ML20079Q109

First Set of Interrogatories.Reply Requested Before 830525. Related Correspondence

ML20079Q109
Person / Time
Site:	Harris
Issue date:	05/06/1983
From:	Eddleman W EDDLEMAN, W.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
82-468-01-OL, 82-468-1-OL, ASLBP-82-468-1, ISSUANCES-OL, NUDOCS 8305110366
Download: ML20079Q109 (10)

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BEFORE THE ATOMIC SAFETY AND LICENSING BO ED7~~

Glenn O. Bri 5ht Dr. James H. Carpenter 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 ani 2) ) ASLBP No. 82-h68-01

) OL Wells Eddlenan's Interrogatories to NRC Staff (First. Set)

Wells Eddlenan hereby requests the NRC Staff to answer the following interrogatories before May 25, 1983 or such other date as counsel for the Staff and I agree on. These interrogatories are submitted under 10 CFR 2.720(h)(ii) and inquire into the studies, information, and knowledge of NRC staff with respect to my contentions, on which discovery is now open. Sines I cannot read the minds of the staff, and this information is not contained in documents which the staff has provided to ne, I an unable to obtain this infor.ation by other means. Where the information is contained in a document I can obtain fron NRC (Public Document Room, etc). I still need the identification of the document in order to obtain the information. The staff has :esources and information which exceed what I have, and as a carty, their position and information are necessary to making my case in this proceeding. These interroga-tories are continuing in nature and should be supple-ented when answers change.

GENEPJL INTERROGATORIES (FIRST SEI)

For each of contentions Joint 2,3,4,5 and 6 and Eddlenan contentions 15,22A,223,29-30("29"),37B,41,45,64F,65,67,75,80and83/84, please provide the following information by answering each of these questions.

1. What is NRC Staff's understanding of the subject natter of this contentioni analysis study or 2 Has NRC Staff made an,i quiryligation into,(a) this contention (b) nyes l

the subject matter of this contention (c) the allegation (s) in this contention 48$ (d) the basis of this contention (e) the information relied upon by intervenor(s)

@$0- in support of this contention?

00 SS 3 For all parts of your response to Interrogatory 2 above for which your 4

0 answer is affirmative, please provide the following information: who made g the analysis, inquiry, study or investigation; what was being considered in oc such analysis, inquiry, study or investigation ("AISI"); the content of the AISI, the results of the AISI, whether the AISI has been conpleded, whether Q

in a date for co.pleting the AISI has been established if it is not conplete, gg what that date is, all documents used in the AISI, all persons consulted c)c.o D

2-in the course of the AISI, all docu-ents containing information discovered

.or analysis or study or infornation developed during or as a result cf the AISI (identify each such docunsnt and state what infornation or results it contains), whether staff believes additional analysis is warranted, or further AISI needs or nay need to be undertaken on this contention, and whether any persons participating in the AISI are to be called as witnesses for the Staff in this case,and what cuestions the staff AISI is intended to answer and what infornation it seeks to develop if it is not co .plete.

4 For all responses to parts of (2) above for which NRC staff's answer is other than affirnative, please state (a) whether NRC staff plans to perform any AISI on this contention, (b) whether anyone on NRC Staff has stated that AISI of any kind is warranted for this centention (even though it has not been nade) (c) whether NRC Staff plans for AISI on this contention include a date for beginning or for ending such AISI, (d) those dates, for all affirnative answers to (c) above, (e) what AISI IGC staff will undertake on this contention (f) what AISI lac staff desires to undertake on this contention (g) all reasons why no AISI is planned on this contention if none is planned (h) all reasons why no AISI has been done yet on this contention if none has been done (1) what the responsibilities of NRC staff with respect to this contention are.

5 Identify all documents the Staff relied on in opposing the admission of this contention, and any specific facts not stated in the Staff's opposition to ad .ission of such contention (already filed in this case) upon which Staff relied in naking such opposition.

6. Identify all docunents not identified in Staff's interrogatories to Wells Eddleman or to Joint Interveners (to present -- a continuing interrogatory )

upon which the Staff relied in naking each such interrogatory.

