Text

Response to W Eddleman General Interrogatories & Interrogatories on Contentions 9,11,41,45,116 & 132 (II) to Applicants Eighth Set.Related Correspondence
	ML20083P525
Person / Time
Site:	Harris
Issue date:	04/17/1984
From:	Swiger M; CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES, SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	; EDDLEMAN, W.
References
	OL, NUDOCS 8404200055
	Download: ML20083P525 (98)
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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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CAROLINA POWER & LIGHT COMPANY

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Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN

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50-401 OL MUNICIPAL POWER AGENCY

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(Shearon Harris Nuclear Power

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Plant, Units 1 and 2)

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APPLICANTS' RESPONSES TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES AND INTERROGATORIES ON CONTENTIONS 9, 11, 41, 45,_116 AND 132C(II)

TO APPLICANTS CAROLINA POWER & LIGHT-COMPANY, ET AL. (EIGHTH SET)-

Applicants Carolina Power & Light Company ("CP&L") and North Carolina Eastern Municipal Power Agency, pursuant to 10 C.F.R. 6 2.740b, hereby submit the following responses to

" Wells Eddleman's General Interrogatories and. Interrogatories on Contentions 9, 11, 41, 45, 116 & 132(c)(2) to Applicants Carolina Power & Light et al. (Eighth Set)."

The provision of answers to these interrogatories is not to be deemed a repre-sentation that Applicants' consider the information sought to be relevant to the issues to be heard in this proceeding.

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l GENERAL INTERROGATORIES INTERROGATORY NO. G1(a). Which contentions of Wells l

Eddleman do Applicants agree are now admitted in this proceed-ing, NRC Dockets 50-400/401 0.L.?

ANSWER:

The contentions of Intervenor Eddleman which are admitted to this proceeding are set forth in various memoranda and orders issued by the Atomic Safety and Licensing Board, all of which are available to Mr. Eddleman.

INTERROGATORY NO. G1(b). [F]or each such contention, pro-vide for any answers to interrogatories by Wells Eddleman which Applicants have previously or presently received (except those suspended by Board order, if any), the following information:

ANSWER:

The answers to General Interrogatories herein are i

restricted to Eddleman Contentions 9, 11,-41, 45, 116 and.

2 132C(II).

INTERROGATORY NO. Gl(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) upon 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 Contentions 9, 11, 41, 45, 116 and 132C(II) and indicates the particular interrogatory answers :for which such person provided information:

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PERSON INTERROGATORY NO(S).

P. Yandow 9-2; 9-3(a), (c); 9-4; 9-5(b),

(c), (d); 9-7; 9-8; 9-10(b), (d),

(e); 9-11(a); 9-12; 11-1(1), (n),

(o), (s), (t), (u); 11-2; 11-3.

R.

Bucci 9-2; 9-3; 9-5(b), (c), (d); 9-6; 9-10(a), (d), (e), (f); 9-11(b),

(c); 9-12; 11-1(a), (b), (c),

(d), (e), (f), (g), (h), (j),

(k), (m), (p), (q), (r), (u);

11-2; 11-3.

A.

Fuller 41-20(184), (185), (186), (187), (189),

(190), (192), (193); 41-21; 41-22; 41-23; 41-29; 41-34; 41-36.

R. M.

Parsons 41-20(191), (194); 41-28.

V. Safarian 41-20 (187), (188), (195); 41-24; 41-32; 41-33; 41-35.

D. Timberlake 41-20(188); 41-29[2); 41-30; 41-33; 41-35.

G.

O. White 41-25; 41-26; 41-27.

J.

Ferguson 132-c-2-22(c), (d)

D. Waters 132-c-2-22(c),(d)

R. Prunty 132-c-2-20; 132-c-2-21, 132-c-22(a),

(b); 132-c-2-23; 132-c-2-24[223];

132-c-2-25[224); 132-c-2-26[225];

132-c-2-27[226]; 132-c-2-28[227];

132-c-2-29[228); 132-c-2-30[229);

132-c-2-31[230).

K. Shaw 45-19(197); 45-19(198); 45-19(199)

M. Gagliardi 45-19(196); 45-19(197); 45-20 D.

Shah 45-19(196); 45-19(197); 45-20 S. Hardy 116-3(a), (h); 116-4(b), (c)

M. Serbanescu 116-1; 116-2; 116-2[ sic]; 116-3; 116-4(a)

n All of the above individuals are employees of Carolina Power &

Light Company at the Shearon Harris Nuclear Power Plant, Route 1, Box 101, New Hill, North Carolina 27562, except for Messrs.

Bucci, Gagliardi and Shah, and Ms. Serbanescu, who are employees of EBASCO, Two World Trade Center, New York, New York 10048.

INTERROGATORY NO. Gl(d). [P] lease identify all facts con-cerning which each such person identified in response to Gl(c)(1) above has first-hand knowledge.

ANSWER:

See answer to Interrogatory No. Gl(c).

INTERROGATORY NO. G1(e). [P] lease identify all facts and/or documents upon which each person identified in response to Gl(c)(2) above relied in providing information to respond to the interrogatory, including the parts of such documents relied upon.

ANSWER:

All facts or documents relied upon by those indi-viduals identified above are indicated within each response to the specific interrogatories on Contentions 9, 11, 41, 45, 116 l

and 132C(II).

INTERROGATORY NO. Gl(f). Please identify any other docu-ment (s) used or relied upon by Applicants in responding to the interrogatory.

ANSWER:

See Answer Gl(e).

INTERROGATORY NO. G1(g). Please state which specific fact each document, identified in response to Gl(e) and Gl(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 4

to the specific interrogatories on Contentions 9, 11, 41, 45, i

116 and 132C(II).

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INTERROGATORY NO. G1(h). Please state specifically what F

information each person identified in response to Gl(c)(1) or i

Gl(c)(2) above provided to or for Applicants' - affiant in an-swering the interrogatory.

If any of this information is not documented, please identify it as " undocumented" in responding j

to this section of General Interrogatory 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, con-tractor, employee, etc.) if any (beyond expert or other witness i

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 previ-ously 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.

j ANSWER:

Applicants have not yet identified the' expert or other witnesses they expect to call in'this proceeding regard-i

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ing these Eddleman contentions.

When and if-such witnesses are

.j identified, Applicants will supplement.this response in a time-ly manner.

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INTERROGATORY NO. G2(b). Please identify each contention regarding which each such person is expected to testify.

ANSWER:

See Answer G2(a).

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INTERROGATORY NO. G2(c). Please state when you firsticon.

tacted 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),

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s INTERROGATORY'NO. G2(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 tes-tify-to.

ANSWER:

See Answer.G2(a).

INTERROGATORY NO. G2(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 testi-mony.

ANSWER:

See Answer G2(a).

l INTERROGATORY NO. G3(a).

[P] lease identify any other

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source (n) 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 other such sources of information, if any, within the answers to the specific.in-terrogatories set forth herein.

INTERROGATORY NO. G3(b). [P] lease-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 source the witness who is expected to use it, and the part-or part(s) or such source (if applicable) which are expected to'be used, and, 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).

[P] lease _identifyfall documents, and which pages or sections thereof Applicants intend orLexpect-

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to use in. cross-examination of-any witness'I.calliin this hear--

ing..

For each such witness,-please provide on a_-timely basis (ASAP near or during hearings) a' list.of'all'auch documents, the subject matter-Applicants believe they relate to, and make the-document (s) available-for inspection'and copyingLas.soon as possible after. Applicants decide or form. intent.to use such:

document in cross-examination.

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ANSWER:

Applicants have not at this time identified which documents, if any, they intend to use in cross-examination'of j

Mr. Eddleman's witnesses.

1 INTERROGATORY NO. G4(b).'[P] lease identify'any 1

undocumented information Applicants _ intend to use in cross-examination of each such witness for me.

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ANSWER:

See Answer G4(a).

I INTERROGATORY NO. G5(a). [F]or each contention Applicants j-state or admit is an admitted Eddleman conter.* ion under Gl(a)

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above, or an admitted joint intervenor contention, please state i

whether applicants have avai.lable to them experts, and informa-i tion, on the subject matter of the contenti6n.

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j ANSWER:

Applicants have:a'vailable to them experts and

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information on the subject matter of Contentions 9','ll, 41, 45, i.

I 116 and 132C(II).

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.x INTERROGATORY No. G5(b).-Ifithe answe$ to (d) ab'ove ; is other than affirmative, state whether Applicants expect'to be able.to obtain expertise in the. subject matter, and informati'on on it, and if not,. hy.not.

w ANSWER:

Not applicable.

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1 INTERROGATORY'NO. G6(a). [F]or each document identified in' response to any interrogatory herein, or referenced in response' A) to any interrogatory herein,'please supply all.the following

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information which has-not already been supplied:

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- (11) title or-identification.of document-(iii) all authors of.the document,bor-the author (iv) all.quali'ficationsf(professiongli techni--

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-,Ecal) of'each-author.of the document-

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6-tha document,'if any, upon which-Applicants 1PW

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(vi) the specific information each part, section or page identified in response to (v) above contains.

(vii) identify all documents used in preparing the document, to the extent known (and also to the extent not identified in the docu-ment itself)

(viii) 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.

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(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 whether Applicants now employ any author (s) of the document, identifying each person for each document.

(xii) state whether Applicants have ever employed any author (s) of the document, identifying each such person for each document.

(xiii) identify all sources of data used in the document.

Answers to all the above may be 4

tabulated or grouped for efficiency.

ANSWER:

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 histori--

cal employment records to determine whether the authors of each

. document identified herein have ever been employed by Appli-cants.

However, Applicants will supplement this response-in a timely manner if and when Mr. Eddleman identifies any such,

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I author regarding whom they are particularly interested in de-termining 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 Gl(a), or (ii) is the sub-ject 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 docu-ments they intend to offer as exhibits relating to Contentions 9,

11, 45, 116 or 132C(II).

As to Contention 41, see Appli-cants' May 12, 1983 answer to Interrogatory G7.

A INTERROGATORY NO. G7(b). Please identify all documents which Applicants plan, expect or intead to 'ise in cross-examination of any other parties' wit. asses or joint in-l tervenor witness in this proceeding, with respect to (i)

Eddleman contentions identified under G7(a)(i) (or Gl(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.

l ANSWER:

Applicants'have not yet identified those docu,

ments they intend to use for cross,e.kamination of any witness.

s INTERROGATORY NO..G7(c). Please identify which of'the documents identified in response.to (b) above (1) 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.

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ANSWER:

See Answer G7(b).

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1 INTERROGATORY NO. G10(a). Where the above general inter-3:

l rogatories, and/or specific interrogatories below, or any of them, call for identification of documents, (i) and no docu-ments are identified, is that the same as Applicants stating that there are no documents responsive to this general inter-4 rogatory, 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 pres-i; ently known which are responsive to the interrogatories? (iii)

If your answer to G10(a)(ii) is other than affirmative, please

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state all reasons for your answer. (iv).If your answer to GlO(a)(1) above is other than affirmative, please state all reasons for your answer.

l ANSWER:

(i)

Yes.

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(ii)

Yes.

(iii)

Not applicable.

(iv)

Not applicable.

INTERROGATORY.NO. G10(b). Where any interrogatory,. general or specific, herein, calls for factual information (i) and an 2

opinion is stated in response,-is that-the expert opinion of any person (s) identified as having contributed information to' that response? (ii)-and facts are given or identified (or.at fact is) in response, but no documents are identified,sdoes-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 4

whom Applicants rely for'each such answer., TheEqualifications-need be stated.only once-for each such person if-they are clearly. referenced in-other answers. (iv) if your-answer:tof(i)~

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- aboveeis other than affirmative, please state'which opinions, if any, given in response to interrogatories (general or spe-cific) 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~

4 your. answer to (i) above is other thaniaffirmative,:please-identify all opinions-of non-experts used'in your responses,.

.and11dentify each non-expert whose-opinion is included.in each answer herein.:(vi) If your response to (ii):above.is'other; than ' affi rmative,: please. identify.each1 document:which contains a fact not previously documented in your. response (s),-stating-what the fact is,'and at what page, place, chapter oriother.

specific part.the document contains'such fact. '

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o ANSWER:

(i)

Yes.

