ML20080R827

Response to Applicants Sixth Set of Interrogatories (Joint Contentions I & Vii).Related Correspondence

ML20080R827
Person / Time
Site:	Harris
Issue date:	02/22/1984
From:	Eddleman W EDDLEMAN, W.
To:
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8402280425
Download: ML20080R827 (18)

Text

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RELATED CORRESP0ficascr. 2 00CKETED USNRFebruarv EL, 198h UNITED STAIES OF AMERICA NUCLEAR BEGULATORY COMMI5840fEB 27 A10iO8 95Q[Nd;C BEFORE THE ATOMIC SAFETY AND LICbSINGnBOAHD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of

) Docket- 50 400 OL CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Units i ani 2) ) ASLBP No. 82-h68-01

) OL Joint Intervenors' Resuonse to Aunlicants' Sixtn Set of Interrogatories (on Joint I'cnd VII)

This response is timely filed because (as Applicants' counsel O'Neill informed us) Washington's Birthday (observed) was yesterday.

We subsecuently asked a further extension til Feb. P3d, due to W.T. getting Answers to General Interrogatories a cold.

1(a) Both joint I and joint VII were fornulated based on contentions of various intervenors, which Joint I and Joint VII respectively superseded. Wells Eddleman relied on the PSA9 and undates thereto in formulating his contention 3 *he basis documents for Eddlenan contentions 112, 113 and 11h, if any were used, would include the PSAR. We nresume you nean nane each person who you (1) know has first-hand knowledge of any facts alleged in this contention, and (2) relied on in fornulating these contentions.

We don't recall any such persons.

(b) see (a) response above.

(c) We presume you mean the facts alleged in each contention.

The only facts alleged in Joint Contention I dra that Applicants' record of safety and performance at their other nuclea" noue" facilities 1 does not demonstrate the adequacy of Anplicants' managing,. eng!neering, 8402280425 840222 PDR ADOCK 05000400 9 q- () 3 O PDR _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

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operating and maintenance eersonnel to safely operatc, maintain and manage the Harris plant; and that a pattern of managenent inadequacies and unqualified and/or inadequate staff is likely to be reproduced at the Harris plant and result in health and safety problems. As to Applicants' record, we uresume Applicants have much of the information, as does NRC staff. We are filing discovery soon (CPEL has agreed to accept hand service of same at its Raleigh offices, subject to some flexibility if they cannot resnond to it within'1h days) to both to get more information.

We believe the record adduced at the 1979 CP renand hearing on CPEL management capability contains sone of the record, as dc-NRC's files, including records of LERs, SALPs, fines prorosed and levied against CP&L, open itens, violations, deficiencies, noncompliances, nonconformances, repeated problens, managenent failures, comments by inspectors (e.g. Board Exhibit 8 of 1979 remand hearings, testimony of CD&L officials before the NCUC, NRC, SC Public Service Comnission, Federal Energy Regulatory Connission, Congress or its'comnittees or subconnittees, etc.

Joiht-Intervenors anticinate depositions will be needed to obtain

.further information concerning CP&L's record, narticularly in the areas of management, safety, qualification of personnel, opera-tions, maintenance, quality assurance / quality c ontrol, management controls, colicy and procedures. We believe further information concerning CP&L's safety and performance record is in the files of the NC Utilities Commission (NCUC) and/or its public staff, including testimony from cases involving CP&L, statements made by CP&L officials in connection with staff conferences, stock sales, bond sales, and other natters; also including records of outages, caoacity factor, causes of outages,

i predictions and commitments made by CP&L; and in orders of the NCUC finding CP&L management at fault in certain ways, uarticulaviv as regards 1981 and 1982 problems at Brunswick dealt with in FCUC Dockets E-2 sub 444 and E-2 sub h61. We believe other information concerning CP&L management and its nuclea9 policies and attitudes is contained in filings with the SCPSC, FERC, Securities and Exchange Commission, Atonic Energy Comnission, made by CP&L; and vorhaus in other files of those bodies. We resnectfully point out that the burden of proof as regards nanagenent carability is on the Applicants.

