ML20077C792

Fourth Set of General Interrogatories & Interrogatories on Contentions 29 & 37B

ML20077C792
Person / Time
Site:	Harris
Issue date:	07/25/1983
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
References
ISSUANCES-OL, NUDOCS 8307260248
Download: ML20077C792 (31)

Text

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0

! UNITED STATES OF AMERICA 0

[:S NC 25 2 NUCLEAR BEGULATORY COMMISSION ( 1983 3 -

%pg BEFORE THE A'IOMIC SAFETY AND LICENSING BOARD l Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman j 1

l In the Matter of '

Dockets 50 400 OL  !

CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL l (Shearon Harris Nuclear Power Plant, ) l Units i ani 2) ) )

) i l

Wells Eddleman's General Interrogatories 6pd .TJf8rysfbaW  !

to Apolicants Carolina Power & Light g al. haus 19 l l (FORTH Set) (edeg'7

+3 6 l

( Under 10 CPR 2.7h0, 2.7h1 and the Board's 9-22-82 Memorandum and Order, Wells Eddleman recuests Applicants to answer senarately and fully in writing, under oath or affirmation, each of the following interrogatories, and to produce a permit insoection and conying of the original' or best copy of all document's identified in resnonse to interrogato-ies as set forth below. .

These interrogatories are intended to be centinuing in nature, and I reouest each answer to be cromotly supplemented o= anended as accrooriate unde" 10 CFR P.7hd(e), should CPAL, NCFMPA, .any othe=

or any contractor or consultant to any, sone or all cf those, Apolicant,por any emnloyee of any or some or all of them, or any individual acting on behalf of any or some of all of them, obtain or create any new or differing information resoonsive to these (wh list genera 4"Them" refe=s to The nterrogatorie .

the precedingor reauest oro!ng(s))

duction of . documents-is also continuing and reauests A p licants to oroduce cromotly if

. not inmediately any additional documents the Applicants and others acting on their behalf or employed by them, as lis'ted in the orevious C307260248 830725 gDRADOCK05000

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sentence, obtain which aro responsive to tha raquact(s) for nroduction of docunents below.

Where identification of a document is reauested, clease briefly describe the document (e.g. book, notebook, letter, memo, recort, notes, transcript, minutes, test data, log, etc. ) and provide the document name , title, number, following information as anolicable:

author (s), date of writing or of publication or both, addressee, date annroved, by whom anuroved, and the name and address of the versens haing normal custody of tha document, and name and addvess of any nerson other than the preceding having actual vossession of the docu9ent. When identifying documents in resconse to these

! interroEatories and reauests, please state the nortion or nortions of the document (e.g. sections, chafers, pages, lines) uron which l

ApolicantsrelyorwhichAp{licantsswearoraffirmis/areresconsive to the acclicable interrogatory or veouest.

j DEFINITIONS herein:

" Harris", " Harris Plant", "SENPP", or " plant" where not snecified otherwise, all mean the Shearon Harris Wuclear Power Plant.

" Applicants" means all of the persons, emoloyees, consultants, contractors and cornorations as listed in the first sentence of the second paragraph on page 1 of this document, above.

"FSAR" means the Harris Final Safety Analysis 'ecort.

"ER" means the Harris Environmental Penort.

t rue, i

" Document @" means all writings end records of ever7 including electronic and ermnuter records, in the nossession, control or custody of Annlicants or any individual (s) acting on Ay{licarts' behalf, including, but not linited to: venorts , books , memoranda, corresnondence, notes, ninutes, (panphlets, leaflets, magazines, articles, surveys, maps, bulletins, shotogranhs, sneeches, transcripts,

. 3 voice recordings, com7 uter Drintouts, information stored in computers or connuter peripheral devices such as disks, drums, etc. , voice recordings, microfilm, Microfiche and all other writings or scordings of any kind (s); and cocies of any of the preceding even though the original (s) are not in the possession of Applicants or in their custody or control. Document (s) shall be deemed to be within the any control of Aplicants or individual's) acting on their behalf ossession, or custody of the document (s) if they have ownership, or a ce{y thereof,- or have the right to secure the docutnent(s) of a copy thereof, from any person or public or rivate entit7 having ph7sical possession thereof.

Epch definitton given above a lies within all other definitions above. '

GSNE$AG INT &kObAY G1 (a) Yhich contentiens of Wells Eddleman do Applicants agree

! are now admitted in this croceeding, NSC Dockets 50-400/k010.L.?

(b) for each such contentien, provide for any answers to interrog-stories by Wells Eddleman which Aeolicants have previously or uresently received (except those suspended by Board order, if any), the following information:

(c) Please state the name, present or last known address, and uresent or last known emuloyer of each person whom Acelicants believe or know (1) has first-hand knowledge of the facts alleged in each such l

l answer; or (2) uuon whom Applicants relied ( other than their l

attorneys) in making such answer.

(d) elease identify all facts concernin8 which each such nerson idenHfied in resconse to G1(c)(1) above has first-hand knowledge. <

(e)pleaseidentifyallfactsand/ordocumentsuponwhicheach nerson identified in response to G1(c)(2) above relied in pro #iding informationtorespondtotheinterrogatory,includingtheparts i

of such documents relied ueon.

tv ftl(tA Q licants (f) Please identify any other document (s) used/by A in responding to the interrogato=y.

(g) Please state which specific fact each document, identified in resconse to G1(e) and 01(f) above, sunports, in the ceinion er

. belief of Acelicants, or which Aonlicants allege such document supeorts.

(h) Please state specifically what information each eerson identified in resnonse to G1(c)(1) or G1(c)(2) above trovided to or for Anplicants' affiant in answering the interrogatory. If any of this information is rot docunented, clease identify it as "undocunented" in resnonding to this sect".on of General InterrcFato=y Gl.

l G2.{a)*1easestatethename,presentorlastknownaddress, title (if any), and cresent or last known syloyer, and econonic interest (shareholder, bondholder, contractor, owlo7ee, etc. ) if f or other any (beyond exnert witness fees) such verson holds in Applicants or excect t

of an7 of them, for . each eerson you intendj o ce.11 as an . exeert witness or a witness in this proceeding, if such information has not vreviously been supnlied, or has changed since such information was last sueplied, to Wells Eddleman. This applies to Eddlenen by Aorlicants.

and Joint o~ t culated (b).Contentions M.ekse identify as admikted'nteEtfon eac co regardire 'which each such person is expected to testify.

(c) Please state when you first contacted each such verson with regard to the possibility of such norson's testifying for l

Apelicants, if you have contacted such corson.

(d) Please state the subject matter, separately for each contention as be which each such person is expected to testify, whicheachsuchpersonisexpectedtotestifyto.

(e) Please identify all docunents or earts thereof unon which each such witness is expected to, nians to, or will rely, in testifying or in preparing testimony.

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5 03(a)' Please identify any other souwee(s) of information which Applicants have used to resnond to any interrogatory identified

, under 01 above, stating for each such source the interrogatory to which it relates, and what information it provides, and identifying where in such source that information is to be found.

(b) Please identify any other sourceh)of information not urev$cusly identified upon which any witness identified under G2 above, or or exhibits other witness, has used in urenaring testinenp/, or exnects to use in testimony or exhibits, identifying for each such source the

! witness who is exoected to use it, and the nart or part(s) of such l

l soLece (if applicable) which are expected to be used, and, if not

! (or both) ureviously stated, the f act(s) or subject matter to which such source relates, and which Gh(a) please identify all documents,guages or sections thereof Applicants intand on expect to use in cross-examination of any witness I call in this hearing. For each such witness, please crovide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject natter Aeolicants believe they relate to, and nake the document (s) availabhe for insoection form intent and cocying as soon as possible after Applicants decide o'rjtuimmi to use such document in crosc-examination.

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

G5 (a) for each contention Apolicants state or admit is an ad itted Eddleman contention under G1(a) above, or an admitted joint intervenor contention, please state whether Aeplicants l have available to them experts, and information, on the subject natter of the contention.

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

-5A-G-6(a) for each document identified in resnonse to any interrogatory herein, or referenced in response to any interrogatory herein, please supply all the following information which has not already been supolied:

(1) date of the document (ii) title or identification of document (iii) all authors of the document, o= the author (iv) all qualifications (professional, technical) of each author of the document of the document, (v) the specific parts, sections or pages, if any, unon which Aunlicants rely (vi) the specific information each cart, section or cage identified in resnonse to (v) above contains.