(ii)

See Answers G1(e), (f) and (g) and G10(a)(i) above.

(iii)

See Attachments (A)-(0) attached hereto.

(iv)

Not applicable.

(v)

Not applicable.

(vi)

Not applicable.

INTERROGATORY NO. Gil. For each answer to each interroga-tory herein (or any subpart or part thereof), please identify each item of information in possession of-Applicants (including facts, opinions of experts, and documents) which (a) contra-dicts the answer you made, (i) in whole (ii) in part (please identify each such part for each item of information identi-fied); (b) casts doubt on your answer (1) 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:

G11(a)-(c):

Applicants have no such information.

ANSWERS TO INTERROGATORIES ON EDDLEMAN 9 INTERROGATORY NO. 9-1.

Please provide a copy of.the cur-rent 10 CFR 50.49.

If you believe it is different from that cited in my responses, please state whether it is being further amended or changed in any way to your present knowledge, or if such changes have been proposed, so state.

ANSWER:

10 C.F.R.

$ 50.49 was published as a final rule-of the Commission on January 21, 1983 at 48 Fed.' Reg. 2729.

The curre. version of 10 C.F.R. 5 50.49 is available in'the Local Public Document Room ("LPDR").

o INTERROGATORY NO. 9-2(a).

Please identify each and every item of electrical equipment at Harris that you believe (a) is fully environmentally qualified under 10 CFR 50 Appendix A Gen-eral Design Criterion 1 and/or GDC 4 and/or 10 CFR 50.49 and/or NUREG-0588, stating under which you believe it is fully quali-fled (you may say "all" if you so believe);

ANSWER:

The Environmental Qualification Master List

(" Master List") for the Shearon Harris Nuclear Power Plant

("SHNPP") identifies electrical equipment at SHNPP required to be environmentally qualified under 10 C.F.R. 9 50.49.

A11 electrical equipment on the Master List will be fully qualified prior to fuel load in accordance with applicable NRC regula-tions and guidance.

As of April 13, 1984,-more than 80% of the Environmental Qualification Reports submitted to Applicants by equipment vendors have been determined to be acceptable.

The Master List and a sample of the Environmental Qualification Packages containing Environmental Qualification Reports, review documentation and other information will be produced for in-spection and copying in accordance with Applicants' Response to Wells Eddleman's Request for Production of Documents.

INTERROGATORY NO. 9-2(b).

[I]s required to be environ-mentally qualified for accident conditions by NRC rule, regula-tion or regulatory position (specify which), but has not been fully qualified.

ANSWER:

See Answer 9-2(a).

INTERROGATORY NO. 9-2(c).

For each item identified under either-(a) or (b) above, please state exactly what accident conditions-are postulated for that item,'and all reasons why those conditions and not any more severe ones are postulated, and

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i ANSWER:

The design basis post-accident condition conse-i quences to which electrical equipment identified in the answer to Interrogatory 9-2(a) must be qualified are described in the c

following sections of the Final Safety Analysis Report for the l

Shearon Harris Nuclear Power Plant ("FSAR"):

Post-Accident Condition Consequences FSAR 4

Compartment Pressurization and Flooding

$$ 3.6, 3.6A Chemical Environment

$$ 3.11.5, 6.5.2 Temperatures and Integrated Radiation Doses 6 3.llB Analysis of Pressure Response of Containment

$ 6.2.1 1

INTERROGATORY NO. 9-2(d).

[S] tate what exact tests were done on (i) that item (ii) a si.711ar item (iii) anything, which l

tests' results were used to estaolish,-in your view, that the item is environmentally qualified.

Include all test conditions in your response, or reference them precisely.

ANSWER:

Applicants have received to date over 100 test i

reports from equipment vendors.

All such test reports are re-viewed by Applicants.for correctness and applicability'to SHNPP.

A sample'of The Environmental Qualification Packages containing test reports will be produced;for inspection and 4

copying as stated in Answer 9-2(a).

I INTERROGATORY No. 9-2(e).

[I]dentify all~ documents containing the results of any tests' identified in response to i

(d) above. Please-note all; tests which any item'(or.any item similar to an item used.at Harris) failed.~

' ANSWER: :See Answers 9-2(d).and/(f).

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INTERROGATORY'No. 9-2(f).

Have there been'any' failures, in tests >you know of, of-(i) items to be used at Harris-(ii) a items similar to those to be used at Harris,:in.or under envi.

ronmental : conditions (aa) as.-severe (bb)-more severe (cc) less l :

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i severe (dd) different, than the conditions you believe the item (or similar item) to be used at Harris must be environmentally qualified under?

Please identify all documents relating to each such failure not already identified above.

Please also (ee) state for each such failure any rationale, reasoning or argument or information which you believe means such failure would not be a to environmentally disqualify the item or simi-lar item at Harris, based on the failure of each such item or similar item in the test (s).

ANSWER:

All test failures must be documented by the ven-dor.

The vendor also must provide an evaluation of the fail-ures.

The following criteria are used by Applicants in're-viewing the adequacy of vendor documentation:

1)

Record failure date and time.

2)

Identify and understand cause of problem or failure which includes determining with reasonable assurance if test monitoring instrumentation and/or test devices were the cause of the abnormality.

3)

Determine with reasonable assurance whether the acceptance criteria were appropriate.

4)

Review the failure to determine if it is common-mode or random.

5)

Determine whether all failed items have been repaired or whether disposition has been determined.

6)

Determine whether the corrective ~ actions have=been t

made in existing identical items to which these actions are pertinent.

7)

If the problem or failure has been corrected by de-sign change, determine whether the change has been incorporated and tested to prove its effectiveness.

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Determine whether the problem and failure report close-out has been reviewed by cognizant technical and manage-ment personnel to ensure adequacy of corrective and close-out action.

All documentation related to test failures is included in the Equipment Qualification Packages, a sample of which will be produced for inspection and copying as stated in Answer 9-2(a).

INTERROGATORY NO. 9-3(a)

State (or state where it is stated) all actions Applicants have taken to comply with the criteria of 10 CFR 50.49 for each item of electrical equipment located in a harsh environment at Harris.

ANSWER:

Applicants' program for environmental qualifica-tion of electrical equipment is designed in accordance with 10 C.F.R. 6 50.49 and NUREG-0588, Interim Staff Position on Envi-ronmental Qualification of Safety-Related Electrical Equipment, 1

(Rev.

1, July 1981), which is endorsed by 10 C.F.R. 9 50.49(k).

The principal elements of Applicants' program to meet section-I 50.49 include:

1 1)

Identify on the Master List all electrical equipment j

required to be environmentally qualified.

2)

Identify environmental parameters at equipment loca-

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tions, e.g.,

radiation, temperature, humidity.

3)

Specify equipment for the appropriate environmental-parameters in accordance with applicable NRC regulations and guidance and-industry standards.

4 4)

Evaluate vendor proposals for meeting the specifica-l tions and evaluate vendor test plans prior to testing.

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Review vendor Equipment Qualification Reports.

6)

Assemble Equipment Qualification Packages containing all required documentation.

7)

Prepare documentation for NRC Staff (" Staff") audit, including:

a)

Equipment Qualification Program Report; b)

Master List; c)

Component Evaluation Sheets; d)

Equipment Qualification Packages 8)

Respond to any Staff audit findings and requests for additional information.

9)

Qualify all equipment prior to fuel load.

10)

Monitor NRC and other studies, reports and Informa-tion Notices, IE Bulletins, vendor information and other indus-try experience for applicability to SENPP.

INTERROGATORY NO. 9-3(b).

[D]efine the term " harsh envi-ronment" as you use it in your interrogatory 9.5(a).

State whether this is the same definition used (1) in 10 CFR 50.49 as presently promulgated (ii) in NUREG-0588 (iii) in 10 CFR 50 Ap-pendix A.

ANSWER:

Applicants' definition of " harsh environment" is as follows:

The harsh environment is-an environ-ment with a significant change (increase in pertinent environmental stress factors) due to a Design Basis Event, such as, Loss of Coolant Accident, Main Steam Line Break or.

High Energy-Line Break, including a'signif-icant increase in radiation due to recirculation of containment sump fluid.

i Neither 10 C.F.R. 50, Appendix As 10'C.F.R. 5 50.49, or NUREG-0588 defines harsh environment.

However, 10 C.F.R. 550.49(c) defines mild environment.

Applicants believe their definition of harsh environment to be consistent with the in-tent of NRC regulations and guidance.

INTERROGATORY NO. 9-3(c).

State which equipment at Harris has been qualified under NUREG-0588 in your opinion, and to the extent not already set forth above (in other responses to the above), state for each item all reasons why you think it is qualified under NUREG-0588 and identify all documents concern-ing its qualification and/or testing.

ANSWER:

See Answers 9-2(a) and (d), and 9-3(a).

INTERROGATORY NO. 9-4(a).

State when, if ever, CP&L plans to complete environmental qualification for the Harris 1 plant.

ANSWER:

Environmental qualification of electrical equip-ment will initially be achieved prior to fuel load.

However, environmental qualification of electrical equipment is an ongoing program at SHNPP for the life of the plant.

Replace-ment parts, spare parts and new equipment will be environ-mentally qualified.

In addition, Applicants will monitor NRC and other studies, reports and Information Notices, IE Bulle-tins, vendor information and other industry experience for ap-plicability to SENPP.

INTERROGATORY NO. 9-4(b).

What work-needs to be done be-tween now and your completion date (or November 30, 1985 if you think this date applies regardless of your completion date) to qualify all the electrical equipment at Harris that must be qualified.

Please identify all documents,-including work schedules, test programs and/or schedules, critical path studies or diagrams, and/or plans, which relate to the comple-tion of the environmental qualification of electrical equipment at Harris.

If a schedule only applies to some equipment, iden-tify all equipment for which that schedule applies.

ANSWER:.The current schedule for completion of the preoperational phase of Applicants' program for environmental qualification of electrical equipment is as follows.

On July 4

1, 1984 Applicants will submit to the Staff their Equipment Qualification Program Report, the Master List, the Component Evaluation Sheets and other information requested by the Staff in 5 3.11.3 of NUREG-1038, Safety Evaluation Report Related to the Operation of Shearon Harris Nuclear Power Plant, Units 1 and 2 (November 1983) ("SER").

The Staff will conduct an audit of Applicants' program in October and will issue an SER supple-ment based on the results of the audit.

All equipment will be fully qualified by fuel load, which is scheduled for June 1985.

INTERROGATORY NO. 9-5(a).

Please provide a copy of FSAR Amendment 4.

ANSWER:

ESAR Amendment 4 will be produced for inspection and copying.

INTERROGATORY NO. 9-5(b).

Please state why you believe compliance with the format requirements of 10 CFR 50.49 (if any

-- see your interrogatory 9-7(a)) would be relevant to this contention.

ANSWER:

10 C.F.R. 6 50.49 contains requirements for iden-tification of electrical equipment and for documentation of component evaluation data.

The formats of FSAR Figure 3.11.1-1, the Master List, and Figure 3.11.1-2, the Component Evaluation Sheets, are designed to address the regulatory requirements by calling for certain categories of information which, along with other information, will be reviewed by the --

Staff.

Any deficiencies or omissions which Intervenor believes to exist in Figures 3.11.1-1 and 3.11.1-2 would thus be poten-tially relevant to Contention 9.

INTERROGATORY NO. 9-5(c).

Please state why you believe compliance with the format requirements of 10 CFR 50.49 (if any

-- see your interrogatory 9-8(a)) would be relevant to this contention.

ANSWER:

See Answer 9-5(b).

INTERROGATORY NO. 9-5(d).

[P] lease explain why I should tell you what changes you need to make in a figure (3.11.1-2) in your FSAR, in order to comply with 10 CFR 50.49.

Please also state whether you believe that figure and the information in it does comply (or demonstrate compliance with) 10 CFR 50.49, and if so, why (state all reasons) and please also state whether NRC staff agrees with your view.