As to the pattern of nanaEenent inadequacies and unqualified and/or inadequate staff, we believe the attitude of Robinson plant nanagement (Board Exhibit 8, N90 Dkt 50-400, 1979 renand hearings) describitg them as doing only what is required by NRC, favoring production over safety, and impeding NRC inspectors' access to facilities; the pattern of radiation exposures and overexposuures to workers at Robinson; the pattern of health rhysics problems at both Robinson and Brunswick; the failure to curb tube leaks in the ~. Robinson stean generators; the record of severe accident premmeursors at both Robinson and Brunswick (one of the most serious sets of any untility, and, we believe, the nost serious group of such precursors attributable to any utility operating as few as 3 reactors); the pattern of extensive QA/QC nroblems at Brurswick, Robinson and Harris; the repeated and heavy fines levied by NRC against CP&L in numerous areas; the security problems at Brunswick, and at Robinson 2; defects in the Harris security plants; CP&L's attitude toward fines and security nroblens as evidenced by its repeated attennts to get out of fines, to down-play security problems, and by its outright rejection of the suggestions made by Joint Intervenors' secuvity exuerts (which

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":? .h were not contentions) ; CP&L's failure to meet commitments, as shown by its repeated violations of N90 rules and regulations,

.its repeated quality assurance and quality control fa' lures,

> violations and deficiencies; CP&L's extensive record-of failure

'to~ follow nrocedures at nuclear clants, including failures to establish adequate procedures as well as failure to follow existing urocedures; CP&L's unwitting offsite radiation release (s) at Brunswick; CP&L's release of LLRW (low level radianctive waste) from Brunswick to local landfills and scran ywards; CPEL's reneated clains that it had solved most of its problems at Brunswick, which were followed by more problems (including many of the sane ones claimed to be solved, e.g. high numbers of LERs, high encloyee turnover, large backlogs of unfinished work required for safety or health, poor maintenance, lack of adequate numbers of qualified personnel, lack of adequate supervision, lack of sufficient management attention, violations of N7C regulations and ruh s, etc); CP&L's extraordinarily poor perfornance in operating the Brunswick plant; other Brunswick problens alleged, including moving the site of taking samples for Sr-90 away fvom a place where higher Sr-90 levels had been detected, having to call in General Electric experts from the nearby nuclear factory on an emergency basis to help CP&L operators control the Brunswick plant, inadequate supervision of contractors; failure to nroverly In hiring our security experts, Joint Intervenors contracted for an objective review of Applicants' Harris security plans and in -

structed our. experts not to make cny contentions concerning any possible flaw (s) in such plans whi:h were not serious, but rather to take any minor defects or possible ninor imurovenents and make them into a list of suggestions. This list of suggestions was subnitted to CP&L and all the suggestions were rejected.

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design, build or operate the Augmented Offgas system at Brunswick; contamination of Brunswick auxiliary boilers (which led to them having to be replaced), failure to adequately naintain the RHR heat exchangers at Brunnswick (the Brunswick RHR failu"e resulting was considered among the most serious nuclear plant uroblems of 1981 by ORNL), failure to place indicator lights in the Brunswick control room to shou whether the watertight doors to the RHR compartment were closed, repeated problems with leaving said doors opern; operating Brunswick with excessive anounts of failed

l. fuel, which apparently led NRC staff to impose a license condition on Brunswick in 1979; rushing Brunswick 2 into cueration in 1974 for financial reasons, and committing to rush Harris into operation earl in 19 6 (in suite of being 4% behind schedule by their own admission to NCUC, and in spite of NRC staff's 1983 judgment that CP&L would

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be 6 months behind its scheduled fuel load date); consistent low SALP ratings at Brunswick for years after both CP&L and NRC staff told the ASLB in 1979 that the Brunswick problems were basically being solved, or had been solved; noor cable layout and fire protection at 3runswick, e.g. as indicated in 8-P1-7h meno from C.E. Murphy (AEC, later NRC) Region II construction inspector; unsupported public statements touting CP&L's record as good in the nuclear field; a relatively consistent attitude of refusitg to admit mistakes, defending past actions and saying to NRC, "you have to make us do it", instead of admitting mistakes and taking action beyond what NRC requires to ensure safety and reliability and adequate staffing and training at its nuclear plants; being a company whose major decisions are basically made by lawyers and others totally lacking in nuclear experience; and other factors.