(vii) identify all documents used in orecarinF the docunent, to the extent known (and also to the extent not identified in the docunent itself)

(viii) state whether Auplicants possess a co-y of the doc ument (ix) state all exnert ouiniors contained in the document, upon which Acolicants rely, or identify each such opinion.

(x) identify the contention (s) with resnect to which Ann 1? cants rely upon (a) the expert ouinions (b) the facts identified with-l Ann in the docunent (xi) state whether Apolicants now ennley any author (s) of the document, identifying each such person for each document.

l (xii) state whether Auplicants have ever emoleyed any authdis) of the document, identifying each such nerson for each document.

(xiii) identify all sources of data used in the document.

Answers to all the above may be tabulated or grouped for efficiency.

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. G-7(a) ylease: identify all documents which Applicants plan, oxnect or a 1

intend to offer as exhibits (other than for cross-examination) with respect to each Eddleman contention admitted in this proceeding which (1) is included in your current resnonse to 01(a), or (ii) is the subject of interrogatories in this set; please state for which contention or contentions each exhibit will be or is exnected to be offered.

(b) Please identify all documents which Auplicants nian, expect or intend to use in cross-examination of any other perties' witnesses or joint intervenor witness in this proceeding, with resnect I

to (1) Eddleman contentions identified under G-7(a)(i) (or G1-(e))

above, or any other Eddleman contention which is the subject of inter-rogatories in this set; (ii) each Joint contention now adnitted in this proceeding; (iii) per our agreement of h-8-83, each contention l

of each other party to this proceeding which is cu=rently admitted.

Please identify for each such document the witnesses, or witness, and all contentions with resnect to whom (or which) that document is planned, expected, or intended to be offered or used.

(c) Please identify which of the documents identifkd in response (1) to (b) above will be offerad into evidence by Anulicants, and (ii) which of the same documents Anolicants expect to offer into evidence or intend to offer as evidence or exhibits in this oroceeding.

G8 (a) Please identify, for each Eddleman contention which !s the subject of this or an earlier set of interrogatories, all inforna-tion not previously identified which was (1) used or relied on in f preparation of Auplicants' responses to that contention and all contentions superseded by it (per transcript of July 1982 soecial prehearing conference, the Board's Sentenber 1982 order adn'ttting Or andrWise contentions, or stipulation by Applicants or W.E/), with respect to any facts alleged therein, identifying for each such fact the specific source (s) of information used or relied upon.

G-8(b) Please identify all persons who supplied information relied on or used in Applicants' response to each contention for which information a

is requested in G -8(a) above. (ii) Please identify for each such person what information was supplied, and with respect to which conten-each iten of tion (s) khak information supplied was used. (iii) Please state all known qualifications of each such verson with respect to the subject matter of the maakankiam each contention for which that person supolied information.

j l G-9(a)Please identify all information not identified in resnonse to the above general interrogatories, including all documents, which Applicantsrelyonorftendtouseinmakingtheircaseorcarrying their burden of proof in this proceeding, ..._. .

with respect (1) to each Eddleman contentien which is the subject of this or an earlier i

set of Eddleman interrogatories to Anolicants; (ii) with resnect to each joint contention on which discovery is now open under the Snard's March 1983 order, or on which discovery has been open under said order establishing a discovery schedule. (The ehrase "or on which discovery has been onen" is intended to keep this interrogatory current and continuing for information and documents which Auplicants rely on or fo*m intent to use af ter the formal close of discovery.

i I interpret Apolicants' continuing interrogatories to menly continuously from their date of subnission to me, and I intend these to anply likewise.)

MS/of specific (U{wrvjahna.s be[op#

G-10(a ) Where the above generh1 interrogatories , or any of then, l call for identification of docunents, (i) and no documents are identified, is that the sane as Apnlicants stating that there i

are no documents resnonsive to this general interrogatory, in each

! case where no documents are identified? (ii) and documents a_re ,

identified, is that the same as Annlicants stating that the identified

- - _ - - - _- -_ - .- -- - - - - - L _ .-._ - - _ _ - ___ --.

documents are the only ones presently known which are responsive to the interrogatories ? (iii) If your answer to G-10(a)(ii) is other than affirmative, please state all reasons for your answer.

(iv) If your answer to G-10(a)(1) above is other than affirmative, please state all reasons for your answer.

(b) Where any interrogatory, general or specific, herein, calls for factual information (i) and an opinion is stated in resnonse, is that the exnert opinion of any person (s) identified as having contributed information to that resnonce? (ii) and facts are given or identified (or a fact is) in resnonse, but no decaments are identified, t

does that mean Applicants have no documents containing such fact (s)?

(iii) If your answer to (i) above is affirmative, please state for each each such resnonse all qualifications of - expert upon whom b

Applicants rely for each such answer. The qualifications need be stated only once for each such person if they are clearly referenced in other answers. (iv) if your answer to (i) above is other than affirmative, please state which oninions, if any, given in response to interrogatories (general or snecific) herein i

is the opinion of an expert, identify each expert whose oninion f

you used in resnonse to each interrogatory, and state in full the i

qualifications of each such expert. (v/ If your answer to (1) above is other than affirnative, please identify all opiniens of non-experts used in your resconses, and identify each non-(

expert whose oninion is included in each answer herein.

i (vi) If your response to (ii) above is other than affirmative, please identify each document which contains a fact not previously documented in your resnonse(s), stating what the fact is, and at

f. what page, place, chapter or other specific nart the document contains such fact.

l:. -9 Further interrogatories on Eddleman 29 and 37B (this ends 2d round);

• filing of these on 20 July 1983 (and filing of Anplicants ' 2d round to me on the same interrogatories on the same date) was agreed upon with Apolicants counsel Baxter.

29-9(a) In your response'to interrogatory 29y1(b) (your j- - I+sponse at page 16),' you say offsite environnental air samplers

"'are changed once per week". (1) Does this mean once every seven days?

(ii) if not exactly every seven days, does your statement mean that each such sampler is changed at least once in each calendar week?

4 (iii) If your answers to (i) and (ii) above are other than affirmative, please describe the. schedule of changes in sufficient detail to predict the next change of a given samuler if one knows p its last change date. (b) In the same response (p, 16) you say .

"the sanples are read at the time of changing through laboratory analysis of the samples obtained." (QIbes this mean that the lab analysis is made on the spot immediately after the samoles are

! changed? (ii) please describe in detail (aa) any time limits of schedules for

! returning samplers to the laboratory, for performing _ analysis of each sanpler for radiciodines, and whether the analysis done l'

also involves any other tests done before testing for radiciodines; i (bb) what happens if a sannler is not changed on schedule, including when it will be changed, and when its sample will be analyzed (cc) exactly what analytical prodcedures are done for each sample, what readings are taken from each sanple, and what measures are taken to avoid contamination of sanples with I radiciodine of other isotopes (cc-a) between the sampler and the laboratory (cc-b) in the laboratory prior to reading (cc-c) in the laboratory after reading.

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'(dd) identify all documents containing the '" established and approved operations procedures for SENPP" for such changing and analysis (your response at 16, re 29-1(b)). Please soecify which procedures apply to samples to be read for radiciodines, or state that all the procedures apply.

(ee) please answer all parts of interrogatory 29-1(c) for the offsite environmental samplers which you identify in response to 29-1(b) (See resconse at 16, including reprint of the interroga-tory at 16-17)

(ff) What account, if any, is taken of the halflife of Iodine-131 in (ff-a) making readings of samples (ff-b) taking samples (ff-c) interpreting the readings fron samples (ff-d) comparing the readings from samples with known dates and times of radiciodine releases, .

according to SHNPP's " established and approved overations procedures" 4

and (ff-e) according to any other plans of Auplicants for Harris?

(c) please identify all acceptaned criteria for equienent connosing the analytical systen used at Harris for radioiodines (your response to 29-1(c) at 17); please identify all documents containing such l

criteria, and state to which part of the equip _ ment each such criterion applies.

. (d) please identify the specific "NBS traceable standards",

the " factor for each dry gas meter", the " quality control program" and the calibration procedure for (1) the Kurz nass flow meter (ii) the connuter-based gamma radiation spectroneter, and the " control each limits" for that system. and all docunents containing Eny of these or a description of it, isisk (all in your resnonse to 29-1(c) at page 17 ) . Please also state exactly the calibration procedure (s) used for each such item of equipment, the frequency of such calibration, and the maximum error allowed for each such item

and how that error is neasured and how (if at all) Applicants have determined it to be an acceptable anount of error.

