ML20082D953
| ML20082D953 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/17/1983 |
| From: | Hollar D CAROLINA POWER & LIGHT CO. |
| To: | Eddleman W EDDLEMAN, W. |
| Shared Package | |
| ML20082D952 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8311230227 | |
| Download: ML20082D953 (31) | |
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00CNETED USNRC N hh gegj7,1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE A_TOMIC SAFETY AND LICENSING BOARD
-In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN )
MUNICIPAL POWER AGENCY Docket Nos. 50-400 OL
) 50-401 OL
)
(Shearon Harris Nuclear Power )
Plant, Units 1 & 2)
)
APPLICANTS' RESPONSE TO WELLS EDDLEM AN'S I GENERAL INTERROGATORIES AND INTERROGATORIES ON EDDLEMAN CONTENTION ISAA (SIXTH Applicants Carolina Power & Light Company (CP&L) and North Carolina Easte Municipal Power Agency, pursuant to 10 C.F.R. S 2.740b, hereby submit t responses to Wells Eddleman's GeneralInterrogatories and Interrogatories on Eddleman Contention 15AA to Applicants Carolina Power & Light Company, et al. (Sixth Se .
Responses to the interrogatories in the Sixth Set relating to Contentions 8F(l) an have been submitted under a separats cover.
The provision of answers to these interrogatories is not to be deemed a representation that Applicants consider the information sought to be relevant to the issues to be heard in this proceeding. u GENERAL INTERROGATORIES INTERROGATORY NO. G1(a) Which contentions of Wells Eddleman do App agree are now admitted in this proceeding, NRC Dockets 50-400/4010.L.? El ANSWER:
5 in The contentions of Intervenor Eddleman which are admitted E l
proceeding are set forth in various memoranda and orders issued by the Atom and Licensing Board, all of which are available to Mr. Eddleman. .-"
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-(b) For each such contention, provide for any answers to interrogatories by Wells l Eddleman which Applicants have previously or presently received (except those i suspended by Board order, if any), the following information j ANSWER: The answers to General Interrogatories herein are restricted to - l Eddleman Contention 15AA. ,
(c) Please state the name, present or last known address, and present or last known )'
- employer of each person whom Applicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) upt>n whom Applicants relied (other than their attorneys) in making such answer.
ANSWER: The following list identifies those persons who provided information upon which Applicants relied in answering the interrogatories on Eddleman Contention 15AA and indicates the particular interrogatory answer for which such person provided information.
PERSON INTERROGATORY B. M. Williams All R. S. Stancil All R. M. Coats 17(f),(g),(h),(j),(t),(u),(v)(iv)&(v);
8( ), d ,(g),(h),(j),(s)(i),(t),
J. L. Harness 17(a),(b),(c),(d),(e),(1),(m),(n),(o),
(p),(w),(x),(y) l Each of these persons is employed by Carolina Power & Light Company, P. O. Box 1551, Raleigh, NC 27602.
! (d) please identify all facts concerning which each such person identified in response to G1(c)(1) above has first-hand knowledge.
ANSWER: See Answer Gl(c).
l (e) please identify all facts and/or documents upon which each person identified in l response to Gl(c)(2) above relied in providing information to respond to the interrogatory, including the parts of such documents relied upon.
l ANSWER: All such facts or documents relied upon by those individuals identified t
above are indicated within each response to the specific interrogatories on Contention j 15 AA.
l m- .__ __ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ . . _ , _
(f) Please identify any other document (s) used or relied upon by Applicants in responding to the interrogatory.
ANSWER: See Answer Gl(e).
(g) Please state which specific fact each document, identified in response to G1(e) and G1(f) above, supports, in the opinion or belief of Applicants, or which Applicants allege such document supports.
ANSWER: Applicants have indicated which specific facts are supported by the documents identified, within each response to the specific interrogatories on Contention 15 AA.
(h) Please state specifically what information each person identified in response to Gl(c)(1) or Gl(c)(2) above provided to or for Applicants' affiant in answering the interrogatory. If any of this information is not documented, please identify it as
" Undocumented"in responding to this section of GeneralInterrogatory Gl.
ANSWER: See Answer Gl(c).
INTERROGATORY NO. G2 (a) Please state the name, present or last known address, title (if any), and present or last known employer, and economic interest (shareholder, bondholder,' contractor, employee, etc.) if any (beyond expert or other witness fees) such person holds in Applicants or any of them, for each person you intend or expect to call as an expert witness or a witness in this proceeding, if such information has not previously been supplied, or has changed since such information was last supplied, to Wells Eddleman. This applies to Eddleman and Joint Contentions as admitted, or stipulated by Applicants.
ANSWER: Applicants have not yet identified the expert er other witnesses they expect to callin this proceeding. When and if such witnesses are identified, Applicants will supplement this response in a timely manner.
(b) Please identify each contention regarding which each such person is expected to testify.
ANSWER: See Answer G2(a).
(c) Please state when you first contacted each such person with regard to the possibility of such person's testifying for Applicants, if you have contacted such person.
ANSWER: See Answer G2(a).
(d) Please state the subject matter, separately for each contention as to which each such person is expected to testify, which each such person is expected to testify to.
ANSWER: See Answer G2(a).
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.a (e) Please identify all documents or parts thereof upon which each such witness is expected to, plans to, or will rely, in testifying or in preparing testimony.
ANSWER: See Answer G2(a).
INTERROGATORY NO. G3(a) Please iden'tify any other source (s) of information
- which Applicants have used to respond to any interrogatory identified under G1 above, stating for each such source the interrogatory to which it relates, and what information it provides, and identifying where in such source that information is to be found.
ANSWER: Applicants have identified all such other sources of information, if any, within the answers to the specific interrogatories set forth herein.
(b) Please identify any other source (s) of information not previously identified upon which any witness identified under G2 above, or other witness, has used in preparing testimony or exhibits or expects to use in testimony or exhibits, identifying for each such i '
source the witness who is expected to use it, and the part or part(s) of such source (if
' applicable) which are expected to be used,' ar.d, if not previously stated, the fact (s) or subject matter (or both) to which such source relates.
ANSWER: See Answer G2(a).
INTERROGATORY NO. G4(a) please identify all documents, and which pages or sections thereof Applicants intend or expect to use in cross- examination of any witness I call in this hearing. For each such witness, please provide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject matter Applicants believe they relate to, and make the document (s) available for inspection and copying as soon as
, possible after Applicants decide or form intent to use such document in cross-examination.
ANSWER: Applicants have not at this time identified which documents, if any, they intend to use in cross-examination of Mr. Eddleman's witnesses.
