ML20078M153
| ML20078M153 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/21/1983 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | CAROLINA POWER & LIGHT CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8310250037 | |
| Download: ML20078M153 (18) | |
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UNITED STATES OF AMERICA DOCKETED
-USNRC NUCLEAR REGULATORY COMMISSION
/4 BEFORE THE A'lVMIC SAFETY AND LICENSING BOARD 0F SECREwn" Glenn O. Bright Dr. James H. Carpenter
""'$hcV James L. Kelley, Chairman In the Matter of Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )
Units 1 armi 2) J
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Wells Eddleman's General Interrogatories 6pd Idf6WefMuW to Anolicants Carolina Power & Light et al. Ce M445'lsbh
~ TFl*df2 IsixtF) Set)
F Kr-93 + 3-lo-93 +
Under 10 CFR 2.7h0, 2.7h1 and the Board's 9-22-82. Memorandun(s) and OrdehWells Eddleman recuests Applicants to answer separately ,
and fully in writing, under oath or affirmation, each of the following interrogatories, and to produce a permit insuection and conying of the original' or best copy of all document's identified in resnonse to interrogatories as set forth below. -
l These interrogatories are intended to be continuing in nature, and I reouest each answer to be uromotly su plemented on anended as anurocriate unde" 10 CFR P.714 d(e), should CP4E,, NCFMPA, .any othe=
or any contractor or consultant to any, sone or all cf those, Apolicant, Aor 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 resnonsive to these list 5ng(s))
(w generpa 4"Them"refe=stotheprecedingororoductionofdocuments-interrogatorie . The reouest is also-continuing and reouests Applicants to oroduce promotly if
. not inmediately any additional documents the Applicants and others acting on their Whalf or employed by them, as lis'ted in the previous 8310250037 831021 /
PDR ADOCK 05000400 l .
C PDR h
2 csntsnes, obtain which cra rosponsivo to the raquast(s) for nroductio'n of docunents below.
Where identification of a document is reauested, clease briefly describe theVdocumeht (e.g. book, notebook, letter, memo, renort, notes, transcript, minutes, test data, log, etc.) and provide the following information as Ennlicable: document name, title, number, author (s), date of writing or of publication or both, addressee, the date annroved, by whom annroved, and the name and address of versens hahng normal custody of tha document, and name and addvess of any nerson other than the preceding having actual possess?on of the document. When identifying documents in restonse to these interroEatories and reouests, please state the nortion or nortiens of the document (e.g. sections, chafrs, pages, lines) ueon which Applicants rely or which A licants swear or affirm is/are responsive to the applicable interrogatory or veouest.
DEFINITIONS herein:
" Harris", " Harris Plant", "SENPP", or " plant" where not specified i
otherwise, all mean the Shearon Harris Muelear Power Plant.
consultants,
" Applicants" means all of the persons, emuloyees, contractors and corporations as listed in the first sentence of the l second paragraph on page 1 of this document, above.
"FSAR" means the Harris Final Safety Analysis " evert.
"ER" means the Harris Environmental Fenort.
" Document ($" means all writings and records of ever7 t yne, including electronic and emuter records, in the possessien, control licarts' or custody of Ayplicants or any individual (s) act$ng on A behalf, including, but not linited to: venorts, books, memorande, corresnondence, notes, minutes, paghlets, leaflets, magazines, articles, surveys, maps, bulletina, photogranhs, speeches, transcripts,
voico recordings, com7utar printouts, information stor3d !n computers or comnuter 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 evsn though the oriEi nal(s) are not in the possession of Applicants or in their custody or controit Document (s) shall be deemed to be within the any controlofAplicantsorindividual's)actingontheirbehalf if they have ownership, ossession, or custody of the document (s) or a co{y thereof, or have the right to secure the document (s) of a copy thereof, from any person or public or rivate entit7 having ph7sical possession thereof.
EPch definiti.on 6 1ven above a lies within all other definitions above.
GSNEhAb IW&kOb0Y G1 (a) Which contentiens of Wells Eddleman do Applicants agree are now admitted in this croceeding, N*C Dockets 50-400/401 0.L.?
(b) for each such contentien, provide for any answers to interrog-stories by Wells Eddleman which Aunlicants have previously or uresently received (except those suspended by Board order, if any), the following information:
(c) Pisase state the name, present or last known address, and cresent or last known emoloyer of each person whom Aeolicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) uuon whom Applicants relied ( other than their attorneys) in making such answer.
(d) ulease identify all facts concerning which each such verson i
iderHfied in resconse to G1(c)(1) above has first-hand knowledFe.