(Cf. your interroga-tory 9-8(c))

ANSWER:

Applicants believe the Interrogatory.i:s relevant for the reasons stated in Answer 9-5(b).. Applicants believe that the format of Figure 3.11.1-2 is adequate because it calls for all of the categories of information required by 10 C.F.R. 5 50.49 and recommended by NUREG-0588.

Applicants believe that the Staff agrees with the format of Figure 3.11.1-2.

Figure 3.11.1-2 is consistent with a figure included by the Staff in IE Bulletin 79-OlB as an example of an acceptable format for providing the types of information required for environmental

. qualification of electrical equipment.

Applicants.are aware of no subsequent Staff issuance repudiating or preempting the sam- '

ple format provided in IE Bulletin 79-OlB.

J

(,

INTERROGATORY NO. 9-6(a).

State what criteria of NUREG-0588 you believe you have (i) completely (ii) partially complied with.

Give all basis for each answer.

Identify all documents you believe support your answer to the above parts, and all documents you believe support your answers to (b) through (d) of 9-5 above.

ANSWER:

Applicants believe that their program for envi-I q

ronmental qualification of electrical equipment complies with all the criteria of NUREG-0588.

For the bases of Applicants' compliance, see Answer 9-3(a).

INTERROGATORY NO. 9-7(a).

Do you believe there are i

inadequacies in SER section 3.11?

ANSWER:

Applicants do not believe there are any inadequacies in SER $ 3.11.

INTERROGATORY NO. 9-7(b).

If so, please detail each such inadequacy.. Identify all documents and/or expert opinions sup-porting your opinion that each is an inadequacy in fact.

ANSWER:

Not applicable.

INTERROGATORY NO. 9-8(a).

What information requested in SER pp 3-49 through 3-51 has CP&L (i) already provided to NRC Staff (ii) committed to provide to NRC Staff (iii) refused or otherwise declined to provide to NRC Staff (iv) not yet pro--

vided to NRC Staff?

Please identify all items of equipment for which you have not yet provided information requested by the Staff, either information requested as detailed in che SER pp 3-49 through 3-51, or any other information requested (specify).

ANSWER:

Applicants have committed to provib all of the information requested in SER 5 3.11.3.

The information will be pro.2ded according to the schedule outlined in Answer 9-4(b).

t Applicants have met with the Staff in order to present a gener-al program description.

'The materials included in the presentation will be produced for inspection and copying.

INTERROGATORY NO.

9-9.

(a) Is there any equipment in your (i) Brunswick (ii) Robinson 2 nuclear plants which is not envi-ronmentally qualified and which should be or must be environ-mentally qualified under 10 CFR 50.49, NUREG-0588, or other ap-plicable NRC rule, requirement or regulation (please specify)?

If so, when do you plan to qualify each such item of equipment (list all -- if no date, say "no date to qualify")?

(b) Do you believe that operating either plant with such equipment (i) has (ii) will (iii) might compromise safety of that plant?

Please give all reasons for your answer and identify all documents you believe support your answer, including any documents submitted to NRC to justify continued operation of either Robinson 2 or either or both Brunswick units with unqualified electrical equipment.

ANSWER:

Applicants object to the Interrogatory as irrele-vant and beyond the scope of Contention 9.

INTERROGATORY No. 9-10(a).

What flooding analysis have you done for equipment inside that Harris containment?

Please identify all documents containing such analysis.

ANSWER.

The flooding analysis for equipment inside con-tainment at SHNPP is described in FSAR 55 3.6 and 3.6A.

INTERROGATORY NO. 9-10(b).

Do you have any Anaconda flex-ible conduit in use anywhere at Harris?

If so, is it in a place or use that you believe should require it to be environ-mentally qualified under 10 CFR 50.49, NUREG-0588 or other'ap-plicable regulation, rule or position of NRC (please specify)?

Please identify all such uses and/or locations of Anaconda flexible conduit.

ANSWER:

Anaconda flexible conduit is used in several dif-ferent applications at various locations at SHNPP.

None.of the conduit is required to be environmentally qualified, either be-cause:

1)

The equipment to which the conduit is connected is qualified to operate independent of the conduit materials.

t

2)

The cables enclosed in the conduit are qualified for use unprotected by conduit.

3)

The conduit is used to enhance moisture protection for outdoor equipment such as terminal boxes.

4)

The conduit is used as a vibration reducer on high vibration equipment, an application which is not impaired by failure of the outside jacket material of the conduit.

INTERROGATORY NO. 9-lO(c).

Are any of the items mentioned in Union of Concerned Scientists' February 7, 1984 petition to NRC re environmental qualification of electrical equipment, in use or planned to be used or installed at Harris?

ANSWER:

Mr. Eddleman did not supply Applicants with a copy of the February 7, 1984 Union of Concerned Scientists' Supplemental Petition for Emergency and Remedial Action; and Applicants were unable to obtain a copy of the petition in suf-ficient time to answer.the Interrogatory.

1 INTERROGATORY NO. 9-10(d).

What equipment in use at Harris, if any, can perform its required functions while sub-merged?

What equipment at Harris has submergence included'in its environmental qualification requirements (i.e. has a quali-fication environment that includes being submerged)?

ANSWER:

All electrical equipment at SHNPP for which sub-mergence is included in its qualification environment will be qualified to perform its required safety function (s) while sub-merged.

Such equipment will be qualified for submergence in the radiation field postulated for the equipment's location.

1 Any electrical equipment located below the maximum flooding level of 228.3 ft. could be submerged during an accident.

The,

. m

elevation level for each item of electrical equipment is indi-cated on the Master List.

INTERROGATORY NO. 9-10(e).

Please list all equipment at Harris which you think (1) is electrical equipment that could be submerged during an accident, e.g.

at TMI-type accident or small-break LOCA where coolant overflows or flows out into con-tainment, but cannot be removed from containment either (aa) because it is too radioactive, or (bb) because containment is isolated; (ii) is electrical equipment that has to be environ-mentally qualified for being submerged in (aa) water (bb) highly contaminated water, e.g.

a high radiation field with water.

Please identify all bases for your answers and a'll documents concerning these matters.

ANSWER:

See Answer 9-10(d).

INTERROGATORY NO. 9-10(f).

Have you analyzed the effects of plateout of radiciodines etc. on the radiation fields to which electrical equipment at Harris may be exposed during an accident?

Please identify all documents concerning such analy-sis by you or by anyone else.

Identify also any documents ana-lyzing this question in general (plateout effects on radiation fields in nuclear plant accidents as this affects electrical equipment or may affect it) or for other nuclear plants or for military nuclear systems, which you know of.

ANSWER:

Applicants have analyzed the effects of plateout of radioiodines on the radiation fields to which electrical equipment at SENPP may be exposed during an accident.

A zero removal rate coefficient is used for all types of halogens in Applicants' plateout model.

This assumption of zero removal is more conservative than the removal rates recommended in NUREG-0588.

INTERROGATORY NO. 9-11(a).

What maintenance procedures for Harris assure that environmentally qualified electrical equipment at Harris is always kept in the same condition or state of repair and/or readiness it was qualified under?

Please identify all documents concerning such maintenance, or maintenance programs for environmentally qualified electrical equipment at Harris.

ANSWER:

Maintenance procedures for SENPP are currently under development.

Maintenance procedures will be based on the following information.

Environmental Qualification Reports submitted by vendors are reviewed for information regarding maintenance by engineering personnel trained in equipment qual-ification.

The engineering reviews also identify equipment qualified to less than the 40-year life of the plant, and docu-ment maintenance to be performed on such equipment to assure continued qualification.

Spare parts and replacement intervals necessary to assure a 40-year life also are identified.

The information generated by the engineering reviews is then trans-mitted to the Operations Department to be included in the SHNPP surveillance and maintenance program.

Operations personnel also review Technical Manuals for inclusion in the program.

NRC and other studies, reports and Information Notices, IE Bul-letins, vendor information and other industry experience will be taken into account in writing and revising maintenance pro-cedures as appropriate.

INTERROGATORY NO. 9-11(b).

Are there any items that must be environmentally qualified for several conditions (e.g.

ra-diation, steam spray and impact) which were not tested under all those conditions at once?

Please identify each such item

~

or describe which items were not so tested.

ANSWER:

Generally, the electrical equipment at SHNPP which must be qualified to accident conditions is not tested under all postulated conditions simultaneously.

Paragraph 2.3 of NUREG-0588 permits sequential testing, and such testing is \\.

i standard industry practice.

However, most equipment is tested under several conditions simultaneously.

The-test methods for particular items of electrical equipment are included in the Equipment Qualification Packages, a sample of which will be produced for inspection and copying as stated in Answer 9-2(a).

i i

INTERROGATORY NO. 9-11(c).

Have radiation fields in the auxiliary building at Harris under (i) MSLB (ii) high energy line break outside containment (iii) EFW failure (iv) AFW fail-ure (v) break in steam line to steam - driven pump (vi)' fire in the auxiliary building, been analyzed for determining condi-tions under which electrical equipment in the Harris auxiliary building must be environmentally qualified?

Please identify j

all documents concerning (aa) such analysis (bb) any reasons for not doing.such an analysis for any or all of the situations inquired about above.

ANSWER:

Except for (vi), which is not analyzed under the environmental qualification program but is analyzed under the

]

fire protection program, each of the above postulated events has been analyzed to assure that the calculated radiatien envi-ronment for electrical equipment in the SENPP. Reactor Auxiliary Building, both for normal plant operation and'the most severe design basis accident to which.the equipment is required to be qualified, is conservative.

. INTERROGATORY NO. 9-12(a).

Please provide copies of (i)

' actual test data (ii) analysis, used or submitted by CP&L to

- show electrical' equipment at Harris is or will Ima environ-mentally qualified, for all items of electrical ~ equipment at Harris which-(aa) you believe must be environmentally ~ qualified (bb) such tests or analysis have been-done and you have a copy l

of the test results or analysis.

Please provide copies of all procedures used in each such. test and all documents giving data or basis used in each such analysis.

s

4

ANSWER:

See Answer 9-2(d).

ANSWERS TO INTERROGATORIES ON EDDLEMAN 11 Applicants have determined that there are no polyethylene-insulated electrical cables in cable raceways at SHMPP which will be exposed to radiation.

See Letter from M. A. McDuffie to Harold R. Denton (April 26, 1983), and attachments, a copy of which was transmitted to Mr. Eddleman.

While Applicants be-lieve Contention 11 is now moot, Applicants are providing an-swers to the interrogatories, pending an opportunity to discuss the contention with Mr. Eddleman, in order to facilitate the proceeding.

INTERROGATORY NO. 11-1(a).

What information do you pos-sess concerning the effects on (i) polyethylene (ii) polyethylene copolymer (iii) neoprene (iv) any other insulation used on (aa) cable (bb) wiring (cc) other equipment, at Harris, of (cc) radiation delivered at a dose rate of (cc-a) under 1 rad per hour (cc-b) 1 rad per hour to 5 rads / hour (cc-c) 5 rads / hour to 20 rads / hour (cc-f) 500 rads / hour to 2000 rads / hour (cc-g) 2000 rads / hour to 10,000 rads / hour (cc-h) 10,000 rads / hour to 50,000 rads / hour (cc-1) 50,000 rads / hour to 200,000 rads / hour (cc-j) 200,000 rads / hour to 1 megarad per hour (cc-k) 1 megarad/ hour to 5 megarads/ hour (cc-1 over 5 megarads per hour?

Please identify all documents containing such information which you know of.

ANSWER:

Applicants have not performed an analysis of the kind requested by the Interrogatory.

Such an analysis would require substantial time and effort.

Applicants' Architect /

Engineer, EBASCO, has an extensive library of documents. con-cerning radiation effects on insulation material at different dose rates and under different environmental conditions.

These documents are located at EBASCO's offices in New York City.

i INTERROGATORY NO. 11-1(b).

