 1997 '7.2 .:_.' - 9. l' . 6.7 ' 7.0 1998 7.1 8.8 - 6.8 7.0 1999 9.0 9.2

~

7.3 6.9 2000 -

. 9.1 -- -

9.4 - , 7.2 6.9 2001 8.0 9.7 6.8 6.9 2002 6.9 9.7 6.7 6.9 2003 6.2 9.6 7.1 7.0 2004 7.4 . 8.2 - ~7.1 7.0 2005 7.7 - 7.6 -

7.5 7.0 2006 7.7 8.0 .

6.6 7.0 2007 7.8' _B.1 -

~6 .7 : 7.0 M

6 6-N e g%g

• d M" im k w ,

6 m

e m

22A-1(c) 4 Source: DRI, U.S. Long-Term Review, Spring 1982

+

- Forecasted Percentage Growth

. Pages 3.23 and 1.24 Gross National Product Year Implicit Price Deflator 1983 *l.3 1984 , , :6.6 1985 .6:9 ~

- . 1986 -

,7.0

1987 6J _

1988 6.6 ,

. 1989 .

~

6.4 ' .

1990 -

-6.5.. . .. .

1991 ~6:3 1992 .E.1 1993 5.9 - -

1994 -

~ 5.'7,_ . ..

1995 5.6 ' 7

_ 1996 . g. - h6 - * -

1997 5.7- .

1998 .'5.7

. . 1999- ..- 5.7

- 2000 - ~

5.7 '

2001 5.7 2002 5.7 - '

- - 2003 - '

5.7 -

2004 -

5.7 -

2005 '

5.7 2006 - 5:7 -

^

2007 5!8 -

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CERTIFICATE OF SERVICE i I hereby certify that a copy of the Applicants' Apswers to Wells Eddleman's

General Interrogatories and Interrogatories on Contentions 22A, 22B, 75, 80, 83/84, and 132 to Applicants Caroliha Power & Light Colnpdiny (Firstdilet)Tnai been served by deposit in the United States Mail, first class prepaid, addressed to the parties listed below this the 28th day of April,1983.

4 .

James L. Kelley, Esquire-  ; - *

Atomic Safety and. Licensing Board U. S. Nuclear Regulatory Commission '. .

Washington, D. C. 20555 Mr. Glenn O. Bright Atomic Safety and Licensing Board 1.,

U. S. Nuclear Regulatory Com.nission :. _ - -

- Washington, D. C. 20555 .

Dr. James H. Carpenter . .

- Atomic Safety and Licensing Board *' -

i ._

e U. S. Nuclear Regulatory Commission'".., . , , .. , .

Washington, D. C. 20555 Charles A. Barth, Esquire ,,; -

~

Myron Karman, Esquire f . .

d Office of Executive Legal Director~~ -

U. S. Regulatory Codimission . .

Washington, D. C. 20555 -

^

L

. Docketing and Servie,e See, tion -

Office of the Secretary U. S. Nuclear Regulatory Commission ,

Washington, D. C. 20555 -'

- Mr. Daniel F. Read,' President . .

Chapel Hill Anti-Nuclear Group Effo.rt, -

Post Office Box 524 _

Chapel Hill, North Carolina 27514 ,

Deborah Greenblatt, Esquire -

1634 Crest Road .

Raleigh, North Carolina 27606 .

-+--- --.- Ruth' anne G. Miller,' Esquire ~ :- -

' ~

~

j Atomic Safety and Licensing Board Panel -

U. S. Nuclear Regulatory C.ommission .- ,

! Washington, D. C. 20555 j John D. Runkle, Esquire- > - -

l Conservation Council of North Garolina 307 Granville Road .

Chapel Hill, North Carplina 27514 }

T .

. s

_ -y-- .. ~ _ _ . - _ _, _ , . - _ - ,.--______.m .

__,_,m__,,__ , . , , , , - . y,.__ .g,,y,yy, , .._,,,-__7 .

,.. , _,_y _

M. Travis Payne, Esquire Edelstein and Payne Post Office Box 12643

• Raleigh, North Carolina 27605 4 Dr. Richard D. Wilson #

729 Hunter Street

• Apex, North Carolina 27502 Mr. Wells Eddleman -

718-A 1redell Street -

j - -

Durham, North Car.olina 27705 .

~

^

Ms. Patricia T. Newman Mr. Slater E. Newman -

Citizens Against Nuclear Power 2309 Weymouth Court, .