(b) please identify any undocumented information Applicants intend to use in cross-examination of each such witness for me.
l - ANSWER: See Answer G4(a).
l INTERROGATORY NO. G5(a) for each contention Applicants state or admit is an
- admitted Eddleman contention under Gl(a) above, or an admitted joint intervenor contention, please state whether Applicants have available to them experts, and
( information, on the subject matter of the contention.
ANSWER: Applicants have available to them experts and information on the l-l subject matter of Contention 15AA.
(b) If the answer to (a) above is other than affirmative, state whether Applicants
, expect to be able to obtain expertise in the subject matter, and information on it, and if l
not, why not.
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ANSWER: Not applicable.
- 'INThRROGATORY NO. G6(a) for each ' document identified in response to any interrogetory herein or referenced in response to any interrogatory herein, please supply all the following information which has not already been supplied:
- (i) - date of the document
- (ii) title or identificaion of document
+ (iii) all authors of the document, or the author
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'(IV) all qualifications (profe:sional, technical) of each author of the document (v) the specific parts, sections or pages, of the document, if any, upon which Applicants rely (vi) the -specific information each part, section or page identified in
-g response to (v) above contains.
(vil) identify all documents used in preparing the document, to the extent known (and also to the extent not identified in the document itself)
(vill) state whether Applicants possess a copy of the document
. (ix) state all expert opinions contained in the document, upon which Applicants rely, or identify each such opinion.
(x) -identify the contention (s) with respect to which Applicants rely upon (a) the expert opinions (b) the facts identified in the document (xi). state 'vhether Applicants now employ any author (s) of the document, identifying each such person for each document.
(xii) state whether Applicants have ever employed any author (s) of the document, identifying each such person for each document.
(xili) identify all sources of data used in the document. Answers to all the above may be tabulated or grouped for efficiency.
ANSWER - G6(a)(i)-(xiii): All such information available to the Applicants with regard to each document identified in response to an interrogatory herein is contained in the particular document which is being made available to Mr. Eddleman. It would be particularly burdensome for Applicants to research all historical employment records to determine whether the authors of each document identified herein have ever been R .
ir .i siismi i a
employed by Applicants. However, Applicants will supplement this response in a timely manner if and when Mr. Eddleman identifies any such author regarding which he is particularly interested in determining this information.
-INTERROGATORY NO. G7(a) Please identify all documents which Applicants plan, expect or intend to offer as exhibits (other than for cross- examination) with respect to each Eddleman contention admitted in this proceeding which (i) is included in your current response to G1(a), or (ii) is the subject of interrogatories in this set; please state for which contention or contentions each exhibit will be or is expected to be offered.
ANSWER: Applicants have not yet identified those documents they intend to offer as exhibits relating to Eddleman Contention 15AA'.
(b) Please identify an documents which Applicants plan, expect or intend to use in cross examination of any other parties' witnesses or joint intervenor witness in this proceeding, with respect to (i) Eddleman contentions identified under G7(a)(i)(or G1(a))
above, or any other Eddleman contention which is the subject of interrogatories in this set; (ii) each Joint contention now admitted in this proceeding; (iii) per our agreement of 4-8-83, each contention of each other party to this proceeding which is currently admitted. Please identify for each such document the witnesses, or witness, and all contentions with respect to whom (or which) that document is planned, expected, or intended to be offered or used.
ANSWER: Applicants have not yet identified those documents they intend to use for cron-examination of any witness.
(c) Please identify which of the documents identified in response to (b) above (i) will be offered into evidence by Applicants and (ii) which of the same documents Applicants expect to offer into evidence or intend to offer as evidence or exhibits in this proceeding ANSWER: See Answer G7(b).
INTERROGATORY NO. G10(a) Where the above general interrogatories and/or specific interrogatories below, or any of them call for identification of documents, (i) and no documents are identified, is that the same as Applicants stating that there are no documents responsive to this generalinterrogatory,in each case where no documents are identified? (ii) and documents are identified, is that the same as Applicants stating that the identified documents are the only ones presently known which are responsive to the interrogatories? (iii) If your answer to G10(a)(ii) is other than affirmative, please state all reasons for your answer. (iv) If your answer to G20(a)(i) above is other than affirmative, please state all reasons for your answer.
ANSWER (a)(i): Yes.
(ii): Yes.
(iii): Not applicable.
l l
i (iv): Not applicable.
(b) Where any interrogatory, general or specific, herein, calls for factual information (i) and an opinion is stated in response, is that the expert opinion of any person (s) identifies as having contributed information to that response? (ii) and facts are given or identified (or a fact is) in response, but.no documents are identified, does that mean Applicants have no documents containing such fact (s)? (iii) If your answer to (i) above is affirmative, please state for each such response all qualifications of each expert upon whom Applicants rely for each such answer. The qualifications need be stated only once for each such person if they are clearly referenced in other answers. (iv) if your answer to (i) above is other than affirmative, please state which opinions, if any, given in response to interrogatories (general or specific) herein is the opinion of an expert, identify each expert whose opinion you used in response to each interrogatory, and state in full the qualifications of each such expert. (v)If your answer to (i) above is other than affirmative, please identify all opinions of non-experts used in your responses, and identify each non-expert whose opinion is included in each answer herein. (vi) If your response to (ii) above is other than affirmative, please identify each document which contains a fact not previously documented in your response (s), stating what the fact is, and at what page, place, chapter or other specific part the document contains such fact.
ANSWER (b)(i): Yes.
(ii): See Answers G1(e), (f), and (g) above.
(iii): See Attachments A, B, C and D attached hereto.
(iv): Not applicable.
(v): Not applicable.
(vi): Not applicable.
INTERROGATORY NO. Gil For each answer to each interrogatory herein (or sny subpart or part thereof), please identify each item of information in possession of Applicants (including facts, opinions of experts, and documents) which (a) contradicts the answer you made, (i) in whole (ii) in part (please identify each such part for each item of information identified); (b) casts doubt on your answer (i) in whole (ii) in part (please identify each such part for each item of information identified). (c) Please identify all documents not already identified in response to parts (a) and (b) above (and their subparts) which contains any item of information asked for in (a) or (b) above. Please identify for each such document what information item (s) it contains and what answer (s) each such item is related to.
ANSWER Gil(a)-(c): Applicants have no such information.
INTERROGATORIES ON 15AA INTERROGATORY NO.15AA-(2d)-17(a) Does CP&L have an estimate of the length of refueling outages (or of a typical refueling outage) for the Harris plant?
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ANSWER: Yes. -
.(b) If answer to (a) is affirmative, what is that estimate in terms of time per refueling outage?
' ANSWER: . Applicants' estimate of the length of a typical refueling outage, based on refueling' operations only, is approximately seve$ weeks. However, during refueling
~ (end of the operating cycle), plant maintenance and inspections are also performed.
