ML20079M169

Corrected Pp 5,18,19 & 22 to 830121 List of Admitted Contentions.Svc List Encl

ML20079M169
Person / Time
Site:	Harris
Issue date:	02/18/1983
From:	CAROLINA POWER & LIGHT CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20079M144	List: ML20079M141 ML20079M169
References
NUDOCS 8302230596
Download: ML20079M169 (5)

Text

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the ALARA standard. The monitoring system is not able to promptly detect the specific radionuclides and their amounts being released inside and outside the plant.

JOINT CONTENTION VII (CANP 2 -- subpart (2) only)

Applicants have failed to demonstrate that the steam generators to be used in the Harris Plant are adequately designea and can be operated in a manner consistent with the public health and safety and ALARA exposure to maintenance personnel in light of (1) vibration problems which have developed in Westinghouse Model D-4 steam generators; (2) tube corrosion and cracking in other Westinghouse steam generators with Inconel-600 tubes and/or carbon steel support plates and i- . .: ~ ,

AVT water chemistry; (3) present detection capability for loose metal or other foreign objects; and (4) existing tube failure analyses.

CCNC 4 The Applicant's request for authorization to store source, special nuclear and by-product material irradiated in nuclear reactors licensed under DPR-23, DPR-66, and DPR-71, should be denied as there has been no analysis in the ER of the envi-ronmental effects of transportation of radioactive wastes and other material from the other reactors to SHNPP. The Applicants' reliance on 10 C.F.R. 51.2O(g), including the table 8302230596 830218 PDR ADOCK 05000400 0 PDR

6 Eddleman 22A and B The cost benefit analysis in the ER is deficient in the following respects:

(A) CP&L's Amendment 2 fuel cost estimates in Table 8.2.1-2 as amended are erroneously low, as are the fuel cost lifetime estimates in section 8.2 as amended and section 11 as amended (all in the ER).

(B) CP&L's estimates in the amended section 8 of the ER that the operating payroll at the Harris plant based on only 2 units will not be decreased by any significant amount, compared to the operation of all 4 units at the site, is not accurate. __

Eddleman 29 and 30 . (CANP 6)

Applicants have underestimated radiciodine releases during normal operations and have not demonstrated that normal radioiodine releases will not exceed Appendix I limitations.

l Eddleman 37B (CANP 5)

The work of I.D.J. Broos (Ph.D.), Rosalie Bertell (Ph.D.)

and others shows that radiation exposure increases the risk not i

only of cancer but a host of other diseases, allergies, and causes of death including heart disease, heart attack, and others. The estimates of the numbers of such victims made by

the preceding workers et al are more accurate than the 2/18/83

estimates (if any) used by Applicants or NRC Staff or BEIR committee reports.

Eddleman 41 (CANP 4)

Applicants' QA/QO program fails to assure that safety-related equipment is properly inspected (e.g. the "OK" tagging of defective pipe hanger welds at SHNPP).

Eddleman 45 SHNPP design cannot comply with the results of the Plant Water Hammer Experience Report, PWR S.G. (steam generator),

feedwater, ECCS & Main Steam System water hammer events evaluation (including systems effect) and potential resolutions '

now being prepared by NRC, and the CR and NUREG r'eports on the water hammer question.

Eddleman 64(f)

There is undue risk to the health and safety of the public since pressure valves on the casks used for spent fuel tran-sport are likely to unseat (e.g. the 4 removed from service by GE in 1981) or the plastic components of such valves could and would melt in a fire less severe than the test basis for spent fuel casks. Open the valve and out comes the coolant --

radioactive contamination -- followed by fuel overheating &

melting, Cs-137 boiling.

2/18/83

1

• i EDDLEMAN 80 The mixing models and dispersion models for radioactive gas, liquid and other radiological releases from SENPP under 10 CFR part 20 are deficient in that they assume more complete mixing and dispersion of such radionuclides released than will actually take place, take insufficient account of rainout of such a release plume in a small area (rain precipitating the radionuclides in the plume) and thus do not assure that releases comply with 10 CFR 20.106 and the protection of the

! public health & safety, including holding individual doses below 25 rem whole body & thyroid doses below 300 rem in an i

accident, and below 10-3 of thesE values in normal opera-tion. ,

EDDLEMAN 83, 84 A. CP&L's ER (and the DEIS and FES of NRC) take no account of the formation of carcinogenic chemicals resulting from CP&L's discharges into the Harris cooling lake, which i include chlorine, ammonia, hydrazine, etc. (See ER 5.3).

These discharges can and will interact to form carcinogenic compounds including NCl 3, NHCl 2 and NH2 Cl among others. These compounds will pose a risk to anyone swimming in the lake, and anyone eating fish from the lake (due to concen-tration of carcinogens in the lake food chain). Any discharges

! of water from the lake into the Cape Fear River will put these 2/18/83

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

In the Matter of )

)

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

)

, (Shearon Harris Nuclear Power )

l Plant, Units 1 and 2) )

SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire

! Atcr.ic Safsty and Licensing Board conservation Ccanvil of North Carolina I

U.S. Nuclear Regulatory r - iasion 307 Granville Road l Washington, D.C. 20555 ~

Chapal Hill, North Carolina 27514 Mr. Glenn O. Bright. M. Travis Payne, Esquire '

~

'i i Atcmic'S'afety and Lir=n=4=.r Boarti "' Edelsteiniand 'Payner '

U.S. Nuclear Regulatory cr==4 ==icm P.O. Box 12643 Washington, D.C. 20555 Raleigh, North Carolina 27605

\

Dr. Janes H. Cag--g_= Dr. Richard D. Wilson l 729 Hunter Street Atmic Safety and Licensing Board U.S. Nuclear Regulatory Cdunission Apex, North Carolina 27502 Washington, D.C. 20555 Mr. Wells Eddleman '

Charles A. Barth, Esquire 718-A IrW11 Street Myron Karman, Esquire Durhan, North Carolina 27705 Office of Executive Iagal Director U.S. Nuclear Regulatory Cm mission Ms. Patricia T. Neman Washington, D.C. 20555 Mr. Slater E. Newman Citizens Against Nuclear Power Docketing and Service Section 2309 Weymouth Court Office of the Secretary Raleigh, North Carolina 27612 U.S. Nuclear Regulatory Ccamission Washington, D.C. 20555 Richard E. Jones, Esquire Vice President & Senior Counsel

, Mr. Daniel F. Read, President Carolina Power & Light Cm pany Chapel Hill Anti-Nuclear Group Effort P.O. Box 1551 l Raleigh, North Carolina 27602 l P.O. Box 524 Chapel Hill, North Carolina 27514

! Dr. Phyllis Lotchin '

108 Bridle Run~

Chapel Hill, North Carolina 27514 i

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