Raleigh, North Carolina 27612 , . _ , ,

Thomas A. Baxter, Esquire .

John H. O'Neill, Jr., Esquire .

Shaw, Pittman, Potts & Trowbridge .

e 1800 M Street, N. W. ,,

f~ ,, .. , .. .

Washington, D. C. 20036 *

~

Dr. Phyllis Lotchin * ~

108 Bridle Run ~ ' ~f - . .

Chapel Hill, North Carolina 27514 -

Bradley W.' Jones, Esijuire .

U. S. Nuclear Regulatory Commission

^

- Region B -

101 Marietta Street '

Atlanta, Georgia 30303

-~

Karen E. Long, Esquire - -

~ ~

l Staff Attorney . .

Public Staff North Carolina Utilities Commission' ;

Post Office Box 991 Raleigh, North Carolina 27602 - .

. ~~

~

w. . _

~

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Hill Carrow Carolina Power & Light Company

~ -

Post Office Box J551 Raleigh, North Carolina 27602 , ,

i -

(919) 836-6839 -

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i April 26, 1983 4

UNITED STATES-OP AMERIQ -

NUCLEAR REGULATORY COMMISSION .

• BEF6'E R THE ATOMIC SAFETY AND LICENSING' BOARD

. In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY AND )= Docket Nos. 50-400 OL NORTH CAROLINA EASTERN MUNICIPAL ' ~

). 50-401 OL POWER AGENCY )(( ~

)

