ML20079R439

Interrogatories & Request for Production of Documents (Sixth Set).Certificate of Svc Encl

ML20079R439
Person / Time
Site:	Harris
Issue date:	01/30/1984
From:	Bauser D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	EDDLEMAN, W., JOINT INTERVENORS - SHEARON HARRIS, KUDZU ALLIANCE
Shared Package
ML20079R431	List: ML20079R430 ML20079R439
References
NUDOCS 8402020230
Download: ML20079R439 (16)

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DOCKETED USNRC January 30) EO.f1 N0:57 gy m r -r g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

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

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO JOINT INTERVENORS (SIXTH SET)

Pursuant to 10 C.F.R. SS 2.740b and 2.741, Carolina Power

& Light Company and North Carolina Eastern Municipal Power Agency hereby request that Joint 1 rite rvenors (Kudzu Alliance, CCNC, CHANGE /ELP & Wells Eddleman) answer separately and fully in writing, and under oath or affirmation, each of the follow-ing interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identi-fled in the responses to the interrogatories below. Under the Commission's Rules of Practice, answers or objections to these 8402020230 840130 PDR ADOCK 05000400 0 PDR

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interrogatories must be served within 14 days after service of the interrogatories; 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 responeive to thece 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 acting on their behalf, obtain which are responsive to the re-quest, in accordance with the provisions of 10 C.F.R.

$ 2.740(e).

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, number, author, date of publication and publisher, addressee, 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 section(s), chapter (s), or page(s)) upon which Joint Interve-nors rely.

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'I Definitions: As used hereinafter, the following defini-tions shall apply:

The "FSAR" is the Final Safety Analysis Report for the Shearon Harris Nuclear Power Plant, as amended.

The "SER" is the Safety Evaluation Report related to the operation of Shearon Harris Nuclear Power Plant, Units 1 and 2, NUREG-1038 (Nov. 1983).

" Applicants" is intended to encompass Carolina Power &

Light Company, North Carolina Eastern Municipal Power Agency and their contractors for the Harris Plant.

" Joint Intervenors" is intended to encompass the following organizations and individuals, jointly and severally: Chapel Hill Anti-Nuclear Group Effort, the Environmental Law Project, the Conservation Council of North Carolina and the Kudzu Alli-ance, as organizations, their members, and their representa-tives, and Mr. Wells Eddleman.

" Document (s)" means all writings and records of every type in the possession, control or custody of Joint Intervenors or any individual acting on their behalf, including, but z.at lim-ited to, memoranda, correspondence, reports, surveys, tabu-lations, charts, books, pamphlets, photographs, maps, bulle-tins, minutes, notes, speeches, articles, transcripts, voice recordings and all other writings or recordings of any kind;

" document (s)" shall also mean copies of documents even though the originals thereof are not in'the possession, custody, or control of Joint Intervenors; a document shall be deemed to be n

9 within the " control" of Joint In,tervenors or any individual acting on their behalf if Joint Intervenors or the individual i

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, i

and upon which Joint Intervenors relied in formulating allega-tions in the contentions which are the subject of this set of 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.

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9 3(a). State the name, address, title, employer and education 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 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-viously identified in response to Interrogatory 2 or 5, which was used in answering the interrogatories set forth herein.

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I (b). Identify the specific interrogatory response (s) to which each such soarce of information relates.

7(a). Identify all documents which Joint Intervenors intend to offer as e:hibits during this proceeding to support the contentions which are the subject of this set of interrogatories or which Joint Intervenors intand to use during cross-examination of witnesses presented by Applicants and/or the NRC Staff on the contcntions wnich 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 I (Management)

I-1. With respect to each incident at Applicants' other nuclear power facilities which forms the basis for Joint Con-tention I, identify (a) the nature of the incident, (b) the date of the incident, and (c) the documents on which Joint In-tervenors rely for information about each incident, including the specific language relied upon within each document.

I-2. Based on your review of the FSAR, the SER, and Ap-plicants' January 10, 1984 Management Capability Report (MCR),

a copy of which has been provided to each of the Joint Interve-nors, have Joint Intervenors identified management or staff inadequacies in Applicants' organiza". ion for operating the Harris plant?

