ML20083M212

Response to Applicant Interrogatories 9,11 & 132(c)(2). Related Correspondence

ML20083M212
Person / Time
Site:	Harris
Issue date:	04/12/1984
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
References
82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8404170521
Download: ML20083M212 (6)

Text

, , 59 ') -- '

_ TED Coim S.'C;DENCE DOLKETED OHP ' UNITED STATES OF AMERICA April 12, 1984 NUCLEAR REGULATOBY COMMISSION

'84 APR 17 A10:47 1

. f tt SEPQBE ATHE ATOMIC SAFETY AND LICENSING BOARD

"'6jjjjicf" "

i Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Unit 1) ) ASLBP No. 82-h68-01

) OL Wells Eddleman's Resnonse to Appkicants' Interrogatories Re 9, 11, and 132(c)(2)

This response is timely under extension agreed to by Applicants' attorney Baxter.

RESPONSE TO GENERAL INTERROGATORIES 2

G1(a) see specific resnonses for answer or objection. (b) see soecific responses.

2(a) see snecific responses. No page citationmeans whole document.

(b) see (a). 3(a) and (b) See specific 9esconses. k, i h h6 i RESPONSE TO SPECIFIC INTERFOGAT09IES

@f6 lNl#%

(*L) 9-10(a) Analysis not complete; see UCS 2-7-84 petition  !

re EQ for some examples. Basically, underqualified or unqualified

, equipment, safety-grade or not, can, by failing (e.g. shorting o ut, changing resistance or resistivity, failing to transmit current or mg heals, distorting signals, water hammer, air hammer, etc. ) cause 7 other fa31ures. The anpropriate mathematics involve chatastronha l g< theory and the theory and science of a cascaded systems in sophisticated  !

e analyses; common sense and great patience and a large -memory is more or less enough for more ordinary analyses. The point is that a signgle failure or one or more ordinary, " routine" or perhans k D3 J

apparently unrelated failures can set off a cascade of events leading to a serious accident. TMI-2's accident is a good example. Silly attempts to blow out an ion exchange column that seemed to be clogged, i got water loose in control systems that tripped the reactor and feedwater, putting the auxiliary feedwater that was valved shut into a vital nosition. Upon the failure of that the reactor over-heated, the PORV vented as it should, stuck as it shouldn't, went undetected (small break LOCA) and within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> there was a general emergency and soon thereafter offsite radiation releases of undetermined amount. In sum, systems interaction all&ws Keystone Kops events in Rube Goldberg machines like nuclear power plants. You ignore i it at your and everyone else's peril. Adequate treatment of interaction of so many items and systems is extremely difficult.

(b). Send me a copy of 10 CFR 50 49(b) and ^you can get an answer. There's no (b) in my 1983 copy of 10 CFR, at kB.50.49.

(c) I'll try to find a better cite for both.

9-11(a). Comnarison of (a) similarity of the systems (b) effects on one system versus another (c) similarity of effects on one system versus another (d) conservatism and analysis of l similarities and differences. (b) virtually all of them, as far as I know, which are " qualified" by comparison or which have not been adequately qualified as I have defined or used the phrase "adeqauately qualified".

9-12(a) Assuming that temperatures would not exceed certain values, based on inadequate or misleading information or oninion or conclusions. (b) I'll try to find a reference. (c) All those whose temoerature tolerance, or the temocrature tolerance of critical parts, components or systems within them, was established by inference. See UCS 2d supplemental petition of Feb 198h.

(d) If Bonzon or the UCS document don't identify them, I'm not sure I know.

. 9-13(a) I haven't got a comnlete all-inclusive definition other than the plain meaning of the words. But the meaning includes use of methods that separate different stresses or conditions (e.g. being wet, exposed to steam, at high temperature or in a varying temperature field, being x exposed to a high radiation field after long exposure at lesser radiation levels, being nenetrated or touched by radioactive material, being physically innacted by debris of missiles, being exposed to oxygen or nitrogen or air, etc) which the item or system mi 6ht be or is exposed to simultaneously.

(b) Analysis currently incomplete, but just look at it and you can see that it doesn't comply with the above. For actual accidents, you underestimate radiationfields on much equipment, ignore immersion of many items of equipment, and ignore systems interactions and simultaneous exposures and exnosure interactions such as those described in response to (a) above and in answers to 9-3 and other past interrogatories.

(c) I haven't found any that I think isn't subject to this problem so far. Given CP&L's "we only do what someone makes us do" attitude toward testing and analysis of equipment, I'd infer from that that it applies to all the equipment at SHT which might come into play or be exposed to radiation, water, heat, steam, etc in an accident or in normal operation.