(e) please identify all facts and/or documents upon which each l nerson identified in response to G1(c)(2) above relied in pro #iding informationtorespondtotheinterrogaton,includingtheparts of such documents relied ueon.
l l - - - _ . _ - . .-
tr ftl(Ed afW l licants (f)'Please identify any other documsnt(s) used/by A 1 j
in responding to the interrogatory.
(g) Please state which specific fact each docunent, identified !
in resoonse to G1(e) and GL(f) above, sunports, in the ooinion er i belief of Anelicants, or which Aunlicants allege such docunent supeorts.
(h) Please state specifically what information each nerson identified in resconse to 01(c)(1) or G1(c)(2) above trovided to If any i
cr for Anplicants' affiant in answering the interrogatory.
of this information is rot docunented, nisase identify it as "undocunented" in resnonding to this sect".on of General InterrcFato7 Gl.
02.{a)*1easestatethenane,presentorlastknownaddress, title (if any), and present or last known sy loyer, and econonic interest (shareholder, bondholder, contractor, ewlo7ee, etc. ) if or other any (beyond exnert witness fees) such verson holds in Applicants or expect or an7 of them, for . each verson you intendj to ce.11 es an . expert witness or a witness in this proceeding, if such informetion has not oreviously been supnlied, or has changed since such information was last sucplied, to Wells Eddlenan. This applies to Eddlenen by Aunlicants.
and Joint Contentions as admitted'ntentfono* st nulated regarding which each (b). *1 ease identify each co such person is exoected to testify.
(c) Please state when you first contacted each such person with regard to the possibility of such nerson's testifying for l
l Apolicants, if you have contacted such person.
(d) Please state the subject natter, separately for each contention as to which each such person is expected to testify, whicheachsuchpersonisexpectedtotestifyto.
(e) Please identify all documents or earts thereof ueon which each such witness is expected to, vlans to, or will rely, in testifying or in preparing testimony.
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5 G3(a) Please identify any other souwce(s) of information which Applicants have used to resnond to any inteyrogatory identified under G1 above, stating for each such source the interrogatory to which it relates, and what informntien it provides, and identifying where in such source that information is to be found.
(b) Please identify any other sourceh)of information not urevicusly identified upon which any witness identified under G2 above, or or exhibits other witness, has used in nrenaring 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 so urce (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 G4(a) please identify all documents,gpages or sections thereof Applicants intand or expect to use in cross-examination of any witness I call in this hearing. For each such witness, please urovide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject matter Annlicants believe they relate to, and nake the document (s) available for inspection form intent and conying as soon as possible after Ap licants decide orpixismi 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.
G5 (a) for each contention Apelicants state or admit is an ad itted Eddleman contention under 01(a) above, or an admitted joint intervenor contention, please state whether Anplicants have available to them experts, and information, on the subject matter of the contention.
(b) If the answer to (a) above is odder d2an affirmative, state whether Annlicants exnect to be able to obt&in exnertise in the subject matter, and inthrmation on it, and if not, why not.
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G-6(a) f or 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) cil authors of the document, on 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 nart, section or uage identified in resnonse to (v) above contains.
(vii) identify all documents used in orenaring the docunent, to the extent known (and also to the extent not identified in the docunent itself)
(viii) state whether Arplicants possess a co"y of the doc ument (ix) state all expert opiniors contained in the document, upon which Apolicants rely, or identify each such oninion.
(x) identify the contention (s) with resnect to which Ann 1? cants rely upon (a) the exnert ocinions (b) the facts identified in the docunent (xi) state whether Apolicants now ennloy any author (s) of _ the document, identifying each such person for each docunent.
(xii) state whether Applicants have ever emoloyed any authdis) of the docunent, 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 grouted for efficiency.
G-7(a) Please identify all documents which Applicants plan, exnec? or a 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 euvrent resnonse to G1(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 Anplicants nian, expect or intend to use in cross-exanination of any other parties' witnesses or joint intervenor witness in this proceeding, with resnect 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 conter. tion now adnitted in -
this proceeding; (iii) per our agreement of h-8-83, each contention of each other party to this nroceeding which is cu=rently adnitted.
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 identif3ed in response (i) to (b) above will be offerad into evidence by Anolicants, and (11) which of the same documents Aunlicants expect to offer into evidence or intend to offer as evidence or exhibits in this roceeding.
G-10(a)
Sdd!by'SPddhC i Where the above general interrogatories, or any of then, hd@ N5h % -
l call for identification of documents, (1) and no documents are l identified, is that the sane as Apnlicants stating that there
! are no documents resnonsive to this general interrogatory, in each l
case where no documents are identified? (ii) and documents a_re identified, is that the same as Applicants stating that the identified '
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l
-8 documents are the only ones presently known which are responsive l 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)(i) above is other than affirnative, 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 response, is that the expert opinion of any person (s) identified as having contributed information to that response? (ii) and facts are given or identified (or a fact is) in resnonse, but no documents are identified, does that mean Applicants have no documents containing such fact (s)?
