ML20078J736
| ML20078J736 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/12/1983 |
| From: | Oneill J CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | JOINT INTERVENORS - SHEARON HARRIS |
| Shared Package | |
| ML20078J565 | List: |
| References | |
| NUDOCS 8310170620 | |
| Download: ML20078J736 (15) | |
Text
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00CKETCO USNRC October 12, 1 3 00T 14 p j dg 9 ncE c= ::c::c,
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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AND NORTH CAROLINA EASTERN
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Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY
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S0-401 OL
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(Shearon. Harris Nuclear Power
)
Plant, Units 1 and 2)
)
APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO JOINT INTERVENORS (FOURTH SET)
Pursuant to 10 C.F.R. SS 2.740b and 2.741 and to the Atom-ic Safety and Licensing Board's " Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference)" of September 22, 1982, Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that Joint Intervenors (Kudzu Alliance, CCNC, CHANGE /ELP & Wells i
Eddleman) answer separately and fully in writing, and under oath or affirmation, each of the following interrogatories, and produce and permit inspection and copying of the original or 8310170620 831012 PDR ADDCK 05000400 Q
r-best copy of all doc'ments identified in the responses to the u
interrogatories below.
Under the Commission's Rules of Practice, answers or objections to these interrogatories must be served within 14 days after service of the interrogatcries; responses or objections to the request for production of documents must be served within 30 days after service of the request.
These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. 5 2.740(e),
should Joint Intervenors or any individual acting on their be-half obtain any new or differing information responsive to these interrogatories.
The request for production of documents is also continuing in nature and Joint Intervenors must produce immediately any additional documents they, or any individual i
acting on their behalf, obtain which are responsive to the re-quest, in accordance with the provisions of 10 C.F.R. 5 2.740(e).
l Where identification of a document is, requested, briefly describe the document (e.g.,
book, letter, memorandum, transcript, report, handwritten notes, test data) and provide the following information as applicable:
document name, title, l
number, author, date of publication and publisher, addressee, i
date written or approved, and the name and address of the
' person or persons having possession of the document.
Also state the portion or portions of the document (whether.
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j/7 Defini ti'ogs :
As used hereindfter, the following defini-tions shall tppip The "EN" is 'tihe Environmental Report - Operating License
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Stage for the Shearcr? Harris Nuclear Power Plant, as amended.
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" Applicants" is intended to encompass Carolina Power &
1 Light Company, Nortil Carolina Eastern Municipal Power Agency
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. m and their contractore[for.t'rd Harris Plant.
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" Joint Intervencrs* ~is intenhied to encompass the following l,4 orgsni$ations and indviduals, jointly and severally:
Chapel s
Hill Ant'i-Nuclear Group Efforti, the Environmental Law Project, the Conservation. Council' of North Carolina and the Kudzu Alli-
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.ance, at organizations, t$ir' members, and their representa-1.tives, and Mr. Wells Eddleman.
" Document (s)" means all writinis and records of every type J
in I.he possession, control or custody of Joint Intervenors or t
s any ' individual acting on their behalf, includir g, but not lim-ited to, memoranda,correshoondence, reports, surveys, tabu-lations, charts, books, pamphlets, photographs, maps, bulle-L tins, minutes, notes, speeches, articles, transcripts, voice i
recordings and all other writings or recordings of any kind;
" document (s)\\ shall also mean copies of documents even though c!;
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the originals thereof.are not in the possession, custody, or
'l 4i control of JointiIntervenors; a document shall be deemed to be within the ' control" ef Joint Intervenors or any individual o
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i acting on their behalf if Joint Intervenors or the individual acting on their behalf have ownership, possession or custody of the document or copy thereof, or have the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.
General Interrogatories 1(a).
State the name, present or last known address, and present or last known employer of each person known to Joint Intervenors to have first-hand knowledge of the facts alleged, and upon which Joint Intervenors relied in formulating allega-tions in the contentions which are the subject of this set of j
interrogatories.
(b).
Identify those facts concerning which each such person has first-hand knowledge.
(c).
State the specific allegation in each contention which Joint Intervenors contend such facts support.