Joint Intervenors don't allege that this is the whole nattern, just l

some of the more significant features of it which we have so far been able to identify.

The facts alleged in Joint VII are that vibration nroblens have developed in Weicinghouse model D-4 stean generators (cf.

. Krsko plant in Yugoslavia, for examule); that tube corrosion and cracking occurs in other Westinghouse stean generators with Inconel-600 tubes and/or carbon steel suncort plantes and AVT water. chenistry (cf. Robinson 2 when it used AVT);

that tube failure analyses do not show Harris steam generators can be operated consistent with ALARA and the Public Health and Safety (cf. Secy 82-72; NU9EG-0909; record of radiation exnosure to steam generator jumpers at Robinson 2 and other Westinghouse PWRs); and that loose parts detection capability dees not ensure operation consistent with ALARA and the public health and safety (e.g. record of loose carts in other Westing-house steam generators; descriution of Harris-loose parts detection gadgets-in the FSA9 as it wam in snring 1982). These last 2 aren't exactly " facts" of the contention since it doesn't exolicitly say they are facts; they nay be considered allegations.

We have tried to answer this sonewhat broadly in that r egard.

2 (a ) .- Joint Intervenors are seeking expert witnesses on Contentions I and VII but have retained nonc as yet. To the extent we rely on nonwitness exuerts' opinions or judgnent we may identify that verson by a nseudonyn. (b) Information supnlied by a pers_on will be referenced in specific resnonses.

3(a) and (b) see 2(a) resnonse above, h(a) because you used the word "and" between the phrases

" pertaining to the subject mattern of" and "upon which Joint Intervenors relied in formulating allegations in the contentions", a literal I

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answer might encompass only a few docunents. CCUC and Kudzu Alliance do possess considerable information from NCUC cases concernine CP&L management, and we believe both may nossess some concerning stean generators / Wells Eddleman possesses a boxful of info *mation concerning stean generators, had considerable information concerning CP&L management including some records and testinony from the 1979 Harris CP remand hearing on managenent. We have not catalogued the information nossessed by CHANGE or any other intervenor, nor of all members of the intervenor groups, concerning these natters, we nake the OBJECTION that it would be burdensone to do so, and 7

beyond our resources, and that nost of the information cane fron CP&L and NRC Staff anyway, and is thus in the possession of CP&L or available to them from their records of legal cases, statenents their enployees have made, test' mony their encloyees gave, or fron URC records publicly available.

(b) Joint Contentions I and VII; see above answer.

(c) Joint Intervenors have conducted no inventony of all these documents as to which- snedific allegation each sunnorts.

There are numerous documents and we believe it wouE be burdensone to undertake this research.

5(a) Where we have identified a suecific page citation to a document in the process of answering interrogatories herein, we will identify it; where we identify the document only, that infornaticn will be urovided.

(b) the information will be listed for specific rosnonse(s).

6(a) Possibly opin1on of nonwitness experts.

(b) where such opinion is used, that fact will be noted.

7(a). Joint Intervenors have not yet identified exhibits to be offered; however, we anticipate asking the Board to take judicial notice of the testimony and exhibits introduced in the 1979 remand

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[ hearings cn tho Harrio CP; and using the tostimony and exhibits of i

witness A. Ronald Jacobstein in NCUC Ebcket E-2 sub hhh (he investigated the Brunswick ulant in 1981 for the Public Staff of the NCUC), the NCUC Order in that docket, the testimony and exhibits of Thomas Lan of NCUC Public Staff concerning Brunswick in Docket E-P sub lt61 before the NCUC, and the order in that docket, or nort!ons of the preceding, either as exhibits or cross-exanination exhibits or both.

In cross-exanining the NRC Staff, we may use statenents various NRC Staff members nade in other N90 hearings or to the ACRS, of nortions thereof.- We stress that these identifications are prelininary and possible and not intended to be all-enconnassing.