(e) Please identify which criteria are' selected and established by the environmental laboratory supervisor (your resconse to 29-1(c) at 18), for what equipment, and state for each criterion (am 1) the basis for its selection, and (ii) the basis for its establishnent, identify the environmental laboratory sunervisor who established it, state all criteria established by or for such supervisor for selection and establishment of criteria for'the accentance criteria for the equipment in the SHNPP analytical system. Please give detailed information as to each criterion used that affects or can affect the accuracy of analysis of samples for radiciodines.

(f) please identify each radioiodine isotone SNNPP will sanole for, and the epecific samplying procedures used fohuds each isotone.

O

. For each isotope for which you have determined a maximum error (1) in the sampling procedure (ii) between the concentration present in the environnent and the result of the sampling procedure, please state that error (in percent or amount, if Apelicable ) and state exactly how it was derived, including all equations, calculations and assumptions you used. Please also 1

state who derived the error eatinate, when, and what qualifications each such person had to derive that estinate.

(g) (refers-to 29-1(d), your response at 18). For each radioiodine l

monitor, sampler, sannling device, or detector or detection device to be used at SHNPP, please state (1) whether Applicants have ida independently deternined the accuracy of it (ii) vhether Applicants l know if anyone else, such as the National Bureau of Standards, the manufacturer, the supulier, or others has independently l

determined the accuracy of it (iii) for all affirnative resnonses to (ii) above, please identify who nade the deternination, and when if known. (iv) for each such determination of accuracy, nlease state exactly how the test was done, what the accentance criteria were, when the test was done, whether the accentance criteria were established (aa)before (bb)after (ce)during the test, the nethod(s) of the test, mil the identity of all documents which include (dd) the test procedure (ee) the test results (ff) reprint or sunmary of test results, the identity of the person (s) who conducted the test, all qualifications of each such person to conduct such test, the identity of the person (s) who set the acceptance criteria for each such test, and all qualifications of each such person to establish such criteria, the linits of accuracy of the test itself, if any, and how such linits were deternined (stating in detail the basis, equations and calculations used to nake such deternination, and any assunntions used therein),

what radioactive naterial was used in the test, what radioiodine l isotopes were used in the test, how the radioiodine cresent I

was assayed or determined (other than by used of the device being tested), the linits of accuracy of such assay or deternination, and any deviation (s) from test procedures that actually occurred during the test. This entire part anplies not just to devices actually to be installed at SHNPP, but also to identical devices and nodels which nay have been tested.

(h) If "cbntanination" in interrogatory 29-1(e) (your response at 18) were defined as"any buildun or introduction of radioactivity" would that change your answer to that interrogatory? If so, please say how the response would change.

29-10 (a) In your resnonse to interrogatory 29-1(g) (response at 20) you say that the requested information "on in-plant monitors is not available in the form requested by the intervenor". Please identify the document (s) if any, which contain the (1) model number (ii) type (iii) manufacturer (iv) cost and (v) whether the monitor is in the possession of Apnlicants or its subcontractors or any of them, for each in4 plant radioiodine monitor at Harris or to be used at Harris. (b) Is there any information in any subcart of .(a) above that Applicants do not kncw? Please state which subnart(s)

(e.g. model number, type, nfr., cost, whether nossessed) for any affirnative response.

29-1 Please answer parts (bb) and (cc) of interrogatory 29-1(h),

response acpears to be missing on uages 21-22 of your response.

(b) please state exactly how the'radiologica}bonitoring systen "

can" account for all radioactive releases (including radioiodine) i to the atmosphere" (your resnonse to 29-1(ah) at 21-22 given that you are not able (resnonse at 21) to sannle the atmospheric j steam duma valves, the steam generator relief valves, the PORVs, and the AF'd pump.

(c) Please describe the radiciodine sampling of the condenser i

! vacuun punp effluent in detail, including the instrument (s) used, x whether monitoring is internittent or continuous, how you know g

when thete is a release from the condenser vacuum pump effluent, all reliability testing of the sampling, the accuracy of the sannling as representative of the condenser vacuum pump effluent, all basis for such accuracy including all calculations and assumptions used l

l to derive it, the method of displaying and of storing the information from such samuling, when such samnles will be taken, on what schedule, and wnen and how they will be analyzed for radiciodines, including any time limit af ter sannling for getting the analysis done (i.e. how long after sannling is analysis done)?

29-11 (a) Do Aunlicants know if the radiciodine control systems and samuling/ monitoring systems of the VC Summer nuclear plant are similar to those at Harris? (b) Please describe the known plants' differences between the two systems with respect to radiciodine release points, control of radioiodine levels in effluents, and sampling, monitoring and testing for re -lioiodines. (c ) Do We Auplicants agree that VC Summer is a clant of Eastinghouse design (PWR) of about 900 MWe and 2775 MWt, much like Harris in these respects? (d) Do Applicants agree that their FSAR says VC Summer and Harris are very similar plants and connares them at sone length?

which is (e) for any answer other than affirmative to (c) or (d) above, niease state in detail all basis for each such answer.

29-12(a) Concerning your answer to 29-1-k (v) and (vi) (your response at 25), do Applicants know whether NQC Staff agrees with their position (1) that direct measurement of radiciodine levels in animal thyroids is inanoronriate (ii) as to effluent release monitoring and sannling backed un by environmental monitoring (not including animal thyroids) and emnloyee whole r body couhting programs provides "the most sensitive surveillance" for potential public exposure to radiciodine? (b) Do Applicants believe that sampling of animal thyroids is inanoropriate for environmental radiciodine monitoring? (c) Do Applicants believe any NRC rule or policy forbids sampling of animal thyroids around nuclear plants as part of environmental monitoring?

(d) please state in detail all basis for your answer to (1): (b) above, and (ii): (c) above.

29-13(a) with respect to radioiodine source terms for (i) liquids and (ii) gases at SHNPP, what acccunt was taken of (aa) abnormal cuerations (bb) accidents (cc) Class VII accidents (dd) Class VIII

accidents (ee) Class IX accidents (ff) sabotage (gg) failures Hof the radwaste processing systems (ghh) failures of radioiodine monitoring, in calculating these source terms as described in your answer to interrogatory 29-1(p) (response at 27-28).

If the answer is different for one source tern, please so state and answer for both separately (gaseous and liquid) unless the

. answer is the same for both.

29-1)(a) please state in detail exactly how you (1) measure dose to individual organs (e.g. thyroid) around Harris, (ii) measure total body doses to indivniduals around Harris, (iii) calculate from any information you have or will collect (specify what information you use and how you will get it) each of the doses identified en page 30 of your resnonse to interrogatory 29-1(q), specifically (answer for all 3 subnarts above)

(aa) gaseous effluent dose quarterly limit "a" (bb) gaseous effluent quarterly limit 1"b" (cc) liquid releases quarterly limit "a" to whole body (dd) liquid releases quarterly limit "a" to any organ (ee) liquid releases quarterly limit "b" to total body (ff) liquid releases quarniterly limit "b" to any organ.

Please use in the resnonses correct limits, since there may be typos (e.g. in liquid "a" $ ren is used, but 1.5 mren; in liquid 1

"b" the same things are limited, but to different values -- these may be for all nuclides, and the others for radiciodines. Please clarify or correct that resconse as necessary before answering the above.)

i 29-15(a) Do Auplicants agree (see your resnonse at 32) that radio-iodines can and do form by decay of other nuclides which may be released into the environment? (b) Please list all radioiodine

isotones that can be formed by decay of any fission product (s),

listing for each all of its potential parent elements; or give a reference (identify the document, pages or parts) from which w

this information is available. Please state 2hich of the requested data in "this paragranh of the interrogatory"( your response at

~

33) is included in Lederer and Hollander's Tables of Isotones.

Please state whether this dodument has yet been nroduced to intervenor.

(

29-16(a) Do, Applicants know if any of the analyses inquired about in interrogatory 29-1(t) have been performed by the vendor (s) of any components identified in resnonse to interrogatory 29-1(s)? (b) If answer to (a) is affirnative, niease identify i each such connonent, its vendor, and which of the tests or analysis have been performed by that vendor on that connonent.

l (c) niease state which (i) design basis (ii) conditions (iii) performance criteria were specified by Apolicants for each such component identified in resnonse to interrogatory 29-1(s).

Please. state exactly what specifications were used to the vendor, for each such component (where answer is same for an identifiable group of components, please so state).