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I I-3. If the answer to Interrogatory I-2 is affirmative, (a) specifically identify each alleged inadequacy, (b) explain I why Joint Intervenors consider this aspect of management to be inadequate, and (c) identify the section(s) of the FSAR, the SER and the MCR in which each alleged inadequacy is discussed.

Interrogatories On Joint Contention VII (Steam Generators)

VII-1. The NRC Staff, in NUREG-1014, " Safety Evaluation Report Related to the D4/DS/E Steam Generator Design," (a enpy of which was served on counsel for Joint Intervenors by the NRC Staff on November 1, 1983), approved modifications proposed by the Counterflow Steam Generator Owners Review Group (of which Carolina Power & Light Company is a member) to alleviate vibra-tion problems experienced in the preheater sections of Model D4, D5 and E Steam Generators. Applicants have committed to undertake the modifications recommended in NUREG-1014 prior to start-up. See Applicants' letter no. LAP-83-559 dated December 2, 1983 to the Staff. Do you contend that the modifications described in NUREG-1014 are inadequate to protect the public.

health and safety?

VII-2. If the answer to the preceding interrogatory is affirmative, state in detail the inadequacies you perceive and all facts which support your allegation.

VII-3. If the answer to Interrogatory VII-1 is affirma-tive, identify in detail all additional modifications which you r

I contend are necessary in order to protect the public health and safety.

VII-4. If the answer to Interrogatory VII-1 is other than affirmative, explain how this answer is consistent with Conten-tion VII and state whether you are willing to withdraw part (1) of Contention VII.

VII-5. Do you contend that operation of the Harris Plant with the proposed modifications to the steam generators will result in an unacceptable ALARA increase in the occupational exposures to maintenance workers at the Harris Plant?

VII-6. If the answer to the preceding interrogatory is affirmative, identify the increases you contend will result and state in detail all facts which support your allegation.

VII-7. If the answer to Interrogatory VII-5 is affirma-tive, identify all additional actions which you contend Appli-cants must implement in order to maintain occupational expo-sures in accordance with ALARA principles in operating the plant with the proposed modifications.

VII-8. If the answer to Interrogatory VII-5 is other than

affirmative, explain how this answer is consistent with Conten-tion VII.

VII-9. Do you contend that the efforts to be undertaken l

by Applicants (see FSAR S 5.4.2.1; SER $ 5.4.2) will be l -e-l

.f' inadequate to minimize corrosion or cracking of the steam generator tubes? Address in particular the AVT water chemistry program described in FSAR S 5.4.2.1.3.

VII-10. If the answer to the preceding interrogatory is affirmative, state in detail the inadequacies you perceive and all facts which support your allegation.

VII-11. If the answer to Interrogatory VII-9 is affirma-tive, identify those additional actions you claim are necessary in order to minimize tube corrosion and/or cracking. Address in particular any additional water chemistry controls you contend are necessary.

VII-12. If the answer to Interrogatory VII-9 is other than affirmative, explain how this answer is consistent with Contention VII and state whether you are to withdraw part (2) of Contention VII.

VII-13. Describe your understanding of the effect that the use of freshwater cooling, as opposed to seawater cooling, has on the effectiveness of an AVT program and on the overall program for minimization of tube corrosion.

VII-14. Do you contend that the use of AVT, and other methods described in FSAR $ 5.4.2.1 to minimize tube corrosion, at the Harris Plant will result in increased occupational expo-sures to maintenance personnel in violation of ALARA principles?

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VII,15. If the answer to the preceding interrogatory is affirmative, identify the increases you contend will result and state in detail all facts which support your allegation.

VII-16. If the answer to Interrogatory VII-14 is other than affirmative, explain how this answer is consistent with Contention VII.

VII-17. The Harris Plant loose parts monitoring program is described in Applicants' letter of October 28, 1983 to H.R.

Denton, NRC (copy of which was served upc n counsel for Joint Intervenors), and SER S 4.4.4 reports on the Staff's review and acceptance of that program. Do you contend that the loose parts monitoring program is inadequate to protect the public health and safety?

VII-18. If the answer to the preceding interrogatory is affirmative, state in detail the inadequacies you perceive and all facts which support your allegation.

VII-19. If the answer to Interrogatory VII-17 is affirma-tive, describe in detail the additional actions you contend are

necessary for an adequate loose parts monitoring program.