We have not determined which documents or things we will actually use as exhibits yet.

RESPONSES TO SPECIFIC INTE990GATORES I-1. You evidently misunderstand Joint Contention I.

It is not about " incidents", but about Applicants ' r ecord and pattern of nanagement (or nisnanagement). Joint Intervenors believe that specific incidents can indeed tell something about management that is dealing with then or involved in then, but we also believe that good managonent (and the nanagement recuired for safe operation and maintenance of a nuclea" niant, which in our view would be extremely if not sunerhumanly excellent manab:nent) is much more than just the handling of incidents. It includes attitudes, mindsets, philosophies, practices, procedu es , natterns and overall performance judged not just by what the regulations or the NRC requires, but by the often-stronger standard of how prevents '

well management anticipates, - -

, admits, and deals with all problems, whether it was required by some rule to deal with any of then or not, and of how well management does in autting together a fully qualified, sufficiently capable and flexibic groun of

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employees to operate and maintain its plants and equinnent, always in sufficient numbers and with sufficient exndrience and sense and knowledge to cN)inuingly assure the protection of the health and ' safety of the public.

I .;2. The FSAR gives a sort of naper outline of CP&L's top management, with boxen and charts and resunes. Sone of its inadequacies are outlined in contentions superseded by Joint I,'

e.g. by Eddleman 3; however, the great weakness of all such paner outlines, including the "Managenent Capability Report" is the-illusion that good management can be reduced to, or demonstrated by, paper organizational charts and qualifications statements. Although such chargts and qualifications can do nuch to demonstrate the inadequuacy of nanagement, they can never show that the management is adequate to safely onerate and maintain

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a nuclear power plant. That CP&L nakes such subnissions is thus an indication to us of less-than-good managenent, and of only doing (in general) what the rules require.

Good management is denonstrated in nart by what it does, in part by how it handles peonle (including recruiting, training and retaining then and ensuring they can work together well), in part by its procedures and practices (narticularly how well it anticipaths difficulties and connlexities and nakes sure sufficient and sufficiently capable nersonnel and resources are in place to adequately handle difficult or complex matters before uroblens arise,d problems an this preventing many problems), in part by its handling of nistakes (does it readily adnit them? does it learn from then? does it effectively prevent their recurrence? does it try to get off cheap in dealing with-a problem or does it do what it takes to solve the problem solidaly?) , ia part by its integrity, honesty and truthfulness, including the extent to which it keeps comnitments (and avoids making

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commitments it may not be able to keep), in part by its actively seeking excellence and improvements at all tinos, in part by its resilience an8 ability to resuond to unusual challenges without in part by its not retaining or covering for " bad apples" panic or falling apart, and in part in many other ways. But no mere description or categorization or cookbook can encompass good management, nor can any chart or resune show it.

Our review of the FSA9, SER and "MCR" is not yet complete, We note that the SER (p.13-1) states that it contains a pronosed organization setuo, which Staff hasn't finished its review of.

CP&L's need to reorganize, narticularly at Brunswick, indicates a continuing management failu=e to place adequate management and staff resources, and adequate organization, in place to manage the Brunsuick plant safely. The more nuclear clants CP&L operates, the nore its resources will be stretched in the nuclear field.

While cancelling Harris 2,3 and 4 may reduce this strain on nuclear resources, the use of personnel who have experienced the poor operation and " brushfire-fighting" style of the Brunswick plant may significantly weaken the Harris planth staff in the all-important area of attitude. What CP&L has done is nore imnortant than what CP&L has said~about its attitude toward safaty, and its actions do not indicate the sort of excellent attitude of

" safety first" that safe nuclear overations obviously would require.

For examole, CP&L refused to shut down a Brunswick unit in sumner 1983 when NRC Staff urged a shutdown to check for pipe cracks. The NRC did not compel CP&L to shut down. When CP&L did shut the unit down, cracks were found, and overlay welds (a " band-aid" approach) were used on them even though CP&L had already ordered replacement piping.

• CP&L's large number of serious accident precursors also shows this inadequate attitude for seeking safety first. Othe* problems are discussed in response to I-3 below.