(d) please identify each NRC requirement each (1) design basis (ii) condition or set of conditions (iii) performance criterion specified by Applicants, for each connonent identified in resnonse to 29-1(s), is designed to meet. Please state all basis that it does meet or contribute to meeting that NRC requirement.

(e) please identify each anplicable performance standard or functional requirenent (see your response at 37) which each f (1) design basis (ii) condition or set of conditions (iii) performance criterion identified above is to meet, and all basis 1

for Applicants' belief that it does neet it (for each). If it does not meet it, so state.

29-17. In response to interrogatory 29-2(g), you state Applicants compared on-site meteorological data with information from the -

Raleigh-Durham airport and other cooperative weather stations in the area-(ref. FSA9 section 2 3) "to assure that the collected l onsite data is representative of the collected onsite data".

l (Ref your response, p.40). Was a line omitted from this nart of I your resoonse, or some other error nade in it? If so, niease i

provide a corrected resconse. (b) what does the statement quoted above mean? (de) what did you use the RDU airnort data for, when you compared it with Harris olant site data? (d) was the l

l data from other cooperative weather stations used in the same way as RDU airport data, in comnarison with SHNPP data? If not, what use was made of it?

(e) why were low-level meteorological data only used in connuting I

dispersion from SENPP? Please state in detail all reasons for l

your answer, all sunporting documentation and opinions of exnerts.

l l

(f) Do dispersion estinates for radioiodines from SHNPP take account of-rainout? Of precipitation in genneral? Of nrecinitation of any type (please list.each such type). (g) For all affirmative answers to any part(s) of (f) above, please state in detail, with equations, assumptions, calculations, and authorities therefor, how the model takes account of each form of orecinitation for which

-your answer in (t.f) above was affirmative.

l t __

29-18 (refers to your answer to 29-3(e) on pages kh-45 of your response): (a) Are there any radiciodine release rathways (i) to atmosphere (ii) to cooling tower blowdown (iii) to the Harris reservoir, which can occur when the Harris plant is not operating under normal conditions? (b) please identify each such release pathway for which Auplicants (i) have nerformed any analysis or study (ii) have not perforned any analysis or study.

29-19 (a) Have Applicants or anyone else you know of Performed any study of the denosition of radioiodines on tobacco leaves (including the hairs thereof)/? (b) If so, please identify each such study and all documents containing it. (c) Have Apnlicants xam considered or studied radioicdine exuosure to tobacco workers (1) in the fields (ii) in warehouses (iii) in cigarette or cigar manufacturing? If so, niease identify each cuch study and to which groups of workers it anplies, identifying all documents in which each such study is contained. (d) Is tobacco analyzed for radioiodine content in the Harris environmental nonitoring program? If not, why not? (e) Have Annlicants'or anvene else l

you know of made any study of radiciodine effects on snokers, i

due to radiciodine in tobacco, or due to smoking conbined with exuosure to radiciodine in air? If so, niease identify each such study and all documents containing it.

you give a l

29-19(a)Inyourresnonseat46-h7(re29-3(f),10,000to1:

partition coefficient between water and air as l (1) is this ratio correctly described as a nartition coefficient?

If not, please give the term for it. (ii) Where do you get this ratio of 10,000 to 1 (water to air) for radioiodines? Please identify all documents which you rely on for this number, and

[ describe in detail (or reference snecifically) how it is calculated l and give all data and assumptions used in such calculation. (iii) l Is the ratio of 10,000 to 1 (water to air) the same for all radio-iodine isotopes? ' Please give detailed reasons and references for your answer, includin identification of 11 do opinions, calculations an assumptions you re$y on $umenhlhg n ma your answer.

l

29-20 (a) please identify each . document, computer run, worknaper or other document (including electronic records, comnuter data) which you used in actually calculating the radioiodine source term for (i) gaseous (ii)1iquid releases from Harris. (b) what onerating conditions did you assume in making each calculation asked about in (a) above? Please specify all such conditions, e.g. filter efficiency, sensitivity of nonitors/ detectors, radiciodine levels in coolaf, radiciodine levels in containment atmosphere, percent or amount of failed fuel rods, efficiency of liquid waste-processing steps in renoving radioiodines, etc.,

which are used or apoly in making each such calculation.

(c) Have Apnlicants analyzed or collected any data on the percent or amount of the time that other nuclear plants in operation actually do meet each condition accumed in your calculation for Harris? (d) If answer to (c) is affirmative, please identify all documents which contain such data, state for each what data it contains, and whether Anplicants have used that data in any analysis or comnarison or review of their source term (s) for Harris radiciodine releases, giving which source term it was used for.

29-21 (refers to answer to 29-3(o)(iv) at nage h9 of your rennonse)

(a) Please sunplement your answer to interrogatory 29-3(o)(iv) to state what "connonly accepted engineering principles" were used in ma king this calculation. (b) Please state exactly how the calculation was made, including all equations, assumntions and principles used in making it. Your answer should be sufficiently detailed to. enable duplication of the calculation. (c) Has CP&L made available the Ebasco calculation file referred to in your resnonse to 29-3(o)(iii) for inspection and copying? When?

Where? (d) Please identify which specific calculation file is' referred to in your answer to 29-3(o)(iii).

29-22(a) Do the statements about " normal oneration" given in response to interrogatories 29-h(a) through (g) annly to your calculation of the radiciodine source terns'for Harris?

(b) If answer to (a) above is other than affirmative, niease identify each source term for which " normal oneration" is defined or taken as different, and exclain in detail each difference with each answer (to 29-h(a) through (4)) for each such source term. (c) In your resnonse to 29-h(f) (resp. at 53) you say"there is no nrinary to secondary leakage value which is considered to be normal operation". (i) do you consider operation outside the Technical Snecifications (TS) for Harris re crimary to secondary leakage to be nornal cueration? Please give all reasons for your answer and all facts which you believe support it.

(ii) Given that there are 3 steam generators at Harris, do the Technical Specifications in fact allow 1500 gallons ner day primary to secondary leakage for Harris? Please anakiin explain your answer and cite all documents and opinions you rely on in making it.

(iii) What is the maximum total prinary to secondary leakage (through all nathways) that Harris is allowed to have and still (aa) continue operation (bb) continue eneration at full power (cc) continue oneration at a reduced nower level -- please snecify that level (dd) continue to increase nower level; all under Please your technical identify specs each such for Harris nrocedure andorwhat annlicable nr)ocedures.

resnonse(s it annlies to and how it affects such resnonse, in this sumbpart (iii) .

1 29-23(a) In your response to interrogatory 29-4(h) (reso. at ,5h)

- you _ use the tern "1.0 microcurie per gram dose equivalent I-13TS .

Please define this term in more detail. (b) Does the term quoted

, in (a) above mean "enough I-131 to give a dose equivalent to 1 nicrocurie (from radiciodine) per gram of primary coolant. "?

(c) Does the term quoted in-(a) above mean "enough I-131 to produce a dose equivalent to 1.0 microcurie, ner gram of exnosed material"? (d) If your answer to (b) or (c) above is other than affirmative, please exclain your answer and the reason (s) for it in detail. (e) How of ten is the I-131 content of primary coolant to be sampled at Harris? Please give any applicable schedule (s).

(f)Is every. sample of primary coolan' to be tested for I-131? If not, which ones will be? (g) Is there any radiciodine isotone other than 'I-131 for which there is any limit in primary coolant at Harris j in light of your answers to interrogatories 29-h(h),(j),(k)?

(h) If answer to (g) is affirmative, identify each such' isotope and the applicable limit. (j) In your answer to 29-4(n) (response at 56) you say there are limited conditions for oneration which are placed on the actuni coolant concentration: (1) is this a concentration of (aa) I-131 (bb) any other radioiodine isotones (nlease list each such)?; (ii) exactly what limi ted conditions for operation are imposed, and what levels of each radiciodine isotone inquired of in (i) above triggers or requires each such condition?

Please identify all documents which contain this information, and state whether the linited conditions for oneration are part of l the Harris tech specs (if not all are, which are?). (iii)'is i

" limited conditions for operation" the same as an "LC0" or a "liniting condition for operation"? Which?. (k) Is the Harris plant procedure for (1) determining values of fuel defects (ii) determining coolant concentration for radiciodine(s) (iii) correlating fuel defects and coolant concentrations (aa) for radiciodines (bb) for any nuclides or nuclide, written yet? Please identify each such nrocedure and all documents containing it. (1) Is a i procedure of conearing known fuel defects to prinary coolant fission nroduc t inventory used at the H.B. Robinson nuclear plant?

