ML20083M303

Response to Applicant Seventh Set of Interrogatories (Joint 7).Experts Under Consultation.Certificate of Svc Encl. Related Correspondence

ML20083M303
Person / Time
Site:	Harris
Issue date:	04/11/1984
From:	Eddleman W EDDLEMAN, W., JOINT INTERVENORS - SHEARON HARRIS
To:	CAROLINA POWER & LIGHT CO.
References
82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8404170557
Download: ML20083M303 (12)

Text

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e RELATED CORRESPONDENCE

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UNITED STATES OF AMERICA April 11, 1984 1 (served April 12

'84 APR 11suB114h BEGULATORY COMMISSION excent,see certificate)

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'BMNTRE A'IVMIC SAFETY AND LICENSING BOARD Glenn O. Bright -u l Dr. James H. Carpenter  ? jf N James L. Kelley, Chairman "y , o 355 5; $. 98 Qg -

IA w e. ~ m In the Matter of D ;a '

4 Docket ?50 4@'0L -

CAROLINA POWER AND LIGHT CO. et al. ) ~'

S (Shearon Harris Nuclear Power Plant, )

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

) OL Joint Intervenors Resnonse to Applicants Seventh Set of Interrogatories (Joint 7)

Gl. Answers will be supplemented as information is available and reviewed.

02(a)Except for nonwitness expert (s) who may have assisted, none.

(b) see specific responses (c) OBJECTION: this information is not required under the Board's 5-27-83 Order; Applicants must show that it is not possible for them to obtain information or opinions on the subject of this contention by other means, before they can even request disclosure of this information (see 10 CFR 2.740). Objections made by Joint Intervenors and by Wells Eddleman to similar interrogatories in all past responses are incoroorated by reference at this point, as if fully set forth here. If you want a list of them we'll try to provide it, but it's all in resnonses previouslyserved on the parties.

(d) Not Applicable, per Applicants' clarification that they do not -

wish persons who simply mail, hand over, or deliver information identifiedc 3 See objection to 2(c) and response to 2(d) above. "AA" is not a witness; if this situation' changes, "AA" will be identified under the interrogatory requesting ID of witnesses.

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4(a) and (b) See specific responses. Where no pages are identified, the entire document is relied on or used.

$(a) and (b) See specific resnonses.

SPECIFIC INTERROGATO9Y RESPONSES VII-34 Analysis is still incomplete. Wells Eddleman has been both ill and extremely busy since about the time those responses were filed. Consultation with experts including "AA" as W.E. recalls, have (except as stated herein, e.g. at VII-35(e) below) not resulted gin any significant change in the analysis reported, but Joint Intervenors have recently retained experts to analyze matters including these. That analysis may not have been begun yet, and definitely has not been completed or communicated to Joint Intervenors yeto VII-35 (a) Except as previously stated, we're not sure. This is one of the things we are trying to get our exnerts to analyze.

(b) will be provided ner our experts' renort(s) (c) Except as previously stated, we don't know further, one way or the other. See

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response to (b) above. (d) See response to (o). ~(e) Yes, we believe there are problems as previously identified. "AA" is being consulted about this. (f) see previous respenses; oninion of "AA" as WE recalls it.

(g) not applicable, see (c) and (e).

VII-36. We're asking our experts.

VII-37 (a) Yes. Of course, each tube is most likely to rupture at only one point; all steam generator tubes are subject to rupture, but we believe the exnanded tubes can be more subject to raupture due to their thinner walls, unrelieved stress of e xpansion, wall defects, vibration, denting, etc. (b) It's pretty obvious that a thinner wall is weaker than a thicker wall of the same material, .

all other things being equal. Unrelieved stresses put a constant force against the metal or parts of it at and near where the expansion occurred. For more details, we are consulting our experts.

. l 1

VII-37(c) Not Applicable. l VII-38 (a) Basic metallurgy and ohysics. The exuansion, in l particular, may ooen small cracks or pits on the outer surface, ,

or otherwise roughen it as it is stretched. This gives more sites for corrosive attack. We're asking our experts formore details re this entire matter.  !

(b) We believe they are. (c) The tubes are already subject to ruuture when unstressed and unthinned. Obviously a thinner tube section, with more stress, is more subject to rupture. The opening (or leaking from) several tubes at once in the Ginna accident shows that the prersent AS'4E standards (assuming the Ginna Diant and Westing house complied with them) shows that even the unstressed, unthinned tubes cannot comply with the criterion that only one tube should fail at a time in each steam generator. We are asking our exoerts for more detail and analysis on this. (d) Not Applicable.