7 Identify by name, personal or business address, NRC staff position or title (if any), and telephone nu-ber (if known) each person on lac staff or consultant to NRC staff or known to NRC Staff or consulted by NRC staff in the staff's analysis of the subject natter of this contention prior to (a) its filing (b) its adnission; state for each such person what analysis was perforned by that person.

8. State all professional qualifications of each person identified in response to interrogatories 7,. 3;4 7 .

9. Provide any statements of the analysis nade by persons identified in response to interrogatories 3,4, or 7:x above, and identify all docunents containing such infernation or statenents not previously identified.

10. Give the identifier number, date, source, and title of all documents identified in response to interrogatories above, which are available through l ,

lac PRIE (Public Docunent Roon).

11. Will lac Staff nake available copies of docunents identified in r.esponse to the above interrogatories to Wells Eddleman for inspection and copying, for docunents not available through 12C's PDR7

12. Identify by name, IEC staff position if any, address and telephone number each person when lac staff intends to xxn use or call as a witness in this proceeding.

13. State fully the professional qualifications of each person identified in response to interrogatory 12 above.

_3 14 Sunnariza tha position (or plannsd testimony) with respect to each contention on which such person is expected to testify, for each person identified in response to interrogatory 12 above.

15 Has lac Staff, any witness identified in response to interrogatory 12, or anyone acting in behalf of the Staff or such a witness or at their direction, made any calculation or analysis (not identified in response to interrogatories 1 through 4 above) with respect to this contention?

16. If the answer to interrogatory 15 above is yes in any case, provide the nane, business or personal address, telephone number and professinnal qualificatior.3 of each person who has nade such calculation or analysis, stating for each what contention it relates to, what person (or Staff) it was nade for or at the direction of, and identifying all docunents containing such calculationer analysis and all docunents used in naking such calculation or analysis or relied upon in it or supplying infornation used in it.

17 Provide a su . nary of each AISI, calculation or analysis idun for which the answer to interrogatory 15. or interrogatory 2 above, is yes.

18. Please give the accession nunber, date and originator of each docanent identified in response to interrogatory 16, which is available at the lac PIE.

19 Will lac Staff nake available to Wells Eddlenan for inspection and copying all docrents identified in response to interrogatory 16 above which are not available through the PE7

20. Identify each person, including telephone nunber, address, and field of expertise and qualifications (conplete) (if any) fa who answered interrogatories with respect to this contention; if . ore than one person contributed to an answer, identify each such person, providing the infornation l

requested above in this interrogatory for each such person, and state what i each such person's contribution to the answer was, for each answer.

21. Identify all docunents which the Staff proposes or intends to use as exhibits with respect to this ;ontention during this proceeding, including exhibits of Staff witnesses (idc..cifying the witness for each, if such a witness has been designated), and exhibits to be used during cross-exanination of witnesses of any party (stating for each which witness it is to be used in cross-exanination of), and identifying for each the particular pages or chapters to be used as exhibits.

22. Identify all docunents which lac staff relied upon in answering interrogatories with respect to this contention, which have not been identified in response to interrogatories 1 through 21 above, stating for l

each which answer (s) re which contention (s) it was used for, and each j specific fact and page nunber therein on which lac staff relied or which -

l lac staff used in answering such interrogastory.

23. Please give the accession number, date, and originator of each docunent identified in response to interrogatories 21 or 22 above which is available through the lac PDR.

! 24. Will NRC Staff provide Wells Eddlenan with copies of the docuents identified in response to interrogatory 21 or 22 above which are not available i at the Pm, for inspection and copying?

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, 25 Idantify any other infornation or sxource of information not identified in response to the abova interrogatories (1 through 24) upon which IE.C staff relied, or which KRC staff used, in answering interrogatories with respect to this contention, and the contentien and response in which it was used, and the location of the relied upon infornation in such source.

26. Does the staff now agree with (a) the contention (b) any part of the contention?

27 If response to 26(b) above is affirnative, which part(s)?

INTERR03ATORIES RE ELDLE'.A" CONTE; TION 15 Note: These, like the ones I sent to Applicants in January 1933, can be held up for response until the Board rules on Eddleman 15 and its revisions and additional contentions re ER Amendrent 5, if the Staff desires.