(m) If resnonse to (1) above is affirmative, niease identify this procedure and all documents containing (i) the urocedure (ii) the method used at Robinson for finding defects in fuel (iii) the nethod used at Robinson for enumerating the defects in fuel rods (iv) the nethod used at Robinson for determining radionuclide levels in primary coolant. (n) Is there any linit at all for

• Harris on the fuel cladding defect fraction? (o) Is there any limit for Brunswick on the fuel cladding defect fraction? (p)

If resconse to (o) is affirmative, was such limit innosed by NRC Staff (1) in early 1979 (ii) at any other time? .(q) what method (s) were used at Brunswick to insoect fuel for defects urior to loading it into the core (i) between 1974 and 1979 (ii) between 1974 and the present? (r) How do the methods for inspection of fuel for defects at (i) Robinson (ii) Marris differ from the methods used at Brunswick? (s) Do Applicants agree that their fuel cladding %

defect fraction at Brunswick has been as high as (or above) (1) 1 (11)2% (iii) 5% (iv) 10% (v) 13% (vi) 15% (vii) 17% (viii) 20%

(ix) 22%-(x) 25% (xi) 27% (xii)29% (xiii) 30% (xiv) 33% (xv) 35%

at Brunswick. (t) Have Apelicants ever had to (1) redued nower (ii) shut down (iii) remove fuel at Brunswick due to excess failed * ' '

fue,1 or due to radioactive releases due to failed fuel rods?

l

4

. 29-23 continued .

(u) Please specify the time and cause of each such instance of (1) power reduction (ii) shutdown (iii) fuel renoval at Brunswick due to (aa) excess failed fuel (bb) failed fuel levels (cc) radioactive releases due to failed fuel (dd) NFC requirements or restrictions related to failed f uel.

(v) In what respects other than insnection of new -fuel pre-loading, do orocedures for Brunswick.and Harris re failed fuel differ?

- Please list each such and explain it.

(w) Is .there any way to be certain of the amount of fuel cladding in a given bundle of fuel for Harris that will beco$e defective, which' can be used prior to loading of fuel into the Harris reactor?

'(x) If answer to (w) is affirmative,.nlease describe the method in detail' and state why (if at all) it w ould not be annlicable to testing fuel used at. Brunswick, arm before loading fuel there.

(y) Please identify all docunents containing information requested in (x) above, including any documents as to why such testing nethod

is not used at Brunswick, description.of das method, results of

'its use.

(z) Can Applicants specify any. maximum fuel cladding failure feraction for Harris (1) as a snecification in nurchasing nuclear fuel for it (ii) for operation? If so, please give all details

of each such-specification.

29-24(a) Please supolenent your answer to interrogatory 29-5

- by identifying which-(i) industry standards (ii) guidance from the URC in which regulatory guides, is used in the (aa) design -

(bb) manufacturing (cc) testing, and will be used Der prodcedure '

. or commitment in (dd) operation'of Harris, forLthe items of equipment asked about in 29-5(a). (b) Have Applicants verified

, compliance with any suchTptandard (ii) guidance fron NRC, for any I (aa) nanufacturer (bb) designer (cc) test or tester, of any equinnent inquired about in Interrogatory 29-5(a), i.e. radiciodine filters,

traps and other conconent intended or expected to remove radiciodines

, from Harris effluents, ? (c) For e'ach affirmative answer to each subpart of (b) above, niease list each such verification, who did it, l

when, by what method, and identify all documents showing such verification, its medhod, or data or information verifying such comoliance.

! 29-25(a) re your resnonse'to 29-6(f)(iii)(x) at page 63, please supnlenent your answer to state what historical data, from what i plants or other sites, Annlicants used in. determining the normal and abnormal range of environnental conditions nostulated to l . occur at the "anuropriate equinment locations", and explain how this data was used in postulating such ranges, including all j calculations made in such nostulations. (b) Do Apnlicants know the (iii) ' component manufacturers (iv) connonent dimensions (xiii) j design life (xiv) replacement schedule (xv) personne1~ exposures i- (xvi) internal and external radiation exoosures (fron replacement of equipment, as is (xv)) for each component inquired about in interrogatory 29-6(f)? (subpart numbers from 29-6(f) are used here ,

, in this part (b) for easy ~ reference) (c) Please supplement your '

answer to 29-6(f) with an answer to subparts (xvii) and (xviii) 4

- to identify the documents containing failure rates estimated by

, vendors of this equipment. (d) Please identify the vendor-esperrogatory 29-6(f) and state the rateimated failure rate for each item of .

29-26(a) Please explain fully why you think (iii) component

. manufacturers (iv) component dimensions (xiii) design life (xiv) replacement schedule (for components) and (xv) radiation exposure to persons replacing such conoonents,and (xvi) internal and external radiation dosse to persons reolacing such comoonents, are irrelevant to Eddleman Contention 29 for discovery nurposes. (b) Do you believe or contend that any of the above itens (all of which apnly to components used to control radiciodine releases from the ulant (Harris)) are information which cannot lead to adnissible evidence re Eddleman 29?

(c) If answer to (b) above is affirmative, please state the basis for your belief for each item in (a) above to which that belief applies. Please explain the basis for anything you " contend" in the same way you are asked to explain the basis of your beliefs.

29-27(a) Is it true that the " minimum configuration of radiciodine trapping, absorbing and filterir.g devices at Harris which is allowed during normal operation" is, none? (b) If response to (a) above is other than affirmative, clease explain in detail how your answer is consistent with resnonse to 29-7(a) on pages 63-6k of your response. (c) What is the mininum operable configuration of the gaseous radwaste treatment systen at Harris under which normal operation of the nlant is allowed? (d) Is there any technical specification for Harris with resueet to ability to trap or absorb radiciodines before they are released to the environment? (e) If answer to (d) is affirmative, please list each such technical specification and identify all documents containing each. (f) Is~ there any limiting condition for oneration or LCO for Harris at present (or oresently written) which involves (1) radiciodine releases as measured at release noints (ii) radio-iodine present in the environment- (iii) radioiodine present in the thyroids of animals (iv) radiciodine uresent in the thyroidis of humans around the plant (v) radioiodine, excluding medical exposures, in thyroids of humans around the plant? (g) If answer to any part of (f) above is affirmative, for each such nart clease list the LCO or condition, the radioiodine level (s) involved in it, what part of (f) they apply to, and how they are measured, and identify all documents containing the LCO or condition or a its basis.

(h) What is the mininun operable configuration of the ventilation exhaust treatment system at Harris under which normal oneration of the olant (e.g. full power operation) is allowed? (j) What is the minimum operable congfiguration of the liquid radwaste treatment system at Harris under which normal coeration is allowed? (k) Please identify all documents giving the minimum configuration (s) inquired about in parts (c), (h) and (j) above, identifyinF which systen(s) they anply to. Please explain in d etail, including any calculations you have made, and all assumptions you use, what the radioiodine renoval capability of thana each such n.*nimun configuration is, how that capability is figured or arrived at by you, and how that capability ensure como11ance with (i)Section II.B of 10 CFR 50 App I, (ii)Section II.C thereof (iii)Section II.D thereof (iv) 10 CFR 50.36;a ,(v) 10 CFR 50.36(a) (vi) General Design Criterion 60 of 10 CFR $0 Appendix A. (1) For each part of your exulanation in resnonse to (k) above and its subparts (i) through (vi), please explain exactly how you assure compDance with each such reouirement, and identify a11 procedures you use to do so, and all docunents

, containing each such procedure.

29-27 continued for H arris (m) Has NRC . staff anproved compliance 2with all of the sections of 10 CFR $0 and its appendices cited by you in resnonse to Interrogatory 29-7(a) (and reproduced or. set forth in part (k) above)? (n) Please state which narts NRC has annroved comoliance with, if any. Please identify all documents in which NRC apnroval of such compliance is given, and for each such docunent, identify all CP&L documents NRC staff was given by Apulicants for making such determination. (o) Exactly what are the "annrop riate portions of these (gaseous radwaste and ventilation exhaust treatment 7 systens" to which you refer in your resnonse to 29-7(a) on nage 6h of your response? (p) Exactly how does each " appropriate nortion" of each such system limit radiciodines, and to what level does each such portion linit radioiodines passing uthrough it (or output i fron it)? (q) Which of the " appropriate portions" of each system is required to be onerable when the Harris plant is (i) operating at any power level above zero (ii) in hot standby (iii) in cold shutdown (iv) in hot shutdown (v) operating at full power (vi) operating at a specified nower level less than 100% as given by any LCO for the plant, including those identified in resnonse to parts (f) or (g) above? Please list each such nortion for each condition, identifying when the nortions required for more than one condition listed above-(i) thru (vi) --are the same (r) Are any other parts of (1) the gaseous radwaste treatment system (ii) the liquid radwaste treatment systen (iii) the ventilation exhaust treatment system at Harris recuired to be operable when the plant is operating under any of the 6 conditions listed under (q) above as (i) thru (vi)? (s) Zf resnonse to (q) is affirmative, niease list each such cart, and the conditions or condition under which it is required to be onerable at Harris.

