ML20077G106
| ML20077G106 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/29/1983 |
| From: | Carrow H CAROLINA POWER & LIGHT CO. |
| To: | EDDLEMAN, W. |
| References | |
| ISSUANCES-OL, NUDOCS 8308030371 | |
| Download: ML20077G106 (31) | |
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- NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIN oaf 4D 4 4 3 p v -
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In the Matter of $
CAROLINA POWER & LIGHT COMPANY AND NORTH CAROLINA EASTERN
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\'a Docket Nos. 50-400'.d!E I MUNICIPAL POWER AGENCY ) 50-401 OL
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(Shearca Harris Nuclear Power Plant, ) -
4' Units 1 & 2) )
- APPLICAN'IS' ANSWERS TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES AND INTERROGATORIES ON CONTENTIONS 64(f),67 and 80 TO APPLICANTS CAROLINA POWER & LIGHT COMPANY ET AL. (THIRD SET)
GENERAL INTERROGATORIES
' Applicants ' Carolina Power & l'ight Company and North Carolina Eastern Municipal Power Agency, pursuant to 10 C.F.R. S 2.740b, hereby submit the following responses to
" Wells Eddleman's General Interrogatories on Contentions 64(f),67 and 80 to Applicants Carolina Power & Light Company, eg. (Third Set).5 The provision of answers to these
. in.terrogatories is not to be deemed a representation that Applicants consider the s
information sought to be relevant to the issues to be iieard in this proceeding.
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INTERROGATORY NO. Gl' (a) Wh'ich contentions of Wells Eddleman do Applicants
~ agree are now admitted in this proceeding, NRC Dockets 50-400/4010.L.?
(b) for each such contention, provide for any answers to interrogatories by Wells Eddleman which Applicants have previously or presently received (except those suspended by Board order, if any), the following information:
i (c) Please state the name, present or last known address, and present. or last known i 2 employer 'of each person whom Applicants believe or know (1) has first-hand knowledge a of the facts allsged in each such answer; or (2)-upon whom Applicants relied (other than trieir attorneys) in making such answer.
(d) please identify all facts concerning which each such person identified in response to Gl(c)(1) atiove has first-hand knowledge.
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- 8308030371 830729 PDR ADOCK 05000400 PDR G.
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(e) please identify all facts and/or documents upon which each person identified in response to G1(cX2) above relied in providing information to respond to the
. interrogatory, including the parts of such documents relied upon.
(f) Please identify any other document (s) used or relied upon by Applicants in responding to the interrogatory.
(g) Please state which specific fact each document, identified in response to Gl(e) and G1(f) above, supports, in the opinion or belief of Applicants, or which Applicants allege such document supports.
! (h) Please state specifically what information each person identified in response to Gl(cX1) or Gl(cX2) above provided to or for Applicants' affiant in answering the interrogatory. If any of this information is not documented, please identify it as 1 " undocumented"in responding to this section of GeneralInterrogatory Gl.
. ANSWER.
(a). The contentions of Intervenor Eddleman which are admitted in this proceeding are set forth in Applicants' " Admitted Contentions" dated January 21,1983, as modified by the Board's " Memorandum and Order (Ruling on Cost Savings Contentions, Discovery Disputes, and Scheduling Matters)," dated May 27,1983.
(b). The answers to General Interrogatories herein are restricted to the interrogatories set forth in Wells Eddleman's " Third Set" of interrogatories on Contentions 64(f), 67, and 80. Answers to General Interrogatories relating to Contentions 75 and 83/84 will be provided in a separate response to interrogatories related to those contentions.
(c). The following list identifies those persons who provided information upon i which Applicants relied in answerinT Me interrogatories on Eddleman Contention Nos.
64(f), 67 and 80.and indicater et es *ular interrogatory answer (s) for which each such person provided information.
PERSON INTERROGATORY NO(S).
Louis H. Martin ) 64-10, 64-11, 64-12, 64-13 Robert K. Kunita ) 64-14 Daniel D. Davis )
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l The above individuals are employees of Carolina Power & Light Company, Post Office Box 1551, Raleigh, North Carolina 27602.
PERSON INTERROGATORY NO(S).
William H. Webster ) 67-5, 67-6, 67-6 Ballard S. Mays )
Mr. Webster and Mr. Mays are employed by Carolina Power & Light Company, Shearon Harris Energy and Environmental Center, Route 1, Box 327, New Hill, North Carolina 27562. -
PERSON INTERROGATORY NO(S).
Brian McFeaters 80-4, 80-5, 80-6, 80-7, 80-8, 80-9, 80-10 Mr. McFeaters is employed by Carolina Power & Light Company, Post Office Box 1551, Raleigh, North Carolina 27602.
(d). See Answer G1(c).
(e). All such facts or documents relied upon by those individuals identified above are indicated within each response to the specific interrogatories on the contentions.
(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 contentions.
(h). See Answer G1(c).
INTERROGATORY NO. G2(a) Please state the name, present or last known address, title (if any), and present or last known employer, and economic interest (shareholder, 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, or has changed since such information was last supplied,to Wells Eddleman. This applies to Eddleman and Joint Contentions as admitted,or stipulated by Applicants.
(b) Please identify each contention regarding which each such person is expected to testify.
(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 state the subject matter, separately for each contention as to which each such person is expected to testify, which each such person is expected to testify to.
(e) Please identify all documents or parts thereof upon which each such witness is expected to, plans to, or will rely, in testifying or in preparing testimony.
ANSWER.
(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 supplement this response in a timely manner.
(b). See Answer G2(a).
(c). See Answer G2(a).
(d). See Answer G2(a).
(e). See Answer G2(a).
INTERROGATORY NO. G3(a) Please identify 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 where in such source that information is to be found.
(b) Please identify any other source (s)of information not previously identified upon which any witness identified under G2 above, or other witness, has used in preparing testimony or exhibits, or expects to use in testimony 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 uced, and, if not previously stated, the fact (s) or subject matter (or both) to which su::h source relates.
ANSWER.
(a). Applicants have identified all such other sources of information, if any, within each response to the specific interrogatories set forth herein.
(b). See Answer G2(a).
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INTERROGATORY NO. G4(a) please identify all documents, and which pages or sections thereof Applicants intend or expect to use in cross-examination of any witness I call in this hearing. For each such witness, please provide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject matter Applicants believe they relate to, and make the document (s) available for inspection and copying as soon as possible after Applicants decide or form intent to use such document in cross-examination. -
(b) please identify any undocumented information Applicants intend to use in cross examination of each such witness for me.
ANSWER.
(a). Applicants have not at this time identified which doedments,if any, they intend to use in cross-examination of Mr. Eddleman's witnesses.
(b). See Answer G4(a) above.
INTERROGATORY NO. G5 (a) for each contention Applicants state or admit is an admitted Eddleman contention under G1(a) above, or an admitted joint intervenor contention, please state whether Applicants have available to them experts and information, on the subject matter of the contention.