(Shearon Harris Nuclear. Power )~ -

Plant, Units 1 and 2) ),' ,

_ ,[ ' -

~~~ ~

" ~ *

~ CERTIFICATION BY COUNSEL ~

~

I, John -H. O'Neill, Jr., Coun~sel]for Applicants in the .,

.above referenced.hroceed.ing, certify that I have made the -

following efforts to resolve Applicahts' objections to certain of " Wells Eddleman's' General *Interrogat6 ries and Interrogatories on Contentions 22A, 22B, 75, 80, 83/84 and 132' to Applicants Carolina Power & Light et al (First Set)" dated March 21, 1983.

l 1. On March 31, l'983, I spoke,by ' telephone;to Mr. Eddleman.

We agreed to meet in person at a_ mutually convenient date, preferably ,

during the week of April 4, 1982.

. - - . -~

2. H. Hill Carrow,.. attorney for, Carolina Power & Light Company, and I met with Mr. Eddl'eman on April 8, 1983, in CP&L's offices in Raleigh, North"Carbl~ina. We agreed that- Applicants'

/

answers to Mr. Eddleman's First Set of interrogat.ories would be provided in two responses.' The first. response woul_d address inter-rogatories on Contenti'ons }.2K, 22B, 75, 80, 83-84dnd{132. We

?

~-

4 discussed Applicqnts' objections ,to,certain o.f_phe interrogatories relating to the aforementioned contentions. I stated that

.ppplicants would contact Mr. Edd, leman.at a later date regarding ,

objections to interrogatori~es relating to Contentions 41, 45.and 65.

3. Applicants view a significant aumber of Mr. Eddleman's interrogatories relating to Contsntipns 22A and 22B as outside the scope of those contentions. After d'iscussing why ppplicants viewed these interrogatories as irrelevant tci the contentions as admitted, weag,reedthatcertainoftheinterrogahoriesmightberelevantto issues which Mr.- Eddleman is seeking-to raise. in the context of Contention 15, as supplemented. App ~liqants agreed to review each such interrogatory with kr. Eddleman, along with interrogatories -

previously submi'tted bp-Mr. Eddlemen on ontention 15 after and~ . _

.in the event the. Board, admits any part of Contention 15.

In the meantime, Applicants have noted an objection where the interrogatories seek information ou.tside the, scope of't'he admitted contentions.

4. In certain instances -Applicants viewed the wording of the interrogatory as overly broad but$ agreed to answer.a more carefully restricted ques, tion ar@ to provide the appropriate qualificat' ions with the answer.

, ~

5. Applicants expr'ssed ~e their~ view that Genera.l. Interrogatory G-8 is overly broad. Mr. Eddlemh.n suggested that he might attempt to redraft General Interroga,toryG ,8 more narrowly.' $r. 'Eddleman

- s did not provide an alternat'ive General Interrogatory prior to the date of this affidavit. Applicants h; ave answered General Inter-

..  :  ; . ~.

6 A e

3-4 rogatory G-8 to the extent possible and objected where the scope of the answer may be. objectionable.

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{ t J6hn H. O ' Neil~l: Jr.

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DISTRICT OF COLUMBIA: i Dated: April 26, 1983 -

Subscribed and sworn to before me . -

this  % day of April, 1983. .

^

hiuu.

otary Public ,

[ at $1sutwL -

~~ ~

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-24 /9[7. [ ' -

-MyCommissionExpIres:h,-r.f . .

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UNITED STATES OF AMERICA 5

NUCLEAR REGULATORY COMMISSION

. w BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

• In-the Matter of )- .

. ) -

CAROLINA POWER & LIGHT COMPANY, , ' Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN '. . 50-401 OL

- MUNICIPAL POWER AGENCY )

_ b (Shearon Harris Nuclear Power Plant, Units 1 and 2)

, ), ,

AFFIDAVIT OF LOUIS H. MARTIN

• ~

County of Wake ) -

_ ) . , . . . . . ,

State of North Carolina ) ,

Louis H. Martin, being duly sworn ecording to law, deposes- -

NGelear Fuel Section_;of Carolina Power & Light and says that he is Manager Company; that the answers to Interrogatories on Contention 22A contained in

Applicants' Answers to Wells Eddleman's General Interrogatories and Interrogatories on Contentions 22A, 22B, 75, 80', 83/84 and.132 to Applicants Carolina Power & Light Company, et al. (Pirst Set)" are true and correct to the best of his information, knowledge and- belief; and 'that the Isources of his information are officers, employees, agents and contractors of Carolina l Power & Light Company. ,

' '~

~

~

, - - - . _ Louis H. Mart.in ,

~  ?

Sworn t nd subscribed before s '" "8 ' ' -

day of April, 1983.,p s%" h ,,,'*."[%

me this 3 ww Notary Public g

i rum 5,

, pggg ** O f j

? .

My cocmission expires kN '

• * * . . * * * * * * ' .Y --

s >

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d##aae464

~ , ,,-- .-. .- .-- - -.- -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION A BEFORE*THE ATOMIC SAFETY -AND LICENSISG BOARD -

In the Matter of )

- )

~ '

CAAOLINA POWER & LIGHT COMPANY

~

) Dodket'Eos,50-400OL ~

AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY .

) -

) -

+

4 (Shearon Harris Nuclear Power }

Plant, Units 1 and 2) ~

)~ ,

~ * ~'

AFFIDAVIT OF BOBBY L. M0'NT UE County of. Wake '. N

~

, )) -

' State of North Carolina'

) '." ~ " *~ '

~

Bobby-L. Montague*, being . duly swo *~ accordirig to law, depos,es ..

and says that he is Vice P,resi_ dent - Planning and Gdordination Department of

~~