(t) On what schedule is thebsoperability (ii) functioning (iii) compliance with anplicable performance standards, to be verified for each connonent of the (aa) gaseous radwaste treatment system (bb) liquid radwaste treatment system (ce) ventilation exhaust treatment system, at Harris, which connonent is inv61ved in or necessary to the tranping, removal or isolation or reduction of radiciodines before they are released to the environment?

Please list the schedule for each.such connonent or identify

documents c ontaining this information.

(u) are any of the parts identified in resnonse to (r) above necessary to remove radiciodines at Harris? (v) For any affirmative j response to (u) above niease list each such cart and exnlain how it is necessary to removal of radiciodines at Harris (from effluents or streans going to effluents or to waste processing, filters etc).

Please identify all documents con taining information about how each such part (or all of then or some nortion(s) of taem) are l

needed to allow the removal of radioiodines. (e.g. blowers are needed to move the gaseous streams through the filters, ese document XXX)0 l

(w) Is there any verification identified in (or asked about inQ (t) above which would, if not made (i) require Harris to shut down (ii) require Harris to reduce power or come into a LCO (iii) require Harsis to go to hot standby within a certain time if not verified operable?

(x) please identify each verification for which your answer to any part of (w) above 'is or would be affirmative, and the condition (1 thru lii above, or other) which it requires to be imnosed on Harris if it has9 not been timely made or (ii) has not been made.

1 L, .

-2h-29-27 continued'

-(y) On what schedule is each component or "nortion" of systems i controlling radiciodine releases from Harris (including byThis tranning, removing, or diverting and holding them) to be replaced?

includes, but is not limited to, _connonents and connonents of

" portions" of _ such systems which you have identified in response to interrogatories above, and includes but is not limited to components of the liquid radwaste treatment system, air-handling system upstrean of the ventilation exhaust treaty.ent system or upstream of the gaseous radwaste treatment system, drains and components that contain radioniodines before they are fed into the liquid radwaste treatment system, components of the ventilation exhaust treatment systen, components of the gaseous radwaste f treatment system. You may answer.only for connenents that are necessary t o control radiciodine releases or are used in such control. Identification of documents giving this information will be acceptable if it is too extensive to readily usearch out.

However, if you have this information on a connuter, please i

search out as much of it as practicable and nroduce that infornation, i e.g. as a computer prihtout.

I (z) For each component inquired about in (y) above or identified in your response to (y) above, please give the schedule, if any (if none, sto state, please), for servicing of that connonent, stating all actions to be taken, all checks to be made, and the conditions (if known) under which renlacement would be required, for servicing that component.

(Note: This interrogatory expands on and specifies in more detail things I was asking about in interrogatory 29-7. Please feel free to contact me for clarification or other information re any of it.)

29-28(a) are the f aloor drains of the Harris containment nade of

! PVC7 (b) If answer to (a) is other than affirmative, what _are they made of? (c) what is the niping f ron the Harris containment sump to liquid radwaste -processing made of? (d) Have Apolicants made any study of embrittlement, cracking or deterioration of the material of (1) the Harris containment floor drains (ii) the piping from the Harris containment sump to liquid waste processing?

(e) Please give the results of, and identify all documents containing, any study inquired about in (d) above. (f) Do Annlicants believe that PVC pipe in the Harris containment floor drains will be exnosed to radioactivity? (g) Do Applicants believe that PVC in the Harris falcor drains nay crack or leak due to deterioration induced by exposure to radioactivity, e.g. gamma radiation, beta rays, alpha radiation? (h) Could radioactive material enten the Harris base mat if the PVC in the drains deteriorated and they leaked?

(j) Could radioactive material (including radiciodines) leak from-the piping _of the Harris containment drains under any other circumstances? (k) If material of Harris floor drains is not PVC, please answer (f),(g) and (h) above for the actual drain mater!al (instead of for PVC as they are written above). (m) Please state

' in full the basis for your answers to (f) through (k) above, stating i

the basis for each answer separately where the answer is not the same.

29-29(a) Do Apolicants know the chemical comnosition of (1)

Cohrlastic R-10480 Gr. Medlun Silicone Rubber (ii) the "self-extin-

- guishing rubber-based" naterial sealing most HEPA filters (iii) the " Fire Retardant Foam", referred to in your resnonse to 29-1(s)?

(see your resconse at 35)

-25.

29-29 continued (b) For each nart of (a) above for which your answer is affirmative please state (i) what polyner(s) if any are in the material, and what percent (by weight, or by volume, please specify, if known) of the material is connosed of each polymer (ii) the non-polyner connonents of the material (iii) the chemical connosition of each component of the material, or the chemical conposition of the material, as applicable.

(c) Are Applicants aware of any information concerning the (1) change in volume (e.g. swelling) (ii) em rfgtlengnt (iii) loss of tensile strength (iv) loss of elasticity oT (a"@fd@oprene (bb) closed cell urethane (ce) Cohrlastic R Oh80 silicone rubber (dd) the "self extinguishing rubber-based" material used in HEPA filter seals (nost of them) (ee) the " Fire 9etardant Foam" (ff) any other polymeric material, including PVC (gg) any other material, l

including steels or asbestos , which (any of which) is used in the seals or materials or gasketing of theSENPP radwaste systen which controls radiciodine emissions (or linits then or prevents them), due to any of the following: (gg) fire ;nh) heat (jj) ionizing radiation of any type (kk) gamma radiation (11) exnosure to lower-than-normal concentrations of oxygen (mm) exnosure to a combination of heat and iohizing radiation (nn) exposure to fire and ionizing radiation (oo) exnosure to lower-than-normal (below 21%) concentrations of oxygen in conjunction with either (ooo) ionizing radiation (oooo) heat (ooooo) fire (oooooo) cgnbustion products from fires; (pp) conbustion oroducts from fires .' Are you aware of (oq)' the document NUREG/CR 2157 (SAND 80-1796) (rr) studies of (rr-a) tensile strength (rr-b) elongation (rr-c) swelling (rr-d) degradation of polynebic material, (rr-e) in NUREG/CR-2157 (rr-f) in any other

, docunent (please identify each other docunent which contains any l such studies, stating what it studies each contains and which natter (s) asked about in vr-a thru rr-d above each includes); (ss) whether fire-retardant cross-linked polyolefin naterial is used in any seals, gaskets or other parts of the Harris radwaste systens exposed to or containing or processing radiciodines ?

Note: item (v) above reads "'elonga tion" .

l 29-30(a) Please state whether Anplicants believe that (1) reduced l tensile strenSth (ii) elongation (iii) embrittlement (iv) reduced l elasticity (v) oxidation (vI) cracking, of polymeric or nolyner-l containing materials used in (aa) seals (bb) gaskets (cc) other narts of systans at Harris containing radiciodines (e.g. gas-processing or filtering, liquid radwaste processing systems) could lead to leaks from those systens or carts of them? (b) for every subpart of (a) above for which your answer is other than affirmative, please state in detail the basis for your belief and identify all t documents and facts upon which you rely in naking your answer.

l (c) Please identify all information of which you are aware, which

! is responsive to each subpart of 29-29(c) above, stating for each

the subpart(s) to which it is responsive and what infornation it contains and where in the document that information is.

NOTE: 29-29 and 29-30 ask more about matters inquired into in interrogatory 29-8 previously. Apolicants' counsel asked for t more snecific questions on this.

29-31 If not already given lease state what information asked about in interrogatory 29-6(a is given in each document you identify in resnonse to 29-6(b) (see your resnonse at 58). Please either supplenent your answer to 29-6(b) or urovide the info here.