Estimates of the length of a typical refueling, maintenance, and inspection outage range from fifteen weeks for the first two outages to thirteen weeks for subsequent end-of-cycle outages.
(c) Please s!ste succinctly all significant bases CP&L relies upon in estimating the length of refueling outages for Harris.. If the outages are estimated to differ in length, please explain all significant reasons for such variations in length of time per refueling outage.
ANSWER:' Applicants' time estimate is based on the vendor's estimated schedule for refueling operations, on anticipated requirements for plant maintenance and inspection, and on outage experience gained at H. B. Robinson Unit No. 2. The estimate of the end-of-cycle outage lengths cited in (b) above reflects a reduction in the length, beginning with the third such outage, based on maturity of the plant.
(d)- Did anyone besides CP&L contribute to your estimate of length of refueling outage (s) for Harris?
ANSWER: Yes.
(e) If answer to (d)is affirmative, please identify each such person (or organization if the organization provided information but you don't know which person (s) provided the information.
ANSWER: Westinghouse Electric Corporation.
(f) How long do you estimate Harris will normally operate (hours or otner units of time) between refueling outages?
ANSWER: Applicants' current estimate of the Harris operating cycle lengths
. (period between refueling outages) per unit is as follows:
Operating Cycle Length Operating Cycle No. (Weeks) 1 (From Conimercial Operation Date) 53 2 63 3 (and Following) ,
68 (g) Has'anyone besides CP&L (e.g. Westinghouse, Ebasco, etc) estimated how long the Harris plant will normally operate between refueling outages?
ANSWER: Not to Applicants' knowledge.
(h) If answer to (g) is affirmative, please state each such estimate you possess.
ANSWER: Not applicable.
(j) . Please state all significant bases known to you for each estimate given in response to (f) or (h) above, identifying the person (s) (or organizations where no persons are known to you but the organization provided information for the estimate) who contributed to or made or provided (i) the estimate (ii) any basis for each estimate.
ANSWER: The lengths of the Harris operating cycle are derived by dividing the estimate of reactor core Effective Full Power Days (EFPD) by the projected thermal capacity factor for that cycle. The number of EFPD's is calculated on the basis of the expected design of the reactor core for each cycle. These calculations are made by the Nuclear Fuels Section of CP&L's Fuels Department. Projected thermal espacity factors are the result of an evaluation of historical capacity factors of CP&L units and recent Westinghouse units. These data are prepared by the Nuclear Staff Support Section of the CP&L's Nuclear Generation Group.
(1) Has CP&L or anyone else known to you estimated the frequency of (i) reactor trips (ii) turbine trips (iii) reactor scrams (iv) forced outages (v) deratings of output (electrical or thermal or both) (vi) partial forced outages, for Harris 1, Harris 2, or both units?
ANSWER: No.
(m) For each part of (1) above for which your answer is affirmative, please state the estimate, who made it, when it was made, what documents (if any) contain it, and state all significant bases for each such esumate, including any expert opinions, documents or portions thereof, and other information known to you which was used in making such estimate. Please provide all the above information (as requested in "(m)') for each estimate.
ANSWER: Not applicable.
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k (n) Has CP&L or anyone else known to you estimated (i) the availability (ii) the 5 equivalent availability of (aa) Harris 1 (bb) Harris 2 (ce) both Harris units? _.
ANSWER: No. Capacity factors are the most valid measurement of base load
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nuclear unit performance. Availability and equivalent availability are more appropriate h_
- - for measuring performance of fossil units which are subjected to system load-following }4 operations. .,
(o) If answer to (n) above is affirmative please (i) define the terms " availability" and -j
" equivalent availability" as they were used for each such estimate (giving any different 3 l
definitions used and stating the estimates to which each such definition applies), (ii) _3
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explain any authority or other basis for each definition of (aa) " availability" (bb) i
" equivalent availability" used; (ill) state who made the estimate, when, and state all significant basis for each such estimate which you know. (iv) give the estimate, in q percent, hours per year or whatever other form you possess the estimate in, stating to @
which unit (s) it applies. J ANSWER: Not applicable, j j
(p) Please identify each person you know of who contributed (i) information or (ii) -
expert opinion to each estimate given in response to (o) (iv) above, or otherwise made or
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'i known to you, with respect to (aa) availability (bb) equivalent availability, for Harris 1, 2, or both, stating for each such person what information or opinion or both each 3 4
contributed, to which estimate (s). %x ANSWER: Not applicable. g (q) Exactly what information concerning planned maintenance did you use from the 3 Robinson Plant (Robinson Unit 2) (see your 9-16-83 response to my interrogatory #25 on li
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15AA) in making estimates of planned maintenance for Harris? Please include in your q
answer (but do not limit it to) exactly what experience data was used, and exactly how it was used, including all relevant calculations or computations; exactly what projections j were used, who made them, how each v;as made, when it was made, what calculations g y
were made in making each such projection, what data was used in the calculations (and in each such calculation), where the data used came from (including identity of all documents containing it), and any other opinions or information you rnied on making
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these projections, stating such data for each such projection. Please provide sufficient data and statement of calculations that the results of the calculations can be checked from the original data and calculational procedures given. l ANSWER: To be provided by Supplemental Response. ) -
(r) Did you take the possibility or likelihood or consequences of additional NRC 3 i
regulations into account in any way in preparing your estimates of Harris Planned ;
Maintenance filed 6/30/82 (the "PURPA 133 document" referred to in your response to interrogatory 25 on 15AA)? h j_
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- ANSWER: No. An evaluation of possible future NRC regulations was not reflected
' in the projections for the Harris units, given in the June 30, 1982 PURPA Section 133 filing under S290.302(b), Item 16.
(s) If ans.wer to (r) is affirmative, please state what you took into account re NRC regulations, and exactly how you did it, including any data, documents, or expert opinions or other information you relied on, stating for each how it was used in making your estimate. -
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ANSWER: Not applicable. ,
(t) Does- CP&L' have any estimates made since the estimates filed 6/30/82 under PURPA Section 133 (with NCUC and [or FERC) as to the amount of Planned maintenance for Harris?
ANSWER: Yes.
(u) If answer to (t) if affirmative, please provide (i) each such estimate (ii) who made it and when (iii) the purpose, if any, for which it was made (iv) for each estimate, all significant bases of such estimate, all data used in making it, all expert opinions or other information relied on in making it, and a statement of each calculation used in making it (including any data input to each calculation, giving the source of each datum (item of data) used as input to each such calculation).
- ANSWER: An estimate of planned maintenance for Harris Unit I was prepared in February, ~1983 for general planning purposes. It was prepared by the CP&L Nuclear Staff Support Section of the Nuclear Generation Group. The bases for this estimate are 2
described in Applicants' response to Interrogatory 15AA-(2d)-17(c) above. The amount of plc.aned maintenance for Harris is that portion of the end-of-cycle outage time in excess of the seven-week refueling operation.