Carolina Power & Light Company; that the answe'rs to Interrogatories on Contention 22B contained in'" Applicants' Answers To Wells Eddleman's General Interrogatories and Interrogatories on-Contentions 22A, 22B, 75, 80, 83/84 and 132 to Applicants Caro' lina Power & Light Company, et al. (First Set)" are true and correct to the best of his' information,- knowledge and ,

belief; and that.the sources of his information.are officers, employees, agents and contractors of Carolina Power & Light Company.

_. . ~

' ~~

-h.. ~ --

.c 'Q[g .., '. . . - - .: b B0 L. MONTAGUE _!

..-]-lh:.'l'd Q ,Q.G.g, bscribed before .

Sworri'to"andydayo']Akril,1983.

me thi c2/ ,.. . _.

,, =.

[, , No,, tag,Ptibl.1,g ' , . - ~

, < , , , s . , . .y -

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MycommiNs'15 hhp [res 4//[ .

// -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of '

)

)

CAROLINA POWER'& LIGHT COMPANY .) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN MUNICIPAL POWER AGENCY

, ) , '_-

50-401 OL

)

) .

,(Shearon Harris Nuclear Power )

+

Plant, Units 1 and 2) _ __)

. AFFIDAVIT OF B. H'.-WEBSTER -

County of Wake )

, ) .-

State of North Carolina

.~ ) -

B. H. Webster, being duly sworn, according to law, deposes and says that he is Manager - Radiologicdl- &~ Chemical Support - -

.~. , .- .. '

Section of Carolina Po'wer i light Company; that th'e answers to

~

~

Interrogatories on, Contention 80 contained in " Applicants' Answers to Wells Eddleman's General Interrogatories and Inter-rogatories on Contentions 22A, .22B, 75, 50,' 83/8d and 132 to Applicants Carolina Power & Light Com'pany, et al. (First Set)"

are true and correct to the best of-his :information, -knowledge

~ -

and belief; and that the sources ol.his information are officers,

(

employees, agents and contractors of Carolina Power &. Light _

.Aompany. - - ..

M. M . ( 1 dYs H .- Webster -

~

Sworn to and subscribed before '

me this 'U__' day of April, l_983. _

~ ' '

m a

.>.s.

Notary Public

. L ' N : ..

\

~

)

. My Commission Expires: 'Li> eMg

-b l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

.2, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter,of ) ,

-+

-) .

CAROLINA POWER & LIGHT COMPANY ) i DocIcet Nos. 50-400 OL AND NORTH CAROLINA EASTERN .) 50-401 OL MUNICIPAL POWER AGENCY ) .

)

(Shearon Harris Nuclear Power -)

Plant, Units 1 and 2) )

AFFIDAVIT OF WILLIAM-T7 HOGARTH County of Wake ) ,

, ) ~

+ -

._ ,_St_ ate of North Carolina ~) -[". ,, , ,, ,, ,

William T. Hogarth, being duly sworn according to law, -

deposes and says th,at he is Manager - Environmental Technology

. _ -. g.

Section of Carolina Power ~& ' Light Company 1 ~that the answers -to Interrogatories on Contentions 75 and 83/,84 contained in

" Applicants' Answers to Wells Eddleman's General Interrogatories and' Interrogatories on Cor3tentions 22A, 22B, 75,- 80, 83/84

~ '

and 132~ to Applicants-Carolina Power',& Light Company, et al.

~

(First Set)" are true and correct to th[e best of his information, knowledge and belief; and that the sources of his information are officers, employees, agents and contractors of Carolina Power &

- -- - Light Company . '

~~

I l

"&de & 4. M William' T. Hocfarth Sworn to and subscribed befbrd -

me this day of April, 1983.__ , ,,

~ ;

~

i l '

/ .

t . .. .,

l Notary Public -

l ,

My commission expires .

Applicants were not able to attach hereto the Affidavit of

.A Leonard I. Loflin, Manager-Engineering, Harris Plant, as to the answers to Interrogatories on Contention ~132, in that Mr. Loflin was out of the, office and unavailable due to other conflicts.

4 .

As soon as this Affidavit is secured, itjwill- be forwarded in a timely manner to the parties for attact) men,t to Applicants' answers. - -

t

, This the 28th day of April, 1983 ,. -

Hill garrow Caro, lina Power & Light Company

. . . Post Office Box 1551 .

Rale [Qh,, North Caroli;1a 27602,

~ ,

Telephone: (919) 836-6839~

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UNITED STATFS OF AMERICA .A NUCLEAR REGULATORY COMMISSIOT BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 .

~ ~ '

In the Matter of ) .

) -

~

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN

~

) 50-401 OL MUNICIPAL POWER AGENCY ) ~~ ,

)

.) 1-

~ (Shearon Harris Nuclear Power Plant, Units 1 and 2) ) -

AFFIDAVIT OF BOBBY L. M0FTAGUE -

County of Wake ) ~

) .- -.

State of North Carolina .) ... _ .

_ Bobby L. Montagug, .being duly-snorn according to law, deposes -

and says that he is Vice President - Planning and Coordination Department of

~~

Carolina Power & Light Company; that ' Applicants' It'esponse to Wells Eddleman's First Request for Admission to Applicants concerning Eddleman' Contention 22-B is true and correct to the best'of his information, knowledge and belief; and that the sources of his information are officersi, employees, agents and contractors of Carolina Power & Light Company. ~ ~

~

- ~

.@'$.sti:"::re,,,

. . _ _ .' BOBB L. MONTAGUE

~ '

.' 1 ,

.a . .p.Y. D. lig?%."m. pc;s

~_

? ',,

QQk?g ?;,V $ I '

• Sworn to and.e b - - -

4 scrfbedi.before day qEf dril, 1983.

me til.i M / *

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P ;;37,

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t Naasaaac .

My commission expires 8 [.

//