2(a).
State the name, present or last known address, and present or last employer of each person, other than affiant, who provided information upon which Joint Intervenors relied in answering each interrogatory herein.
(b).
Identify all such information which was provided by each such person and the specific interrogatory response in which such information is contained.
2, - -.. - __
3(a).
State the name, address, title, employer and educa: ion and professional qualifications of each person Joint Intervenors intend to call as an expert witness or a witness relating to the contentions which are the subject of this set of interrogatories.
(b).
State the subject matter to which each such person 4
is expected to testify.
4(a).
Identify all documents in Joint Intervenors' possession, custody or control, including all relevant page ci-tations, pertaining to the subject matter of, and upon which Joint Intervenors relied in formulating allegations in the con-tentions which are the subject of this set of interrogatories.
(b).
Identify the contentions to which each such document relates.
(c).
State the specific allegation in each contention which Joint Intervenors contend each document supports.
5(a).
Identify all documents in Joint Intervenors' possession, custody or control, including all relevant page ci-tations, upon which Joint Intervenors relied in answering each interrogatory herein.
(b).
Identify the specific interrogatory response (s) to which each such document relates.
6(a).
Identify any other source of information, not pre-1 viously identified in response to Interrogatory 2 or 5, which was used in answering the interrogatories set forth herein.
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(b).
Identify the specific interrogatory response (s) to which each such source of information relates.
7(a).
Identify all documents which Joint Intervenors intend to offer as exhibits during this proceeding to support the contentions which are the subject.of this set of interrogatories or which Joint Intervenors intend to use during l
cross-examination of witnesses presented by Applicants and/or the NRC Staff on the contentions which are the subject of this set of interrogatories.
(b).
Identify the particular page citations of each document applicable to each contention.
INTERROGATORIES ON JOINT CONTENTION IV (TLD'S)
IV-S(a).
Which of the following radiation types and ener-gy ranges do Joint Intervenors believe to pose significant I
external exposure hazards to the safety and health of workers at Shearon Harris Nuclear Power Plant ("SHNPP")?
l (i)
Gamma below 1 mev; (ii)
Gamma 1-10 mev; (iii)
Gamma above 10 mev; (iv)
Beta below 100 kev; (v)
Beta 100-1000 kev; (vi)
Beta 1000-10,000 kev; (vii)
Beta 10,000-100,000 kev; (viii)
Beta 1,000,000-1,000,000,000 kev; i..
(ix)
Beta above 1,000,000,000 kev; (x)
Alpha, specifying the energy range believed to pose significant external exposure hazards to the safety and health of workers at SENPP; (xi)
Neutrons, specifying the energy range believed to pose significant external exposure hazards to the safety and health of workers at SENPP; (xii)
Protons, specifying the energy range believed to pose significant external exposure hazards to the safety and health of workers at SHNPP; (xiii)
Any other radiation, specifying the energy range believed to pose significant external exposure hazards to the safety and health of workers at SHNPP.
(b).
For each radiation type and energy range identified in response to IV-8(a), describe in detail all facts which i
support Joint Intervenors' belief that such radiation poses a significant external exposure hazard to the safety and health of workers at SHNPP.
(c).
For each radiation type and energy range listed in Interrogatory IV-8(a) but not, included in Joint Intervenors' response thereto, explain how monitoring such radiation is rel-evant to Joint Contention IV.
(d).
For each radiation type and energy range identified in response to IV-8(a), identify the major radionuclide sources within SHNPP from which such radiation is believed to be l
emitted and state the relative amount of radiation which Joint Intervenors expect to result from each source.
Describe in de-tail all facts which support this conclusion.
(e).
For each radiation type and energy range identified in response to IV-8(a), state the relative amount of exposure to workers that is expected to occur'from such radiation com-pared to other radiation types and energy ranges and describe in detail all facts which support this conclusion.
(f).
For each radiation type and energy range identified in response to IV-8(a), state the level of accuracy which Joint Intervenors believe is necessary to assure worker health and safety.
(g).
