ML20080C777

Supplemental Responses to Second Set of General Interrogatories,Interrogatories & Request for Production of Documents on Contentions 29 & 37B.Certificate of Svc Encl

ML20080C777
Person / Time
Site:	Harris
Issue date:	08/24/1983
From:	Gibbs J CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Eddleman W EDDLEMAN, W.
References
ISSUANCES-OL, NUDOCS 8308290304
Download: ML20080C777 (9)

Text

.

.. k August 24, 1983 DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g3 g g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD WhCE OF SECRep, 00CKETps&SEpan

1. NO In the Matter of )

)

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

)

(Shearon Harris Nuclear Power )

1 Plant, Units 1 and 2) )

J APPLICANTS' SUPPLEMENTAL RESPONSES TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES AND INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS ON CONTENTIONS 29 AND 37B TO APPLICANTS CAROLINA POWER & LIGHT COMPANY, et al.

(SECOND SET)

Applicants Carolina Power & Light Company ("CP&L") and North Carolina Eastern Municipal Power Agency, pursuant to 10 C.F.R. 5 2.740, hereby submit the following supplemental responses to " Wells Eddleman's General Interrogatories on Contentions 29 and 37B to Applicants Carolina Power & Light Company, et al. (Second Set) . " Applicants' provision of answers to Intervenor Zddleman's Interrogatories should not be deemed an admission of relevancy with regard to the 1/

information provided by Applicants or that sought by Intervenor.

The responses herein are deemed to supplement and incorporate, and do not displace, the answers and objections contained in Applicants' original responses.

1/ Applicants' responses dated August 19, 1983 to Intervenor Eddleman's second round of interrogatories (Fourth Set) addressed the supplemental material provided herein.

8308290304 830824 gDRADOCK05000 g%3i

The following supplemental responses refer to information regarding environmental water samplers which was not included in Applicants' responses to Intervenor Eddleman's first round of interrogatories on Contention 29. Applicants experienced, and continue to experience, difficulty in interpreting Inter-venor's extensive and compound interrogatories and originally concluded from the wording of Interrogatory No. 29-1 (a) that the first round interrogatories only addressed air samplers.

Applicants, in reviewing Intervenor's first and second round of interrogatories have now concluded that the first round of interrogatories may have included references to water samplers as well. Although Applicants feel the issue is uncertain, in an effort to be responsive, Applicants supple-ment their responses to Intervenor Eddleman's General Inter-rogatories and Interrogatories on Contention 29 to Applicants Carolina Power & Light Company, et al. (Second Set) as follows:

GENERAL INTERROGATORIES General Interrogatory No. G-l(c)

Person Interrogatory No.

Ronald Shearin 29-1 (a)- (c) , (e), (g).

The above individual is an employee of Carolina Power &

Light Company, P.O. Box 1551, Raleigh, North Carolina 27602.

I i

INTERROGATORIES ON CONTENTION 29 l Applicants supplement their responses to Intervenors' Interrogatories on Contention 29 as follows:

29-1 (a ) ANSWER:

Liquid - Surface Water Composite Samplers Location Sampler Location Category Surface Water Composite Harris Lake (vii), (ix)

Spillway (SW-26)

Surface Water Composite Cape Fear River (vii), (ix) at Lillington Water Plant (SW-40) .

Surface Water Composite Cape Fear River (vii), (ix) at confluence of the Haw and Deep Rivers (SW-38)

[ Control Station]

29-1(b) ANSWER: Water samplers listed above collect aliquots to form a composite sample of the surface water at equal time

intervals over a 168-hour period such that at least 150 aliquots are collected to comprise a collected volume of at least 8 liters for the time interval. An environmental technician collects the sample weekly and verifies proper operation of the sampler by direct observation and comparison of the indicated versus collected sample volumes.

The analytical results are reviewed by the Environmental Laboratory Supervisor and by the Environmental l

t Principal Specialist. Any concentration value of 2 pCi/l or greater is reported to the NRC.

2 9-1 (c) ANSWER: The applicants have independently deter-mined the accuracy of the samplers by a comparison of actual versus indicated sample volumes collected. This was performed by operating the sampler in the lab for greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, measuring the accumulated volume, dividing the volume by the -

aliquot volume, and comparing that value to the value indica-ted on the aliquot counter.

An environmental specialist established the criteria on interpretation of NUREG 0472 specifications and he performed the tests. The tests indicated that the sampling error was insignificant, less than 1 percent, compared to the counting error at the lower limit of detection for iodine in water. See FSAR S 16.2.

Tne sample volume verification performed weekly at the time of collection is equivalent to calibration.

29-1(e) ANSWER: In environmental sampling, the radioactive matcrial collected is considered sample material and not contamination. The sampler is not known to be subject to

" contamination" as defined in Applicants' Response.