(b) If the answer to (a) above is other than affirmative, state whether Applicants expect to be able to obtain expertise in the subject matter, and information on it, and if not, why not.
ANSWER.
(a). Applicants have available to them experts and information on the subject matter of each contention referred to herein.
(b). Not applicable.
l l INTERROGATORY NO. G6(a) for each document identified in response to any interrdgatory herein, or referenced in response to any interrogatory herein, please supply all the following information which has not already been supplied:
(i) date of the document (ii) title or identification of document (i.ii) all authors of the document, or the author (iv) all qualifications (professional, technical) of each author of the document 1
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(v) the specific parts, sections or pages of the document, if any, upon which ;
Applicants rely l (vi) the specific information each part, section or page identified in response to (v) above contains.
(vii) identify. all documents used in preparing the document, to the extent known (and also to the extent not identified in the document itself)
(viii) state whether Applicants possess a copy of the document (ix) state all expert opinions contained in the document, upon which Applicants rely, or identify each such opinion.
(x) identify the contention (s) with respect to which Applicants rely upon (a) the expert opinions (b) the facts identified in the document (xi) state whether Applicants now employ any author (s) of the document, identifying each such person for each document. ,
(xii) state whether Applicants have ever employed any author (s) of the document, identifying each such person 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.
ANSWER.
(a). All such information available to the Applicants with regard to each document identified in these answers is set forth along with the document identified within each response to the specific interrogatories on the contentions.
i INTERROGATORY NO. G-7(a) Please identify all documents which Applicants
- plan, expect or intend to offer as exhibits (other than for cross-examination) with respect to each Eddleman contention admitted in this proceeding which (i) is included in your current response to G1(a), or (ii) is the subject of interrogatories in this set; please state l
for which contention or contentions each exhibit will be or is expected to be offered.
(b) Please identify all documents which Applicants plan, expect or intend to use in cross-examination of any other parties' witnesses or joint intervenor witness in this proceeding, with respect to (i) Eddleman contentions identified under G-7(a)(i)(or G-1(a))
j above, or any other Eddleman contention which is the subject of interrogatories in this set; (ii) each Joint contention now admitted in this proceeding;(iii) per our agreement of 4-8-83, each contention of each other party to this proceeding which is currently admitted. Please identify for each such document the witnesses, or witness, and all contentions with respect to whom (or which) that document is planned, expected, or l intended to be offered or used.
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(c) Please identify which of the documents identified in response to (b) above (i) will be offered into evidence by Applicants, and (ii) which of the same documents
. Applicants expect to offer into evidence or intend to offer as evidence or exhibits in this proceeding.
ANSWER.
(a). Applicants have not yet identified those documents they intend to offer as exhibits relating to Eddleman Contentions 64(f),67, and 80.
(b). Applicants have not yet identified those documents they intend to use for cross-examination of any witnesses. - -
(c). See Answer G7(b).
INTERROGATORY NO. G8 (a) Please identify, for each Eddleman contention which is the subject of this or an earlier set of interrogatories, all information not previously identified which was (i) used or relied on in preparation of Applicants' responses to that contention and all contentions superseded by it (per transcript of July 1982 special prehearing conference, the Board's September 1982 order admittting (sic) 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.
INTERROGATORY NO. G-8(b) Please identify all persons who supplied information relied on or used in Applicants' response to each contention for which information is requested in G -8(a) above. (ii) Please identify for each such person what information was supplied, and with respect to which contention (s) each item of information supplied was used. (iii) Please state all known qualifications of each such person with respect to the subject matter of the each contention for which that person supplied information.
INTERROGATORY NO. G-9(a)Please identify all information not identified in response to the above general interrogatories, including all documents, which Applicants rely on or intend to use in making their case of carrying their burden of proof in this proceeding, with respect (i) to each Eddleman contention which is the subject of this or an earlier set of Eddleman interrogatories to Applicants; (ii) with respect to each joint contention on which discovery is now open under the Board's March 10 1983 order, or on which discovery has been open under said order establishing a discovery schedule. (The phrase "or on which discovery has been open" is intended to keep this interrogatory current and continuing for information and documents which Applicants rely on or form intent to use after the formal close of discovery. I interpret Applicants' continuing interrogatories to apply continuously from their date of submission to me, and I intend these to apply likewise.)
OBJECTION. Applicants have previously objected to General Interrogatories G8 and G9 as being overly broad, irrelevant, burdensome and seeking protected and privileged information. See, eA " Applicants' Responses to Wells Eddleman's General Interrogatories and Interrogatories on Contentiens 64(f) and 67 to Applicants Carolina Power & Light Company, et al (Second Set)," filed May 27,1983 at 8-11. Applicants renew their objections here.
INTERROGATORIES ON CONTENTION 64(f)
INTERROGATORY NO. 64-10(a) Does the consolidated safbty analysis repor't (CSAR) for the IF-300 series cask consider the possibility of the valve box (i) being crushed (ii) being sheared (iii) being sheared off (iv) being penetrated by a solid object (v) being penetrated by a lor.g object being impacted, such as a steel beam, rail, or reinforcing bar (vi) having the cask roll over onto it, causing damage? (b) for each part of (a) above for which your answer is affirmative, please state at what pages the CSAR considers such possibility, and state all additional views Applicants hold concerning such possibility (which aren't in the CSAR), stating in detail the technical or other basis for each such view and all facts that underly it, identifying all documents in which such view or the basis for it or part of the basis for it is contained. (c) Do Applicants agree that if the valve box were open to the outside or without integrity (e.g. due to events such as are inquired about in (a) above), the valve could be directly exposed to flammable fluids in an accident? (d) If your answer to (c) above is other than affirmative, please state in detail all basis for your view, identifying all documents and expert opinions upon which you rely in holding such view.
ANSWER.
(a) (i) - (vi). Yes. The CSAR addresses the integrity of the cask valve box under several postulated accident conditions.
(b). See CSAR Sections 5.5.4, 5.5.4.1, 5.5.4.2, 5.5.4.3, 5.5.4.4., 5.5.4.5.,
5.5.4.6., 5.6.2, 5.6.2.1., 5.6.2.2., 5.6.2.3, 5.6.2.4, 5.7.2, 5.7.2.1., 5.7.2.2., 5.7.2.3, 5.7.2.4, 5.7.2.5.
(c). OBJECTION. The question is irrelevant. The analyses described in the CSAR Sections referenced in (b) above demonstrate that the valve box will hold its integrity. There is no foundation for the hypothetical question. Furthermore, since CP&L is removing the pressure relief valve, under no circumstance could the valve be exposed to flammable fluids in an accident.
(d). Not applicable.
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INTERROGATORY NO. 64-ll(a) Are there any other methods for providing cask internal pressure relief, besides a pressure relief valve, currently approved by NRC for use with the IF-300 cask? (b) If you answer to (a) is affirmative, please list each such method, describe it in detail, and reference the CSAR pages and any other documents which describe such method. Please also cite and identify each NRC document which approves each such method.