I-3 Joint Intervenors wish to emphasize again that Joint Contention I concerns patterns of mismanagement and of management; it also concerns the overall record of safety and ver-formance at Applicants' nuclear facilities. We reaffirm that the burden of proof is on Applicants to whos that they can safely operate, maintain and manage the Shenron Harris plant without allowing or creating health and/or safety problems. While incidents or specific p"oblems may help to show inadequacy, they do not show a pattern of adequacy of the type that anticipates and prevents problems and is able to deal effectively with unexpected as well ,

as expected difficulties.

Joint Intervenors also note that we are unable to list all of CP&L managenent's inadequacies or problems. We continue to research them. The following should not be considered an exhaustive list of incdequacies or problems CPhL management has.

(a) one specific inadequacy is having and/or using the idea that organizational charts, resumes, totals of years persons have spent'in a given line of work, or a paper managenent canability report can demonstrate that managenent at CP&L is adequate to maintain, operate and manage nucicar plants (or Harris) safely.

Another is the use of people without connercial PWo. exoerience in top construction positions at Harris: if the plant'a not built right, it can't bd operated safely or without risk to the public health. A third inadequacy is CP&L managenent's tendency to take a legalistic approach to nuclear managenent and nuclear problems, challenging regulators to prove management was wrong, denying problems or covering them up, and apparently trying to get their act nore together prior to significant licensing hearings (e.g. Harris CP and CP remand, Harris OL) with a pattern of slacking off or getting

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s -b2-into more problems thereafter. A fourth inadequacy is CP&L's tendency to make inflated commitments and fail to keep its commitments.

A fifth is CP&L's record of large numbers of precuarsors to sermious nuclear accidents. A sixth is CP&L's large number of violations, deficiencies, noncompliances and open items dealing with NRC and AEC regulations. A seventh is inadequate security and security planning.

An eighth is CP&L's failure to follow up many onerating and other nuclear problems properly or adequately. A ninth is CP&L's mismanagement of low - level radioactive wastes at Brunswick, which we believe to be the only nuclear power plant in the nation

. to allow LL9W. to be imnroperly disposed of in local landfills and to local scran dealers. A tenth is CP&L's extensive problems with quality assurance and quality control: although Robinson 2 was a turnkey plant (CP&L didn't have to do anything to get it built)

CP&L's construction and other work at Brunswick has been shot through with-QA/QC problems from the beginning, and Harris has often matched this pattern, e.g. in the area of hangers and nine supports, materials QA, etc. CP&L's charts show direct access to top management to call attention to such problens, but annarently these channels have not been used, even in cases such as the Harris nine hangers where a near-total breakdown of QA/QC and inspection integrity is evident (e.g. 95% failure rate of a sample of h00 pipe hangers already OK'd by inspectors at Harris).

An eleventh is CP&L's tendency to place financial considerations first, above quality or safety or taking adequate time to be sure a job is done right, e.g. Robinson attitude of " production first" as reported in Board Exhibit 8 of 1979 remand hearings on nanagement canability before the ASLB for Harris, rushing Brunswick 2 into operation in 1974 for financial reasons (which rush resulted in many later problems), connitting to meet the current schedule 4

13-to operate Harris in a sinilar rush, apparently for sinilar reasons.

A twelf th is inability to retain qualified employees in sufficient numbers. Here the Brunswick plant is a prine example with its high turnover problems, lack of enough qualified people to either make or supervise needed rep _ airs or modifications, as shown e.g. in statenents of F.S. Cantrell, NRC inspection &

enforcement, and of A. R. Jacobstein, consultant to NCUC Public Staff.

Joint Intenrvenors are pursuing discovery concern?ng most of these patterns and other patterns and events in Apolicants' record. We wish to enphasize again that we cannot produce a complete list of CP&L management's problems; this is due in part to our lack of resources to check everything, and in part to CP&L's apparent tendency to be less than responsive about its problens (and, appprently, to be less than forthcoming with certain information, even simple things like reports of power plant costs, or load forecasts, which night conceivably be used to cast doubt on the general capability or performance of its management; we recall a statement (we believe it is in Boa *d Exhibit 8 of 1979 renand) that CP&L only renorts the ccnspicuously reportable problems (at Robinson 2). We continue to lock into the problems of CP&L managenent.