(e) Cold working can result in an increase in yield strength, but at a cost of increased brittleness. We don't know if we agree that the yield strength will increase as described in NImEG-1014, or that this will increase the margin between leak and break, or l

- that increasedyield strength will improve safety. We think it l

could reduce safety by allowing somewhat higher pressures before failure of the tube (and thus more catastrophic failure). We are asking our exuerts concerning all these matters. (f) see (e) (g) N/A VII-39(a) See reschnses to VII-38(a),(c) and (e) above.

In addition, loose objects imnacting a more brittle, more stressed, thinner tube wall (the expanded part) can either directly, or through I flow blockage or diversion (eg leading to extra forces or to vibration of the tube) or through setting up corrosion between the metal of l

a loose part or portion or particle thereof trauped against or near l'

_g.

the tube or its expanded part, all can weaken the tubes of make them more subject to raupture. Impact could cause a crack to nronagate leading to rupture, for example. We 're seeking more info on this situation also from our exnerts.

(b) The sleeve would not fit both the expanded part and the unexpanded part. Thus the sleeve would not actually reinforce the tube where it has been expanded, leaving a site for corrosion, denting of the sleeve, vibration, etc. While it is possible to refer to a tube with an 111 fitting sleeve as " sleeved", it won't provide the same protection as a tube sleeved with a properly fitting sleeve.

(dc) Expanded to the same extent, at the same rate, at all toints.

In particular, above and below the expanded nortion, some area of partial expansion may exist; also due to impurities or differences in the metal, or due to residaual or other streasses, expansion may be uneven, e.g. at a weak spot in the tube.

(d) It may be. It' certainly beats letting the tube leak or lentting it sit there subject to sudden or other failure.

(e) Common sense. We'll also ask our experts.

(f) The tube may be able to be physically plugged, but the integrity of the plug-in-position may not be as readily assured, particularly if the expanded tube is ruptured at any point, which would allow forces to act on the nlug. Plugs have come out of steam tubes at other plants, as we understand it. We're asking our experts about. these matters also. (g) see f(g).

I

! /II-40. We're asking our experts. We believe that the l

l greater possibility of failures of expanded tubes will lead to a ore maintenance and cleaning and inspection work. We believe that more inaspection of the modified D-4 steam generators will be necessary (comp (bb 2h15 (ared a Ubto Wall steam generator PtM si (Vot2 fa h A Awhich Q "*# never I had the vibr g

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l VII-hl. We haven't gone back to SECY 8?-72 to check thoroughly; however, WE recalls statements to the effect that radiation exvosures due to steam generator problems and work are significant and were above what NRC used to exstimate; also, that multiole tube failures are a realistic possiblility, leading to acciddnts more severe than had been thought credible (by NRC and/or nuclear industry); also, that steam generators are needing more repairs and are having more problems, leaks and accidents than had been anticinated. Obviously, leaks allow orimary coolant out of the primary system, increasing radiation exuosure and accident risks; radiation and tradioactive material can be released from steam generators to atmosphere directly through atmosoheric dumo valves or indirectly in many ways during 0

an accident. (It hanpened at Einna.) We are asking our exnerts about this conclusion and its basis.

VII-42. See response to VII-40 and previous 1 responses. We believe exposure would be reduced by installing new steam generators not subject to the Model D or D-k steam generator nroblems. We're also asking our experts more re this matter.

VII-43 ALARA requires minimizing radiation exposure. The nuclear industry tends to take a sloppy view that many exuosures are necessary.

We believe that greater efforts to minimize radiation exposure are necessary. Compare, e.g. the views of Dr. Edward Radford and of J.

Rotblat reported in articles in the 9/78 Bulleting of the Atomic ScientistG radiation to the effect that occupational exoosure limits should be lowedred by q factor of 10.

VII-44 WB recollection of reports on steam generator "fix" gg )y switching Robinson to phosiphate after tube corrosion / leak problems.

" ave not had time to investigate in detail yet.

VII-45(a) We don't have a list yet. We'll ask our experts. This applies to both (1) and (11). (b) Corrosion expands metal around the tubes (orm, more precisely, the corrosion products have a greater volume than the metal, as is seen in rusting steel);these squeezer the tube, creating a narrow part and stressed walls. Contact with corrosion products makes the tube more subject to corrosion also.

We believe, based on conversations with nonwitness experts 9K N Bill Blew" and " Cell Cope" that AVT water chemistry is unable to prevent this and other forms of corrosion. However, it's been a long time since we communicated with these folks; we'll ask our present experts.

(c) Not without something to dent, like a steam generator. Running the steam generator with AVT water chemistry, we believe, can cause denting. See response to (b) above. We'll ask our exnerts for more information on this. (d) see (c) and (b) (e) Not anolicable.

VII-46. We'll ask our experts. Further analysis so far incomplete.

VII-47 We're not sure there are any. What does "qcceptably minimize" mean? Acceptable to us? To CP&L? To the NRC? to the public? We will ask our experts for more information.