ANSWER.
(a). No. See answer to 64-14 below.
(b). Not applicable. -
INTERROGATORY NO. 64-12(a) Has the integrity of the pressure relief valve on the IF-300 cask ever been tested under (i) actual (ii) simulated accident conditions? (b) If your answer to (aXi) or (aXii) is affirmative, for each such affirmative answer please state the following: (i) all conditions of such test or accident, including internal cask heat generation rate, whether a fire burned outside the cask, the temperature and duration of each such fire, whether the valve box was crushed during the accident / test, whether the valve box was penetrated during the accident / test, the speed of impact if any, whether the cask rolled over, whether the valve seating was positively known at all times during the accident / test (and if not, for what times it was known), whether the valve unseated during the accident or test, the maximum temperature inside the cask during the test / accident, the maximum pressure inside the cask during the test accident, whether any fission products were inside the cask during the test / accident, whether anything was released from the cask during the test / accident, what any such released material was I released from (if known), the date of such test, the conductors of such test, the date of such accident, all documents containing report (s) or analysis of such test / accident, and whether any persons working for CP&L were involved in the test or accident in any way (and if so, how).
ANSWER.
(a). OBJECTION. The pressure relief valve on the IF-300 series cask is being removed from cask service. Thus, all interrogatories regarding its characteristics or testing are irrelevant. Indeed, the contention is moot.
(b). Not applicable.
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INTERROGATORY NO. 64-13(a) What is the melting point of the Rulon material used in the IF-300 pressure relief valve (i) at 1 atmosphere pressure (ii) at 375 psig? (b) what is the modulus of elasticity of Rulon (i) at I atm pressure and 20 e (ii) at 375 psi
! pressure (gauge) and 400* F (iii) at any other pressure and temperature at which its modulus of elasticity has been determined? (c) what is the modulus of compressibility of f
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Rulon (i) at 1 atm and 20* C (ii) at 375 psig and 400* F (iii) at any other temperature and pressure for which its modulus of compressibility (bulk modulus) has been determined?
(d) what is the shear modulus of Rulon ? (e) has the shear modulus of Rulon ever been tested at a temperature over 100*F? If so, what temperature was it tested at and what was the shear modulus - please list the results of all such tests known, and all shear moduli determined for Rulon at elevated temperatures. (f) Is Rulon embrittled by (i) neutron exposure (ii) gamma radiation (iii) heat (iv) continuous pressure on it? (g) for any part of (f) for which your answer is affirmative, please state the conditions and degree of embrittlement which have been found. (h)If Rulon has not been tested for embrittlement under each agent identified in (f) above, please so state, for (i) neutrons (ii) gamma radiation (iii) heat (iv) pressure. (j) does intermittent pressure embrittle Rulon to any extent? How much, under what pressure and conditions of intermittency? (k) please identify all documents which contain information concerning the above-asked properties of vulnerabilities of Rulon, stating for each which response above it relates to, and what facts it contains that are responsive to each part of each question above, if any.
ANSWER.
(a)-(k). OBJECTION. See cbjection to 64-12 above.
INTERROGATORY NO. 64-14(a)If a rupture disk were used on the IF-300 cask, and it ruptured, would there be any valve that could be used to stop the escape of materials from the cask cavity through the broken rupture disk? (b) please identify any such valve, its CSAR reference if any, all documents describing such valve, and what would have to be done to use it to close off the escape of material through a ruptured rupture disk on the IF-300 cask.
ANSWER.
(a). No. However, a rupture disk is used for dry shipments (this is currently the only method for which the cask is licensed). As shown in CSAR Section 6.3.20.4, the maximum cavity pressure generated unde accident conditions for a dry shipment is 248 psig. This pressure is well below the cask design pressure of 400 psig. Therefore, the l cask does not need a cavity relief valve for overpressurization protection. A 350- to 400-psig rated rupture disk is used to seg the cavity for dry shipments (CSAR Section 6.5.b). This disk has been approved by the NRC in Certificate of Compliance No. 9001, l paragraph 14.
I (b). Not applicable.
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INTERROGATORIES ON CONTENTION 67 INTERROGATORY NO. 67-5(a) please identify every item which Applicants expect or believe will be disposed of from the Harris plant as low-level radioactive waste (LLRW). A description.will suffice for items that cannot now be identified, e.g. cleaning materials, contaminated parts removed in repairs, etc. (b) Are Applicants willing to have a license condition on Harris (in the operating license) that restricts disposal of the items identified as LLRW in response to (a) above so that they can only be disposed of as LLRW or as high-level waste under NRC rules? (c) If answer to (b) is other than affirmative,
, please state in detail all reasons for your answer, and state if there are any items not included in response to (a) above which may be disposed of as LLRW from Harris, and list all such items. (d) For each item identified in response to (a) above, please state (not legible) (i) the expected average, (ii) the expected maximum, and (iii) the maximum allowed (under tech specs as proposed, NRC regulations, or any other limitation known to Applicants): (aa) weight (bb) volume (ce) content of each radionuclide (not legible) in 10 CFR part 20 and its appendices, as a minimum and a maximum, in (cc-a) curies per unit volume (cc-b) curies per unit weight (cc-c) total curies (cc-d) curies per unit of the item (cc-e) mass of such radionuclide (cc-f) any other terms which Applicants have used to characterize the radioactivity of such item. (NOTE, milli, micro, nano, pico curies etc can be used in answers to this part - it doesn't ask recalculation into curies); (dd) number of such items per year in normal operation (ee) number of such items to be disposed of over the lifetime of (i) one Harris unit (ii) both units; (ff) number of such items which Applicants plan to dispose of as LLRW (ff-a) per year of operation per Harris unit (ff-b) over the lifetime of each Harris unit (ff-c) over the operating lifetime of both Harris units (ff-d) as a result of accidents and other events beyond normal maintenance (ff-e) as a result of repairs to Harris unit 1 (ff-f) as a result of repairs to Harris unit 2; (gg) maximum limit, if any, of such items which can be disposed of from Harris as LLRW, in (gg-a) number of items (gg-b) quantity of radioactive material contained in such items, listing the number of such items, and the radioactivity of each radionuclide c~ontained in each item or the total (maximum) number of items; (hh) a description in full of the storage or care of each item from the time it becomes radioactive or is contaminated with radioactive material, to any on-site storage, to shipment to any offsite disposal site (including packaging)(and loading), the arrangements made by Applicants to monitor such material when produced, when identified as LLRW, when it has not yet been stored as LLRW at Harris, while in storage as LLRW at Harris, during packaging for shipment off-site from Harris, during loading for such shipment, during such shipment, at the receiving l site, and at disposal; any arrangements made by Applicants to contain the radioactivity of such material during any of the preceding states ("when produced ... and at disposal")
listed above, including the equipment used, its method of containing such radioactivity, its efficiency, (hh-a) by test (hh-b) as calculated, giving in full all supporting calculations and information, and identifying all documents wherein such information is found or such calculation (s) have been made (hh-c) in actual operation, identifying the site of such operation, the method of assessing such efficiency, all reasons for the choice of such method of assessing efficiency, and identifying all documents which include information on the test requested in (hh-a) above, or the actual operation from which determination was made. " Efficiency" as used herein means either "% containment of each radionuclide, or the total curies of all radionuclides, in the LLRW (items or aggregate) "