(v) (i) Please define the term Equivalent Forced Outage Rate (EFOR) which you use in your response to item 17 in interrogatory 25 (9-16-83 at page 6 of your response) (ii)
- Does CP&L believe that Harris will have the same EFOR-as an average nuclear unit
( during the period 1971-80? (iii) If answer to (ii) is affirmative please state all basis for l- your belief, including all documents or portions thereof, conclusions, calculations,
! statistics or expert opinions or other information you rely on. (iv) Does CP&L possess EFOR data for nuclear units (a) pre-commercial operation (bb) in commercial operation, for (ce) 1979 (dd) 1980 (ee)1981 (ff) 1982 (gg) any part of the period 1-1-79 to the present? (v) Please identify each document which contains EFOR data required under part (iv) above, identifying for each which units are new in commercial operation, and what time period the data covers.
ANSWER (v)(i): The Equivalent Forced Outage Rate is a measure of the i
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l composite effect of partial and full forced outages, on a full- l forced outage basis. ;
(ii): No.
i
, (iii): Not applicable.
(iv):
(a) Applicants do not possess EFOR data for precommercial operation of any nuclear units. (bb)-(gg): The EFOR data that Applicants possess for all nuclear units in commercial operation during the years requested are as follows:
1979 - 20.0 %
1980 - 16.3 %
1981 - 14.7 %
1982 - Not available (v):
The information furnished in (iv) above was obtained from t North American Electric Reliability Council's ." Ten-Year Review 1972-1981 Report on Equipment Availability." This is the only publication known to Applicants to contain historical EFOR data on commercial nuclear units. The document contains EFORs for the total population of nuclear units categorized by type and year. It does not have information on
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individual units or precommercial operations. t
.g factor (ii) planned maintenance (iii) forced outage rate equivalent availability, for Harris? j u.
ANSWER: g To be provided by Supplemental Response.
(x) Does in (w))above CP&L have any estimates of any or all of the 6 items inquired about f Harris,
, or prepared by or made by anyone else?
- h ANSWER: No. =.
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(y) Please give each estimate for which your answer to any part of (w) or (x) above (or to all of (x)) is affirmative, and please state who made it, when, for what purpose (if known), and all significant bases of said estimate which you know.
' ANSWER: To be provided by Supplemental Response.
INTERROGATORY NO.15AA-(2d)-18(a) In' response to Interrogatory 3 on 15AA, you cite " utility operating experience"; in response to Interrogatory 7 on 15AA you cite
" nuclear industry experience for units similar to the Harris units"; in response to Interrogatory 8 thereon, you cite " industry experience"; in response to Interrogatory 13 thereon you cite " general industry experience"; in response to interrogatory 39 thereon, you cite " industry experience with units similar to the Harris units." For each of these statements, are you referring to actual experience of capacity factors for nuclear units?
ANSWER: The term '" utility operating experience" refers to general utility operating experience at the time the projection was made, which was primarily experience with fossil-fired units. For the other statements referenced in this interrogatory, Applicants were referring to actual experience with capacity factors for nuclear units.
b) If your answer to (a), for any quote cited therein, is other than affirmative, please explain for each such cited language excerpt, what the " experience" is you are referring to, stating whether it is for nuclear units or not, what time (s)if any your are referring to experience in, and what way you use this " experience"in estimating capacity factor.
ANSWER: Regarding the term " utility operating experience," there were relatively few commercial nuclear generating units in operation at the time Mr. Morgan's l projection was made. Therefore, the operating experience generally used by the industry l
l as a basis for nuclear projections was primarily that of fossil units in operation. Itis l
! ' recollected that the general industry approach was based on the assumption that a nuclear unit would not experience the maintenance requirements or outages attributable I
to fossil boilers. It was thought that annual maintenance and modifications, as necessary, could be accomplished during the relatively short refueling outages. By not having boiler-related outages, the primary contributor to forced outages was the turbine-
. generator. Because the nuclear turbines operate at lower temperature and pressure than fossil turbines, it was expected that nuclear turbines would have fewer forced outages
than fossil turbines. Therefore, the projections of nuclear operating performance were generally based on relatively.short refueling outages and fossil turbine-generator related forced outages.
(c) Does CP&L believe that- actual capacity factors in commercial operating experience for nuclear- power plants are useful in (i) projecting capacity factors of
. similar nuclear power plants (ii) projecting capacity factors of new nuclear plants made by the same manufacturer (iii) projecting capacity factors of new nuclear plants of the
- same type (i.e. PWR, BWR, HTGR, etc)
- please answer specifically for PWks (iv) in L _ making estimates of the net output of new nuclear plants?
ANSWER: (i): - Yes.
(ii): Yes.
(iii): Yes.
(iv): Yes.
(d) Please sta_te the basis for your answer to each part of (c) above, including all expert opinions, documents, studies or facts or other information you rely on.
ANSWER: Historical operating experience is one of many useful parameters in projecting future performance. ' Generally,the more precisely the historical data can be matched to a'particular application (e.g., the greater the similarities between the plants compared), the more confidence one can have in using historical data as a basis for projections. ' The number of observations or data points must also be considered to assure h that the historical basis for making such projections is statistically sound.
(e) Do you (or anyone working for you) recall whether CP&L was the one who provided the information to the NC Utilities Commission in its Docket E-2 sub 203 (Harris plant certificate of convenience and necessity) that Harris was similar to Beaver Valley and North Anna?
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ANSWER: Yes.
(f)If answer to (e)is affirmative, did CP&L provide the information that Harris was similar to (i) Beaver Valley (ii) North Anna (iii both?
ANSWER: (1): Yes.
(ii): Yes.
(iii): Yes.
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.(g) Is Harris in fact similar in design to (i) Beaver Valley I (ii) North Anna I (iii) North
-Anna 2 (iv) VC Summer, to your knowledge? (v)If your answer is affirmative to any part
.( i) thru (iv) above, please state the similarities of NSSS design, manufacturer of NSSS (Nuclear Steam Supply System),'and any other characteristic you know which is relevant to capacity factor, for each such plant for which your answer is affirmative.
ANSWER: There are some similarities in the design of Harris 1 and 2, Beaver Valley 1, North Anna 1 and 2, and VC Summer. The nuclear steam supply systems for these units are all Westinghouse, three-loop PWRs having design ratings within 50 MWe net of 3
- 900 MWe net. Applicants have not attempted to evaluate every characteristic of the
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plants that may be similar.
(h) If your answer to any part of (g) is other than affirmative, please state all basis for your answer, including any opinions or documents you rely on.