VII-48. We'll ask our experts for more details. We're not sure that any or all of these methods can keen corrosion or cracking at levels acceptable to us, or to anyone.

VII-49. See resoonse to VII-38(a) and other resoonses above.

VII-$0. Safety grade meants nuclear Class 1 or Class 1E as anolicable. Opinion of "AA" as we understand it is that all the components should be safety grade. We'll ask our experts for more details.

VII-511Ah "The whole system" includes oower supplies, wiring, instruments, conduit, sensors, connections of all kinds, and all other components of a loose parts monitoring and/or reporting system, including devices to record, transmit, give alarms or indications 8l loose parts.

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VII-51(b) see VII-50 response. (c ) We'll ask our experts. (d) we'll ask our experts, but ith obvious that bigger objects have bigger impacts (e) through stupidity, negligence, mismanagement, etc. We understand that objects as large as a welding rig have been ground inside nuclear reactor vesseals and/or steam generators.

We'll ask our experts further about all matters in all parts of VII-51.

VII-52. We believe that removal of loose parts by robots or mechanical means or other means, taking excellent care not to damage the steam generator or other parts of the reactor /NSSS/ safety systens, would allow removal of the loose parts with less radiation exnosure to humans. We do not favor leaving or getting loose narts in SG8s, nor having them in there, nor exposing neoule to radiation from nuclear sources.

VII-53 Except as stated previously, our analysis has to go further. We'll also ask our experts.

VII-54 See above resoonse to VII-53 VII-55 Even if it did, we're not sure that intent is worth nuch in practical terms, since it's imolemented by the NRC Staff and CP&L. We'll ask our experts. VII-56: N/A see 55 VII-567 (a) Maly of them do. If the work on radiatetive things can be done without exposing people, it would be better to do it that way. See, e.g., response to VII-52 above.

V7.I-58. X(a) We don't possess the renort. We'll ask our experts.

(b) "AA" says these are imoortant issues re SGs.

VII-59. We think so. We'll ask our experts for more info.

VII-60. Except as previously stated, we 'll have to ask our experts and/or do more analysis. VII-61 N/A.

VII-62. Except as previously stated, no further analysis has been done by us so far. We will also ask our experts.

VII-63 See VII-62 and previous responses. VII-64: N/A VII-65 Except as previously stated, no further analysis yet done.

We dom believe that offsite doses from a steam generator tube rupture event could (1) imperil the health and safety of the publie ,

l and (2) exceed allowable limits. We're not sure which guidelines l you are referring to. We'll ask our experts re all of this.

VII-66. Multiple tube ruptures, or even a single tube rupture without appropriate action to limit radiation releases, could result in large amounts of the core radioactive inventory being released.

a ruptured tube can be equivalent to a small LOCA. If steam containing radioactive material is released or is vented to atmosphere, the radiation release can be quite significant. Our analysis of this matter is incomplete and we will ask our experts about it too.

VII-67 N/h.

VII-68. Additional radiation doses do not protect the public health and/or safety. See response to VII-66 and VII-65 above.

Also See NUREG-Oi909 p. I-19 item 2 re excessive I, Cs, Co, Ba & Mo nuclid; Nobody knows for sure what will happen in a SGTR accident. s VII-69. Even BEIR evidently agrees that there is no " safe dose" of radiation. They reject the threshold hypothesis. See also responses referenced in answer 68 above. We 'll also akk our experts re this and may do or have done more radiation analysis (re dose, etc). VII-70: N/A.

VII-71(a)It appears that WE misrecalled this. NUREG-0909 refers to a single rupture and multiple tubes damaged. See, e.g.

pp 7-16 and 7-17; see also p.7-18 re loose parts and tube damage, radioactive (b) We have not made a complete analysis, but the excessgrelease or transfer (for radio-iodines) referred to in answer 68 above, the info about corrosion and tube damage, e.g. at po 7-1 thru 7-217 the loose parts and extensive damage identified on pp7-17 and -18, we think supports our contention. We will also ask our experts.

(c) 5kut (b).

VII-72(a). Try reading NUREG-0909. Both the PORV and the SG Code valve lifted. (b) Analysis not complete, but it's obvious that extra radioactive material has to be cleaned up somehow, and ,

this can involve more exoosure to humans if steps aren't taken to (1) prevent release of such material inside containment, and/or (ii) clean it up without exposing humans.

l We will ask our experts further re both (a) and (b).

l VII-73 (a) Read NUREG-0909. If they hadn't been able to isolate the stream generator, the release could have been much greater, we believe. We will ask our experts further. (b) i We did not measure radiation levels at Ginna. We are far from sure the NRC, licensee, et al, measured them accurately. Va do l

not believe this estimate is necessarily courrect. Nor do we believe that just being within 10 CFR 100 guidelines protects the health and safety of the oublic adequately. Analysis not now complete. We will ask our experts further. (c) see kb) (d) N/A:

Joint VII was formulated long before Eddleman 180 and thus does not

" incorporate" it, though it may include some of the same issues, and W.E. believes it does.