9-14(a) Analysis incomplete. It includes that the effects or long-term exposure to a given dose are greater than the effects of the same dose more ranidly delivered in a test urocedure. It also includes radiolytic interactions in high radiation fields and chemical interactions and physical interactions (e.g. cracking of insulation, radiolytis of it and skum+ chemical interactions with the exnosed j carts and radiolytic products or radichls ). I can't begin to list all the ways CP&L understates radiation effects, but try the above plus

-g-(b) All insulators or materials of polymeric structure the same or similar to those having exnerienced the identified effects; also metals, semiconductors, anything that can be damaged by radiation, so far as I know.

9-15(a) Differences. (b) Look at the test reports. Any difference is sufficient to identify an item, and you can do it as easily as I can.

I don't have a list read $ to hand now. If I find or make or get one, I'll supply it.

9-16(a) Configuration means the relative position of things l one to another. Orientation means which directions things face, or more simply, which end (or side or corner) is up, down, facing or not facing something, etc. (b) virtually all of it. I don't recall any such analysis by CP&L.

9-17(a) To the extent that SHNPP's program incorporates anything criticized in any such criticism, or fails to do anything the criticism says it should, of course it does. It's silly for me to act like CP&L and commission a piece of paper specifically designed to say things about the plant that CP&L wants to hear.

(b) Analysis incomplete. You can figure it out as easily as I can, I'd hope, if you're competent.

(c ) I haven't checked this. NRC regulatory standards for EQ are inadequate, which is wh67 the UCS keeps suing them, filing for relief, etc.

11-13(a) Free radicals produced in smaller numbers would be more likely to interact with intact insulating molecules rather I than other free radicals. Radiation can also further energizo or split free radicals, creating a synergistic effect.

(b) These reactions are fairly complex, I believe, but are oxidation, depolymerization, etc. I need more into basically to give a more comolete description. .

(c) radiation from induced radioactivity. By spreading out the low-dose radiation, and maintaining a low-but-above-background dose rate when direct radioactive contamination or direct radioactivity is absent. 1 (d) secondary emission after imnact of radiation. The secondaries are at lower energy, thus lower dose rates; also they originate inside the material they emanate from, e.g. insulators or things near them.

(e) try a physics or chemistry (polymer chemistry) a text.

11-14(a) Look at 13(d) above. Revadiation means radiation resulting from impact of or interaction with radiation. (b) Look at (c) in 13 above. (c) Jacketing of the cable or insulator. See (c) above.

(d) see 13(c) above. (e) see (e) above.

11-15(a) I haven't had a chance to check yet and still get my other work done. (b) Did I say that these effects are bounded by the gamma effects? I'm not sure that's true. Analysis continues.

11 - 16(a) Common sense. Cracks propagate uretty gar fast (or can) when they form. Such failures are random in the sense that they cannot be individually well predicted in time without excessive effort, and maybe not even then. More frequent inspection is supported by the opinions of non-witness experts I have talked to, though I consulted none of them to make this answer and object to identifying them --

no showing CP&L can't obtain info on this matter by other means.

I'll look for documents. (b) Analysis incomolete.

RESPONSES ON 132(C)(II) l (a) You can do it as easily as I can. I haven't had time to do it yet. (b) You haven't provided the info nocessary to do this.

Your DCRDR re this is illegible. But the DORDR does say what's on the panels, and that was put into the contention. Your failure to provide information does nothing to justify your position.

(e Isn't it obvi li hts or meters, oust han 20-20 vision isn't adeounte to read smalland I dormation overload a

s problem. (d)(e) Haven't had time yet.

7(a) Info needed not yet nrovided by you. (b) Look at your attachment 1 (I can't believe this is a serious question). The operator console "19" is directly hm*=== through panels 1 and 2 from panel 6. On this scale drawing, operator console 19 is directly through panels 2 and 3 from panel 7. I amend my answer to say the view of 6 and 7 is blocked by 1, 2 and 3 therefore.

8. Until you provide more inato, I can't nrovide nore detail.

9. Analysis continues when I have more time. If you can't read information or it can't be coordinated in an accident so f that the info is not useful or timely or accurately available (e.g.

as described in the contention) you are violating GDC 1 by not having your equipment safely designed mnd able to perforn its functions, if the problem is caused by the equipment layout.

Setting this layout into concrete before the NRC finished reviewing your nonstandard DCRDR is also a mistake: mismanagement, and bad design to t he extent it does not rectify mistkkes made that are identified or exnaressed in the contention.

10. Have you ever observed a fluorescent bulb at nartial i voltage, partial power, or when current is interrupted. It does these things. I'd hope CP&L would know that much.

11. That's the opinion of an eye doctor (name not recalled) who examined my depth perception, and who regularly examines airline pilots and Air Force pilots and oilot trainees, or did in 1976 and years previous to that.

12. Given my general health, I have set no specific date.

I'll do it when I can, and I'll let you know when I've done it l

and we can set a place and time.

13 Not that it's relevant, but it's a tape of Helen Cnidicott, I believe addressing nuclear power, weanons and related insantities.

It's been a long time since I looked at it.

ATTEST: The above is true to the best of my present knowledge and belief, p.12.gg /

,p