Do any of the documents iden-tified in response to the above interrogatory also discuss the effects of (i) heat (ii) pressure (iii) steam (iv) oxygen (v) surface area (vi) nitrogen (vii) particulates (e.g. soot from fires, radioactive particulates) (viii) conduit (ix) cable con-figuration (x) insulator position or configuration (xi) other materials used in conjunction with insulation (xii) insulation stripped from conductors (xiii) mechanical stress (xiv) fire (xv) submergence (xvi) impact of objects (e.g. shrapnel from exploding pump, line break, etc.) (xvii) pipe whip (xviii) vi-bration (xix) seismic forces (xx) explosions (xxi) hydrogen burns or rapid deflagrations (xxii) other factors, in combina-tion with radiation, on the (aa) insulating ability (bb) integ-rity (cc) properties (specify) (dd) resistivity (ee) strength (ff) tensile strength (gg) volume (hh) elasticity (jj) bulk modulus (kk) other characteristics (please specify) of the in-sulation or of polyethylene, polyethylene copolymer (PE co-P),

neoprene, or other insulating material used or to be used at Harris for cable or wiring or other electrical equipment insu-lation?

Please identify what of the above is discussed in each document, and identify all documents not identified in response to the above which discuss any of the above factors or prop-erties under conditions of radiation exposure combined with any of items (i) thru (xxii) above.

ANSWER:

See Answer 11-1(a).

INTERROGATORY NO. 11-1(c).

Please identify any documents or other information which you believe indicates that insula-tion in a conduit (specify.what the conduit is made of) is shielded from, or (ii) not subject to, degradation effects such as those alleged in Eddleman contention 11.

ANSWER:

Insulation in a conduit is assumed to be affected by all gamma radiation existing outside the conduit (i.e., no gamma shielding credit is taken for the conduit).

INTERROGATORY NO. 11-1(d).

Please state the lowest (1) gamma (ii) total, radiation dose rate at which you believe the effects alleged in Eddleman contention 11 (i.e. accelerated degradation of insulation) (aa) cannot occur (bb) will not occur (cc) probably will not occur (dd) might not occur.

Please give all bases for each of your answers and identify any and all documents containing information you believe supports your answer.

l I

ANSWER:

The investigation of cable insulation deteriora-tion in the containment building of the Savannah River Nuclear Reactor, as documented in K. T. Gillen and R.

L. Clough, Inves-tigation of Cable Deterioration in the Containment Building of the Savannah River Nuclear Reactor, NUREG/CR-2877 (August l

1982), showed that there were alternating areas of flexible and brittle cable insulation corresponding to differences in the radiation fields experienced by the cable at those points.

The brittle portions of the cable were exposed to approximately 25 rads /hr., while the relatively undamaged portions were exposed to approximately 13 rads /hr.

This strongly suggests that there i

is a minimum threshold dose rate below which dose-rate effects are not significant.

That dose rate appears to be sotewhere between 13 and 25 rads /hr.

INTERROGATORY NO. 11-1(e).

Please state the highest (i) gamma (ii) total, radiation dose rate at which you believe the accelerated degradation of insulation described (e.g.) in Eddleman 11, NUREG/CR 2763, NUREG/CR 2877, etc. (aa) cannot (bb) does not (cc) probably will not (dd) might not, occur.

Please give all basis for your answer, including identification of all documents containing information you believe supports your answer.

ANSWER:

Gillen and Clough in their tests used dose rates ranging from 1.4 x 10E3 rads /hr. to 1.2 x 10E6 rads /hr.

See K.

T. Gillen and R. L. Clough, Occurrences and Implications of Ra-diation Dose-Rate Effects for Material Aging Studies, NUREG/

l CR-2157 (June 1981); R. L. Clough and K. T. Gillen, Radiation-Thermal Degradation of PE and PVC:

Mechanism of Synergism and Dose-Rate Effects, NUREG/CR-2156 (June 1981).

l !

l l

I k

Conclusions concerning dose-rate effects for dose rates higher than 1.2 x 10E6 rads /hr. cannot be drawn from the Gillen and Clough studies.

INTERROGATORY NO. ll-1(f).

Please state if there is any radiation dose rate or total integrated radiation dose (specify which, and what dose or dose rate) above which insulation (e.g.

polyethylene, neoprene) cannot be degraded or is not degraded in such a way that its function or the safety function of ener-gy or signals insulated by it will not be impaired.

Please state all such doses or dose rates and all bases for your con-clusion that they exist and/or are at the letzel(s) state'd, stating which type (s) of insulation (e.g. polyethylene, PE-co-P, neoprene) each such dose rate applies to, and identi-fying all documents containing informatior, you believe supports each such total dose or dose rate or answer you have made.

ANSWER:

Applicants are not aware of any radiation dose rate or total integrated dose above which insulation does not degrade.

INTERROGATORY NO. 11-1(g).

(S] tate which, if any, total integrated (i) gamma (ii) total, radiation dose rate exists below which degradation of the type alleged in Eddleman 11 and/or described in NUREG/CR 2156, 2157, 2763 and 2877 (specify which one(s)) (aa) does not occur (bb) cannot occur.

Please state all basis for each of your answers, including identifica-tion of all documents containing any information you believe supports your answer (s) or any of them (specify which).

AN5WER:

Applicants do not know what the Interrogatory means by a " total integrated.

radiation dose rate."

The degradation curves shown in Figures 1 through 4 of NUREG/

CR-2157 indicate that, until the materials tested received a total integrated dose of approximately 2 x 10E7 rads, no sig-nificant degradation occurred; and no significant differences in degradation were observed regardless of the dose rates used to reach that total dose.

INTERROGATORY NO. 11-1(h).

Please identify all radiation dose rate levels which you believe (1) exist in normal opera-1 tion of Harris, or would exist in normal operation of Harris, in any zone or area through which insulated cables or wiring or other insulated equipment insulated with polyethylene or PE co-P, pass (ii) exist or would exist during normal shutdowns at Harris in any such area (iii) exist or would exist during refueling or other prolonged outages at Harris in any such area (iv) exist or could exist during any accident (specify the accident) in any such area.

Please also provide (v) maps, drawings or diagrams showing the areas of given radiation dose levels for Harris (vi) all assumptions and calculations, including computer runs and programs and assumptions and input data for each such run (and a listing of the source code for each program so used), used to figure those radiation do'se lev-els, specifying for which zone (s) or area (s) each was used.

Please provide this information for the auxiliary building end all other areas in which cables or wiring insulated with polyethylene, PE co-P or neoprene, or other equipment so insu-lated, could be exposed to radiation.

ANSWER:

Radiation dose maps for all radiation zones at SENPP are contained in FSAR Appendix 3.llB.

The radiation doses given are based on 100% reactor output.

Radiatien dose rates under normal, full-power operating conditions can be cal-culated by dividing the 40-year total integrated dose by the number of hours in 40 years.

Radiation dose rates during de-sign basis accident conditions are similar to the dose rates normally employed during equipment qualification tests.

Be-cause the qualification tests sufficiently simulate accident conditions, accident dose rates are irrelevant to the question of low dose-rate effects.

INTERROGATORY NO. 11-1(j).

Have you, or anyone else, per-formed any analysis of the ability of (i) all (ii) (specify) wiring, cable or other electrical equipment insulated with (aa) polyethylene, (bb) PE co-P (cc) neoprene (dd) other insulation, to perform its safety-related functions and/or to avoid suprious signals or short circuits, under the degradation ef-fects described in (ee) Eddleman contention 11 (ff) NUREG/

CR-2156 (gg) NUREG/CR-2157 (hh) NUREG/CR 2763 (jj) NUREG/CR.

2877 (kk) other studies of radiation effects or synergistic ef-

-facts of conditions including radiation, on such insulation?

Please identify all such studies you (11) possess (mm) know of.

ANSWER:

In the Gillen and Clough tests, the properties measured to detect polymer degradation were mechanical prop-erties - namely, tensile strength and elongation.

Other engi-neering properties of interest, particularly electrical prop-erties like insulation resistance and dielectric strength, were-not measured.

Cable qualification tests have demonstrated that a cable with substantial degradation in mechanical properties of the insulation will still perform its. electrical function.

A more recent Sandia study by Minor and Furgal has indi-cated that degradation of the mechanical properties of cable insulation does not prevent the cable from performing its re-quired electrical function.

See E. E. Minor and'D. T.

Furgal, Equipment Qualification Research Test of Electrical' Cable with Factory Splices and Insulation Rework No. 2, NUREG/CR-2932 (2 vols.) (September 1982).

In the study, cross-linked polyolefin insulated electrical cable was exposed to a relatively low dose rate (6.2 x 10E4 rads /hr.).

Despite degradation of mechanical-properties, the cable was able to perform its electrical func-tion at all times.

This series of tests was conducted.ac-cording to industry standards (IEEE Standards 323-1974 and 383-1974) and NRC guidelines (NUREG-0588).

. Minor'and Furgal.

concluded that the methodology. employed by the nuclear -industry-to qualify electrical-equipment, despite the dose-rate effect on mechanical properties found.by Gillen and Clough,fis adequate.

. - ~

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i INTERROGATORY NO. 11-1(k).

Are you able to analyze all instances in which (i) cable (ii) wiring (iii) other electrical equipment at Harris, might fail under the influence of degrada-i i

tion effects such as are discussed in any of the documents or contention 11 listed in (j) (ee) through (j) (kk) above?

If so i

present and identify any such analysis you have done for equip-ment at Harris which is insulated with (aa) polyethylene (bb) i PE co-P (cc) neoprene (dd) other insulating material.

l ANSWER:

See Answer 11-1(j).

I INTERROGATORY NO. 11-1(1).

Please state all features, procedures, or requirements of your Harris (aa) inspection (bb) maintenance (cc) test program (s) which provides or provide for l

(1) inspection (ii) testing (iii) replacement, of cable or

]

wiring insulation which may have become degraded.

Please specify (dd) how you plan to. inspect insulation inside conduit 3

(ee) how you plan to inspect insulation inside bundled wiring l

or cables (ff) how you plan to inspect multiconductor cables or l

wires (gg) how you plan to test the insulation on wiring or cable inside conduit (hh) how you plan to test insulation in-i.

side bundled wiring or cables (jj) how you plan to test insula-i tion inside multiconductor cables or wires..Please identify all documents relating to each of the above subparts or the matters or items inquired about in each.

i t

j ANSWER:

Applicants are in the process of developing-their surveillance and maintenance program for SHNPP.

In any event, there are no polyethylene-insulated electrical cables in cable.

i raceways at SHNPP which will be exposed to radiation.

See Let-ter from M.A. McDuffie to Harold R. Denton (April 26, 1983),

j;

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s and attachments.

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INTERROGATORY NO. 11-1(m).

Identify each= specific proper-i ty or property you believe is (i) always.(ii) usually (iii) sometimes necessary for wiring or. cable insulation to perform j

its safety function.

Define the safety function.of.(iv) wiring j

(v). cable (vi) other electrical', insulation at Harris.. Specify the level or range of'each property identified in response to.

(1), (ii) or (iii) above'which.is necessary in your opinion fort the insulation to perform its safety function..

State all^ basis-i for each of your~ answers and identify all documents containing i

information<used in your answers or which you believe supports any of.your answers (specify which you believe~it supports).

4 4

e

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ANSWER:

The safety function of electrical cable insula-tion is to enable electrical cable continuously to carry cur-rent and hold a voltage.

The properties of electrical cable insulation necessary for the insulation to perform its safety function include both electrical and mechanical properties.

However, as stated in Answer 11-1(j), cable qualification tests as well as a recent Sandia study have demonstrated that a cable with substantial degradation in mechanical properties wi~11 still perform its electrical function.

INTERROGATORY NO. 11-1(n).

Are there any performance-based acceptance criteria for insulation at Harris to perform its safety function?

If so, specify each such criterion for each application (e.g. ECCS power supply wiring) for which in-sulation is used at Harris.

Identify all documents giving de-scriptions of or basis for or information relating to such acceptance criteria.

ANSWER:

See Answer 11-1(1).

INTERROGATORY NO. ll-1(o).

Are there any other acceptance criteria for insulation to be used in areas at Harris where it can or will be exposed to radiation?