or "any measure of the amount contained, the amount trapped, or the amount released" of radioactivity in LLRW, known to Applicants and applied by them to such method of containing the radioactivity of LLRW. (hh-d) Do Applicants know of any information
i l requested above in part (hh) and its subparts, or any part thereof, which was determined
- or is known to someone other than Applicants? (hh-e) If answer to hh-d above is afffirmative (sic), please identify all documents Applicants possess that contain such information, and identify all other such information. (hh-f) Please state which part(s) of part(hh) above each item of information or document identified in response to (hh-e) above contains information responsive to, stating the information if possible. (jj) Are there any facilities at Harris for storage of such item, i.e. dedicated to storing that item only; (kk) Are there any facilities at Harris for storage of such item together with other LLRW? (11) are there any facilities at Harris for storage of such item (aa) with other radioactive wastes or spent fuel (bb) with nonradioactive items (ce) with other radioactive materials, e.g. fresh fuel, radioactive items in smoke detectors etc in use at the plant, radioactive items in instruments in use at the plant ("in use" includes items
! stored for possible use at Harris or for use elsewhere, if such storage is at Harris),
" medium leval" radioactive wastes? (mm) for each facility identified in response to any of jj, kk,11 above, please state (aa) the location of such facility (bb) the maximum volume of waste (LLRW) which can be stored in such facility (ce) the maximum volume of items 4 other than LLRW which can be stored in such facility while it contains any LLRW (dd) the volume of such facility (dd-a) internal (dd-b) external (ee) whether the facility is l continuously monitored for radiation levels, and if so how, identifying all instruments used for such and their locations and how they are read (ff) whether the facility is continuously monitored for levels of each radionuclide listed in 10 CFR part 20 and its appendices, in air in the facility, in water or liquids in the facility, or in any other 1
content of the facility including the LLRW itself, stating for each nuclide monitored continuously the forms it may take (particle, gas, dust, solid, liquid, solution, etc) the method and instrumentation used for such monitoring, how such monitors are read, who reads them, and how often such reading is required (gg) whether the facility is monitored
, in any way other than continuously for radiation (hh) if answer to (gg) is affirmative please state the identity and location of all such monitoring equipment, the nuclides
- and/or forms of radiation such monitoring equipment can detect, the lower and upper thresholds of such detection, how such monitoring equipment is read, how often, by whom, and how often it is required to be read, and whether it determines the nuclides l present in LLRW stored in or passing through the facility (jj) what monitors or methods are used to detect radioactive material escaping from such facility (a) along expected routes of removal, e.g. through air ducts, drains, vi P.5, etc (b) through leaks or abnormal escapes or along routes other than those radioactivity is expe.
- ted to escape through (c) through unauthorized removal of radioactive material by pccsons (d) through removal of l radioactive material by other living creatures, e.g. mice, rats; identifying for each such
! monitor its location, alarming levels if any, and its method of detecting such radioactive material release / removal and it sensitivity to such release removal for each form of radiation and for each radionuclide to which it is sensitive or which it can detect. (end of (mm)) (nn) Please identify any other control, monitoring, or containment methods for l Harris LLRW not identified in response to the above questions or parts. For each, please i state where and how it is used, describe it, and state whether it can detect or prevent
] LLRW at Harris being released to the environment, giving the basis of such response in detail and identifying all documents containing such information or supporting this response or any part of it. (oo) Please state exactly what technology for storage and containment of LLRW is used for each facility identified in response to (jj) (kk) or (11) above (not part jj under part mm) by Applicants, what sites other than Harris Applicants know the same technology is used at, what sites other than Harris Applicants know that similar techhology is used at, whether there have been any releases of radioactive materialinto the environment from LLRW at each such site (stating the time, date, and amount released if known, identifying which site the release was from if known).(e) Do l
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Applicants contend that landfills will not leak within the (i) halflife (ii) 20-halflife period (iii) 30 half-life period of (aa) Cesium-137 (bb) Sr- 90 (ce) plutonium-239 (dd) nickel- 59 (ee) niobium -94 (ff) lodine-129, if radioactive waste (LLRW) containing any or all of such l materials is disposed in them (f) please answer all parts of (e) above assuming a rainfall '
of 50 inches per year of water on the landfill and a clay cap (g) please answer all parts of i (e) above assuming a rainfall on the landfill of 50 inches per year and a clay cap and a
. plastic cover below that, over the landfill. (h) please state whether there is any level of l rainfall less than 50 inches per year that would change your answers to either (f) or (g) above, stating what changes would result at which level of rainfall on the landfill: (i) please state whether there is any kind of landfillliner in commercial use for which your answer to any part of (e) above would be affirmative, stating for each such liner its manufacturer (s), what it is made of, the longest it has been used in any LLRW 1andfill, whether any landfill using such liner leaks, to the present date, (this is a continuing interrogatory, of course: later leaks should be noted when Applicants learn of them),
which part(s) of (e) above are answered affirmatively for such liner, and identifying all basis for such answer including all documents, studies and information which support your answer. (j) please state whether there is any combination of landfill location, liner, cover, filling procedure, or other landfill characteristics (and/or the preceding characteristics) which in Applicants view guarantee that a LLRW landfill will not leak (i) during its operating life (ii) within 100 years (iii) within 500 years (iv) within 1000 years (v) within 20 halflives of Pu-239; (vi) within 20 halflives of I-129 (vii) within any other specific time period, (k) If answer to (j) above is affirmative, please state the combination of landfill characteristics required, in detail, and give all basis, analysis and information which supports your answer, identifying all documents which contain such information or analysis, studies, etc. (m) please list all violaticns or deviations or noncompliances with packaging regulations or other regulations for the transport of LLRW which CP&L (i) has been caught in by NRC (ii) has committed but not previously
, reported to NRC (iii) has been caught in by someone other than NRC (iv) reported to j NRC (v) reported late to NRC, i.e. beyond the required notification deadline for such l violation, deviation or noncompliance. (n) please state the maximum number of curies of LLRW which CP&L has ever shipped for disposal as:one item (ii) one shipment (iii) total shipped through 12-31-82 from all CP&L nuclear facilities: (iv) total shipped to date. (o)
Has CP&L shipped any radioactive material (LLRW) which arrived at a disposal site or other authorized receiver (i) leaking (ii) with a radioactivity level at or at a given distance from its surface in violation of transport regulations for LLRW or in excess of that permitted for the type of shipment (I, II, III, etc) made? (p)If answer to (o) above is affirmative, please list each such and state the condition it arrived in. (q) has any shipment from CP&L to any LLRW site ever been rejected for disposalin such site? (r)
If answer to (q) is affirmative, please list each such shipment, the reason given for its rejection, and where and how such shipment was disposed (or where it is now stored),
describing its contents and radioactivity in as much detail as CP&L knows (i) at the time of shipment (ii) at arrival at the site (iii) at the time of rejection (iv) at present, if known.