(iii) If your answer to (1) above is affirmative, please state for each each such response all qualifications of . expert unon whom 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 (1) above is other than affirmative, please state which oninions, if any, given in response to. interrogatories (general or snecific) herein is the opinion of an expert, identify each expert whose opinion you used in response to each interrogatory, and- state in full the qualifications of each such expert. (v) If your answer to (1) i above is other than affirmative, please identify all opinions of non-experts used in your resconses, and identify each non-expert whose opinion is included in each answer herein.
(vi) If your response to (ii) above is other than affirmative, please _dentify each document which contains a fact not previously documented in your resnonse(s), stating what the fact "s, and at what page, place, chapter or other specific part the docunent contains such fact.
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G-11 For each answer to each interrogatory herein (or any subpart or part thereof), please identify each iten of information in possession of Applicants (including facts, opinions of experts, and documents ) which (a) contradicts the answer you made, (1) in whole (ii) in part (please identify each such part for each iten of information identified); (b) easts doubt on your answer (1) in whole (ii) in part (please identify each such part for each iten of information identified). (c) Please identify all docunonts not already identified in resnonse to narts (a) and (b) above (and their subparts) which contains any iten of information asked for in (a) or (b) above. Please identify for each such document what information iten(s) it contains and what answer (s) each such iten is related to.
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SPECIFIC INTER #0GATORIES on Contention 15AA (note that #'s 20,25,28,29,37,38,39 are in 1.st set) 15AA-(2d)-16: To the extent answers have not been ureviously nrovided, please answer each of the above General Interrogatories with respect to the interrogatories (and each of them, where aunlicable) you answered re 15AA in your filing of 9-16-83, entitled " Applicants' Answers to Wells Eddlemen's Initial Interrogatories Relating to
.i Eddleman Contention 15-AA".
15AA-(2d)-17(a) Does CP&L have an estimate of the length of refueling outages (or of a typical refueling outage) for the Harris nlant?
(b) If answer to (a) is affirmative, what is that estimate in terms of time per refueling outage? (c) Please state succinctly all significant bases CP&L relies upon in estimating ths length of refueling outages for Harris. If the outages are estimated to differ in lenghth, please epxplain all significant reasons for such variations in length of time per refueling outage. (d) Did anyone besides CP&L contribute to your estimate of length of refueling outage (s) for Harris? (e) If answer to (d) is affirmative, please identify each such verson (or organization if the organ!zation provided information but you don't know which verson(s) provided the information. (f) How long do you estimate Harris will normally operate (hours or other units of time) between refueling outages?
(g) Has anyone besides CP&L (e.g. Westinghouse, Ebasco, etc) estimated how long the Harris plant will normally operate between refueling outages?
(h) If answer to (g) is affirmative, ple ase state each such estimate you possess. (j) Please state all significant bases known to you for each estimate given in response to (f) or (h) above, identifying the person (s) (or organizations where no persons are known to you but the organization provided information for the estimate) who contributed to or made or prov$ded (i) the estimate (ii) any basis for each enstimate.
(1) Has CPAL or anyone else known to you estimated the frequency of (1) reactor trips (ii) turbine trips (iii) reactor scrams (iv) forced outages (v) deratings of output (electrical or thermal or both) (vi) partial forced outages, for Harris 1, Harris 2, or both units?
(m) For each part of (1) above for which your answer is affirmative, please state the estimate, who made it, when it was made, what documents Uf any) contain it, and state all significant bases for each such estimate, including any expert opinions, documents or nortions thereof, and other information known to you which was used in making such estimate.
Please provide all the above information (as roquested in "(m)") for each estimate.
(n) Has CP&L or anyone elase known to you estimated (i) the availability (ii) the equivalent availability of (aa) Harris 1 (bb)
Harris 2 (cc) both Harris units? (o) If answer to (n) above is affirmative, please (1) define the terms " availability" and "' equivalent availability" as they were used for each such estimate (giving any different definitions used anzd stating the estimates to which each such definition applies),
(ii) explain any authority or other basis for each definition of (Cb)
" availability" (hb) " equivalent availability" used; (iii) state who made the estimate, when, and state all significant basis for each such estimate which you know. (iv) give the estimate, in percent, hours ner year or whatever other form you possess the estimate in, stating to which unit (s) it applies.