Please identify each such criterion and give all basis for it and state to what insula-tion or what areas or what items it applies.

Identify all documents listing or describing the areas or items where each such acceptance criterion applies, and also identify any docu-ments listing or describing areas or items for which each acceptance criterion identified in response to any part of (1)(m) or (n) above applies or why it applies to that area or item.

ANSWER:

See Answer 11-1(1).

INTERROGATORY NO. 11-1(p).

If not already stated, give the radiation levels in each radiation zone (and a description or drawings locating each such zone) at Harris in full-power

" normal" operation (as you define " normal"), including (i) gamma dose (ii) neutron dose (iii) total radiation dose including alpha, beta, gamma, neutrons, etc.

ANSWER:

See Answer 11-1(h).

INTERROGATORY NO. 11-1(q).

Can neutrons or other radia-tion at Harris create activation products (radioactive atoms) in (i) insulation (ii) conductors (iii) other components of wiring or cables (iv) electrical equipment (v) electrical equipment holders, boxes or cabinets (vi) conduit (vii) air (viii) water (ix) steam, at Harris?

Have radiation doses or dose rates to insulation on (aa) cable (bb) wiring (cc) other electrical equipment due to such activation products, been analysed for (x) Harris (xi) any other nuclear plant you know of?

Identify all documents you know of containing such analy-sis.

Please give all reasons for not doing such analysis if you haven't done it or it hasn't been done.

ANSWER:

Gamma energies during normal full-power operating conditions are too low to create activation products.

INTERROGATORY NO. 11-1(r).

[S] tate the number of hours par year of " normal operation" (an average or typical year will do) in which the level of radiation in each radiation zone at Harris is greater than or equal to (1) 0.001 R/hr (ii) 0.10 R/hr (iii) 0.01 R/hr (iv) 1.0 R/hr (v) 5 R/hr (vi) 10 R/hr (vii) 20 R/hr (viii) 50 R/hr (ix) 100 R/hr (x) 200 R/hr (xi) 500 R/hr (xii) 1000 R/hr (xiii) 2000 R/hr (xiv) 5000 R/hr (xv) 10,000 R/hr (xvi) 20,000 R/hr (xvii) 50,000 R/hr (xix) 100,000 R/hr (xx) 200,000 R/hr (xxi) 500,000 R/hr (xxii) 1 megarad/hr (xxiii) 2 MR/hr (xxiv) 5 MR/hr (xxv) 10 MR/hr (xxvi) 100 MR/hr.

Please also state or give radiation level profile of each radiation zone at Harris showing typical radiation levels, lo-cation of all wiring or cables in that zone, stating what ca-bles or wiring are inconduit (and what the conduit is made of and how thick it is and all its dimensions), the hours per year at each radiation level, and the total integrated radiation dose received by each wire, cable or electrical insulator in the zone for which you have thus far (or ever) computed a total integrated radiation dose.

Also give the radiation dose rate at each wire, cable or other electrical insulator for which you have computed a radiation dose rate.

If this dose rate varies, specify how it varies and what levels you expect it to be at for what fractions of the time, hours per year, etc.

ANSWER:

See Answer 11-1(h).

3 INTERROGATORY NO. 11-1(s).

(S]pecify all " unacceptance criteria" by which degraded cables or wiring at Harris will be removed from service and/or replaced when they meet the

" unacceptance criteria" or any of them.

ANSWER:

See Answer 11-1(1).

INTERROGATORY NO. 11-1(t).

[E]xplain how you will replace wiring or cable with degraded insulation at Harris.

Please discuss in detail the relevance, if any, to this of the cable pulling problems identified by Paul Bemis NRC Region II to the ACRS subcommittee on Harris, Jan.-3 and 4, 1984 at Apex NC.

Please give all details including replacement procedures, acceptance criteria, splicing or connection criteria and/or procedures, and identify all documentt containing information discussed or asked about in each part of this subsection (s).

Please also identify all documents in your possession con-cerning cable pulling problems at Harrin thus far.

Please explain how cable pulling would differ whsn the plant is " hot" (radioactive) or under operating conditions, compared to cobdi-tions under which CP&L has so far tried~ cable pulling at Harris.

Please state all reasons why CP&L has stopped cable pulling at Harris each time you stopped, and state which rea-sons would apply in the event of cable or wiring replacement at Harris.

ANSWER:

See Answer 11-1(1).

INTERROGATORY NO. 11-1(u)'.

PIease identify all studies or documentation or information which you have re wiring, cable or electrical insulation at Harris which accounts for radiation '

dose-rate effects (cf. your ' i'nterrogatory 11'-12 ( a ) ) (i) Please identify all NRC staff " evaluations" of Applicants' program for environmental qualification of electrical equipment with re-spect to radiation dose rate effects on insulation.

(cf. your interrogatory 11-12(b)).

(ii) Please identify any other studies of radiation dose-rate effects on insulation you know -

of that have not been identified in response to above interrog-atories.

ANSWER:

See Answers 11-1(a) and 9-4(a)..

INTERROGATORY NO. 11-2.

Please identify.all ' cables or viring at Harris which you believe (1).is-envir9nmentally qual-ified (ii) must be environmentally qualified, with respect..to radiation dose-rate effects on insulation.

Please_ state what radiation zone each is in.-

Please also state which such ca-bles, wiring, etc. have been' accepted rpocifically,by NRC staff 9.

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1.

J A as environmentally qualified for Harris.

Please identify all documents related to each such qualification, testing, analy-sis, or acceptance, as regards radiation dose-rate effects.

ANSWER:

Electrical cables required to be environmentally 1

qualified are identified on the Master List.

See Answer 9-2(a).

The locations of such cables are shown on project-related drawings which will be made available for inspection and copying.

INTERROGATORY NO. 11-3.

Please identify all electrical equipment at Harris that is exposed to radiation and which is insulated with polyethylene or polyethylene copolymer (specify which).

State which is exposed to low dose rates of radiation.

State which is exposed to any radiation dose rate or total dose (specify) at which you believe dose-rate-related degradation effects can occur.

State and identify all documents in which you make or report all analysis of radiation dose-rate rx ef-facts on the insulation of each such item of electrical equip-J ment.

If you consider this irrelevant to Eddleman 11 please answer it as an interrogatory re Eddleman 9.

a l

ANSWER:

Except for electrical cables (see April 26, 1983 Letter from M. A. McDuffie to Harold R. Denton, and attach-ments), Applicants do not have a list of electrical equipment at SHNPP which identifies the materials contained in electrical i

equipment components.

Although Applicants have some such information, identification of electrical equipment component 3

materials is not required as part of Applicants' equipment qualification program.

The ability of electrical equipment to I

perform its safety function under normal and accident condi-tions is based on test data.

The requested information is in the possession of the component manufacturers.

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i ANSWERS TO INTERROGA'.'ORIES ON EDDLEMAN 41 INTERROGATORY.NO. 41-20.

Please answer the interrogato-rios numbered 184 through 195 (copy attached).which were posed,

to NRC staff re Eddleman 41.

Please consider that "you" means CP&L or Applicants in formulating your answers.

Where an interrogatory asks re NRC/NRC staff only, please answer as if' the question read "NRC, NRC Staff, or CP&L or~ Applicants" in-stead of "NRC Staff" or "NRC".

INTERROGATORY NO. 41-20(184).

Has CP&L completed its 100%

reinspection of pipe hangers.at Harris?

If not, when does CP&L.

/

tell you they expect'to complete it?

i ANSWER:

The100%reinspectionofseismiclpipehangerswas completed prior to the submittal of Applicants' June 11, 1981 Final Report.

INTERROGATORY NO. 41-20(185).

Have you inspected any more pipe hangers at Harris nince you last answered interrogatories?-

If so, which ones, with what results?

i ANSWER:

Yes.

See answer to Interrogatory 41-21.

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INTERROGATORY NO. 41-20(186).

Please identify all docu-ments pertaining to-the matters and inspections inquired about s

in interrogatories 184 and.185 above.

~

ANSWER:

See answers to Interrogatories 41-20(184),

41-20(185) and 41-21.

INTERROGATORY NO. 41-20(187).

Has any (i) welder (ii),

welding inspector, ever been fired or discharged or asked to resign.from Harris because of (aa) making (bb) approving, de-.

factive welds or defective pipe hangers?

If'so, please identi-fy each such person.

ANSWER:.See Applicants' answers ^to.Interros >.ories

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41-1(s) andl(t) dated May 12, 1983 and January la, 1984.

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i INTERROGATORY NO.~41-20(188).

Has any.(i) welder (ii) 2 3

welding inspector"(iii)-other person,'ever been-(aa)tdisci-

?p plined (bb). laid off-(cc) sent'for retraining (dd) required to

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Hbe retrained or to take further training, because ofl-(A)Lmaking.

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(B) approving, defective (iv) welds (v) pipe hangers, at Harris?

If so, please identify each such person.

l ANSWER:

Applicants have been unable to-prepare a response to this interrogatory in the required time, but will submit a supplemental response in the near future.

i INTERROGATORY NO. 41-20(189).

Have you identified any de-fective pipe hangers at Harris which have not yet been re-paired?

If so, which ones?

ANSWER:

Yes.

At any given time there are hangers with f

welds that have been rejected upon initial inspection and are in the process of being repaired.

These are inprocess hangers and are not specifically tracked.

INTERROGATORY NO. 41-20(190).

Have you written any evalu-l ation or recommendations for improvement (or has anyone working for NRC Staff or CP&L done so) for CP&L' Harris QA or QC con-cerning their inspection of pipe hangers (a) ever (b)'since 9/1/1980?

If so, please identify each document containing each such evaluation and/or recommendation.

ANSWER:

See answer to Interrogatory 41-22.

INTERROGATORY NO.. 41-20(191).

Have you contacted any of the valders identified to Wells Eddleman by CP&L in response to :

his interrogatories served in 1983?

If so, please describe the nature of each such contact and the information (a)'you gave to-(b) you received from, each such welder.

Please identify or state any statements, questions, or other things you have com-municated orally or in writing to each such welder, and_all re-sponse(s) you have received to each.

ANSWER:

Daniel has sent a letter to its employees identi-fled in Applicants' March 14,'

1984 response to Interrogatories t

41-1(1) and 41-1(m).

An identical letter was-sent to.each i

employee identified in exhibit B of that-response.- An identi-o cal letter, different from the above, was.sent to each other R

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L employee identified in Exhibit A.

A copy of the two letters will be produced in accordance with Applicants' Response to Wells Eddleman's Request for Production of Documents.

INTERROGATORY NO. 41-20(192).

Please identify all docu-ments concerning reinspection of pipe hangers at Harris which have occurred since June 1, 1983.

ANSWER:

See answer to Interrogatory 41-21 below.

INTERROGATORY NO. 41-20(193).

Please identify all docu-ments concerning defects in pipe hangers at Harris found since 1 June, 1983, which (a) you possess (b) you know someone else possesses (please identify who possesses it, if you know).

ANSWER:

See answer to Interrogatory 41-21 below.

1 INTERROGATORY NO. 41-2O(194).

Has (a) CP&L (b) Daniel In-ternational (c) anyone else including employees of CP&L or Daniel, who worked at the Harris site, ever (i) made any false statement to NRC concerning pipe hangers at Harris (ii) made any statement to NRC concerning pipe hangers at' Harris, which was later shown to be false (iii) made any statement to NRC concerning the pipe hangers or any pipe hanger at Harris, which

+

was later shown to be inaccurate, misleading or incorrect?

I Please give all details and identify all documents concerning each such statement.

i ANSWER:

To the best of Applicants' knowledge, no such statements have been made to the NRC Staff.

INTERROGATORY NO. 41-20(195).

How serious do you believe-

"OK" tagging of defective pipe hangers is (a) as a breach of faith with NRC (b) as a violation of'NRC regulations (c) as a threat to safety of the Harris plant?

Please give'all' reasons-for each of your answers.

ANSWER:

Not applicable.

Applicants do not perform "OK" status tagging of pipe hangers.