2 9-1 (g) ANSWEE: Applicants are in possession of the environmental water samplers for SHNPP, which are Hydragard Automatic Liquid Samplers, Model CU.

Request for Production of Documents

-Applicants supplement their responses to intervenor's Request for Production of Documents as follows:

INTERROGATORY DESCRIPTION s 29-1(c) NUREG 0472, Revision 2, Radiological Effluent Technical Specifications for PWR's (1979) i Respectfully submitted n/ 7' Q.m' b

,!,,a w"4>: / f/ %)L/ / -

f/

' Themas/ A .' Baxterf P.C.

Jef'frey 'J . A. Gibbs

. ' SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samancha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 26602 (919) 836-7707 Dated: August 24, 1983 l

1 l

- _ , . - _ - . , . , . . . ~ - . . - . . , . . , . . . .-. . , - . .-

...~

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

)

CAROLINA POWBR & LIGHT COMDANY ) Docket Nos. $0-400 OL AND NORTH CAROLINA BASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

) -

(Shearon Harris Nuclear Pcwer )

Plant, Units 1 and 2) )

AFFIDAVIT OF B.H. WEBSTEE County of Wako )

) ss. ,

State of North Carolina )

B.H. Webster, being duly sworn, according to law, deposes and s$ys that he is Manager - Radiological & Chemical Support Section of Carolina Power & Light Company; that the supplemental answers to Interrogatories 29-1(a) to (c), (e) and (g) contained in " Applicants' Supplemental Responses to Welle Eddleman's' -

General Interrogatories and Interrogatories on Contentions 29 and 37B to Applicants Carolina Power & Light Company, et al.

(Second Set)" are true and correct to the best of his information, knowledge and belief; and that the sources of his information are officers, employees agents and contractors of Carolina Power & Light Company, ,

, N, (. dis bb

g. H. ~ Webster - .

. :.. ;.hiv,,

Sworn to and subscribed before

/;kM

-b,0 ..0o n$,. .,

me this g day of # ud ,1983. ,

,;

• g g ,, k.

A d4 J. AG AeJ  !

NotaryfPpblic .

k A. A&os,l4,,

V Q,.

My commission Expires: gy jpgg ' ,'-@k,[,,['s. ,,,,,hf/ ...

r-DOCKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION _

BEFORE THE ATOMIC SAFETY AND LICENSkhG I$hA% A10 :38 In the Matter of ) 0FFICE OF SECRETAs-

) 00CKETING & SERVici.

CAROLINA POWER &l LIGHT COMPANY ) Docket Sb'NI.CH50-400 OL AND NORTH CAROLIIJA EASTERN ) 50-401 OL MUNICIPAL POWER.GENCY )

)

(Shearon Harris l Nuclear Power )

Plant, Units 1 ynd 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Supplemental Responses to Wells Eddleman's General Interrogatories and Interrogatories on Contentions 29 and 37B to Applicants Carolina Power & Light Company, et al. (Second Set)" were served this 24th day of August, 1983 by deposit in the U.S.

mail, first class, postage prepaid, to the parties on the attached Service List.

/

/ //

'AAA f%)h k)/

i

.Jef f' rey- J. A.jGibbs t_ lij!'fll

/

l J

Dated: August 24, 1983

.- j

" UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION a BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I

In the Matter of )

4

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL 50-401 OL

and NORTH CAROLINA EASTERN )

I MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

l SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Comission 307 Granville Road Washington, D.C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne

U.S. Nuclear Regulatory Commission Post Office Box 12607 Washington, D.C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D.C. 20555 Charles A. Barth, Esquire (4) Mr. Wells Eddleman 718-A Iredell Street Myron Karman, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U.S. Nuclear Regulatory Commission Richard E. Jones, Esquire Washington, D.C. 20555 Vice President and Senior Counsel Docketing and Service Section (3) Carolina Power & Light Company Office of the Secretary Post Office Box 1551 U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27602 Washington, D.C. 20555 Dr. Phyllis Lotchin Mr, Daniel F. Read, President 108 Bridle Run CHANGE 7EEP* '. * '

Chapel Hill, North Carolina 27514 5 7 0.7 .W a.ycrose :S t r e e t R.a re 1 gh., N o.r th .C'a.ro 1ina 27606 Dr. Iinda Iittle Gove_wr's Waste Managere.nt Board

. 513 A1hle B'41aing 325 North 914 en Street Raleigh, North Carolina 27611 i

__ y

Sarvica List Pags Two Bradlef W. Jones, Esquire U.S. Nuclear Regulatory Commission Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Karen E. Long, Esquire Public Staff - NCUC Post Office Box 991 Raleigh, North Carolina 27602 t

l I

i l

l l -- - . #" F 4-**- , .p_,,,