(p) Please identify each person you know of who contributed (i) information or (ii) expert opinion to each estimate given in resnonse to (o) (iv) above, or otherwise made or known to you, with respect to (aa) availability (bb) equivalent availability, for Herris 1, 2, or both, stating for each such person what information or oninica or both each contributed, to which estimate (s),
(q) Exactly what information concerning planned maintenance did you use from the Robinson Plant (Robinson Unit 2) (see your 9-16-83 response to my interrogatory #25 on 15AA) in making estimates of planned maintenance for Harris? Please include in your answer (but do not limit it to ) oxactly what experience data was used, and exactly how it was used, including all relevant calculations or computations; enzactly what projections were used, wno made them, how each was made, when it was made, what calculations were made in making each such projection, what data was used in the calculations (and in each such calculation), where the data used came from (including identity of all documents containing it), and any other opinions or information you relied on making these nrojections, stating such data for each such projection. Please nrovide sufficient data and statement of calculations that the results of the calculat$ ons can be checked from the original data dnd calculational procedures given.
(r) Did you take the possibility or likelihood or consequences of additional NRC regulations into account in any way in preparing gour estimates of Harris Planned Maintenance filed 6/30/82 (the PURPA 133 documer.t" referred to in your response to interrogatory 25 on 15AA)? (s) If answer to (r) is affirmative, please state what you took into account re NRC regulations, and exactly how you did it, including any data, documents, or expert opinions or other information you relied on, stating for each how it was used in mdking your estimate.
(t) Does CP&L have any estimates made since the estimates filed 6/30/82 under PURPA Section 133 (widh NCUC and /or FE90) as to the amount of Planned maintenance for Harris? (u) If answer to (pt) if affirmative, please provide (i) each such estimate (ii) Who made it and when (iii) the purpose, if any, for which it was made (iv) for euch estimate, all significant bases of such estimate, all data used in making it, all expert opinions or other information relied on in making it, and a statement of each calculation used in making it (including any data input to each calculation, giving the source of each datum (item of data) used as input to a each such calcule. tion).
(v) (i) Please define the term Equivalent Forced Outage Rate (EFOR) which you use in your response to item 17 in interrogatory 25 (9-16-83 at page 6 of your response) (ii) Does CP&L believe that Harris will have the same EPOR as an average nuclear unit during the period 1971-80?
(iii) If answer to (ii) is affirmative, please state all basis for your belief, including all documents or portions thereof, conclusions, calculations, statistics or exnert opinions or other information you rely on. (iv) Does CP&L possess EPOR data for nuclear units (a) uve-commercial operation (bb) in commzercial oneration, for (cc)1979 (dd) 1980 4
(ee)1981 (ff) 1982 (gg) any part of the period 1-1-79 to the eresent?
(v) Please identify each document which contains EPOR data required
, under part (iv) abcys, identifying for each which units are new in commercial operation, and what time period the data covers.
(w) Did CP&L take into account NRC-ordered shutdowns in estimating (i) capacity factor (ii) planned maintenance (iii) forced outage rates (iv) EPORs (v) availability (vi) equivalent availability,nfor Harris?
(x Do a C ny estimates of any or all of the 6 items inquired abo)utfliP&Lhave vi) in ( )above,te for Harris or made bv anyone else?
estima for wMch prenared byyour answey a any natt (y) Please of (w) or (give enex) above (or to all of (x)) is affirmative, and ulease state
who made it, when, for what purpose (if known), and all significent bases of said estimate which you know.
! 15AA-(2d)-18(a) In response to Interrogatory 3 on 15AA, you cite " utility operating experience"; in resucnse to Interrogatory 7 on 15AA you cite " nuclear industry experience for units similar to the Harris units"; in response to Interrogatory 8 thereon, you cite
" industry experience"; in response to IRterrogatory 13 thereon you cite"' general industry experience"; in response to interrogatory 39 thereon, you cite " industry experience with units a similar to the Harris units." For each of these statements, are you referring to - actual experience of capacity factors for nuclear units?
(b) If your answer to (a), for any quote cited therein, is other than affirmative, please explain for each such cited language excerpt, what the " experience" is you are referring to, stating whether it is for nuclear units or not, what time (s) if any you are referring to experience in, and what way you use this " experience" in estimating capacity factor.
(c) Does CP&L believe that actual canacity factors in commercial operating experience for nuclear power plants are useful in (i) projecting capacity factors of similar nuclear nower n1 ants (ii) projecting capacity factors of new nuclear plants made by the same manufacturer (iii) projecting capacity factors of new nuclear plants of the same type (i.e. PWR, EWR, HTGR, etc ): please answer specifically for PWRs (iv) in making estimates of the net output of new nunclear plants?
(d) Please state the basis for your answer to each part of (c) above, including all expert oniniens, documents, studies or facts or other information you rely on.
(e) Do you (or anyone working for you) recall whether CP&L was the one who provided the information to the NC Utilities Commission in its Docket E-2 sub 203 (Harris plant certificate of convenzience and necessity) that Harris was similar to Beaver Valley and North Anna?