ANSWER.
(a). Those items described in FSAR Sections 11.1,11.2,11.3, and 11.4.
(b). No.
(c). It is unnecessary to have a license condition which requires the licensee to comply with NRC regulations.
(d) (1). See FSAR Seetions 11.1,11.2,11.3, and 11.4.
(ii). Unknown.
(iii)(aa). No limit.
(bb). No limit, except as may be imposed by a burial site.
(cc). Unknown.
(cc-a). Unknown, but see 10 CFR 61.55.
(cc-b). FSAR Seetions 11.1,11.2,11.3, and 11.4.
(cc-c). FSAR Table 11.4.2-2 and Table 11.4.2-3.
(cc-d). Unknown.
(cc-e). See the Periodic Table of Elements for mass number.
(cc-f). Not applicable.
(dd). Unknown.
(ee). Unknown.
(i). Unknown.
(ii). Unknown.
l (ff). Unknown.
, (ff-a). Unknown.
l (ff-b). Unknown.
I (ff-c). Unknown.
l (ff-d). Unknown.
l (ff-e). Unknown.
(ff-f). Unknown.
(gg). None.
(gg-a). Unknown.
(gg-b). Unknown.
(hh). See FSAR Sections 11.1,11.2,11.3, and 11.4.
l
See FSAR Sections 12.1,12.2,12.3, and 12.5.
(hh-a). Unknown.
(hh-b). Unknown.
l (hh-c). Unknown.
(hh-d). No.
l (hh-e). Not applicable (hh-f). Not applicable.
(jj) - (oo). OBJECTION. Applicants find these interrogatories so ambiguous and confusing that they are incapable of a response. In general, Applicants' plans for storage of low-level radioactive waste are described in FSAR Chapter 11.
(e) - (k). OBJECTION. Contention 67 is limited to the safety of the operation of the Harris Plant in the absence of a low-level waste disposal site. Interrogatories 67-5(e) through (k) deal with the design criteria for low-level waste " landfills." Such questions are outside the scope of Contention 67 and are thus irrelevant to the issue admitted in this proceeding. Nor would responding to these interrogatories likely lead to the development of relevant l
information. Applicants refer Mr. Eddleman to the Commission's regulations at 10 CFR Part 61, which govern the siting and licensing of low-level waste disposal facilities.
1 (m) (i). See response to Interrogatory 67-1(b), previously provided.
(ii). None.
(iii). See response to (mXi) above.
- (iv). See response to (m)(i) above.
(v). None.
l
}
(n) - (e). OBJECTION. Contention 67 is limited to the safety of the operation of the Harris Plant in the absence of a low-level waste disposal site. Interrogatories 67-5(n) through (r) deal with CP&L's compliance with regulations in shipping low-level waste to diposal sites. Such questions are outside the scope of Contention 67 and are irrelevant to the issue admitted in this proceeding. Nor would responding to these interrogatories likely lead to the development of relevant information. The predicate for Contention 67 is the unavailability of low-level waste disposal sites to which low-level waste can be shipped. Interrogatories regarding the physical conditions of low-level waste shipments are inconsistent with the thesis advanced for Contention 67.
INTERROGATORY NO. 67-6(a) Do Applicants have any plans for (i) LLRW storage at Hads (ii) other options for LLRW disposal, (iii) reducing the amount of LLRW produced at Harris, which they have (aa) considered (bb) planned (cc) adopted for use in the event that the State of NC does not ratify a compact with other states for LLRW disposal or fails to develop its own LLRW disposal site while having not ratified a compact with another State or States for LLRW disposal? (b) please list each such plan, state which (if any) of the following it involves: (i) LLRW storage (ii) expanded LLRW storage areas (iii) LLRW incineration (iv) LLRW pulverizction (v) LLRW compaction (vi) reducing the amount of LLRW produced, (vii) disposal of LLRW at sea (viii) disposal of LLRW in other countries (ix) other options for disposal of LLRW, identifying each such.
(c) please state whether each plan listed in response to (b) above is (i) now adopted (ii) proposed for adoption (iii) something CP&L or Applicants have considered (iv),an option for CP&L or Applicants (v) considered too expensive, listing cost (vi) considered to engender citizen opposition. (d) Has CP&L considered any illegal methods of LLRW disposal for use.at Harris? If so, please state each such and whether it was apprc,ved or rejected, by whom, and when, giving the amount of LLRW disposed thereby, if any. (e)
Does CP&L or Applicants have any arrangement or agreement or understanding with any other utilities for storage, incineration or disposal of LLRW by the other utilities (of any of them) for Harris LLRW? (f) If answer to (e) is affirmative, please list each such arrangement, agreement or understanding, all other parties to it, what it provides for, what conditions it comes into effect under, and how much LLRW can be handled under the arrangement, agreement or understanding (by volume, curies, or any other measure involved in such arrangement, agreement or understanding). If there is no upper limit on the amount 'of LLRW involved, please so state. (g) does CP&L have any plan or arrangement for disposal of LLRW other than shipment to an approved site for disposal, and the ones listed in response to interrogatories and parts thereof above? If so, please identify each such plan or arrangement, all documents containing such plan or arrangement, and specify all details of such plan or arrangement. (h) please identify all
documents containing information inquired about in parts (a) through (f) above (or any part or subpart thereof), stating which subpart(s) each has information about in it.
ANSWER.
(a) (i). Yes. See FSAR Sections 11.1,11.2,11.3, and 11.4.
(ii). Yes.
(iii)(aa). Yes.
(bb). Yes.
(ce). Yes.
(b) (i). See FSAR Sections 11.1,11.2,11.3, and 11.4.
(ii). Applicants pesently have no such plans.
(iii). No.
(iv). No.
(v). See FSAR Seetions 11.1,11.2,11.3, and 11.4.
(vi). No.
(vii). No.
(viii). No.
(ix). Shipment to an off-site licensed facility.
(c) (i). See FSAR Seetions 11.1,11.2,11.3, and 11.4.
(ii). See FSAR Sections 11.1,11.2,11.3, and 11.4.
(iii). Other options, such as expanded on-site storage and incineration, are still being evaluated.
(iv). Unknown.
(v). Unknown.
(vi). Unknown.
(d). No.
(e). No.
(f). Not applicable.
(g). No.
(h). See FSAR Sections 11.1,11.2,11.3, and 11.4.