VII-20. If the answer to Interrogatory VII-17 is other than affirmative, explain how this answer is consistent with Contention VII and state whether you are wiling to withdraw part (3) of Contention VII.

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VII-21. Do you contend that Applicants' loose parts moni-toring program will result in an increase in the occupational exposures to maintenance personnel at the Harris Plant?

VII-22. If the answer to the preceding interrogatory is affirmative, identify the increases you content will result and

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state in detail all facts which support your allegation.

VII-23. If the answer to Interrogatory VII-21 is other than affirmative, explain how this answer is <onsistent with Contention VII.

VII-24. Do you contend that Applicants' steam generator tube rupture ("SGTR") analysis, as described in FSAR S 15.6.3 and in Applicants' letter dated July 1, 1983 to the NRC Staff (LAP-83-248)(a copy of which was served on counsel for Joint Intervenors) does not meet the NRC Staff's requirements?

VII-25. If the answer to the preceding interrogatory is affirmative, identify the failure to meet Staff requirements and state in detail all facts which support your allegation.

VII-26. If the answer to Interrogatory VII-24 is other than affirmative, explain how this answer is consistent with Contention VII.

VII-27. Do you contend that Applicants' SGTR analysis is inadequate to provide for protection of the public health and safety?

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, l VII-28. If the answer to the-preceding interrogatory is affirmative, identify in detail each and every alleged inade-quacy.

VII-29. If the answer to Interrogatory VII-27 is affirma-tive, state in detail all facts which support your allegation.

VII-30. If the answer to Interrogatory VII-27 is other than affirmative, explain how this answer is consistent with Contention VII and state whether you are willing to withdraw part (4) of Contention VII.

VII-31. Do you contend that Applicants' analysis of the radiological consequences of a SGTR event is inadequate to as-sure that occupational exposures to maintenance personnel are limited in accordance with ALARA principles?

VII-32. If the answer to the preceding interrogatory is affirmative, state in detail all facts which support your alle-gation.

VII-33. If.the answer to Interrogatory VII-31 is other than affirmative, state how this answer is consi stent with Con-tention VII.

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Request 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 identified or described in the answers to each of the above interrogatories at a place mutually convenient to the parties.

Respectfully submitted, Q M /h./ & 11+ %

Thomas A. Baxter, P.C.

John H. O'Neill, Jr., P.C.

Deborah B. Bauser i

SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 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: January 30, 1984

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

^

In the Matter of )

)

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

)

(Shearon Harris Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE ,

I hereby certify that copies of " Applicants' Interrogatories and Request for Production of Documents to Intervenor Richard D.

Wilson (Fifth Set)" and " Applicants' Interrogatories and Request for Production of Documents to Joint Intervenors (Sixth Set) "

were served this 30th day of January, 1984, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.

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Deborah B. Bauser I

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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

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

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

SERVICE LIST Janes L. Kelley, Esquire John D. Runkle, Esquire Atanic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Ccmnission 307 Granville Road Washington, D.C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Ataric Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Ccmnission P.O. Box 12607 Washington, D.C. 20555 Raleigh,' North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atanic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Cannission Apex, tbrth Carolina 27502 Washington, D.C. 20555 Mr. Wells Eddlerian Charles A. Barth, Esquire 718-A Iredell Street Janice E. Moore, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U.S. Nuclear Regulatory Ctmnission Richard E. Jones, Esquire Washington, D.C.' 20555 Vice President ard Senior Counsel Carolina Power & Light Campany Docketing ard Service Section P.O. Box 1551 Office of the Secretary Raleigh, North Carolina 27602 U.S. Nuclear Regulatory Ctmnission Washington, D.C. 20555 Dr. Phyllis Iotchin 108 Bridle Run Mr. Daniel F. Read, President Chapel Hill, North Carolina 27514 CHANGE /ELP 5707 Waycross Street Dr. Linda W. Littic Raleigh, North Carolina 27606 Governor's Waste Management Board 513 Albenarle St:ilding 325 North Salishiry Street Raleigh, North C.irolina 27611 I

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, Bradley W. Jones, Esquire U.S. Nuclear Regulatory Ccanission

_-Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esqture Atanic Safety and Licensing Board Panel U.S. Nuclear Regulatory Castission Washington, D.C. 20555 Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 i

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