(f) If answer to (e) is affirmative, did SP&L nrovide the information that Harris was similar to (i) Beaver Valley (ii) North Anna (iii both?
(g) Is Harris in fact similar in desi (11; North Anna I (iii) North Anna 2 (iv)gn VC to (i) Beaver Summer, Valley to your I knowledge?
(v) If your answer is affirmative to any part (1) thru (iv) above, please state the similarities of NSSS design, manufacturer of NSSS (Nuclear Steam Supply System), and any other characteristic you know which is relevant to capacity factor, for each such plant for which your answer is affirmative.
(h) If your answer to any part of (g) above i= other than e.ffirmative, please state all basis for your answer, including any opiniens or documents you rely on.
$j) Does CP&L know what the average capacity factor of (i) Westinghouse nuclear plants of 800 MWe and up (lifetime, DER basis ),
(ii) Westinghouse nuclear plants of 900 MWe and un (lifeti me , DER basis )
is? If so, please state these averages and the date at which they are computed (e.g. as of 6-30-83).
(k) Does CP&L have any opinion as to why its Brunswick units
. have the lowest lifetime DER capacity factors of any two commercial electricity generating BWRS over 300 MWe (design capacity) in the US?
(1) If answer to (k) is affirmative, what is that opinion? Please state all facts you rely on to support that opinion.
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'(m) Does CP&L believe there are reasons for the noor nerformance (CJ$)
of _ the Brunswick n clear units it co-owns and onerates that relate to i
gRfregulationsconstruction (v CP&L( i)noncompliance design (iii) operation (iv) management (v) with NFC regulations?
l 13-(n) If snowar to any pa rt of (m) above is affirmative, plcase i state for each such part, each reasons CP&L believes the matter inquired about in that part has contributed to lower or voor performance of the Brunswick nuclear units, in terms of canacity factor over their operating lifetimes.
(o) If answer to any part of (m) above is 6ther than affirmative, please state all basis for each such belief.
(p) Is the " industry expdrience" you refer to in the resnonses cited in 18(a) above always limited to the experience of the comnercial LWR nuclear industry within the USA? (i) If not, please state whht (aa) nontommercial (bb) non-LER (cc) non-US experience you refer to in each such answer.
I (q) Does CP&L now disnute the NC Utilities Commission's finding in its Order in Docket E-2 sub 203 (granting certificate of convenience l' and necessity to construct the Harris plant, 4 units) that (i) Harris is similar in design to Eeaver Valley (ii) Harris is similar in design to North Anna (iii) Harris was expected to have any 80%
capacity factor? (iv) If your answer to any of parts 1,11 or iii immediately above is affirmative, niease state (aa) whether CP&L took exception to this finding (bb) whether CP&L apnealed this finding (cc) whether CP&L has ever sought otherwise to reopen the record in Docket E-2 sub 203 to change this finding, for each such find!ng.
(v) If an answer to any part of (iv) above is affirmative, niease provide details of each such exception, anpeal, or attemnt to correct or reopen the record, when filed, what the result was, and identifying all documents you possesa relating to it.
(vi) Has CP&L, in its annual reports to the NCUC on the Harris plant under its Order in Docket E-2 sub 203, ever told the NCUC that Harris is no longer expected to perform at an 80% capacity factor? If so, when, at what page(s)? (vii) Has CP&L ever informed the NCUC in any_other filing of its in Docket E-2 sub 203 that Harris is no longer expected to nerform at an 80% capacity factor?. ( viii)
Has CP&L ever informed the NCUC of the Staff's estinate of Harris 2 capacity factor for the DES? If so, when and how; please identify 4
all documents used to so inform the NCUC, giving the date and author l of each, and any response the NCUC has made dhereto (documented ob known j to you).
(r) Does CP&L believe that the NRC Staff's 55% capacity factor for Harris is (i) right (ii) wrong (iii) close enough for use in the NRC operating license nroceeding (iv) too low (v) too high?
(vi) Please give the basis for your answers to each part (i) thru (v) above.
(s) With respect to your response to Interrogatory 11 on 15-AA, and attachment A thereof, please state (i) what the (aa) lifetime CF (DER)
, (bb) lifetime EFOR (cc) lifetime everage weeks per year of planned mainten-ance are for Robinson 2, Brunswick 1 and Brunswick 2 resnectively; (ii) How, if at all, the actual lifetime CF, FFOR or nianned maintenance time for Robinson 2, Brunswick 1 or Brunswick 2 entered into the estimates of (aa) Capacity Factor (bb) EPOR (cc) olanned maintenance (weeks /your) given for Harris (dd) 1 (ee) 2(nuclear units) givsn in Attachment A re interrogatory 11 on 15AA. Please state an+ calcula tions made, and any assumptions made, in using information re actual lifetime DORS, CFs and planned maintenance of CP&L's existing nuclear units length for pla,nned maintenance.re Harris nuclear units ' estimated CF, EFORs, and outage
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(t) Please state (i) .the actual length, in y hours, or weeks, or any other time units you have the information in, for each refueling outage the Robinson 2 plant has had in comnercial oneration, giving the date and year on which each such outage commenced if known.