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l INTERROGATORY NO. 41-21.

Please provide access to all weld inspection reports completed since May 1, 1983, for Harris.

ANSWER:

The specific dates of weld inspections are recorded in the seismic weld data reports (SWDR), although they are not tracked in a format that makes this information easily retrievable.

To give a totally accurate answer would be bur-densome since it would involve reviewing approximately 18,000 hanger packages.

Approximately 2100 weld inspections performed since 5/1/83 can be readily identified however, and a 10% sam-ple of these will be produced.

INTERROGATORY NO. 41-22.

Please identify each change or improvement to Applicants' QA/QC program at Harris which has been made (1) wholly (ii) partly in response to problems with pipe hanger inspection.

Please identify all documents re-questing or approving or describing each such change.

ANSWER:

Since the initial problem of pipe hanger weld in-spections was identified on September 3, 1980, there have been many changes to the pipe hanger inspection program.

Documents filed with the NRC for Interim Report Number 2 for our October 3, 1983 submittal on items 96 and 72, Interim Report No. 3 for our March 21, 1984 submittal on items 95 and 72, and the June 11, 1981 Final Report all identify improvements made.

Also, work procedure WP-110 and WP-139 describe the present construc-tion program.

QC instruction QCI-19.3 describes the present weld inspection documentation program.

Additional background information on changes to these programs ~are contained in CP&L memoranda dated September 23, 1983 and December 15, 1983..

The above-referenced documents will be produced in accor-dance with Applicants' Response to Wells Eddleman's Request for Production of Documents, with the exception of the 1981 Final Report, which was previously provided to Mr. Eddleman.

INTERROGATORY NO. 41-23.

Please state all reasons for each other change in Applicants' QA/QC program at Harris as it

~

relates to pipe hangers.

j ANSWER:

See documents referenced in the answer to Inter-rogatory 41-22.

d INTERROGATORY NO. 41-24.

Please identify all persons who are involved in the 100% reinspection of pipe hangers at Harris.

State the qualifications of each to (a) reinspect pipe hangers (b) perform any other work she or he performs in this reinspection.

4 ANSWER:

Persons who have inspected Seismic Category I pipe hanger welds are identified in Exhibit 1 to Applicants' May 12, 1983 Responses to Interrogatories on Contention 41 and in Exhibit I hereto.

INTERROGATORY NO. 41-25.

How many defects in pipe hangers have been identified so far'at Harris?

Of these, how many re-main unrepaired?

When do you-anticipate that'the last pipe hanger needing repair to make it fully acceptable, will be re-paired?.

ANSWER:

Weld discontinuities are_ identified and repaired in process, _and are not catalogued as a unique item.

Response

Safe Shutdown Analysis 7/22/83 4

i NRC Safety-Review

-280.1,11,30 8/12/83 Question Responses NRC Acceptance Review 280.24;18,30,9,3 8/12/83 Question ~ Responses NRC Safety Review

-280.16,21,31

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Question Responses' 8/31/83- ;

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Safe Shutdown Analysis 280.1 (Rev 1) 10/14/83 Revision 1 and NRC Safety Review Question

Response

Safe Shutdown Analysis 280.1 (Rev 2) 2/24/84 Revision 2 and NRC Safety Review Question Responses NRC Safety Review Question 280.13,14,15,17, 7/11/83 Responses 18,22,23 j

(b) Refer to the NRC's SER related to the operation of the Harris Plant NUREG-1038, Section 9.5.1, for the identification of open. items regarding fire protection.

(c) The applicable fire protection. codes, standards and a

guidelines are identified in FSAR Section 9.5.1.2.1 and Appli-

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cants' response to NRC Safety Review-Question 280.1.

1

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(d) SNHPP follows NRC regulatory requirements, i.e, BTP CHEB 9.5.1 " Guidelines for Fire Protection for Nuclear-Power Plants", with certain differences-which are outlined in the re-sponses to the 280.1 Safety Review Question.

INTERROGATORY NO. 116-2(a).

Under what conditions can (i) control (ii) power, fail to any (aa)-firefighting (bb) safety-(cc) fire suppression, equipment at Harris?

Please give all reasons for your answer (s)-in detail and identify.all documents relating to such failures or their possibility, probability, J

improbability, etc. at Harris.

4 (b).

What is~the last FSAR-amend-ment that affected section 9.5.1.1.?

~

(c).

What'other amendments have changed'section 9.5.1.1.1?

(d).

.What analysis, test or other information'is used to support the ratings of each fire barrier J

at Harris?

Please provide copies of all such analysis,-test (s) or information that is not in the FSAR at present.

Please 4

state where in the FSAR such information is found.

Please a

provide copies of the actual test results, and copies of the test procedures, for each fire barrier tested for Harris.

j (e).

Please provide copies of all actual test results re " fire resistant" or " fire resistive" ma-terials used at Harris.

Please also provide copies of all test procedures actually used in each such test.

Please identify each material and the test (s) applied to it.

(f).

If any analysis of fire re-sistance of any material used at Harris was made, provide all ~

workpapers and documents underlying each such analysis, stating what material the analysis is for and where in the Harris plant such material is used.

(g).

(cf your interrogatory 116-5(f)) Please identify and make available all information underlying or supporting each belief CP&L has that in any fire area (s) at Harris, it is "not feasible to use such fire barri-ers or other means of separation of safety related cable."

(h).

Please identify all tests of flame spread (i) in (ii) between cables of the type (s) used in any of the areas referred to in your interrogatory 116-5(f),

and all other tests involving fires in such cables, that have been done to your knowledge.

Please identify all documents re-ferring to such tests or giving the methods or result (s) of any such test (s).

ANSWER:

(a) The SHNPP fire protection system as discussed.

in FSAR 65 9.5.1 and 9.5A and the safe shutdown analysis is de-signed such that in case of a fire in any area of the plant, the plant can be safely shut down.

The fire protection system itself, with the exception of containment boundary penetra-tions, is a nonsafety system as designated by the NRC.

Con-tainment penetrations comply with all applicable regulations delineated in FSAR Sections 3.8 and 6.2.

(b) The last FSAR amendment that affected Section 9.5.1.1.1 is Amendment No. 2 which made changes to table 9.5.1-1. -

(c) No other FSAR amendments have affected Section 9.5.1.1.1.

l (d) The analysis and or test which is used to support the ratings of each fire barrier at. Harris are based on standard fire tests made in accordance with " Standard Methods of Fire Tests of Building Construction and Material" ASTM E-119, and NFPA 251, and IEEE-634 as modified by Appendix A-14 of the Nu-clear Mutual Limited Guidelines (NML).

Copies of ASTM E-119, NFPA 251, IEEE-634 and the NML Guidelines.will be available at CP&L's offices for your review along with copies of any actual test results regarding fire barriers which CP&L currently has a

in its possession.

(e) The Manufacturer supplies the appropriate fire resis-tant material:and guarantees its rating.according to tests which he has performed in accordance with procedures either-written by him or in accordance with national standards such as i

NFPA or ASTM. -CP&L does not perform these tests or write the procedures.

(f) See response to (e) above.

(g) CP&L's justification for its belief in the Safe. Shut-doJn Analysis that it is not feasible to use such fire barriers or other means of separation is described in.its Safe Shutdown Analysis and exemption request submitted in Table 9.5B-3 dated 10/14/83 and 2/24/84.

(h).All Class IE cables at SHNPP haveLbeen qualified inL accordance.with IEEE Standard l383-1974. -It1should be noted,

that CP&L provides specifications.for Class IE cables to the manufacturer / supplier.

Based on these specifications the manu-facturer/ supplier provides an acceptable cable.

SNHPP's speci-fications for all Class IE cables are as follows:

i CAR-SH-E14A,B,C, and D CAR-SH-E15A,B and C.

INTERROGATORY NO. 116-2(a)[2].

define " maximum credible fire" as you use the term (i) in your Harris fire analyses (ii) in your interrogatory 116-7.

(b).

explain exactly how the " max-imum credible fire" for each fire area at Harris was "postu-lated".

(c).

what consideration of combus-tible materials was made in postulating each such " maximum credible fire".

(d).

what consideration have you made of simultaneous-fires at Harris and/or your-ability to fight them.

Please identify all documents concerning simulta-neous fires at Harris, stating on what page(s) or in which sec-tion (s) they deal with simultaneous fires.

ANSWER:

(a) Maximum credible fire as used by CP&L' defines the postulated fire in a particular fire area.

The fire is postulated for various fire areas of the plant as described in FSAR Section 9.5.1.3.

(b) The postulated fire for each fire area is described in-the Fire Hazard Analysis (FSAR Section 9.5A) and is based on identified in-situ combustibles plus transient combustibles.

(c) See. response to (b) above.

The maximum credible fire was based on the project design and operational considerations.

Conservative estimates were used to assure the Fire Hazard

, ~-

i Analysis is always bounded.

Note that the Fire Hazard Analysis is a "living document" (i.e., one which is regularly reviewed and/or updated) to assure its continued validity.

(d) SHNPP follows BTP CHEB 9.5.1 " Guidelines for Fire Pro-tection for Nuclear Power Plants", which does not require the consideration of simultaneous fires.

d INTERROGATORY NO. 116-3 ( a )'.

Do you believe Harris 1 is required to (i) have (ii) maintain safe shutdown capabil'ity in the event of a fire?

(b) is this requirement waived in any way by any NRC rule or regulation during a nuclear accident?

Please provide all bases for your answers.

ANSWER:

(a) Yes, as stated in SRP 9.5.1, BTP CHEM 9.5.1 and the Safe Shutdown Analysis.

(b) Yes, as stated in the Safe Shutdown Analysis.

INTERROGATORY NO. 116-4(a).

When do you expect to-finish providing NRC Staff with the additional information it has re-quested concerning fire hazard analyses?

(b) When do you ex-pect to be able to test the fire control system at Harris?

(c)

Please identify all startup test procedures for fire control and/or fire detection at Harris.

Please identify all documents containing such procedures and/or schedules for each or any or all of them.

- ANSWEP.:

(a) At this time there remain three fire protec-tion issues as to which the NRC Staff has requested additional _

_information from CP&L:

(1) fire door qualification; (2)' safe shutdown analysis; and-(3) alternate shutdown analysis.

CP&L currently plans to provide the information to NRC within three-weeks on fire door qualification-and by August 15, 1983 on the remaining two items.

The Fire Hazard Analysis will be updated; continuously since it'will reflect the "as built" conditions of SHNPP..__

(b) System testing began 1 year ago and will continue with full integrated testing to be performed prior to fuel load at Harris.

(c) Methodology, instruction, guidance and procedural information related to fire control and fire detection at Harris _is contained within the SHNPP startup manual'which is locaed at the Harris site.

The SENPP initial test program is based on the requirements of 10 CFR 50.34, Section XI of 10 CFR 2

50, Appendix B, and the NRC Reg. Guide 1.68 specific informa-

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tion is contained within the Applicant's FSAR Section 14.2.

I ANSWERS TO INTERROGATORIES ON EDDLEMAN 132(C)(II) i INTERROGATORY No. 132-c-2-2O(a).

What analysis, if any, i

have you made of the number of operators who can or should be present in the Harris control room during nuclear accidents, and what task (s) each will.have to perform? -(b) What informa-tion must be identified from each panel numbered 1 thru 15 in.

}

each accident sequence you have. analyzed for human factors and adequate procedures at Harris.

(c) Please. identify all docu-ments in which information inquired about in (a) or (b) above l

can be found.

Please state where-it is in each such document, for which information, if-you know.

i ANSWER:

CP&L has provided information related to this interrogatory on at least two previous occasions:

i (1)

M. A. McDuffie to H. R. Denton-letter dated September 27, 1983 SER: LAP-83-426 (a copy of which.has been provided to Mr. Eddleman)

(2)

ACRS Presentations in January,'1984_

As stated in Attachments 2'and 3 to the above letter (in part):

-56 :

~

A Task Analysis has been performed on the High-Pressure (HP) Basic version of the Westinghouse Owners' Group (WOG). Emergency Response Guidelines (ERGS) by a working group under the purview of the WOG Proce-dure Subcommittee.