I include then here for completeness in this set.

28 Has the staff predicted or estimated or projected any capacity factor (MDC, DER or other basis, gross or net) for any power reactor now licensed to operate in the US?

29 Has the Staff estinated, projected or predicted the additional net capacity to be delivered by any reactor now licensed to operate in the US?

(negawatts electric, for electric power generating reactors only) 30 Has the Staff estinated, projected or predicted any fuel savings (a) versus coal fueled power plants (b) versus oil fired power plants (c) versus hydroelectric power plants, in its DEIS or FES or ES or FEIS for any nuclear power reactor now licen::ed to operate in the US?

31. If the answer to any part (or all ) of 28,29 or 30 above is affirmative, please list each such reae. tor and each estimate, projection or prediction made for it.

32. For each reactor listed in response to 31 above or whi for which the answer to 28 or 29 or any,part of 30 above is affirmative, please state whether information on thePactual operating capacity factor (b) actual operating cap acity at the time of sunner or winter peak denand (or both) on the grid to which such reactor is connected or serves, (c) actual operating fuel savings (d) O&M costs (e) repair costs (f) nu-ber of 1.EFS (g) tine of shutdowns and length of and reason for shutdowns (h) tir.e, length and reason for deratings, of such reactor is available (1) in the NRC PDR (ii) otherwise within the NRC.

l 33. Please identify all docunents containing the above information, l giving the accession nunber and date for each that is at the PDR.

l INTERROGATORIES RE EDDLEFAN GIG 22A 3'.

4 Has the Staff made any independent estinate of fuel costs for Harris?

35 Has the Staff made any independent estinate of uranium oxide (yellowcake),

UF6 conversion costs, enrich .ent costs, fabrication costs, or the actual cost of spent fuel storage and ultimate disposal (or ultimate disposal) for (a)

Harris, or (b) any other power reactor licensed or not, since 1-1-1980.7

.5

36. If your answer to 34 or any part of 35,above, is affirnative, please identify the reactor involved, state the estimate, and identify all doeunents which contain the estimate, calculations involved in making the estinate, and/ordatasupportingtheestinateorusedinmakingit. If you made assunptions (NRC staff did) in any such estinate, please state each assunption made for each estimate.

37 Has NRC Staff made any study of how accurate its estimates of nuclear fuel costs (a) at the CP stage (b) at the OL stage for power reactors have proved?

38. If response to 37 above is affirmative, please identify all documents which contain such study or its results, and all documents, estinates, calculations and assunptions, and all data sources, used in making such study.

Please also state who nade the study, when, and what that person's qualifications were either for that person's job or for making such study.

39 Has NRC Staff had a consultant or consultants who studied of estimated any matter inquired about in interrogatories 34, 3J , or 37 above? If so please identify such consultant (s), the subject of such study or estimate, when it was nade, and identify all docunents containing such study.

40. Has NRC Staff nade any study of the accuracy of estinates by CP&L of (a) nuclear fuel costs (b) OC costs (c) variable OE costs (d) repair costs (6) nuclear waste disposal costs (f) spent fuel disposal costs (g) capacity factor of nuclear plants (h) any conponents of nuclear fuel costs, e.g. mining, nilling, fabrication, enrichnent, etc (i) nuck ar fuel burnup (j) nuclear fuel cost per kilowatt hour (k) additional megawatts of capacity available fron nuclear units at the tine of the systen peak, (in addition to non-nuclear capacity, purchases, and exchanges of power, etc)?

41. For any part of response to 40 above for which your answer is affirmative, please identify each such study, all docunents containing it, and who nade it and when it was made.

IN E ROGATORIES CN EDDLrAN 22 B

42. Has NRC staff nade any study of the effect of additional NRC requirenents on staffing needs for nuclear power plants?

43 Has NRC staff made any study of the variation among licensees, for similar nuclear power plants, of the number of persons employed (a) permaniently (b) temporarily at those plants?

l 44. Has NRC staff made any study of tahe effect of licensee conpetence on the nunber of staff required to safely operate nuclear power plants?