ANSWER: Not applicable. .
(j) Does CP&L know what the average capacity factor of (i) Westinghouse nuclear plants of 800 MWe and up (lifetime, DER basis), (ii) Westinghouse nuclear plants of 900 MWe and up (lifetime, DER basis)is? If so, please state these averages and the date at
.which they are computed (e.g. as of 6-30-83).
ANSWER: To be provided by Supplemental Response.
'(k) Does CP&L have any opinion as to why _its Brunswick units have the lowest lifetim'e DER capacity factors of any two' commercial electricity generating BWRS over 300 MWe (design capacity)in the US?
ANSWER: To be provided by Supplemental Response, i (1) If answer to (k) is affirmative, what is that opinion? Please state all facts you l rely on to support that opinion.
ANSWER: To be provided by Supplemental Response.
(m) Does CP&L believe there are reasons for the poor performance of the Brunswick
~
nuclear units it co-owns and operates that relate to (i) construction (ii) design (iii) operation (iv) management (v) NRC regulations (v) CP&L non compliance with NRC regulations?
I' ANSWER: To be provided by Supplemental Response.
-(n) If answer to any part of (m) above is affirmative, please state for each such part, l
each reasons CP&L believes the matter inquired about in that part has contributed to lower or poor performance of the Brunswick nuclear units, in terms of capacity factor over their operating lifetimes.
l ANSWER: To be provided by Supplemental Response.
l I
_ (. o) If answer to any part of (m) above is other than affirmative, please state all basis for' each such belief.
ANSWER: To be provided by Supplemental Response.
(p) Is the " industry experience" you refer to in the responses cited in 18(a) above always limited to the experience of the commercial LWR nuclear industry within the
-USA? (i) If not, please state what (aa) noncommercial (bb) non-LWR (ce) non- US experience you refer to in each such answer.
ANSWER: Except for the reference to fossil-fired units discussed in Applicants' l
response to Interrogatory 15AA (2d)-18(a) above, the term " industry experience" refers to the commercial LWR nuclear industry within the United States.
7 (q) Does CP&L now dispute the NC Utilities Commission's finding in its Order in
- Docket E-2 sub 203 (granting certificate of convenience and necessity to construct the Harris plant, 4 units) that (i) Harris is similar in design to Beaver Valley (ii) Harris is similar in design to North Anna (iii) Harris was expected to have an 80% capacity factor?
(iv) If your answer to any of parts I,11 or lii immediately above is affirmative, please state (aa) whether CP&L took exception to this finding (bb) whether CP&L appealed this finding (ce) whether CP&L has ever sought otherwise to reopen the record in Docket E-2 sub 203 to change this finding, for each such finding. (v)If an answer to any part of (iv) above is affirmative, please provide details of each such exception, appeal, or attempt to correct or reopen the record, when filed, what the result was, and identifying all documents you possess relating to it. (vi) Has CP&L, in its annual reports to the NCUC on the Harris plant under its Order in Docket E-2 sub 203, ever told the NCUC that Harris is no longer expected to perform at an 80% capacity factor? If so, when, at what l page(s)? (vil) Has CP&L ever informed the NCUC in any other filing of its in Docket E-2 sub 203 that Harris is no longer expected to perform at an 80% capacity factor? (viii)
Has CP&L ever informed the NCUC of the Staff's estimate of Harris capacity factor for the DES? If so, when and how; please identify all documents used to so inform the NCUC, giving the date and author of each, and any response the NCUC has made thereto (documented or known to you).
l ANSWER (i): Applicants do not dispute the finding of the North Carolina Utilities Commission which was based on the testimony presented in Docket No. E-2, Sub 203.
(ii): Applicants do not dispute the finding of the North Carolina Utilities Commission which was based on the testimony presented in Docket j No. E-2, Sub 203. :
1 (iii): Applicants do not dispute that based on the best information j
( l available at the time of the granting of the Certificate of Public l L
' l l 4 l
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Convenience and Necessity, the Harris units were projected to operate at an 80% capacity factor.
(iv): Applicants wish to point out that the projected 80% capacity factor referred to in part (iii) of this interrogatory does not appear in any of the Findings of Fact, Conclusions, or Ordering paragraphs of the NCUC's Order under Docket No. E-2, Sub 203. Therefore, ,
Applicants' response to this part of Interrogatory 15AA-(2d)-18(q) refers only to the similarity of the Harris Units to other nuclear units as mentioned only in Finding No. 6 of the above-referenced order.
(aa) CP&L did not take exception to this finding.
(bb) CP&L has not appealed this finding.
(cc) CP&L has not sought to otherwise open the record in Docket E-2, Sub 203 to change the findings contained therein.
'(v): Not applicable.
(vi): The annual report under Docket E-2, Sub 203 requires a progress report on construction and the anticipated operational dates for the facility. Projected capacity factor has not been addressed in these l
! annual reports. However,in other filings and proceedings before the I NCUC, capacity factor projections of less than 80% have been used i
and/or discussed. For example, in Docket No. E-2, Sub 461 a CP&L witness referred to a capacity factor of approximately 60% for Harris Unit 1.
(vii): No.
(viii): CP&L has not notified the NCUC directly of the capacity factor used by the NRC Staff in the Harris DES. However, a member of the Public . Staff of the NCUC is on the distribution list for all documents in this proceeding, including the correspondence citing the 55% capacity factor estimate used by the NRC, such as the July
. ' 1, 1983 " Applicants' Respo'nse to the Board's May 27, -1983 Memorandum and Order."
(r) Does CP&L believe that the NRC Staff's 55% capacity factor for Harris is (i) right (ii) wrong (iii) close enough for use in the NRC operating license proceeding (iv) too low (v) too high? (vi) Please give the basis for your answers to each part (i) thru (v) above.
. ANSWER: See Applicants' July 1,1983. response to the Board's May 27, 1983 Memorandum and Order.
(s) With respect to your response to Interrogatory 11 on 15-AA, and attachment A thereof, please state (i) what the (aa) 1ifetime CF (DER) (bb) 1ifetime EFOR (ce) lifetime average weeks per year of planned maintenance are for Robinson 2, Brunswick 1 and Brunswick 2 respectively; (ii) How, if at all, the actual lifetime CF, EFOR or planned ,
maintenance time for Robinson 2, Brunswick 1 or Brunswick 2 entered into the estimates of (aa) Capacity Factor (bb) EFOR (ce) planned maintenance (weeks / year) given for Harris (dd) 1 (ee) 2(nuclear units) given in Attachment A re interrogatory 11 on 15AA.