The generic Task Analysis utilized a top-down approach that identifies the j

guidelines (i.e.,

event sequences), plant systems utilized in responding to event se-quences, operator functions and operator tasks performed in responding to event se-quences, and detailed elements that com-prise the operator tasks.

As a minimum, CP&L intends to identify the deviations from the generic ERGS for the SHNPP-Unit 1 EOPs, task analyze those-differences and generate plant specific lists of instruments and Controls necessary to perform the EOPs in the SHNPP-Unit 1 control room.

Additionally, CP&L will review the ge-neric Task Analysis along with the ERGS de-viations analysis, thus insuring review of-each step of the SHNPP-Unit 1 EOPs.

We be-lieve that no major discrepancies will be identified because of our extensive func-tional analysis performed during the SHNPP-Unit 1 MCB redesign process and be-cause of the task analysis performed cn1 the-y event-based procedures during the Control I

Room Design Review The basic version of the WOG ERGS have undergone one week of simulator verifica-tion and validation testing.

Carol.ina Power & Light Company has been deeply involved in the development of?

the ERGS since their inception through par-ticipation in both the full-Owners' Group and the Procedures Subcommittee.

H The above information was-summarized again during the ACRS pre-sentation, with the additional statement that ".

modified H. B. Robinson EOPs have been walked through on (the]-new U ;

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[Shearon Harris] control board arrangement."

ACRS Subcommittee Meeting, January 3, 1984, at 172.

INTERROGATORY NO. 132-c-2-21(a).

Please provide actual locations of all dials, readouts, indicators or lights on each panel numbered 1,2,3,...through 15 in the Harris control room, stating what information or thing each indicates.

(Cf your interrogatory 6(b) on this contention).

ANSWER:

Front view drawings are identified in the docu-ment list attached to Applicants' Response to Wells Eddleman's Request for Production of Documents and will be made available for review by Mr. Eddleman pursuant to the Response.

INTERROGATORY No. 132-c-2-22(a).

What signal density analyses have been made for Harris other than those " reported" in the DCRDR.

(b) What studies or experience with lighting in nuclear plant control rooms under emergency conditions are you aware of?

(d) what studies of depth perception of Harris plant operators (i) have been made (ii) will be required?

(c) What are the acceptance criteria for (i) near vision (ii) far vision (iii) depth perception (iv) field discrimination, for Harris operators?

ANSWER:

(a).

None.

(b).

NUREG-0700 addresses lighting levels.

The Illumina-tion Engineering Society Handbook provided guidance during the Essex Corporation evaluation.

CP&L has used experience gained at the Robinson and North Anna Plants, and the Skaales Energy Control Center in conjunction with interfaces with K. B.

Stephens, Co. and CFB Associates (lighting manufacturers repre-sentatives) to upgrade our 1972 design to a state-of-the-art Lithonia anti-glare system in March 1983.

-(c)-(d).

Applicants' criteria for acceptance for vision L

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is based upon the doctors' recommendation for work l i

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acceptability.

The physical examination which must be given to every prospective _ operator requires documentation by the examining physician of any physical restriction for work.

A decision is then made by Applicants as to the prospective employee's ability to perform in the position for which he or she is being considered.

That decision is made based upon dis-cussions with the physician and supervision ac to the prospec-tive operator's ability to perform the required duties.

INTERROGATORY NO. 132-c-2-23(a).

What is your understand-ing of how GDC 1 applies to the Harris control room?

Specifi-cally, also state what role GDC 1 played in your Harris DCRDR.

(b) What is your understanding of how GDC 19 applies to the Harris control room?

(c) What role did GDC 19 play in your Harris DCRDR?

(d) Did you misidentify interrogatory 132-c-II-6 in your interrogatory no. 14 on 132-c-2, or are there two 132-c-II-6's.

ANSWER:

(a)-(c).

Applicants' commitment to GDC 1 (Quali-ty Standards & Records) and GDC 19 (Control Room) is listed in FSAR S 3.1.

It should be noted that the previous control board / control room arrangement was not contrary to the GDC or good engineering practices.

At the time'it was developed, it was based on several years of previous CP&L, Westinghouse,.

Ebasco, and industry human factors experience to date.

As with any technical field, experience is gained and enhancements-are made.

CP&L considers'the'new-control board / control room-layout an operator and man-machine. interface enhancement.

It preceded the requirements of NUREG 0700)and.0737, but meets the intent of both. ! The. previous arrangement, however, chad served the Company well and was not considered ~ inadequate.

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(d).

In Wells Eddleman's Response to Applicant's Inter-rogatories Concerning Contentions 9, 11 and 132C(2), dated March 7, 1984, on page 19, in response to Interrogatory 132(C)(II), you state "When I am able, I will dig out what I have on this Interrogatory 132(II)-14 asks for the dates as to when you will do this..There has been no misidentification of interrogatories.

1 INTERROGATORY NO. 132-c-2-24(223].

Do you possess read-able documents or drawings which show what instrumentation is on the front of control room panels 1, 2, 3, 4,

5, 6,

7, 8, 9,

10, 11, 12, 13, 14, and/or 15 at Harris?

If so, will you pro-vide copies of same?

1 ANSWER:

See Answer 132-C-2-21.

INTERROGATORY NO. 132-c-2-25(224].

Has the Staff complet-ed its DCRDR for Harris l?

If not, when do you expect to com-plete it?

Please identify all documents and work papers you have so far generated in this review.

ANSWER:

The Staff's DCRDR was conducted on August 15-19, 1983.

CP&L provided follow-up information in a-letter (LAP-83-426) from M. A. McDuffie to H. Denton, dated 9/27/83.

I Mr. Eddleman was on the distribution-list and should have're-ceived a copy of this letter.

As of this date, no Technical EvaluationLReport (TER) has been received from the NRC or j

Lawrence Livermore National Labs (LLNL), consultants to NRC..

' INTERROGATORY NO. 132-c-2-26(225].

Has the Staff analyzed

..tte uses-that must be made during any (or all). credible. Harris accidents, of the information appearing on any-panel listed in-Eddleman contention 132(c)(2)?.If so,~. which accidents, and which information on which panels?

Please-identify all'docu -

ments.concerning each such analysis.

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ANSWER:

See Answer to 132-C-2-20.

INTERROGATORY NO. 132-c-2-27(226].

Has the Staff any opinion concerning the qualifications of the people who did the DCRDR for CP&L (the " human factors experts")?

Does your opin-ion of the adequacy of these persons' qualifications incorpo-rate the views of the Licensing Board in Byron (1984)?

Please state your view of the adequacy of these persons' qualifica-tions if you have one.

ANSWER:

Essex Corporation has done considerable human factors work for industry and has been previously under con-tract to the NRC.

The Byron situation involved only procedural fixes, not hardware modifications as at the Harris Plant.

Qualifications of personnel involved on the Harris project were included in the Essex report and were resubmitted as the result of a specific question at the ACRS subcommittee meeting in January 1984.

INTERROGATORY NO. 132-c-2-28[227].

What HEDs and HERSs for Harris has the Staff reviewed?

Please identify all docu-ments giving the results of your review of each.

ANSWER:

The staff reviewed all uncorrected HEDs (Human Engineering Discrepancies).

They sampled the corrected HEDs.

HER (Human Engineering Requirements Specifications) were not reviewed by the NRC, nor were they intended to be.

They are only for internal CP&L use as centrols for-future design and construction.

INTERROGATORY NO. 132-c-2-29(228].

What information needed by operators in accidents at Harris, which appears on any of the panels contention 132(c)(2) says cannot be se < from each other (or by persons standing near each, whose view may be blocked by other panels), can be seen from a distance of (a) 5 feet (b) 10 feet (c) more than 10 feet (d) more than 2 feet, with sufficient reliability for accurate interpretation and reading under high stress conditions such as would prevail in an accident, in your opinion?

ANSWER:

See Answer 132-C-2-20.

INTERROGATORY NO. 132-c-2-30[229].

Has the Staff made any review of the visual blockages possible in the Harris control room layout?

If so, what documents contain the results or your review?

Please identify all work papers used in your review.

ANSWER:

The Essex study, referred to above, addressed the information requested.

INTERROGATORY NO. 132-c-2-31[230].

Does the Staff believe CP&L was (a) right (b) responsible, when it set into concrete in the Harris 1 control room floor the positions of the cabi-nets recommended by its DCRDR consultants, prior to Staff completing its control room design review for Harris 1?

Please give all reasons for your answer.and identify all documents information from which was used to make or support your answer.

ANSWER:

CP&L acted very responsibly during the Essex study.

Construction concrete work in the floor was stopped until the study was complete.

Design drawings were revised and recommended changes were implemented.

This entire process pre-ceded the issuance of NUREG 0700 and 0737 which provided formal t

. i

T guidance.

CP&L initiated this work on its own.

The NRC Stafft has n'ever given any indications to the contrary.

~

Respectfully submitted, FRAY h. bh Thomas A.

Baxter, P.C.

Michael A.

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

Washington, D.C.

20030 (202) 822-1000 x

Richard E. Jones Samantha Francis Flynn

,N H. Hill-Carrow.

CAROLINA ?OWER & LIGHT COMPANY

'n Post Office Box 1551 k

Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Appl'icants

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PETER'MAURICE YANDOW Senior Engineer BIRTH DATE:

December 7, 1951 1.

EDUCATION A.

Bellows Free Academy, Fairfax, Vermont - 1969 B.

B.S.E.E.,

Northeastern University, Boston, MA - 1974 11.

EXPERIENCE A.

June 1974 to December 1974 1.

Stone and Webster Engineering Corporation, Boston, MA.

a.

Employed as a Career Development Engineer B.

January 1975 to April 1978 1.

Combustion Engineering, Incorporated, Boston, MA.

a.

Employed as a Cognizant Engineer for Protection System for five operation nuclear power plants.

Duties included maintenance of operating systems, detection and solution of design problems and the procurement of spare and replacement items.

C.

April 1978 to May 1983 1.

Yankee Atomic Electric Company, Framingham, MA.

a.

Employed as a Senior Engineer.

Duties include follow-up work on all major instrumentation systems at three operating nuclear plants and one presently being built.

D.

May 9, 1983 1.

Carolina Power and Light Company a.

Employed as a Senior Engineer in the Electrical Unit, Harris Plant Engineering Section, Nuclear Plant Engineering Department, located at New Hill, NC.

m RICHARD M. BUCCI N'.: lear Services Section Leader

/

Corporate and Consulting Electrical Engineering Equipment Qualification Program Manager EXPERIENCE

SUMMARY

Registered Professional Engineer with over ten years experience in electrical and related power engineering for fossil and nuclear power plants, including five years experience in Technical Super-vision of engineering and design teams for nuclear power plants.

Responsible for managing nuclear consulting services (electrical),

development of corporate programs, guidance and positions on nuclear plant electrical systems, equipment qualification and computer aided design (CAD) programs.

Technical responsibilities have incl ded developing, implementing and consulting on system and physical design criteria;' preparation and review of electrical one-line diagrams, physical drawings and specifications; review /analysisjof equipment qualification; economic and technical equipment evaluations; monitoring vendor information, specification conformance and delivery; engineering support of plant construction, start-up and operations; preparation of electricl and equipment qualiification sections of PSAR, FSAR and responses to NRC.

Developed and applied computer-aided methods for electrical auxiliary system studies, cable and raceway ~ system design monitoring system start-up packages, analyses of plant, j

design for conformance with safety requirements, preparation /

l maintenance of equipment qualification documentation and electrical j

design / graphics.

t Administrative responsibilities included planning and implementin '

~

corporate engineering program's, project implementation of QA' and Equipment Qualification Programs, development of schedule and budget, manpower forecasts and performance evaluations, job control by monitoring / reporting on accomplishments, schedule and workdays, training and development of' design engineers, and management of multidiscipline corporate equipment qualification program efforts and electrical consulting projects.