VII-74 We disagree.

VII-75. Even if true, the phosphate chemistry plants have operated longer than plants that start up on AVT (Harris hasn't operated), so it's not clear which have the worst nroblems at the same stage of one ration. Seawater or barackish coolant has caused problems. We have not analysed this statement comprehensively.

We'll ask our experts.

Re 3-loop plants, we believe, based on analysis by Chas.

Komanoff, an expert in statistics and economics and nuclear capacity j factors, 3 loop plants lose an average of 11.8% or so CF compared to 2-loop capacity factor, and the - 0 $o .

We don't know which plants you claim are similar to Harris.

We would identify Beaver Valley I, North Anna I and II, and VC Summer.

Our analysis of these matters (re operating record of nlants with AVT which are similar to Harris, and always used AVT -- we don't know for sure which, if any, of the above plants have always used AVT, and VC Summer is very new and went thru a long startup veriod and may not even yet be in commercial operation), is incomplete.

i We'll ask our experts. We do not accent Kopne's statement.

We'll ask our experts.

(a)(b)(c)(d) Analysis currently incomplete. VII-76 N/A.

VII-77. We believe crevices are responsible for some eroblems with SGas. We are not convinced AVT will prevent formation of c revices, nor that crevices are the only SG problem. We do disagree.

1 VIII-78. Re other damage besides fumarom crevices, see e.g.

NUREG-01909 pp 7-17 thru 19 (and 7-16), ete; SECY-82-72 (as remembered);

we haven't completed a listing of documents which support this, but believe that others in W.E. 's possession do. We'll ask experts further.

VII-79 N/A.

VII-80. We enphatically disagree. This is a non sequitur.

Koppe is wrong to use all Westinghouse plants as a comparison group.

Those over 600 or 700 MW are (and each group is) very different statisti-cally in performance. We believe Harris performance will not be even as good as NRC Staff projects, or surely could be. VII-81: see above.

More info will be in Eddleman response to Summary Disposition on 15-AA, to be filed $- h-16-84 under extensi6n of time granted by Judge Kelley 4-1[

VII-82. Not anplicable.

Production of documents: Any of the above documents mi not alreaQ roduced or in possession of Applicants or NRC may be produced by contact p/

w Wells Eddleman to arragnge time and place mutually acceptable.

ATTEST The above answers are true and currect to the best of my present knowledge and belief.

April 11,1984 _

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_ #- D Wells Eddleman for Joint Intervenors i

UNITED STATES OF AMERICA NUCLTAR REGULATORY C01 CESSION 4

Docket 50-400 In the matter of CAROLIKA POWER k LIGHT Co. 1 Et al. )) 0 0.L.

Shearon Harris Nuclear Power Plant. Unit CEICIFICATEOF SERVICE t Response to I hereby certify that copies of Joinnt In h vanora

^

Applicants Seventh Set of Interrogatories (Joint 7)

HAVE been served this 12" day of April 198h,bydepositin the US Wil, first-class postage prepaid, upon all parties whose names are listed below, except those whose nanes are arked with an asterisk, for whom service was acconplished by Exnress Mail Acril 11 by special agreement with Aeplicants counsel Baxter, ok'd by NRC Staff also -- all other parties to be served in mailing of the 1Pth.

JudE es James Kelley, Glenn Bright and Jav.es Carpenter (1 egy each)

Atomic Safety and Licensing Board i

US Nuclear Regulatory Conmission Washington DC 20555 GeorEe F. Trowbridge (attorney for Applicants)

Shaw, Pittman, Potts & Trowbridge R.uthanne G. Miller 1600 M St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 25 5 5 l

l Office of the Executive Legal Director Phillis Lotchin, Ph.D.

Attn Docke ts 50-400/401 0.L. 105 Bridle Run USliRC Chanel Hill NC 2751h Washington DC 20555 Dan Read Docketing and Service Section (3x) CEA!E/FLP Attn Docke ts 50-h00/h010.L. .

Raleigh,5707 NCWaveross 27606

Office of the Secretary Dr. Linda W. Little I

' a neton DC 20555 Governor's Waste Mgt. Bd.

513 Albemarle Bldg John Runkle -

325 N. Salisbu St.

I" '

Granville Rd .

Chapel Hill Ne 2751h Bradley W. Jones Robert Gruber USNRC Region II

'Travi s Payne Exec. Director 101 Marietta St.

Edelstein & Payne Public Staff Atlanta GA 30303 Blox 12601 Box 991 Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D. Certified by h 729 Hunter St.

Apex NC 27502

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