45 Has NRC Staff made any study of the number of persons needed to staff l (a) the control roon at a nuclear plant (b) health physics services at a nuclear plant (c) other personnel at a nuclear plant (d) the Harris units, or Harris 1 or Harris 2 or both units?

46. Has NRC Staff made any study of the accuracy of estimates of staff w*=d re=uired to operate any nuclear plant (a) as made by the Staff (b)~as nade by any Applicant _(s) : (i) at the CP stage (ii) at the OL stage, I versus the nu=ber of staff required in actual operation.

h7 Has NRC Staff made any study of the accuracy of esti .ates of (a) operating payroll (b) number of multiplier dollars created by operating payroll in the

. local or regional econo y , from a nuclear plant or fron nuclear plants?

43. Has NRC Staff deternined, at or before the issuance of any regulation (s),

how nany personnel such regulation (or each such) will or should require at a nuclear reactor such as Harris, or at nuclear plants generally? (4) P:; M"C 69{4 confoad ct cuts sh%ekuq cf (?cbmSM1 + IJc.rrn, u-bfensrwd ye

49. For any answer to interrogatories 42 through 48 above, or any of then So % % 9 or any part of then, which is affirnative, please identify the infornation rb deternined, the study, all docanents containing the infornation deternined ((Q, Q ?'

or the study or its results, which Applicants, nuclear reac_ tors, power companies, or areas was studied, who nade the study or deternination, when it was nade, and all documents on which it was based.

50. For any doeunents identified in response to 49 above which are available at the PDR, please give the accession number for each document.

INTERR03ATORIES ON EDOIl2% 29 (29/3_o)

51. Does Ec staff recommend that all radiciodines escaping fro: operating nuclear plants be nonitored and neasured, or =enitored, or neasured (a) at the point of release (b) before release (c) otherwise?

52 Does nc staff require that all releases of radiciodines fro. nuclear plants be nonitored?

53 Does any regulation state what radiciodine releases from nuclear plants have to be monitored by licensees?

54. Does NRC require data to be collected on radiciodines (a) in milk (b) in vegetables (c) in liver (d) in thyroids of voles or other animals (e) in thyroids of deer (f) in thyroids of food aninals, e.g. sheep, goats, pigs, cattle (g) in air (h) in water (i) in other living things (j) otherwise in the environment, be nonitored or neasured around nuclear plants?

55 Does NR20 Staff know if data on radiciodine concentrations in foods are measured around operating nuclear plants?

56.

Does NRc staff know if levels of radiciodine in the thyroids of stillborn children or neonatal deaths or deaths below the age of 2 years, are measured

)

routinely near any operating nuclear plants or at any other location?

57 For each affirmative answer to any part of 51 through 56 above, please state what rules are involved, what documents specify or contain the information, how often the information is required to be collected (if applicable), how often the infornation is collected (if applicable) where the infornation is published, j

where infernatinn inquired about in the interrogatory or part thereof is published or documented, and for what dates, plants, or areas the infornation is available or the rule is applicaible. Please state particularly if the Harris plant is includid among the plants for which any part of any answer to 51 through 56 above is affirmative.

58.

Does NRC staff have any infornation indicating that the amount of radiciodines absorbed by (a) a fetus (b) infants (c) any person (d) any adult nay be larger than the NRC's dose models predict? If so, please identify all such information, whether you possess a copy of it, whether it is available at the PDR, who provided the informatio;, who authored it, and when; and where ,

ist was published or where it is available, if known.

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59. Please give, or identify a document which gives, a conplete derivation and all assumptions used by NRC staff to model radiciodine doses and dose conmitnents from (a) Harris (b) a nuclear plant (c) any facility releasing radiciodines into the envirornent. For each such, state what if any studies have been made by IGC or by others to substantiate the predictions of such modela, and any data known to NRC which fail to substantiate such predictions in any way, particularly with reference to concentrations of radiciodines deslivered to members of the public, nixing and dispersion of radioiodines or release plumes from nuclear plants in the environment, rainout, fallout, and additional modes of uptake of radiciodines beyond those NRC has considered, e.g. effect of tobacco smoking, fly ash fron coal fired power plants, etc on intake of radiciodines by breathing; eating materials containing radioiodines.