(ii) tie ' actual EPOR for Robinson 2 for (aa) its lifetime (bb) for each calendar year 1971-1982 and for 1983 when that data becomes available l (iii)- the actual CF for Robinson 2 for the years 1979,1980,1981, 1982 and 1983 Where your CF data differs from the NUREG-0020 CF data, please give:any exnlanation known to you for the difference (s).
(iv) the actually-achieved DER '. CW (annual) for North Anna 1 4
- for the years 1979,1980,1981,1982 and 1983 (v) the actually achieved
~
DER CF (annual) for North Anna 2 for the years 1980, 1981, 1982 and 1983
- (vi) the actual DER CF (annual) for Beaver Valley I for each of the years 1980,1981,1982 and 1983 (and 1979 also). (vii) do you
' know thelifetime EFDR for Beaver Valley I through 1982? to present?
If so, please state each such lifetime EFOR. (viii) Do you know the lifetime EPOR of (aa) North Anna 1 (bb) North Anna 2, as of the end of 1982 or as of any other date? If so , please state each lifetime EFOR you know for a North Anna unit, giving the date it is through and the unit it applies to.
(u) (a) In your attachment B (9-16-83 responses to interrogatories on 15AA), related to interrogatory 29 thereon, are the Brunswick and Robinson 2 CF data different by more than 1% for any year (from) those shown in attachment A therein re Interrogatory 11?
(b) Are the planned maintenance data for Brunswick, Robinson 2 and Harris the same in Attachment A and attachment B except for Brunswick 1 in 1983? (c) Are the EFORs for Brunswick 1 and 2 and for Robinson 2 always the same in Attachment A as in attachment B in each year? (d) Are the Harris 1 and 2 CFs, excent for Harris 2 in 1489, at' a 5% (or more) higher level in Attachment B than in Attachment A?
(e) Are the Harris 1 and ,. 2 EFROMs shown in Attachment B maturing in one year from 29% to 16%7 (f) Are the Harris 1 and 2 EFORS in Attachment A maturing over 3 years from 30% to 22%?
(g) Does CP&L have any data concerning how long it takes the actual EFBRs of Westinghouse PWRs to mature (i.e. stot declining)?
i (h) What EPOR data on Wesstinghouse PWRs does CP&L nossess?
(i)- Does CP&L really believe that Harris 1 or 2 could actually
. mature in terms of EFOR within one year of commercial ooeration?
(j) Does CP&L actually believe that the Harris 1 or 2 EFOR in operation will be 16 percent (or average 16%) in the second and following years of operation? (k) Please state all basis for your answers to (i) and lj) above-including all information you rely on in making your answer to each of these 2 questionc.
15-AA(2d)-19(a) Does CP&L have any data on the lifetime CF estimates used by AEC or NRC Staff for (i) Robinson 2 (CP, OL or both)
(ii) Harris CP (iii) Brunswick CP or OL or both (iv) Beaver Valley I, CP, OL or both (v) VC Summer, CP, OL or both (vi) McGuire, CP, OL or both (vii) North Anna, CP, OL or both7 (b) For each reactor for which your answer to (a) above is affirmative, please state the CF used at (i) the CP stage (ii) the OL stage, by NRC or AEC Staff, for that reactor. (c) If you know, for each reactor inquired about in (a) above, what CF did the ASLB adopt at the (i) CP (ii)OL stage?
(d) Does CP&L dispute the ruling of the NC Utilities Commission in Docket E-2 sub 4h4 that CP&L management was at fault for the length NU n k k- "k6S kbah Ch$ ma$ age b t b'aE h*eso s b "for
1 the' failure to test the Brunswick plant as required by NRC, !
which failure led to an extended shutdown in the summer of 198x2? l (f) Does CP&L dispute that the Brunswick turbine outage of 1981 reduced Brunswick's capacity factor for 1981? (g) Does CP&L dispute that the Brunswick testing shutdown of sammer 1982 reduced Brunswick's capacity factor for 1982? (h) Please give all basis for your answers to (d),b), (f) and (g) above, stating which basis applies to which answer.