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VII-1. Joint Intervenors' review of NUREG-101h is incomplete.

A nonwitness -expert, " Alice Ace", believes that NUREG-101h does not nrovide basis to assure that. multiple tube failures will not occur.

We also believe that the expanded tubes at Harris will be thinned and put into a more stressed condition by.the expansion involved in the NUREG-1014 "fix". We and "AA" believe that more analysis is needed to determine the magnitude and significance of such stresses. .We believe the effect of the thinning is clear: it weakens the tubes; it will also make daem more subject to denting. We believe that the burden of proof is on Apnlicants to show that the NURDG-1014 "fix" is adequate in all respects to protect the nublic health and safety.

VII-2: See above answer; when you expand a tube, its wall volume doesn't change significantly but its wall area does.

Thus the tube is thinned in the area where the expansion takes place. When you cold-work metc1, you leave residual stresses.

Tube exnansion of the NUMEG-101h "fix" type appears to us to be a form of cold working of the tube metal. The stresses therefrom may weaken the tube or part of it or make it more cubject to corrosion.

VII-3 First, we noint out that if the NU9TG-101h nodifications are nade and weaken the tubes or nake then nore subject to failure, corrosion, denting, rupture due to loose objects in the s team gen-erator, etc. , further nodifications nay not be able to solve the problem. To the extent that these modifications cause problems, they should not be made; replacement of the Harris steam gene =ators with models not subject to the type Dh/D5/E (or type D) vibration problems should be e considered. It may not be nossible to sleeve a tube which has only been exnanded at certain points, (e.g. at tube suonort plates or baffles), and if the tube has not been exnanded evenly sleeving nay not work at all. I

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Joint Interv;nora hava not conolotod our rOview of NUREG-101h and the modifications it proposes. We do believe that anv fix should be made prior to ammmmerini operation of Harris or radioactive water flowing through the steam generators, in order to minimize radiation exnosure to workers. We are seeking expert. help on this contention.

VII-h: Not aoplicable.

VII-5: Yes, to the extent that it does not nrevent corrosion, cracking, multiole tube failures, damage caused by loose parts in the steam generators, tube leaks and other problems.

VII-6: We haven't calculated a nudber for the added exnosure, but it is clear that steam Eenerator nroblems are significantly increasing radiation exposure to nuclear utant workers.

See the booklet " Tube Leaks" at unge 29; see ibid at P8-36 re radiation exposure and problems associated with it. In referencing o

tDis we do not endorse the BEIR radiation death estinates velated to occunational exposure given on p.31. We believe Dr. Gofman's estimates of such deaths are more accurate, and that Dr. Gofman's deaths ner nerson-ren estinate would give a nore accu

• ate picture of 6ne health . effect of such radiation exposurn.

VII-7. It would be nice to be able to specify such actions which you could then take (although your failuwe to think of then first and carry them out may berspeak less-than-good management).

SECY 82-72 at k (cf. Tube Leaks at 21) says that it is " Virtually impossible" to orevent tube leaks and that "There are no simple a .

corrective actions. Stean generators with tubes that resist both corrosion and vibration much better than the D-hs do, and which do not ninch their tubes or dont then due to nlate corrosion, and which would really last for the useful life oc the nuclear plant, would be things you should consider. We don't believe that the crocosed modifications are consistent with ALARA.

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VII-8. Not Applienblo.

VII-9. Of course it's inadequate. Did AVT water chenistry stop the corrosion of steam generator tubes at Robinson ??

' SeCY-82-72 points out (p.5) thatAVT water chenistry is linked to denting of stean generator tubes (cf. Tube Lekks at 19).

We_have not made a more complete analysis of.this problen yet, and "AA" poi 6ts out that AVT will not stop corrosion. The question is, will it slow it down enough? It did not appear to do so et Robinson =2 when AVT was first used there.

VII-10. Analysis not complete. See above resnonse.