Interrogatories on Eddleman 37-B 37-B-5(a) Why haven't Applicants nade any estinate of increased incidence of any disease due to the operation of the Harris plant (and resulting radiation / radioactive material releases bo the environnent)? (b) Why do Applicants believe that I can research the information you possess which would be resnonsive to interrogatory 37-B-1(c)(a11 parts) and 37-B-1(d)? (c) Have Anplicants provided any docunents to Wells Eddleman so far that are responsive to

' interrogatory 37-B-1(cz, 'N1) or 37-B-1(d) ? (d) Please list each such document and state when made available, for documents inquired about in (c) above. (e) What other way (besides exanining documents in Auplicants' possession) would intervenor Eddlenan have to research the content of documents in the exossession of Applicants, (see your resnonse at page 68)? Please snecify each such other way, and indicate if this way ims presently available to Eddleman to your knowledge, and whether Apolicants would oppose or do oppose the use of that way by Edd1enan. (f) Exactly what infornation inquired about in Interrogatory 37-B-2(a) (see your response at 68-69) is , protected under the urovisions of 10 CFR 2.740(b)(2) in your view? Which provision (s) protect this information? Why?

(g) Do you contend that anything asked about in interrogatory 37-B-2(a) is work product (1) of attorneys (ii) of your experts or consultants (iii) of anyone else? (h) Which things asked about in interrogatory 37-B-2(a) are the work product of (1) anyone working for Aunlicants l

on this case (ii) attorneys (iii) experts (iv) other nersons?

(h) Have Applicants nade any analysis or study of the work of (1)

John Gofman (ii) K.Z. Morgan (iii) Dr. Rosalie Berte11 (iv) I.D.J. Bross et al, concerning the health effects of ionizing radiation (aa) as mentioned in contention 37-B (bb) as described in documents identified by Wells Eddleman in resnonse to Anplicants ' nrevious or continuin6 interrogatories? (j) If response to any nart of (h) above is affirnative, do you contend any of the analysis you have made is privileged? (k) Do you contend that the fact of whether

you have nade any analysis of the work inquired about in (h) above is privileged or protected information? (1) For any affirmative answer to (k) or (j) above, please state what information or study or analysis you contend is privileged, what you contend is nrotected, I and state fully the reasons why you believe each such iten of information i is (1) privileged (ii) protected, or both. (m) Do you contend, irrespective of your resnonse to (h) above, that your analysis of information provided by Wells Eddleman in resnonse to your interrogatories on 37-B, insofar as it regards factual matters and/or expert opinions concerning radiation health effects (not legal opinions or legal strategy), is orivileged or nbotected?

(n) If answer to (m) is affirnative, please state in full the basis for your answer, stating what information you believe is (1) protected (ii) privileged. (n) Are Ann 11 cants willing to (1) identify documents containing analysis inouired about in

(.;aa) (m) above; (bb) (h) above;(cc) 37-B-1(c) of the last set l of interrogatories on this contention (dd) 37-B-1(d) ibid ,

l available to Wells Eddleman for inspection and conying? (p) If answer to (n) is affirmative, pleasb list the docunents you will make available. (r) If answer to (o) above is other than affirnative for any docunent, please state all basis not already given in resnonse to the above interrogatories, for your anwer.

l

- 37-B-6(a) (This references your-responses to 37-B-3 and its carts, your response at 73) Do Apolicants believe that- the only kinds of-diseases " caused or enhanced" by radiation are stochastic

effects (i.e. cancer.and increased incidence of hereditary danage) and non-stochastic-(e.g. cataracts)? (b)If your answer to. (a) above is other than affirmative, please exclain its basis in detail and cite all references and opinions upon which you rely for 4

your answer. Please also. explain how-your answer is consistent with your previous resnonse_at page 71.'(c) Please state in-full the basis of your belief that non non-stochastic radiation health effects will occur to (1) employees (ii) " neighbors" of the Harris plant. .Please identify all docunents and opinions upon which you rely in making that statenent (see your response at 71).

(d) What other non-stochastic radiation-induced. health effects i are Applicants aware of besides cataracts? Please provide a list or identify documenta in which such are listed or discussed.

(e) Is it true, in light of your answer ("nartial answer / objection")

to 37-B-3(e) that a list describing all diseases that Applicants believe can be caused by radiation from Harris would read: All cancers, and all diseases caused by genetic damage? (f) If answer to (e) is other than affirmative, please state what kinds of' diseases (or what diseases) should be included in a list or description of all diseases Applicants believe can be caused by

. - exposure to radiation such as will be released by the Harris clant.

(g) Please state in detail, with reference to all documents and expert opinions on which you rely, the basis for your answer to (e) above and to (f) above. If not already stated, nicase state in detail (including reference to all documents and expert opinions on which you rely, and the specific parts ..of each such document on

, which you rely) the basis of Applicants' beliexf that diseases other.than cancer and genetic . diseases cannot be caused by radiation 3

from Harris. (h) Do Applicants believe that any disease can be enhanced by e xposure to radiation, such as that the Harris plant

, will emit (' including internal exposure to radioactive materials enitted from Harris)? (j) If answer to (h) above is affirmative, please state what diseases can be so enhanced. A list or a description

of the types of diseases will suffice.(k) Please state in full, with reference to all docunents and exnert oninions on which your rely, the basis of your belief that (i) your answer to (j) above is correct (ii) . your answer to (h) above is correct (iii) no other diseases than those you list in resnonse to (j) above are enthanced by radiation exoosure such as Harris will give to employies an ? uhe general public. (1) If not already stated in response to the.above, are there any diseases Applicants believe cannot be (1) caused (ii) enhanced by radiation exnosure at the levels employees and persons living nee.r Ha.rris will receive from the Harris plant's operation? (m) If- your answer to either part of (1) cbove is affirmative or would be affirmative if answered, please state what diseases are not (1) caused (ii) enhanced by such exposure ("All diseases other than . . . ." is an accentable answer if that la your belief, as is "All diseases" if you believe that).

(n) Please state in. detail, to the extent not given in resnonse to interrogatories above,-the basis for your belief expressed in response to (n)(1) above and n(ii) above, citing all authorities and docunents you rely on for each such belief.

37-B-6 continued (o) Do Applicants believe there are other diseases, besides those they agree can be caused or enhanced by radiation exnosure, which have been linked by the nedical and scientific connunity (or any person practicing science or nedicine, or trained therein) to radiation? (ref. your response at nage 70). (p) If response to (o) is affirnative, what such diseases are you aware of, and who has linked then to (i) radiation exnosure (ii) low-level radiation?

(q) If your resnonse to (o) is other than affirmative, please state the basis for your belief in detail, including any authorities, experts or docunents unon which you rely. (r) Is it true that the answer to each part of interrogatory 37-B-3(g) is "We know of none"? (s) Please supplenent your answer to 37-B-3(h) if you can define the diseases which Auplicants believe cannot be caused by radiation. Your objection (p.73) only goes to listing.

-(t) to the extent not stated above(in..resnonse to this and past interrogatories, including die above), please describe or state what diseases Applicants believe are outside the scope of Eddlenan contention 37-B.- . (u) Is it true that your answer to 37-3-3(j) (response at 73) neans that Auplicants believe that only cancers and genetically caused diseases can be caused by low-level radiaticn? (v) If answer to (u) above is affirnative, please state in detail why you believe this, unless you have already answered this question in detail.

37-B-7(a) Are there any forns of nental retardation which Annlicants believe are caused by genetic problens? (b) Are there any forns of nental retardation which are " hereditary danage" as described in your partial answer re 37-B-3 on page 71 of your past resnonse?

(c) If your answer to (a) or (b) above or both is affirnative, i describe please for each affirnative answer which such diseases l you believe (i) can be caused by radiation exnosure to a carent l or ancestor (ii) cannot be so caused. (d) are there any forns of nontal retardation that Apolicants know of, such that you don't know whether they can be genetically caused or not? (e) Can you define or describe any diseases inquired about in (d) above? If so, please do so, for as many as you can define or describe. (f) please l

state in detail the basis for your beliefs and answers above.

! 37-B-8(a) Why can't you say that oueration of the Harris niant will not produce cancer and hereditary danage anong persons l living within 50 niles of the Harris plant? (reference your resnonse at 7k)? (b) Is contracting cancer "of significance to health" in Anplicants' view? (c)Is genetic danage to a person "of significance" to (1) that person (ii) their offspring," significance i

in Annlicants' view? (d) Is contracting cancer of l to" general well-being in Apnlicant s ' view? (e) You state, p.7k, l

resnonse to 37-B-4(a), that individuals who suffer fron cancer l

or hereditary disease can undergo pain and suffering, can incur expenses, and can die. Which, if any, of these consequences, do Applicants believe are not of any significance?