Interrogatories on 8F1 8F1-4 This interrogatory may be answered by a set of columns for parts (i), (ii) and (iii) and (iv);9With one row for each of the chemicals (aa)(bb) etc inquired about. A "yes" or "no" where avnlicable should anpear at the intersection of each row and column. Or you can lay out your answer in any reasonable way you want:
Does CP&L have any oninion, knowledge or belief concerning ,
(i) the minimum amount which if inhaled can cause cancer (ii) the maximum safe concentration for breathing on a continmuous basis (iii) the maximum safe concentration for breathing over an A 8-hour period (iv).the maximum lung burden which assuredly will not cause cancer (v) the maximum lung burden which will not impair breathing, of:
(aa) arsenic (bb) cadmium (cc) chromium (dd) lead (ee) vanadiun (ff) cooper (gg) polycyclic aromatic hydrocarbons formed by coal combustion (hh) polycyc1tc aromatic hydrocarbons vanrofijed during coal combustion (jj) particulates from coal combustion, of any size (kk) particulates under 10 microns in size, resulting from coal combustion (11) particulates under 5 microns in size, resulting from coal combustion (mm) coal-combustion narticulates under 2 microns in size (nn) coal-combustion particulates under 1 micron in size (oo) coal-combustion particulates under o.5 micron in size (pp) coal-combustion particulates under O.2 micron in size (qq) coal-particulates formed by combudion of coal, over 10 microns in size (rr) arsenic on coal particulates of 10 microns or less in size (ss) cadmium on coal particulates of 10 microns or less in size (tt) chromium on coal particulates of 10 microns or less in size (uu) lead on coal particulates of 10 microns or less in size (vv) vanadium on coal particulates of 10 microns or less in size (ww) copper on coal particulates of less than 10 microns in size (xx) any other metals on or in coal particulates (yy) any other organic comoounds on coal narticulates (zz) any radioactive elements on or in coal particulates. Throughout this interrogatory, " coal particulates" means narticulate matter formed, by combusti on of coal, such as occurs in coal-fired powerolant boilers, e.g. as referred
- to in Table S-3 of 10 CFR 51.20.
8F1-5 For each part of BF1-4 above for which your answer is affirmative, please state (i) CP&L's knowledge (ii) CP&L's opinion (iii) CD&L's belief, if any, and please also identify each document upon which you rely or which contains the knowledge, opinion or belief you cite, stating for each such document which part of 8F1-k it relates to and whether it relates to knowledge, opinion, belief about that matter, or some combination of knowledge, oninion and belief.
8F1-6 (a) Have Applicants ever (i) had on staff (ii) hired as a i consultant iii) had working for them kan otherwise any verson whom you con (sider an expert on the health effects of coal-fired powerplant (aa) emissions (bb) particulate emissions (cc) particulate emissions interaction with other pollutants, e.g. SO2 ,NOx, nacid
8F1-6 continued precipitation)? (b) If answer to any part of (a) above is affirmative, please identify each such person, provide a statement of that person's qualifications if you possess one, and state which of the matters inquired about in (aa),(bb), (cc) above that verson is an expert in, e.g. (aa) only, (bb) and (cc) only, all three.
(c) When did each expert identified in response to (b) above work for you? When did each begin work, and when did each end work for you?
(d) Was the work each such exnert, identified in response to (b) above, did, related to health effects of coal-fired power plant emissions?
(e) If answer to (d) is other than affirmative, please list or identify each expert who did work for you on the health effects of coal-fired power plant emissions.
(f) Has CP&L made any inquiries of anyone during the year 1982 t' concdrning the health effects of coal-fired vower nlant narticulate emissions?
(g) Has CP&L made any inquiries of anyone during dae year 1983 concerning the health effects of coal-fired ocwer olant particulate emissions?
(h) If answer to (f) or (g) above is affirmative, please identify each such nerson, state the nature and content of any inouiries to eadh such person, and identify all documents containing (i) the inouiry (ii) any responses, for each such person.
8F1-8(a) Which, if any, of the EPRI studies identified by you in response to interrogatory 8F1-1(b), dos ycu rely on with respect to contention 8Fl? (b) Which, if any, of the draf t do cuments identified by you in response to interrogatory 8F1-(d), do you rely on with respect to contention 8Fl? (c) Does CP&L stand on or rely on (at present) (i) Une statement of Charles Barham Jr for CP&L given to the NC Environmental Management Commission in March 1982 (ii) the statement of Charles Barham Jr for CP&L given to the NC Environmental Management Commission 9/30/82 (iii) all of the data CP&L submitted to the EMC for the rulemaking proceeding of 1982-83 concerning narticulate emissions
' (iv) any testimony from the 1979 NC Enviro. M'gt. Commission variance hearing on coal particulates, whether presented by CP&L alone, or by CP&L and Duke Power Co. jointly, with respect to contention- 8Fl? (d) for any suhnart of (c) l for which your answer is affirmative, please identify each document concerning health effects of coal-fired nower plant
. particulate emissions which was used in prenaration of the material or statement you rely on.