FURTHER INTERROGATORIES ON CONTENTION 67 INTERROGATORY NO. 67-7(a) Do Applicants agree that NC may withdraw from the radioactive waste compact if it is ratified (SE compact)? (b) is there a provision in the NC compact legislation that provides for such withdrawalif another state refuses to take a site for LLRW disposal? (c) Is there any other provision in the legislation for NC ratifying the compact which permits withdrawal by NC? (d) for each answer to any of a,b or e above which is other than affirmative, please state in detail all reasons for your answer and all facts which support your answer, giving the source of each such fact or opinion or reason. (e) please state all contingency plans Applicants have if NC withdraws from the SE compact, or identify all documents containing such plans,giving the title, author and date of each. (f) does CP&L have any plans to reduce LLRW generation at Harris (i) if NC does not ratify the SE LLRW compact (ii) if NC withdraws from such compact at a future date? (g) for each affirmative answer to any part of (f) above, please identify all documents which include such plan (s), the author (s), title and date of each. (h) Does CP&L have any plans to prevent NC from withdrawing from the SE LLRW compact? (j) If so, please identify any documents containing such plans or information about such plans.
ANSWER.
(a) - (d). The answers to Interrogatories 67-7(a) through (d) cannot be determined until the Southeast Interstate Radioactive Waste Management Compact is ratified by the participating states and approved by the Congress and the language of the North Carolina legislation which ratifies the Regional Compact is finalized.
(e). Not developed at this time.
(f) (i). No.
(ii). No.
(g). Not applicable.
(h). No.
(j). Not applicable.
. INTERROGATORIES ON CONTENTION 80
INTERROGATORY NO. 80-4(a) To Applicants' knowledge, for how long has lack of ability to model rainout accurately been acknowledged to be a problem with radiation dispersion (or diffusion) studies (i) for reactor accidents (ii) for routine operation of reactors where radioactive material is being released? (b) Do Applicants know of any modeling techniques or. computer programs which can model(i) rainout (ii) dry deposition of radioactive material (iii) snow deposition of radioactive material (iv) entrainment of radioactive material in hail (v) deposition of radioactive material in any other form (s) of precipitation? (c) identify each model you know of for each part of (b) above for which your answer is affirmative. Please list for each such model its author (s), title, date and what it models. Please state for each such model whether you know of any determinations of the accuracy of that model versus any test data, and if so, what test data, identifying all documents in which the test data or the deterniination of accuracy of the modelis contained.
ANSWER.
(a). The Applicants do not acknowledge that current models are inadequate for " rainout."
(b) (i). Yes.
(ii). Yes.
(iii). No.
l (iv). No.
I (v). No.
(c). Modeling techniques for rainout and dry deposition are set forth in:
" Proceedings of the FIRST SRL MODEL VALIDATION WORKSHOP (November 19-21, 1980) at Hilton Head, South Carolina," Melvin R. Buckner, compiler, E.I. du Pont de Nemours l
& Co., Savannah River Laboratory, Aiken, South Carolina 29808 DP-1597, CP&L Document No. 000141 (previously provided to Mr. Eddleman).
The above-cited article contains discussions of model accuracy, and where applicable, identifies tests that have been performed to evaluate various models.
c.
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
. )
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL
)
(Shearon Harris Nuclear Power Plant, )
Units 1 & 2) )
i f
APPLICANTS' RESPONSE TO WELLS EDDLEMAN'S REQUEST FOR PRODUCTION OF DOCUMENTS (CONTENTIONS 64(f),67 AND 80) j Pursuant to 10 C.F.R. S2.741(d), Applicants hereby respond to Wells Eddleman's
! Request for Production of Documents as contained in Wells Eddleman's General i
Interrogatories and Interrogatories on Contentions 64(f),67 and 80 to Applicants Carolina
~ Power & Light el al. (Third Set) by stating that the documents identified in Applicants' Answers to Wells Eddleman's GeneralInterrogatories and Interrogatories on Contentions 64(f), 67 and 80 to Applicants (Third Set) will be made available to Mr. Eddleman for inspection and copying in the following manner:
The requested documents will be made available at the corporate offices of Carolina Power & Light Company,411 Fayetteville Street Mall, Raleigh, North Carolina, I
i 27602. The documents will be made available during Carolina Power & Light Company business hours (or such other mutually agreeable time). Appointments to inspect the l documents may be arranged by telephoning Hill Carrow at 836-6839, at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i
before the requested inspection. Applicants will maintain the requested documents assembled in Carolina Power & Light Company offices available for inspection by l Mr. Eddleman, for a reasonable time (i.e., through August 29, 1983), after which they will
- be returned to their place of origin.
i
_ _ . . _ . - .-_m._ m_.,, , . - . . ..~,,m _,_,..,._r .,_m_-_._ - . _ ,,_ - m . - ,_________,-____m,
INTERROGATORY NO. 80-5(a) For each document previously made available to Wells Eddleman re contention 80, please state (i) whether CP&L or Applicants rely on any facts or fact in the document (ii) identify each such fact, and on what page(s) it appears in the document (iii) whether Applicants rely on any opinion expressed or quoted in the document (iv) identify each such opinion and the page(s) on which it appears. (b)
Please answer each part of (a) above for the document " Dispersion in the Vicinity of Buildings" (your response to 1st set of interrogatories, p.24) when you locate it.
ANSWER.
(a). OBJECTION. Applicants object to the interrogatory as propounded by Mr. Eddleman. The documents provided by Applicants in response to Mr. Eddleman's previous interrogatories on Contention 80 provide the basis of accumulated knowledge of the responding individuals. Although each of these documents addresses the question of atmospheric dispersion or diffusion in some manner, a speci.fic document may or may not have been used as a basis of " fact" in the preparation of analysis.for the SHNPP power plant. To identify each fact or opinion which may or may not have been used in the formulation of an atmospheric dispersion analysis is an undue burden, tantamount to having individuals who performed the analysis reiterate years of accumulated knowledge.
(b). This document is a part of the general working knowledge of Applicants' employees. No single fact contained therein was utilized as the basis for total atmospheric dispersion analysis.
INTERROGATORY NO. 80-6(a) Do Applicants know of any atmospheric diffusion or dispersion tests where the results were within 1% of those predicted by any model? (b) please identify each such test, its date, and all documents containing the model predictions and/or the results of each such test. (c) please state for each such test whether it was done at the site of (i) a nuclear power plant (ii) a nuclear facility of any kind (iii) a CP&L plant (iv) a CP&L nuclear' plant , where CP&L plants include those co-owned with NCEMPA and/or others.
ANSWER. Applicants do not know of any atmospheric diffusion tests with results within 1% of those predicted by any model.