60. Does 12C know a minimum or typical concentration of airborne iodine which is as low, or about as low, as can be tasted by (a) the average person (b) any person?

61. If answer to 60 is affirmative in any part, what is that concentration and who or what characteristic of person can taste it?

62. How nuch radiciodines were released from Brunswick nuclear plant as a consequence of its operation with more than 1% failed fuel prior to 1 July 19797 63 How nuch radioiodines have been released from the Brunswick plant since (a) July 1979 (b) Jan.1,1980 (c) Jan 1,1931 (d) Jan 1,1982 (e) Jan 1,19837

64. For all answers to parts or all of 62 and 63 above, please state in detail how you know, the observed or calculated accuracy of such nunbers, and who measured them or who calculated then, and state all calculations and assunptions maddi in deriving or arriving at such numbers. Numbers of curies or nil 11 curies, etc for each radiciodine isotope or for radiciodines in total, are the kind of answers I'n seeking above, though weight or anount data of any kind is responsive.

65 Hhich noble gas isotopes can decay into radioactive iodine isotopes?

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INTER"03ATORIES ON EDDIIyaN 37 3 f ~[#

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66. Please list or characterize every dissease which 13C Staff believes py, cannot be caused by radiation or radioactive materials released fron nuclear power plants.

l 67 Please list or characterize every genetic defect or genetic predisposition to disease or defect, nental retardation, etc. which IEC staff believes cannot be caused by radiation or radioactive materials released from nuclear power palants. .

68. Please list or characterize each and eirery disease or type of disease

or genetic defect or type of genetic disease ofr defect which 18C Staff

! believes cannot be caused by nuclear radiation at all.

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69 Picasa state Wich, if any, of the diseasas listed abova have been established to occur in the absence of nuclear radiation (alpha, beta, ganna, or neutaron).

70. Please state Wether lac ctaff believes suicide rates nay be elevated after, or as a consequence of, exposure to nuclear radiation fron nuclear power plants, or radioactive caterial enitted therefron.

(x) dosineters

71. W at is the accuracy e (c.) TLD (b) continuous reading radiation nonitors (c) whole body counters (d)q radio-iodine detectors (e) other radioisotope detectors (f) stack counters (g) other radiation nonitors for release points (h) in-plant radiation nonitors, Wich is required by lEC regulation?

Give accuracy in units, plus or rinus percent, etc. as applicable.

72. For each iten in:,uired about in 71 above, please state the -aximum nargin vz aff of error, or absolute error of neasure .ent, pernitted by 13C regulation in operation at Harris.

73 Are personnel dosineters required by 1GC to be tested for accuracy against a known source in a shielded environnent (i.e. Were the source is the only radiation, and the erposure of the dosineter is thus known, and compared with the dosineter reading nade independently)? If so, when, how often.

74 Are there any require..ents of lac on the accuracy of (a) personnel radiation exposure records (b) readings of environnental radioactivity (c) records or menitoring of radioactive releases, at nuclear power plants?

75 Please list or state all requirenents for each part of response to 74 above which is affirmative.

76. How often will lac take readings of radioactivity in the environ ent around the Harris plant in operation?

77. Will lac nake any baseline health study of the population around the Harris plant before it operates?

78. Will 130 nake any health study, nortality or norbidity study of the population around the Harris plant during or after its operation?

79 For each affirmative answer to 76, 77 or 78 above please detail the readings or study to be made, the frequency of such readings or study, who will do then, and the plan for such activity and all docunents which include information on such plan.

INTERRO3ATORIES RE EDDLEUN 41

80. Wat failures to properly inspect safety-related equipment at Harris other than pipe hangers are known to 13C Staff to have occurred? Please identify what equip .ent, and when the failure occurred. .

81. Does NRC Staff consider a 95% failure rate of approved pipe hangers (inspected by Applicants already) to be acceptable 7

82. Does NRC Staff. consider a 12% failure rate of pipe hangers welded after retraining of CP&L's welding crew (or that employed by then directly or indirectly) at Harris to be acceptable?

?