8F1-9(a) Is CP&L or anyone working f or CP&L or Applicants aware of any court decisions which you believe suoport your interprestation of the national ambient air quality would standards not present (if met) ensure that particulate " emissions any known public health impact", as you stated in resconse to interrogatory 8F1(za)? (b) Is it CP&L's nosition or belief that any level of coalwfired powerplant particulate emissions which are within the national ambient air quality standards in effect would have or do have zero health effects?
l I now
[c ) If answer,to (b) is affirmative, please state all basis for y un n sit' ion or your belief and identify all documents you re1y n to support your position or belief.
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1 4
-17e Interrogatories on 8F2 8F2-6(a) Do Anolicants agree with NRC Staff that NUREG-0668 is a draft, not a final, position? (b) If answer to (a) is other than affirmative, please state all reasons for your nosition or disagreement. (c) Have Applicants or anyone working f or them made any study of what the dose estimates would be if NRC Translation 520 were changed to reflect all the different estimates given in NUREG-0668 in criticism of Translation 520? (d) Do Applicants kno'w isranycne else has calculated or studied what the dose estimates given in NRC Translation 520 would become if (1) any (ii) each (iii) all different estimate (s) in NURDG-0668 were used in place of the ones actually used in Translation $20? (e) If answer to any
_part of (d) is affirmative, identify each such person or groun and all documents containing ' ench such study. (f) Please state or identif y any documents known to you which state estimates inquired about in (c) or (d) above, other dian NUPEG-0668 and NRC Translation 520. (g) Please state whether Anpkicants rely on NUREG-0668 in this proceeding, or any parts of it, stating which pages or parts (if any). (h) Please state Whether Anolicants rely on the letter from E.K.F. Bautz identified in resnonse to my interrogatory 8F2-4(d), or any parts of it, in this nroceeding, identifying any particulab varts relied upon (j) Please state whether Applicants rely on the GPS " Comment" of March 1979, identifbd in response to my interrogatory 8F2-4(d), identifying any parts of it you rely on in this proceeding. (k) Please state whether (i) NUREG-0668 (ii)' the letter of E.K.F. Bautz (iii) the GRS " Comment" cited above, has ever been (aa) published in a peer-reviewed scientific journal (abb) published in a neer-reviewed engineering journal (cc) published in the proceedings of any i scientific society or group (dd) submitted for publication by any peer reviewed journal of science or engineering or any field of science or engineering. (1) For all parts or subparts of (k) above for which your answer is affirmative, nisase identify (i) the document publication date, if any (ii) dae date of submittal, if known (iii) the journal or publication which nublished it, if any (iv) the date, volume, issue and page numbers where it was published, if known (v) the address of the editors of such nublication, if known.
8F2-7(a) Do Applicants know if health effects of uranium
, fuel cycle emissions (as set forth in Table S-3) have been litigated
- in any other nuclear plant operating. license proceeding? (b) Please
- identify each license proceeding in whiqh these health effects were litigated. (c) Do Applicants know if th(nodels, data, assumptions, ,
or conclusions (or .any of them) of NRC translation 520 have been litigated in any other NRC licensing proceeding? (d) Please identify each such proceeding known to you and state (if known) what matters relating to NRC translation 520, and what contention (s) relating to NRC translation 520 were litigated or are being litigated in each such proceeding. (e) Have Appslicants participated in any NRC proceeding (i) related to determining the health effects of radioactive effluents given in Table S-3 (ii) related to th6
. determination of the values fer effluent emissions given in Table S-3?
(f)'for any nart of (e) for whidh you= answer is affirmative, please identify each such proceeding and state what nosition, if any, Applicants took in it, whether ad decision has been reached in the proceeding, and if so, what that decision was as it related to Table S-3 emissions and their health effects.
__---_-_----.--__.,,,--,,-.,,...--,n,__, - - - a,,,,,,-,.,,,,,.m.,,, ,,,,,._,--.-.,.--,,,,,,e,,w,,,,,-.,n. .,.,,-.,-,,_7,,,. ,.,v .-, e
o (g) Are there other ongoing NRC proceeding known to Applicants in which the health effects of radioattive emissions as set forth in Table S-3 are at issue? (h) Please identify each such proceeding and state (if known) the contention (s) relating to health effects of radioactive emissions set forth in Table S-3 that are at issue therein, whose contention each is, and whether you possess any documents relating to that contention in that proceeding. Please list, for each such contention, the documents relating to it which Applicants possess.
PRODUCTION OF DOCUNENTS Wells Eddleman hereby asks Applicants to make available for inspection and conying an original or the best cony of each document identified in response to interrogatories above, at a time and place mutually agreeable between us.
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