Please state any calculations made, and any assumptions made, in using information re actual lifetime EFORs, CFs and planned maintenance of CP&L's existing nuclear units,
,- re Harris .-nuclear units' estimated CF, EFORs, and outage length for planned maintenance.
l ANSWER: The wording of this interrogatory is vague and convoluted. Applicants have interpreted part (i) to refer to historical data through the most current date for ,
which records are.available. Applicants have interpreted part (ii) to refer to projections of future system operation based on the study done for the NCUC Cogeneration Hearings in December,1982. On the basis of these interpretations, the following answers are l provided.
(i)(aa): The lifetime CF(DER) for CP&L units through 9-30-83 is:
f Brunswick Unit 1 - 44%
Brunswick Unit 2 - 43%
l f Robinson Unit 2 - 63%
l
.o (bb)-(ce): . Lifetime EFOR and lifetime average weeks per year of planned maintenance have not been calculated and are not maintained by Applicants.
(ii)(aa):~ - The capacity factor for the. Harris units shown in response to Interrogatory 11 was an indirect result of the modeling process t ,
and was dependent ~upon the estimate of planned maintenance 3 time and forced outage rates used.
_ (bb): Applicants do not routinely use EFOR data in planning or modeling its nuclear . units._ The EFOR data provided in response to the first set of interrogatories were compiled -
specifically in response to those interrogatories. A primary i
basis for the EFOR data reflected in response to Interrogatory 11 was the " Ten Year Review 1970-1979 NERC Report on
- Equipment Availability." To the extent that Robinson Unit 2 and Brunswick Units 1 and 2 data were included in that report, such data for that period were reflected in the EFOR data provided.
(ce}-(ee): The estimated planned maintenance time for the Harris units was not based on historical information for Brunswick, but on the then current planning assumptions for Robinson Unit 2 which considered CP&L's experience with that unit.
.(t) Please sta'te (i) the actual length, in hours, or weeks, or any other time units you
- have the information in, for each refueling outage the Robinson 2 plant has had in commercial operation, giving the date and year on which each such outage commenced if known. (ii) the actual EFOR for Robinson 2 for (aa) its lifetime (bb) for each calendar year'1971-1982 'and for 1983 when that data becomes available (iii) the actual CF for Robinson 2 for the years 1979,1980,1981,1982 and 1983. Where your CF data differs from the NUREG-0020 - CF data, please give any explanation known to you for the difference (s). (iv) the actually-achieved DER OF (annual) for North Anna 1 for the years 1979,1980,'1981,1982 and 1983 '(v) the actually achieved DER CF (annual) for North Anna 2 for the years 1980,1981,1982 and 1983; (vi) the actual DER CF (annual) for
Beaver Valley I for each of the years 1980,1981,1982 and 1983 (and 1979 also). (vii) do you know the lifetime EFOR for Beaver Valley I through 1982? to present? If so, please state each such lifetime EFOR. (viii) Do you know the lifetime EFOR of (aa) North Anna 1 (bb) North Anna 2, as of the end of 1982 or as of any other c .te? If so, please state each lifetime EFOR you know for a North Anna unit, giving the date it is through and the unit it applies to.
ANSWER' (1): It should be noted that " refueling outages" generally include annual maintenance and inspections, and may also include major maintenance projects and plant modifications as well as normal refueling activities. Refueling, annual maintenance, and inspection outages at Robinson Unit 2 since commercial operation are as follows:
No.1 - 8.5 weeks beginning 3-16-73 No. 2 - 7 weeks beginning 5-6-74 No. 3 - 6 weeks beginning 10-31-75 No. 4 - 6 weeks beginning 10-29-76 No. 5 - 12 weeks beginning 1-27-78 No. 6 - 14.5 weeks beginning 4-11-79 No. 7 - 11 weeks beginning 8-8-80 No. 8 - 21 weeks beginning 2-26-82 (ii): EFOR data is not routinely calculated and maintained by Applicants.
(iii): Actual CF (MDC) for Robinson 2 is as follows:
1979 - 68.8 %
1980 - 54.6 %
1981 - 60.1 %
1982 - 38.7 %
i '
1983 - 62.7% (through 9-30-83)
These capacity factors are consistent with those in NUREG-0020 for all years except 1980, where the NRC shows 55 percent. The small discrepancy is due to different methods used by the NRC and 7
CP&L at that time to account for negative generation.
(iv) -(viii): As stated in response to Interrogatories 15AA-(2d)-18(j) and (s),
Applicants do not calculate and maintain DER CF for non-CP&L y units or EFORs for any units. Although Applicants have some CF (MDC) data on the units in question, that data is not maintained in ,
the format requested.
(u) (a) In your attachment B (9-16-83 responses to interrogatories on 15AA), related to interrogatory 29 thereon, are the Brunswick and Robinson 2 CF data different by more than 1% for any year (from) those shown in attachment A therein re Interrogatory 11?
(b) Are the planned maintenance data for Brunswick, Robinson 2 and Harris the same in Attachment A and attachment B except for Brunswick 1 in 1983? (c) Are the EFORs for Brunswick 1 ano 2 and for Robinson 2 always the same in Attachment A as in attachment B in each year? (d) Are the Harris 1 and 2 CFs, except for Harris 2 in 1989, at a 5% (or more) higher level in Attachment E than in Attachment A? (e) Are the Harris 1 and 2 EFORs shown in Attachment B maturing in one year from 29% to 16%? (f) Are the Harris.1 and 2 EFORs in Attachment A maturing over 3 years from 30% to 22%? (g)
Does CP&L have any data concerning how long it takes the actual EFORs of Westin'ghouse PWRs to mature (i.e. stop declining)? (h) What EFOR data on Westinghouse PWRs does CP&L possess? (i) Does CP&L really believe that Harris 1 or 2 could actually mature in terms of EFOR within one year of commercial operation? (j) Does CP&L actually believe that the Harris 1 or 2 EFOR in operation will be 16 percent (or average 16%) in the second and following years of operation? (k) Please state all basis for your answers to (i) and (j) above including allinformation you rely on in making your answer to each of these 2 questions.
ANSWER (a): Yes.
(b): No, the planned maintenance for Robinson Unit 2 also varies in
-1983.
- , (c)
- Yes.
.(d): Y es.
(e): Yes. This data reflects a computer simulation that was made for use in the Harris ER Amendment 5, in which three capacity factor I
sensitivity cases were analyzed. For these particular cases, the
normal unit maturation process was not fully modeled. However, Applicants do not anticipate that this fact would significantly alter the long term results of this study.
, (f): Yes.
(g): No. CP&L does not routinely use EFOR data for nuclear units.
(h): None.
(i): No. As stated in part (e) of this interrogatory, this was a simulation in which the normal unit maturation was not fully modeled.
Q): See Applicants' response to part (i) of this interrogatory.