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._ - _ _ - _ -. ._ _ - - . - _ _ . _ _ = _ _ - _ _ _ - _ _ -

t 83 How nany pipe hangers has NRC staff personally inspected since 1-1-81 at Harris? .How many since 1-1-827 How nany since 1 1-837 84 Does EC staff know how =any safety related pipe hangers were installed at Harris (a) before September 1980 (b) after 1-181 (c) after 1-1-92 (d) after 1-1-837 If so, for each date, how manyt 85 Has NRC staff personally inspected all blueprints used f)r safety-related pipe hangers at Harrist If not, how many has EC staff persenally inspected i and when? Who inspected them?

86. Has 130 Staff personally inspected all field chany quests for safety-related pipe hangers at Harris? If not, how ns . 'as EC staff .

personally inspected, and when, and who inspected them

87. Has NRC S,aff found any nore defective pipe hangers since CP&L and its contractors began repairing them in response to IEC staff discovery of defective pipe hangers at Harrist If so, how many were found, when, by whom, and what has becone of themt SS. Is 13C Staff aware of any defective pipe hangers at Harris at present?

1 If so, how many, and which ones are defective, and how do you know?

89.

Does 13C Staff believe that having over 30% of blueprints for pipe hanger welds at Harris either wrong or so unclear they could not be read, is acceptable practice?

90.

Does NRC Staffb believe that having 95% failures in a sar:ple of 400 pipe hangers, or over 50% failures in all pipe hangers (failures meaning that they did not neet applicable requirenents) is an indication of misnanagement or a breakdown in QA/QC at Harris?

91. Has anyone other than an IEC inspector reported any defective pipe hangers at Harris? If um so, who did, and when, and how many hangers were involved?

92.

Does nC consider the massive failure of pipe hanger QA/QC at Harris to be (a) a breach of faith with Applicants' promises in setting up their QA/QC progrant (b) less than a nassive failuref 93 Have all the safety related pipe hangers needed at Harris been installed j so far? If not, do you know how nany (If so, more need to be forinstalled to complete each unit, or roughly the plant? To complete unit 17

' how nany if you don't know exactly) refers(tod,hown to NRC staff) many, verified the ability of all welding inspectors at Harris 94 Has NRC Staff If not, have you verified

.to properly read and interpret welding blueprints?When and which inspector, and exactly any welding inspector's ability to do so?

how did NRC Staff verify thist 95 Why does !GC Staff consider QA/QC problems at Harris a amanagement capability issue in this proceeding?

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4 INTE?30GATO?.IES RE EDDLEGN 65

96. Please identify all docu .ents indicating or relating to voids in concrete at,the (a) Callaway (b) Wolf Creek (de) Farley (d) Harris plants.

97 Please identify all docunents relating to inproper installation of (a) rebar (b) concrete in the base nat and walls of each of the above-listed plants.

98. DoesNRC Staff know which power plants are being constructed by Daniel International in addition to the 4 listed above? If so, please list which plants.

99. Does lac Staff know which operating plants (not listed above in these interrogatories starting with nu:.ber 96) have been constructed by Danniel International?

100. Is 130 Staff aware of any cover-ups of information relating to defects in any plants being constructed by Lansiel International (including these listed above) during construction? Or of any failures to provide such infornation promptly and accurately to NRC staff?

101. For any plant for which any response to part or all of interrogatory 100 above is affirnative, please give the details, and identify all documents relating to, such coverup (s) ofr failures to provide infernstion on defects accurately and pronptly to Staff.

PRODUC IO:: OF DCC7.'.EC di ME h 9 d '

102. Please identify all documents identifie bove or which you have not given PIE accession nunbers, but which are available through tha PD3. P& MAS Please give the accession number for each if known.

103 For each document identified above (i.e. in response to interrogatcries above) which is net available fren the PE (or is, but has not been identified by accession nu .ber) will 130 staff nake a copy of that docu .ent available to Wells Eddler.an for inspection and copying?

?/ ngreenent between ne and NRC Staff Attorney 3arth, further cuestions relating to Eddlenan 45, 64F, 67, 75,80,83/84, and for Joint contentions, will be nade later as part of the first round of discovery to NRC staff in this case for those contentions.

Tnis 6th day of May 1953 hd 0~ * - ' 1 ,~

Wells Eddleman

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