INTERROGATORY NO. 80-7(a) What is the accuracy of prediction of atmospheric diffiusion models relied on by Applicants, compared to actual tests of diffusion? Please identify the numerical accuracy (plus or minus percent) of each such model, which test established such accuracy, and how such accuracy was calculated and whether it applies J
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to all predictions of such model. (b) Do Applicants know any reliable way to assess the accuracy of atmospheric diffusion or dispersal models as compared to actual test results? (c) If answer to (b) is affirmative, describe each such way, identify what model it is applicable to, what test results such way is applicable to for each such model, and whether CP&L uses the model in question, and whether NRC Staff uses the model in question "model in question" meaning any model you identify a way as applicable to. If a way is applicable to more than one model, answer each part of (c) for each such model; if more than one way exists, please list models to which each way applies, separately under each way. Then for each such model answer each part of (c) above. (d) for each way of assessing accuracy of models identifed above, please give all reasons and opinions you rely on for your statement that this way (i) is accurate (ii) is applicable to each model for which you say it is applicable (iii) is accurate for each such modeL ANSWER. Applicants did not perform tests to determine the accuracy of models utilized in the SHNPP analysis, but relied upon the work of those individuals in the scientific community who have the expertise to perform and evaluate such comparative tests. Applicants used the computer model"XOQDOQ," developed by Sagendorf and J. T.
Goll of the NRC (NUREG-0324) and the methodologies of Regulatory Guide 1.145 to
, perform atmospheric dispersion assessments at SHNPP. Both of the approaches appear in reference material previously supplied to Mr. Eddleman in response to interrogatories on Contention 80. The specific answer to the above interrogatory can be found in the j following documents previously supplied to Mr. Eddleman:
" Proceedings of the FIRST SRL MODEL VALIDATION WORKSHOP (November 19-21, 1980 at Hilton Head, South Carolina)," Melvin R. Buckner, complier, E.I. du Pont de Nemours
& Co., Savannah River Laboratory, Aiken, South Carolina 29808 DP-1597, CP&L Document No. 000141; and
' Technical Basis for Regulatory Guide 1.145, Atmospheric Dispersion Models for Potential Accident Consequences Assessments at Nuclear Power Plants," W. G. Snell and R. W.
Jubach, prepared for the NRC by NUS Corporation, 4 Research
! Pl&ce, Rockville, Maryland 20850, CP&L Document No. 000158.
i
. _ . . - -_~ -
INTERROGATORY NO. 80-8(a) Have (i) Applicants (ii) anyone working for Applicants (iii) NRC (iv) anyone else known to Applicants (state who if identity is known) actually tested dispersion of (1) any gases (2) Kr 85 (3) non-radioactive tracer gases (4)
, non radioactive particles (5) radioactive particles (6) radioactive gas other than Kr 85 (7) non-radioactive aerosols (8) radioactive aerosols released from (aa) the Harris plant site (bb) the Harris cooling tower (ce) the Harris 1 turbine deck (dd) the area of the Harris turbine (ee) the Harris steam vents (ff) the Harris radwaste stack (gg) the Harris containment (hh) any other part of the Harris plant -- please specify in detail which part
- (jj) any part of CP&L's Brunswick plant (kk) any part of the Robinson plant at Hartsville SC? (b) for each part of (a) above for which your answer is affirmative, please list each such test, the date, location of release (each location if more than one release point ) what was release from each release point, who did the test, who collected the data from the test, what protocols, plans, and measurements were used in making the
- test, what sampling equipment was used, where it was located, all specifications for test methods, releases and sampling equipment used in the test, and identify all documents containing the test plan, test results, specifications of equipment used during the test, including sampling and detection equipment, protocols for data collection, sampling or detection of material dispersed, and the duration of the test. (c) identify each person known to Applicants who performed each test identified in. response to (b) above, state
- their qualifications, what each such person did concerning the test, whether that person
- evaluated any test data (and if so, when), and state how such evaluation was performed.
(d) For each test identified in response to (b) above please state whether the test results
, were compared with the predictions of any model, and if so, what model, what
- predictions, what the results of the comparison were; please also identify all documents for each test in which such comparison (s) are made, and all documents which contain the prediction (s) of the model which were compared, and all documents which contain the specifications of the model which made those predictions. Please give the date of each such document, for each model and for each comparison, if known.
ANSWER. No. Applicants know of no atmospheric dispersion tests conducted at SHNPP, or at the Brunswick or Robinson plants.
l INTERROGATORY NO. 80-9(a) Have Applicants 'or anyone working for them made any study of rainout of radionuclides, or any investigation into rainout of radionuclides?
(b) If answer to (a) is affirmative, identify please all the documents in which such study i
or investigation is contained, each author of each such document, the date of each, indicate whether Applicants possess a copy, and state the opinions or facts in each such document on which Applicants rely, if any. (c) Are Applicants aware of any other i studies or investigations into rainout of radionuclides other than those identified in i response to (b) above? (d) If answer to'(c) is affirmative, please identify each such
! study, or investigation, all documents which contain each such study or investigation, and
- specify all information and all opinions therein upon which Applicants rely. Please also indicate if Applicants possess a copy of each such document.
3 ANSWER.
1 (a). No.
(b). Not applicable.
i (c). No.
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(d). Not applicable.
INTERROGATORY NO. 80-10(a) Are Applicants aware of any study or investigation of entrainment of radioactive gases in rain, snow, hail, thunderstorm or other precipitation? (b) if answer to (a) is affirmative, please identify all documents containing each such study or investigation, its results, its author (s), and state what facts or opinions therein Applicants rely upon, if any.
ANSWER. At this time, Applicants are aware only of those studies previously supplied for Mr. Eddleman's inspection in response to the first set of interrogatories on Contention 80.
This the 29th day of July,1983. ,
OBJECTIONS SUBMITTED BY:
O
\&)
Hill Carroiv Carolina Power & Light Company i
Post Office Box 1551 l Raleigh, North Carolina 27602 l Telephone: (919) 836-6839 Attorneys for Applicants:
Thomas A. Baxter, Esquire John H. O'Neill, Jr., Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D. C. 20036 l
Richard E. Jones, Esquire Samantha Francis Flynn, Esquire Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 i Telephone: (919) 836-6517
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of .
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN MUNICIPAL )
POWER AGENCY )
) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ) 50-401 OL Units 1 & 2) ) -
)
)
AFFIDAVIT OF LOUIS H. MARTIN County of Wake )
) .
State of North Carolina )
- Louis H. Martin, being duly sworn according to law, deposes and says that he is Manager - Nuclear Fuel Section of Carolina Power & Light Company; that the answers to Interrogatories on Contention 64(f) contained in " Applicants' Answers to Wells Eddleman's General Interrogatories and Interrogatories on Contentions 64(f),67 and 80 to l
i Applicants Carolina Power & Light Company, et al. (Third 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.
V Louis H. Martin Sworn to and subscribed before me this4#Nay of July 1983.
l // -
{- Notary >PublicW 9 Mye n! si a e res //[
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- _ . . . _ _ _ _ _ _ . - . _ , . _ _ _ . . _ - , ,, . _ , . _ , _ _ . . - . - . ~ , . . . - _ _ , _ _ . . _ . . .