With regard to each level of accuracy stated in re-sponse to IV-8(e), list all regulatory guides, NRC regulations and recommendations of nationally or internationally recognized associations which support your response.
(h).
With regard to each level of accuracy stated in re-sponse to IV-8(e), describe in detail all facts other than those listed in response to IV-8(f) which support Joint Inter-i venors' conclusion that such accuracy level is necessary to as-sure worker health and safety.
IV-9(a).
Do Joint Intervenors believe that TLD's are inade-quate to measure any of the radiation types and energy ranges identified in response to IV-8(a)? -_
(b).
If the answer to IV-9(a) is affirmative, for each radiation type and energy range for which Joint Intervenors believe TLD's are inadequate, describe in detail all facts which support this conclusion.
(c).
If the answer to IV-9(a) is other than affirmative, explain in detail huw this response is consistent with the al-legation set forth in Joint Contention IV.
IV-10(a).
Define the term " portable pressurized ioniza-tion chambers."
(b).
Do Joint Intervenors contend that portable pressur-ized ionization chambers can be used to monitor the exposure of workers with greater accuracy than TLD's?
(c). If the answer-to IV-10(b) is affirmative, explain in detail how the results from an off-the-body instrument (porta-ble pressurized ionization chamber) can corroborate exposures measured by an on-the-body dosimeter (TLD).
Explain specifi-cally how the following variables in off-the-body measurement can be accounted for in determining the cumulative radiation exposure of a worker:
(i)
Spatial variations in the exposure rate within the work area; (ii)
Variations over time in the exposure rate at any specific location within the work area; i
l (iii)
The movement of workers within non-uniform radi-i ation fields;
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4 (iv)
Gradients in the exposure rate over the worker's-body at any given location within the work area; (v)
The variable amount of time spent by the worker in the radiation field.
(d).
If the answer to IV-10(b) is other than affirmative, explain in detail how this response is consistent with the al-legations set forth in Joint Contention IV.
IV-11(a).
Do Joint Intervenors contend that a portable pressurized ionization chamber is capable of measuring each ra-diation type and energy range listed in response to IV-8(a)?
(b).
If the answer to IV-11(a) is affirmative, provide the model, manufacturer and specifications, including sensitiv-ity, range, accuracy and reproducibility of results for each radiation type and energy range listed in response to IV-8(a).
(c).
If the answer to IV-11(b) is other than affirmative, describe in detail how this response is consistent with the re-sponse to IV-8(a) and the allegations set forth in Joint Con-tention IV.
IV-12(a).
Are Joint Intervenors aware of any commercially available portable pressurized ionization chamber that is suit-able for corroborating TLD measurements of radiation dose to workers?
(b).
If the answer to IV-12(a) is affirmative, provide the model, manufacturer and specifications, including sensitiv-ity, range, accuracy and reproducibility of results for each..- _ - - _
radiation type and energy range listed in response to IV-8(a) above.
(c).
If the answer to IV-12(a) is other than affirmative, describe in detail how this response is consistent with the al-legations set forth in Joint Contention IV.
IV-13(a).
Do Joint Intervenors have knowledge of any nu-clear power plant that routinely uses portable pressurized ion-ization chambers to corroborate radiation doses to workers measured by TLD's?
(b).
If the answer to IV-13(a) is affirmative, for each such power plant state:
(i) the facility name; (ii) the address; (iii) the name of the person responsible for occupa-tional radiation exposure control; (iv) the model, manufacturer and specifications, including sensitivity, range, accuracy and reproducibility of results of the portable pres-surized ionization chamber used by each facili-ty.
IV-14(a).
Define "real time monitoring" and cite to any sources upon which you rely in support of this definition.
(b).
Do Joint Intervenors contend that TLD's lack "real time monitoring" capability?
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(c).
If the answer to IV-14(b) is affirmative, describe in detail all facts upon which Joint Intervenors rely in support of this allegation.
(d).
If the answer to IV-14(b) is other than affirmative, explain in detail how this response is consistent with the al-legations set forth in Joint Contention IV.
(e).