(k):
Applicants' answers to parts (i) and Q) of this interrogatory are based on a review and recollection of the study performed.
INTERROGATORY NO.15-AA (2d)-19(a) Does CP&L have any data on the lifetime CF estimates used by AEC or NRC Staff for (1) Robinson 2 (CP, OL or both)(ii) Harris CP (iii) Brunswick CP or OL or both (iv) Beaver Valley I, CP, OL or both (v) VC Summ CP, OL or both (vi) McGuire, CP, OL or both (vii) North Anna, CP, OL or both?
ANSWER (i): Yes.
i (ii): Yes.
(iii): Yes. .
I (iv): No, i
(v): No.
(vi): No.
(vii): No. _
=
(b) For each reactor for which your answer to (a) above is affirmative, please state 2 in the CF used at (i) the CP stage (ii) the OL stage, by NRC or AEC Staff, for that reactor.
5..
ANSWER (i):
As reflected in the Final Environmental Statement (FES), the i._
capacity factor used for Harris in the CP stage was 80%
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4 (ii): As reflected in the Final Environmental Statement (FES) for each plant, the ' capacity factors used for Robinson Unit 2, and the Brunswick units in the OL stage were all 80%.
(c) If you know, for each reactor inquired about in (a) above, what CF did the ASLB adopt at the (i) CP (ii) OL stage?
ANSWER:
Applicants are not aware that the ~ licensing Board " adopted" any capacity factor at the CP stage for Harris, Brunswick or Robinson, or that it " adopted" a capacity factor at the OL stage for Brunswick or Robinson. In each instance, the Board did approve the FES which was based on an 80 percent capacity factor. Applicants do not know the capacity factors " adopted" at the CP or OL stage for the other units referenced in Interrogatory 15 AA(2d)-19(a).
(d) Does CP&L dispute the ruling of the NC Utilities Commission in Docket E-2 sub 444 that CP&L management was at fault for the length of the Brunswick turbine outage?
OBJECTION. Applicants object to this Interrogatory on the basis that it exceecs the proper bounds of discovery on the capacity factor issue by delving into the area of management capability. In admitting Contention 15AA, the Board stated that "[olur admission of this contention is not to be construed as reopening discovery" on the subject of management capability. Memorandum and Order Ruling on Wells Eddleman's Contentions on the Staff Draft Environmental Statement at 7 (August 18, 1983). 3 (e) Does CP&L dispute the ruling of the NCUC in Docket E-2 sub 461 that CP&L ~3 management was responsible for the failure to test the Brunswick plant as required by NRC, which failure led to an extended shutdown in the summer of 1982? ;
OBJECTION. See response to Interrogatory No.15AA(2d)-19(d) above.
9 (f) - Does CP&L dispute that the Brunswick turbine outage of 1981 reduced y l Brunswick's capacity factor for 1981?
ANSWER: No. ~
l
' (g) Does CP&L dispute that the Brunswick testing shutdown of summer 1982 "
reduced Brunswick's capacity factor for 1982? -
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ANSWER: No.
(h) Please give all basis for your answers to (d), (e), (f) and (g) above, stating which basis applies to which answer.
ANSWE.R: For Interrogatories 15AA(2d)-19(d) and (e), see Applicants' objections. ,
For Interrogatories (f) and (g) capacity factor is by definition a function of the on-line time of a unit. Therefore, any outage or shutdown will reduce the capacity factor.
Dated: November 17,1983.
Objections submitted by:
M Dale E. Hollar, Esq.
Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 Attorneys for Applicants:
Thomas A. Baxter John H. O'Neill, Jr.
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 Post Office Box 1551 Raleigh, North Carolina 27602 ,
(919) 836-6517 !
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.~,m I
I 00CKETED USNRC UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION _ .. ..
l 13 NOV 21 MO30 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
' FFCi OE SEC0tIlj -
In the Matte,r of ) h$lk;f'
)
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN )
MUNICIPAL POWER AGENCY ) -
) Docket Nos. 50-400 OL Ghearon Harris Nuclear Power Plant, ) 50-401 OL Units 1 & 2) )
AFFIDAVIT OF B. M. WILLIAMS County of Wake )
)
State of North Carolina )
B. M. Williams, being duly sworn according to law, deposes and says that he is Director of Staff Services - Planning and Coordination Department of Carolina Power &
Light Company; that the answers to Interrogatories on Eddleman Contention 15AA contained in " Applicants' Answers to Wells Eddleman's General Interrogatories and Interrogatories on Eddleman Contention 15AA (Sixth 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.
- M Nt do~
B. M. Williams l
Sworn to and subscribed before j me this IKth day of November,1983.
l J k~/
l Notary Public My commission expires: ihI. /, ' "s 'I
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ATTACHMENT A B. Mitchell Williams Director-Staff Services
. Education & Training B.S. Degree in Agricultural Engineering from N.C.S.U. - 1969.
Professional Societies
. North Carolina Society of Engineers member.
Experience A. Prior to Joining CP&L:
June 1969'- August 1972 -
Engineer - Distribution Engineering -
Virginia Electric & Power Company -
Williamston, NC.
August 1972 - August 1973 -
Engineer - Transmission Line Engineering - Virginia Electric &
Power Company - Richmond, Virginia B. Carolina Power & Light Company:
August 1973 Agricultural Development Engineer - Henderson District - Nashville Area Office - Northern Division Operations - Nashville, NC.
April 1974 Transmission Line Coordinator - Transmission Location Unit - Transmission Engineering & Construction Section - System Engineering t Construction
, Department - Raleigh, NC.
January 1977 Senior Industrial Power Engineer - Sumter District
, Office - Southern Division Operations - Sumter, SC.
January 1979 Senior Industrial Services Engineer - Industrial Services Unit - Energy Services Section - Customer
! Service Operations Support Department - Raleigh, NC.
August 1979 Project Staff Services Specialist - Administrative i
Unit - Staff Services Section - System Planning &
Coordination Department - Raleigh, NC.
July 1981 Principal Engineer - Regulatory Unit - Staff Services Section - Planning & Coordination Department -
I Raleigh, NC.
February 1982- . Director-Staf f Services - Staf f Services Section -
present Planning & Coordinatien Department - Raleigh, NC.
(
ATTACHMENT B Robert S. Stancil Principal Engineer-Regulatory Staff Services Education &. Training B.S. Degree'in Civil Engineering from N.C.S.U. - 1971.
Registered Professional Engineer in N. C.
Registered Land Surveyor in N. C.
Professional Societies American Society of Civil Engineers - member.
North Carolina Society of Engineers - member.
Experience
.A. Prior to Joining CP&L:
May 1971 - July 1973 Roadway Design Engineer-in-Training - North Carolina State Highway Commission -
Raleigh, NC.