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 ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclesr 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 - Radiological & Chemical Support Section of Carolina Power & Light Company; that the answers to Interrogatories on Contention 67 contained in " Applicants' Responses to Wells Eddleman's General Interrogatories and Interrogatories on Contentions 64(f), 67, and 80 to Applicants Carolina Power & Light Company, et al . (Third 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.
- k. B.N. H. Webster
/
Sworn to and subscribed before me this ,gg day of - , 1983.
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/$ w 0. M;A .ii Aj , T,fd,'
gptary Public V
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My Commission Expires: d a f, cQ 8 . / 9 8 5 Y;.w..Y '
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f . . . . .. . -
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of .
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN MUNICIPAL )
POWER AGENCY )
) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ) 50-401 OL Unite 1 & 2) .
)
)
)
AFFIDAVIT OF SHERWOOD R. ZIMMERMAN County of Wake )
)
State of North Carolina )
Sherwood R. Zimmerman, being duly sworn according to law, depose s and says that he is Manager - Licensing and Permits Section of Carolina Power & Light Company; that the answers to Interrogatories on Contention 80 contained in " Applicants' Answers to Wells Eddleman's GeneralInterrogatories and Interrogatories on contentions 64(f),67 and 80 to Applicants Carolina Power & Light Company, et al. (Third Set)" are true and correct to the best of his information, knowledge and belief; and that the sources of his imformation are officers, employees, agents and contractors of Carolina Power & Light Company.
l l '
. .W Sherwood R. Zimmer an Sworn to anct subscribed before me this,g8"5 day of July 1983.
,w s . . , ,, ,
.' bo - ( ;/
! N, S Notary Public ' j "
i j My commission expires: JT 8,..
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s Inspected documents which Mr. Eddleman wishes to have copied will be reproauced by Carolina Power & Light Company on a schedule compatible with other, demands for i duplicating equipment. A Carolina Power & Light Company employee,will be available during the inspection .in order to receive any requests for copying. Copies 'of such documents will then be furnished to Mr. Eddleman upon.payme'nt of 7 cents per page, to meet Carolina Power & Light Company's cost of reproduction. . .
Hill Carrow
' ~
CAROLINA POWER & LIGHT COM'P ANY Post Office Box 1551 Ralei (919) 836-6839 gh, North Carolina . 27602' ,
'~
Attorneys For Applicants: x Thomas A. Baxter John H. O'Neill, Jr.
SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N. W.
Washington, D. C. 20036 (202) 822-1148 ' -
Richard E. Jones '
Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 27602 _
(919) 836-6517 Dated: July 29,1983 d
s i
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'w July 29, 1983 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
)- 50-401 OL i AND NORTH CAROLINA EASTERN l
MUNICIPAL POWER AGENCY -)
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(Shearon Harris Nuclear Power
)
Plant, Units 1 and 2) ' )-
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CERTIFhCA'hION OF COUNSEL I hereby certify that I have made the following efforts to resolve Applicants' objections to certain of Wells Eddleman's Interrogatories (Third set), dated July 2,1983, regarding Conten-tions 64 (f) , 67 and 80.
I spoke with Mr. Eddleman by telephone on July 29, 1983, to discuss the nature of Applicants' objections. With respect l- to Contention 64 (f) bpent fuel shipping cask pressure relief valve),
Applicants believe that the substance of the contention has become moot because Applicants plan to remove the pressure relief valve on its spent fuel shipping cask prior to the next shipment of spent fuel. As noted in " Certification of Counsel," dated May 27, 1983, Applicants and Mr. Eddleman were involved in settlement negotiations regarding this issue. Unfortunately, the parties were unable to reach agreement regarding the withdrawal of Contention 64 (f) . Appli-cants had previously provided formal answers to Mr. Eddleman's inter-l 1
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. l rogatories regarding this contention and BR=11y provided additicmal information to assist settlement discussions. With the breakdown of settlement negotiations, Applicants object to providing additional, detailed information on valves that Applicants will not be using. Mr. Eddleman believes he is nonetheless entitled to such information.
Applicants also object to certain of Mr. Eddleman's inter-rogatories as seeking information not related to those contentions.
In one case Applicants objected to certain interrogatories that were too. confusing to formulate a response. Mr. Eddleman and I agreed that we would attempt to work out the substance of the ambiguous questions informally. Applicants advised Mr. Eddleman that in the future his interrogatories should be written in short sentences rather than one sentence that runs on for two or three single-spaced pages.
Finally, Applicants and Mr. Eddleman disagree again as to the permissible scope of Interrogatory Nos. G-8 and G-9.
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Jopn H. O'Neill, Jr. T
.S HhW, PITTMAN, POTTS & TR RIDGE 1 0 M Street, N.W.
ashington, D.C. 20036 (202) 822-1148 Counsel for Applicants Dated: July 29, 1983 l
D UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN MUNICIPAL )
POWER AGENCY )
) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ) 50-401 OL Units 1 & 2) )
) .
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CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Answers to Wells Eddlemen's General Interrogatories and Interrogatories on Contentions 64(f),67 and 80 to Applicants Carolina Power & Light Company, et a_1. (Third Set)", " Applicants' Response to Wells Eddleman's Request for Production of Documents", and Certification of Counsel were served this 29th day of July,1983 by deposit in the United States mail, first class, postage prepaid, to the parties on the attached Service List.
Hill Carrow Attorney Dated: July 29,1983
SERVICE LIST J5mes L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of North Carolina U. S. Nuclear Regulatory Commission 307 Granville Road Washington, D. C. 20555 , Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U. S. Nuclear Regulatory Commission Post Office Box 12643 Washington, D. C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter .
Dr. Richard D. Wilson - -
Atomic Safety and Licensing Board 729 Hunter Street U. S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D. C. 20555 Mr. Wells Eddleman Charles A. Barth, Esquire 718-A Iredell Street Myron Karman, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U. S. Nuclear Regulatory Commission Thomas A. Baxter, Esquire Washington, D. C. 20555 John H. O'Neill, Jr.
Shaw, Pittman, Potts & Trowbridge Docketing and Service Section 1800 M Street, N.W.
Office of the Secretary Washington, D. C. 20036 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Phyllis Lotchin i 108 Bridle Run
- Mr. Daniel F. Read, President Chapel Hill, North Carolina 27514 Chapel Hill Anti-Nuclear Group Effort Bradley W. Jones, Esquire Post Office Box 524 U. S. Nuclear Regulatory Commission Chapel Hill, North Carolina 27514 Region II 101 Marietta Street Dr. Linda Little Atlanta, Georgia 30303 Gsvernor's Waste Management Board 513 Albemarle Building Karen E. Long, Esquire
, 325 Salisbury Street Staff Attorney Raleigh, North Carolina 27611 Public Staff l
North Carolina Utilities Commission Ruthanne G. Miller, Esquire Post Office Box 991 Atomic Safety and Licensing Raleigh, North Carolina 27601 Board Panel U. S. Nuclear Regulatory Commission Wtshington, D. C. 20555 l
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