If the answer to IV-14(b) is affirmative, do Joint Intervenors contend that the lack of real time monitoring capa-bility poses a significant health hazard to workers at SHNPP?
(f).
If the answer to IV-14(e) is affirmative, describe in detail all facts upon which Joint Intervenors rely in support of this allegation.
(g).
If the answar to IV-14(e) is other than affirmative, explain in detail the significance of the alleged lack of real time monitoring capability.
IV-15(a).
In response to Interrogatory IV-2(b) on Joint Contention IV, Joint Intervenors stated that TLD's are inade-quate to measure cumulative radiation doses as required by 10 C.F.R. Part 20 and ALARA because "plus or minus 30% is too in-accurate."
State where Joint Intervenors obtained the "plus or minus 30%" figure and describe in detail all facts that support the assertion of this figure.
(b).
Explain in detail why Joint Intervenors believe that plus or minus 30% is too inaccurate to ensure compliance with 10 C.F.R. Part 20 and ALARA.
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IV-16(a).
Applicants' use of TLD's complies with the standards of ANSI N13.ll, as documented in NUREG/CR-2891 and NUREG/CR-2892.
Do Joint Intervenors contend that the ANSI per-formance criteria are not sufficient to ensure TLD accuracy?
(b).
If the answer to IV-16(b) is affirmative, explain in 4
detail all facts upon which Joint Intervenors rely in support of this response.
(c).
If the answer to IV-16(a) is other than affirmative, explain in detail how this response is consistent with the al-legations set forth in Joint Contention IV.
INTERROGATORIES ON JOINT CONTENTION V (PORTABLE AIR SAMPLERS AND CONTINUOUS AIR MONITORS) l V-5(a).
Define the term " continuous air monitor" and in-dicate how it is distinct from the term " portable air sampler."
l Describe in detail all facts upon which Joint Intervenors rely 1
in support of this response.
(b).
Describe in detail the purpose for which Joint In-tervenors believe continuous air monitors are used at SHNPP.
(c).
Describe in detail the purpose for which Joint In-tervenors believe portable air samplers are used at SHNPP.
V-6(a).
Explain in detail the bases for Joint Interve-I l
nors' assertion that ALARA requires "minimizat' ion" of radiation l
l exposure (quoting Joint Intervenors' response to Interrogatory l
l V-1(b)).
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(b).
Explain in detail the bases for Joint Intervenors' assertion that ALARA requires portable air samplers and continuous air monitors to be "as accurate as possible" (quoting Joint Intervenors' response to Interrogatory V-3(b)).
V-7(a).
Explain in detail the bases for Joint Interve-nors' assertion that portable air samplers and continuous air monitors must be accurate within plus or minus 5%-
(b).
Do Joint Intervenors know of any commercially avail-able continuous air monitors or portable air samplers that can be calibrated and maintained within plus or minus 5%?
(c).
If the answer to V-7(b) is affirmative, state the model, manufacturer and specifications, including sensitivity range, accuracy and reproducibility of results for each radia-tion type listed in response to IV -8 ( a ) above.
(d).
If the answer to V-7(b) is other than affirmative, explain in detail the bases for Joint Intervenors' belief that plus or minus 5% accuracy is reasonably achievable.
V-8(a).
Explain in detail the basis of Joint Intervenors' belief that calibration of continuous air monitors and portable air samplers once every six months is inadequate to provide as-l surance of complianen with ALARA.
(b).
Explain in detail the facts upon which Joint Inter-venors rely in support of their assertion that calibration of continuous air monitors and portable air samplers must be performed once a month.
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O Recuest for Production of Documents Applicants request that Joint Intervenors respond in writ-ing to this request for production of documents and produce the
, original or best copy of each of the documents ident f ei i d or described in the answers to each of the above interrogatories at a place mutually convenient to the parties.
spe tfully s bmitted, I
,l Jch H.
O'Neill, Jr.'l )
Pame a H. Anderson l
l SHAW PITTMAN, POTTS d10WBRIDGE 180 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Richard E.
Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O.
Box 1551 Raleigh, North Carolina 26602 (919) 836-7707 Dated:
October 12, 1983 i
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