(f) Do Applicants know the cost (for any hospitals or areas within L $0 miles of the Harris plant) of (1) treatment for any cancer (ii) treatment for any snecific cancer (iii) treatnent for cancer where the patient recovers (iv) treatnent for cancer where the natient dies? (g) If Applicants' answer to any part of (f) above is affirmative, please state what you know regarding each subpart (h) Does CP&L niace any value on a hunan life of (f) above.

(dollar value) in its nuclear operations? If so, what is that value-and does it differ according to (i) age (ii) sex (iii) income (iv) job (v) any other_ factors (please specify). Please give all values you use.

4 37-B-7 continued

! (j) what part(s) of the two documents. cited in your answer to Interrogatory 37-B-4(c) do you rely on? Please-identify 1

pages, chaphr(s) and specific facts therein (if any) on which you rely. (k) Do Applicants believe that radiation ernosure l (i) plays no role in (ii) ' . enhances (iii) can cause heart.

I disease? For 'each part, please state in full the basis of your belief,-including all documents and expert opinions on which you rely. (1) IM Apolicants believe that radiation exposure (1) p lays no role in (ii) may enhance (iii) does enhance (iv) can enhance (v) can.cause (:,vi) does cause allergies?

Please-state for each part the full basis for your answer, including all documents and expert opinions on which you . rely.

(m) Do- Applicants believe that radiation exposure (i) plays no role in (ii) may enhance (iii) can enhance (iv) does enhance (v) may cause (vi) can.cause (vii) does cause heart attacks in humans? Please state, for each part, the full basis of your answer including any documents and any expert opinions you rely on. . (n) Do Applicants believe there is any relationship between radiation exposure and (1) accidental death (ii) suicide i (aa) for low-level radiation such as Harris is exuected to emit l in " normal operation"-(bb) for low-level radiation such as Harris L

may emit-in accidents below Class VIII (cc) for radiation such as Harris may emit during a Class IX accident (dd) for radiation exposures in the " worst case" analysis of the N90's'DEIS (the greatet radiation release considered therein) ? (o) For each subpart (2 x 4 = 8 subparts ) of (n) above, '

please exclain in detail the basis for your answer, including

. all documents and expert opinions on which you rely. (p) is there any other basis for your answer to 37-B-4(c) than given in your resnonse?

If so .please state all such additional basis.

37-B-6(a),Do Applicants have any information on what dollar value, if any, persons living.within 50. miles of the Shearon Harris plant (or.any .such person) piece (s) on their own life?

(b) If answer to (a) is affirmative, please state that value or values and the number of how these values (persons each such to value)which were eachdetermined.

such value applies, and (c) Da Applicants know if there are persons residing within 50 miles of the Harris plant who would refuse to accent any amount of noney, no matter.how-large, as the dollar value of their life?

Do Apolicants know any persons who do refuse to do so? - ,

(d) Do Applicants have .any opinion as to how much electricity generation a person's life is worth? (e) Do Applicants have any opinion as to how nuch additional capacity on the CP&L system one person's life is worth? (f) Please state in full the basis for each opinion you have in regard to the matter of (d) above and of (e) above, giving all documents, connutations, opinions and information you rely on for your resnonse. (g) Do Applicants believe that the entire expected lifetime electrical outnut of the Harris plant (by their estimates).is worth (i) less than one person's life (ii) one person's-life (iii) more than one person's life? (h) If your resnonse to (g)(iii) above is affirmative, how many lives do you think it is worth? (j) Do Applicants believe that, for NEPA purposes, the benefits of electricity to be derived from the Harris plant (i) at 70% lifetime capacity factor, per Applicants (ii) at $$% lifetine canacity factor, per x NRC Staff,

37-B-8 continued (j) continued are, on balance, greater than the environmental detriment of (aa) the loss of one human life (bb) the loss of less than one human life (ce) the loss of more than one human life (dd) the loss of one human life per reactor-year of operation (ee) an increase in the incidence of genetic disease of (ee-a) one (ee-b) one per future generation (ee-c ) less than one (ee-d) less unan one per future generation (ee-e) nore than one ner future generation (ee-f) nore than ten ner future generation (ee-g) more than 100 per future generation (ee-H) .. nere than one in fatal genetic

-diseases (ee-1) more than one per generation in fatal genetic diseases (ee-j) more than 10 per generation in fatal genetic diseases (ee-k) nore than 100 per generation in fatal genetic diseases (ee-1) nore than 1000 per generation in fatal genetic diseases (ee-m) nore than 10,000 per generation in fatal genetic diseases (ee-n) nore than 100,000 per generation in fatal genetic diseases (ee-0) more than 1,000,000 per generation in fatal genetic diseases (ee-p) nore than 1000 ner generation in fatalities i from genebic and non-genetic diseases (ee-r) nore dhan 10,000 per generation in deaths from genetic and non-genetic diseases (ee-s) the loss of ten human lives per reactor-year of oneration (ee-t) the loss of 30 human lives per reactor year of operation (ee-u) the loss of 100 human lives ner reactor year of operation (ee-v) the loss of 1000 human lives per reactor year of operation (ee-Jw) the loss of 10,000 human lives per reactor-year of oneration (ee-x) the loss of 100,000 human lives per reactor-year of operation (ee-y) the loss of 1,000,000 human lives per reactor-year of operation (ee-z) the risk (as you many estimate or quantify it) of a catastrophic nuclear accident at the Harris site? (k) * -

Is there any upper limit on (1) the number of directly caused somatic deaths (ii) the number of genetically caused deaths (iii) the notential property damange from a nuclear accident (iv) the notential loss of life from somatic effects of a nuclear accident (v) the potential loss of life fron. genetic effects of a nuclear accident, for Harris, that Applicants believe would be unacceptable under NEPA in connarison to the benefits of electricity and canacity Applicants esticate will be derived from Harris? (1) Are any of the limits you identify in response to any part of (k) above ones that you believe should cause NHC to deny an operating license to Harris if the effect to which the limit applies (i) equals (ii) exceeds that 11 nit?

If so please specif each subpart of (k)yabove, whichin limits. (m) What are the limits for Applicants' view? Please quantify or specify then. (e.g. the limit is 1500 deathsiper (i)).

(n) Please give the basis for your answer t o each cart or subpart of (g) through (m) above, identifying all documents and expert opinions you rely on for your answer. (o) Is there any number of cases of (1) all diseases (ii) any diseases (iii) heart disease (iv) allergies which, if shown to be caused by radiat!on emitted

, . f rom the Harris plant (or to be so emitted), would in Anolicants' view (aa) justify not issuing an operating license for Harris on NEPA grounds (bb) justify shutting down the plant if it were ooerating (cc) justify placing additional limitations on radioactive enissions fron Harris?

is asked for each subpart(p)ofPlease state(3the (o) above x 4number (if any() q)

= 12 parts). which Please state the basis for your answer to each part of (o) and (p) above huludirg all documents and expert oninions on which you rely.

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37-B-8 continued sc) Is there any amount of pain and suffering associated with (1) all health effects, including genetic (ii) all non-genetic health effects (iii) all genetic health. effects fron Harris which, if it were exceeded, would justify the NRC under NEPA in (aa) not licensing the Harris plant to operate (bb) shutting Harris down (cc) liniting Harris' radioactive emissions nore strongly than at present, if that anount were shown to be caused by Harris' radioactive emissions, in Applicants' view? (s) For each part of (r) above (3x3=9 parts) please state the number or amount (e.g. $ people in severe pain for 30 years, or 150 person-years of severe pain, etc. ) which is asked about in that part.

(t) Is there any conbination of health effects and pain and suffering which, if it were shown to be caused by Harris oueration, would justffy NRC in denying an operating license to the Harris plant under NEPA, in your view? If so, please state the conbination (or the least severe conbination you think would so justify the NRC in not licensing Harris under NFPA). If not, clease state in full the basis for your answer, including all cases, doc uments or exnert opinions you rely on. (u) Are you glad this is the last interrogatory in.this set? (Answer optional--no notion to compel will be made on this part (u)!! )

REQUEST FOR PRODUCTION OF DOCUMEN"'S I hereby request that Aunlicants nake available to ne within 30 days of the date hereof (7-20-83 is today) for insnection and copying an original or best cony of all documents identified in response to the above interrogatories, at a tine and place nutually agreeable, for sufficient tine for ne to review the docunents.

Wells Eddlenan l

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