July 1973 - October 1974 Engineering Supervisor - Landmark Engineering Company, Inc. -
Cary, NC.
.B. Carolina Power & Light Company:
October 1974 Junior Engineer - Environmental Engineering Section -
Power Plant Engineering Department - Raleigh, NC.
April 1975 Civil Engineer - Environmental Engineering Section -
Power Plant Engineering Department - Raleigh, NC.
September 1975 Engineer III (Civil) - Environmental Engineering
'Section - Power Plant Engineering Department -
Raleigh, NC.
August 1976 Senior Engineer - Environmental Engineering Section -
Power Plant Engineering Department - Raleigh, NC.
4 January 1977 Senior Engineer - Project Engineering Section - Power Plant Engineering Department - Raleigh, NC.
December 1979 Senict Engineer - Civil Unit - Engineering Support-Fossil Power Plant Section - Fossil Power Plant Engineering Department - Raleigh, NC.
May 1980 Senior Engineer - Regulatory Staff Services Unit -
Staf f Services Section - System Planning &
Coordination Department - Raleigh, NC.
.- :- ATTACHMENT C RONNIE MAC COATS
. -- Accistant - Group Exec'ttive - Fossil Generation &
- (._) August 7, 1945 Power Transmission EDUCATION AND TRAINING A. B.S.- Degree in Chemical Engineering from North Carolina State University - 1967. '
B. Graduate School at North Carolina State University, one semester 1968.
Site Lecture Series of Westinghouse Training Program.
EXPERIENCE A. June, 1965, Research Assistant in Nuclear Engineering Department at North Carolina State University.
September, 1967, Graduate Student Laboratory Instructor at North Carolina State University.
B. January,1968 -- Employed as a Chemical Engineer in the Design and Construction Section. Located in the General Office.
) February,1970 - Employed as a Radiochemical Engineer in the Technical Services Section. Located in the General Office.
July, 1971 - Employed as a Senior Chemical Engineer in the Nuclear Design Section of the Power Plant Design and Construction Department. Located in the General Office.
April, 1972 - Employed as a Principal Engineer in the Nuclear Plant Engineering Section I of;the Power Plant Engineering and Construction Deaprtment. Located in the General Office.
August, 1973 - E= ployed as a Principal Engineer - Projects in the
! Nuclear Plant Engineering Section I of the Power Plant Engineering l Department. Located at the Brunswick Plant.
August, 1975 - Employed as Principal Engineer on the staff of the Assistant to Group Executive - Engineering, Construction, and Operating. Located in the General Office.
October, 1976 - Employed as a Principal Engineer in the Staff Services Unit of the System Planning & Coordinatica Department.
Located in the General Office.
January, 1977 - Employed as Manager - Generation Services Section of the Generation Department. Located in the General Office.
November, 1979 - Employed as Manager - Nuclear Operations
- Administration Section of the Nuclear Operations Department.
{ Located in the General Office.
Februar;, 1981 - Employed as Manager - Nuclear Operations Administration Section of the Iecitalsal C?" vices Department.
Located in the General Office. '
March, 1982 - Employed as Assistant to the Group Executive Power Supply. Power Supply Staff. Located in the General Office.
August, 1983 - Employed as Assistant to the Group Execut!ve Fossil Generation and Power Transmission. Located in the General Office.
PROFESSIONAL SOCIETIES American Institute of Chemical Engineers Registered Professional Engineer - State of North Carolina
/.
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s, I
' ATIACHMENI D T- t . , -
^
Joseph L. Harness Assistant to Vice President - Nuclear Operations .
October 22, 1939 '
-Education and Training -
A. .B.S. Degree in Physical Science, Colorado State University, Fort Collins, Colorado (1969).
M.S. ' Degree in Radiation Biology, Colorado State University, Fort Collins, Colorado (1970).
B. Certificate from the U.S. Navy Electronics School (1958),
U.S. Navy Nuclear Propulsion School (1960), Advanced Nuclear Propulsion School (1961).
Professional Societies Health Physics Society (National)
Certified Health Physicist-(1977)
Licensed Reactor Operator by U.S. Atomic -
Energy Commission (1964-1970)
C Experience A. - May 1957 to May 1964 - Reactor Operator / Technician, United States Navy. ,
' June 1964 to January 1969 - Senior Instrumentman, Department f .,.
of Radiology and Radiation Biology, Colorado State University, l
' Fort Collins, Colorado.
June 1969 to August 1970 - Reactor Supervisor, Department of t
Radiology and Radiaticn Biology, Colorado State University, Fort Collins, Colorado.
August 1970 to May 1971 - Radiation Safety Officer II. Georgia l
' Department of Public Health.
August 1975 to September 1976 - Environmental Projects Manager,
l September 1976 to November 1976 - Senior Health Physicist, Allied Chemical Corporation, Idaho Falls, Idaho. ,
November 1976 to September 1977 - Health Physics Supervisor,
'TVA Browns Ferry Nuclear Plant, Decatur, Alabama.
i \
. e.' .
Joseph L. Harness
,{ Page 2 September 1977 to July 1979 - QA Supervisor, TVA Browns Ferry Nuclear Plant, Decatur, Alabama.
Ju'y l 1979 to September 1981 - Assistant Power Plant Manager, TVA Browns. Ferry Nuclear Plant, Decatur, Alabama.
B. May 1971 to February 1972 employed as a Nuclear Engineer in the
' Environmental & Technical Services Section of the Generation & .
Systems Operations Department. Located in the General Office,
- Raleigh, North Carolina.
~
February'1972 to July 1972 employed as a Senior Nuclear Engineer in the Environmental & Technical Services Section of the Special Services Department. Located in the General Office, Raleigh, North Carolina.-
July 1972 to February 1973 employed as a Senior Nuclear Engineer at the H. B. Robinson Plant. Located in Hartsville, South Carolina.
February 1973 to August 1975 employed as an Environmental &
Radiation-Control Supervisor at the H. B. Robinson Plant.
Located in Hartsville, South Carolina.
( October 5, 1981, employed as a Principal Specialist - Health
, Physics in the Environmental & Radiation Control Section of the Technical Services Department. Located at the Harris Energy &
Environmental. Center in New Hill, North' Carolina.
January 1982 employed as Assistant to Vice President - Nuclear Operations, Nuclear Operations Department. Located in the General Office.
l- August 1982 employed as Manager - Plant Operations in the Brunswick l
Plant Section of the Nuclear Operations Department,'Southport, NC September 1982 employed as Manager - Plant Operations, Brunswick l Nuclear Proj ect, Southport, NC l .
l July 1983 employed as Assistant to Vice President - Nuclear j Operations, Nuclear Operations Department. Located in the
! General Office.
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