VII-11. We are not sure that any available water chenistry thankn controls by thenselves will be sufficient to mininize or prevent tube corrosion or cracking and sat $ sfy this contention.

We are not certain that any water chenistry can vrevent corrosion caused.by the use of different netals in the stean generator and the turbine and the condenser and associated piping, nunns, and equipment in contact with the stean, feedwater, or both.

Changes in the s tean generator naterials , use of sacrificial anodos or other modifications or outright renlacement of the E stean generstor nay be required. Expanding the tubes nay actually increase suscepthibility to corrosion "or those tubes.

VII-12. Not applicable.

VII-13 We don't know at uresent in any detail. Robinsen 2 is cooled by fresh water -(lake Robinson) and still exnerienced steam generator corrosion and problems with AVT water chenistry.

We know that seawater cooling, or brackzish water cooling, can -

have adverse effects on condenser and heat exchange"e and other equinnent exposed to the seawater or brackish water.

VII-14 Yes.

VII-15 With AVT you have corrosion and leaks. The leaks require repairs which increase occunational exposure. The corrosion

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4 r;quirss. flushing, hnd that involvos radiation exrosure. In steam generators of this design, sone areas may not be able to be adequately

, flushed. Corrosion will build up in then, laading to more leaks

. or tube ruutures which also require fixing.

VII-16. Not Apnlicable.

VII-17. The question refers to a " program" whereas the SER at 4 4.4 refers to a netal impact v.onitoring "systen" or just loose parts-nonitoring "systen". Our review of this watter is not conplete, but we believe that both the sensors and the systen's other components should be safety grade. ("AA" called our attention to this safety grade issue).

VII-18. Review incomplete. The whole systen should be safety grade and tested for large weights (cf. SE9 h.4.4) as we_11 as small ones.

VII-19. Analysis currently inconplete.

VII-20. Analysis currently inconnlete. See VII-17 e.bove.

We are not now willing to withdraw rart (a) of contention VII.

VII-21. If it finds loose carts, occupational etnosure wfl1 be required to get then out, though the safety consequences of leavind then in could well be worse. If it needs renair or replacement, occupational exnosure will come with this work once the stean generators and urimary loop are " hot" (radioactive).

VII-22. We presuno you mean " contend" not " content". We know that increases can result from the situations described in the above answer. We have not deternined their magnitude. When neonle work near radioactive things like the Harris stean gererators will be, they incur radiation exposure.

VII-23 Not annlicable.

VII-24. Which counsel did you serve? John O'Neill indicated to Wells Eddleman II-16-8h that Anplicants had been serving such docunents on all the intervenors (or at least on Eddleman). _J I

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At any rata, wa haven't located this document yet in our files.

We will be continuing to-seek exnert analysis on this question.

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.We believe that reconnendations in a report-by Science Applications Inc (SAI) concerning steam generators are also relevant to this question, but we have not obtained or reviewed this report yet.

We have not conpleted our own review of this question.

VII-25,26,27,28,29: See response to VII-24 We also believe NUREG-0909 provides basis for believning that a steam generator tube rupture analysic based on a maximun of one "untured tube in any stean generator at any time is inadequate both for safety and. to protect the public health and safety (VII:;-27).

-VII-30. Not Applicable.

VII-31. We have not completed an analysis of the radiological consequences of SGTR. 'de do believe that nultinle tube ruptures aref a credible event and should be analysed (cf. SEGY 82-72, which points out that nultiple tube ruptures can occurn; NUPEG-0909, which shows they did). We do not believe that ALARA is consistent with events like SGTRs that release radioactivity inside containment.

VII-32. See above. VII-33. Not Applicable.

-Production of Documents Joint Intervenors agree to nake available for inspection and copying ' (1) Wells Eddleman's file of steam generator documents y (2) any other documents referenced in the above responses which

.CP&L does not already possess. We also reference, and will uroduce, those parts of the NC Anvil series on the Brunmswick plant entitled "An' Accident In The Making", as relevant to nanagement capability (or' lack thereof) by CP&L.

AFFIRMATION Wells Eddleman hereby affirms that the above responses are true to the best of his present knowledge and beliexf. This 22d day of February 19Bh. #

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