~

REPRESENTATIVE EXPERIENCE Client Project / Station Type Position J

Ebasco Corpor' ate

' Nuclear. Services, Section.

and Consulting Development / Consulting Nuclear Leaderd Engineering Dept.

Electrical f

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Ebasco Corporate Corporate Equipment

. Progrmr.

I and Consulting Qualification. Pro-Nuclear Manager-Engineering Dept.

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Ebasco Corporate CAD Development Electrical and Consulting Program Section Engineering Dept.

Leader Carolina Power Shearon Harris Nuclear Lead Elec-

& Light Co.

Units 1 & 2 trical Engineer Florida Power &

St. Lucie Units Nuclear Electrical Light Co.

1& 2 Consultant

.c 4

New York Power Indian Point Nuclear Electrical Authority Unit 3 Consultant 4

i Houston Lighting Allens Creek Nuclear Electrical

& Power Co.

Units 1 & 2 Engineer Houston Lighting Cedar Bayou Fuel Oil Electrical

& Power Co.

Oil Conversion Engineer Houston Lighting PH Robinson Fuel Oil Electrical

& Power Co.

Oil Engineer EMPLOYMENT HISTORY Ebasco Services Incorporated, New York, N.Y.:

1974-Present Principal Engineer, 1982-Present Senior Engineer, 1980-1982 Engineer, 1978-1979 Associate Engineer, 1976-1977 Assistant Engineer, 1974-1975 University of Illinois, School of Engineering, Urbana, Illinois, 1972-1974 Research Assistant, Computer Applications Litcom Division, Litton Industries, Melville, N.Y.

1972 Junior Test Engineer, 1972-EDUCATION Pratt Institute - BEE - 1972 University of Illinois-Graduate Study in Electrical Engineering, 1972-1973 REGISTRATIONS Professional Engineer - New York i

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i PROFESSIONAL AFFILIATIONS IEE - Member:

Power Engineering Society, Computer Society American Nuclear Society - Member:

Power Division, Nuclear Reactor Safety Division Tau Beta Pi Engineering Honor Society Eta Kappa Nu Electrical Engineering Honor Society PUBLICATIONS

Author, Developing and Maintaining Equipment Qualification Programs:

A Computer-Aided Approach"', TRANSACTIONS of the 1983 ANS Winter Meeting.

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m.

Alexander G. Fuller Principal Engineer - Mechanical I.

Date of Birth - October 14, 1951' II.

Education A.

BS Degree in Civil Engineering from N. C. State University, 1973.

III.

Experience A.

Summer, 1970 1.

Carolina Builders a.

Salesman.

B.

Summers, 1971 and 1972 1.

N. C. State Highway Commission ti a.

Engineering Assistant.

C.

May 28, 1973, to Present t.7 1.

Carolina Power & Light Company

[.

May.8, 1973 - Employed as Junior Engineer in the Construction 2

a.

Section of the Power Plant Engineering & Construction Depart-ment. Located at the Harris site, New Hill, N. C.

7;.'

b.

September 1, 1973 - Transferred from Power Plant Engineering &

Construction Department to Power Plant Construction Department,

.)

Nuclear Construction Section. Located at the Harris site,

-4 j New Hill, N. C.

c.

August 17, 1974 - Transferred from the Nuclear Construction Section to the Fossil Construction Section. Assigned to Cape Fear Plant working out of General Office.

d.

January 18, 1975 - Promoted to Civil Engineer.in the Fossil Construction Section of the Power Plant Construction Depart-ment. Assigned to Cape Fear Plant working out of General.

Office.

e.

September 27, 1975 - Transferred from Fossil Construction Section to Nuclear Construction Section. Located at the Harris site, New Hill, N. C.

f.

September 27, 1975 - Reclassified as Engineer II in the Nuclear Construction Section of the Power Plant Construction Department.

Located at the Harris site, New Hill, N. C.

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g.

August 16, 1976 - Transferred from Harris site to Cape Fear Plant as Engineer in the Nuclear Construction Section of the Power Plant Construction Department. Assigned to supervise contractor accomplishment of drainge modifica-tions at the Cape Fear Plant.

h.

April 2, 1977 - Transferred from Cape Fear Plant to Harris site as Engineer in the Nuclear Construction Section of the Power Plant Construction Department. Resumed duties as civil engineer in the Resident Engineer subunit.

i. March 25, 1978 - Promoted to Senior Engineer in the Nuclear Construction Section of the Power Plant Construction Depart-ment.

Located at the Harris site, New Hill, N. C.

j.

July 1, 1978 - Transferred to the Miscellaneous Projects Unit in the Nuclear Construction Section of the Power Plant Con-struction Department.

Located at the Harris site, New Hill, N. C.

t-k.

Novedbar.15,1980 - Promoted to Project Engineer - Civil in the Miscellaneous Projects Unit, Nuclear Construction Section, q

"~

Power Plant Construction Department.

Located at the Harris site, New Hill, N. C.

l.

1.

January 31, 1981 - Transferre'd to the Outlying Structures Unit b

in the Harris Site Management Section of the Nuclear Plant Construction Department. Lo,cated at the Harris. site, New Hill, N. C.

m.

June 27, 1981 - Reclassified as Project Engineer-Mechanical in the Harris Site Management Section of the Nuclear Plant 1-Construction Department. Located at. the Harris site, New Hill,. [

N. C.

~

n.. October 30, 1982 - Promoted to Principal Engineer-Mechanical ~

in the Harris Site Management Section of' the Nuclear Plant 1

Construction Department. Located.at the Harris site, New Hill, N. C.

IV.

Professional Societies:

A.

Professional Engineer Registered in North Carolina - July 7, 1978 12 a:.

.~

i sRevised 9/16/82

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ATTACHtIENT D Roland M. Persons Project General Manager I.

Date of Birth: March 13, 1936 II.

Education:

A.

BS Degree in Civil Engineering from Fresno State College, 1959 III.

Experience:

A.

August, 1964 to November, 1966 1.

U. S. Forest Service, Nevada City, California a.' Forest service representative on hydroelectric developments built on forest service land by others.

B.

November, 1966 to September, 1973 1.

Ebasco Services, Inc., Hartsville, South Carolina; and Jensen Beach, Florida a.

November, 1956 - Field Engineer on construction of H. B.

Robinson Unit No. 2 (700 MW Westinghouse PWR nuclear power plant).

b.

November, 1967 - Resident Engineer responsible for site engineering and quality control for construction of H. B.

' Robinson Unit 2.

c.

April,1971 - Senior Resident Engineer responsible for all site engineering for construction of St. Lucie Unit No. 1 4

(810 MW combustion engineering PWR nuclear power plant).

C.

September, 1973 to May, 1974 1.

Daniel Construction, Jenkinsville, South Carolina a.

Site Manager of Engineering responsible for all site engi-nearing for construction of V. C. Summer Nuclear Power Plant.

1 D.

June, 1974 to September, 1976 1.

Ebasco Services, Elma, Washington a.

Senior Resident Engineer responsible for all site engineering on 1300 MW PWR nuclear power plant.

E.

September 20, 1976 to Present 1.

Carolina Power & Light Company a.

September 20, 1976 - Employed as Site Manager in the Nuclear l

Construction Section of the Power Plant Construction Depart-ment.

Located at the Harris site, New Hill, N. C.

Rolcnd M. Pars:na -

b.

April 27, 1979 - Reclassified as Site Manager (Harris) in the Harris Site Management Section of the Power Plant Construction Department.

Located at the Harris site, New Hill, N. C.

c.

May 3, 1980 - Reclassified as Site Manager - Harris Plant Construction in the Harris Site Management Section of the Power Plant Construction Department.

Located at the Harris site, New Hill, N. C.

d.

January 31, 1981 - Reorganization - Site Manager - Harris Plant in the Harris Site Management Section of the Nuclear Plant Construction Department.

Located at the Harris site, New Hill, N. C.

e.

March 22, 1982 - Title changed to Project General Manager, f.

September 3, 1983 - Reorganization - Project General Manager -

Nuclear Generation Group Harris Nuclear Project Department, Harris Plant Construction Section.

Located at the Harris site, New Hill, N. C.

IV.

Societies, Memberships and Publications:

A.

American Society of Civil Engineers B.

Registered Professional Engineer in North Carolina - No. 7634 C.

Registered Professional Engineer in South Carolina - No. 3422 D.

Registered Professional Engineer in California - No. 16379 E.

Registered Professional Engineer in Washington - No. 15111 F.

Registered Professional Engineer in Florida - No. 16700 i

G.

Publication:

System For Control of Construction Quality; Proceedings of The American Society of Civil Engineers, Journal of The Construction Division' March.-1972.

H.

Publication:

System for Material Movement to Work Areas; Journal of The Construction Division, March, 1980.

I.

Publication:

Is Total CPM Really the Answer for Super Projects; Civil Engineering Magazine, November,-1983.

Rev. 12/21/83

I Victor M. Safarian Project QA/QC Specialist I.

Date of Birth July 9, 1946 II.

Education and Training A.

High school graduate, Page High School, Greensboro, North Carolina, 1964.

B.

U. S. Air Force Medical Technician School, 12 months C.

Other Training Courses:

1.

Eastman Kodak Company's School of Industrial Radiography, Rochester, New York 2.

Magnaflux Corporation School for Magnetic Particle, Fluorescent Penetrant and Visual Penetrant Inspections.

Chicago, Illinois III.

Experience A.

U. S. Air Force 1.

1964 - 1968 Medical Technician / Operating Room Specialist a.

B.

Bexar County Ambulance Service, San Antonio, Texas 1.

April 1968 - February 1969 a.

Driver and Attendant C.

Alladin Company, Ltd., Greensboro, North Carolina 1.

February 1969 - July 1969 a.

Salesman D.

Pittsburgh Testing Laboratory, Greensboro, North Carolina 1.

July 1969 - November 1975 i

a.

NDE Inspector E.

Daniel International

)

4 l'

' November 1975 - March 1976 (Fabrication Services Corporation,_

Albany, Georgia) a.

NDE Piping Inspector o

2.

March 1976 - April 1978 (Callaway Nuclear Plant, Fulton, Missouri) a.

Project Level II NDE Inspector F.

Carolina Power & Light Company 1.

April 1978 employed as a QA Specialist in the Engineering

& Construction QA Section of the Technical Services Department.

Located at the Harris site, New Hill, North Carolina.

a.

April 1980 promoted as a Senior QA Specialist in the Engineering & Construction QA Section of the Technical ^

Services Department.

Located at the Harris site, New Hill, North Carolina.

b.

March 1981 transferred and reclassified as a Senior QA/QC Specialist in the Engineering & Construction QA/QC Section of the Corporate Quality Assurance Department.

Located at the Harris site, New Hill, North Carolina, March 1981 promoted and transferred as a Project QA/QC c.

Specialist in the Engineering & Construction QA/QC Section of the Corporate Quality Assurance Department.

Located at the Mayo Plant, Roxboro, North Carolina.

d.

October 1982 transferred as a Project QA/QC Specialist in the Engineering & Constru'ction QA/QC Section of the Corporate Quality Assurance Department.

Located at the Harris site, New Hill, North Carolina.

February 1983 - SECTION TITLE CHANGE - Project QA/QC e.

Specialist in the QA/QC Harris Plant Unit of the QA/QC Harris Plant Section of the Corporate Quality Assurance Department.

Located at the Harris site, New Hill, North Carolina.

IV.

Professional Societies None

)

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e

bMMXcEaW TF Dnvid R. Timboriska Senior Engineer Da:e of Eir:b - June 26, 1950 II.

Education A.

35 Degree in Engineering Operations fro: N. C. State University,1972 III.

Experience A.

June, 1972 to Septe=ber, 1974 1.

Newpor: News Shipbuilding a.

Welding engineer.

B.

February, 1975 to November, 1977 1.

National Welders, Charlotte, N. C.

a.

District manager - managed retail velding supply distributor-ship.i C.

December, 1977 to thy, 1978 1.

Vic:or Equipment Co=pany, Denton, Texas a.

Contractor specialist.

D.

May, 1978 to March, 1979 1.

Brown & Root, Glen Rose, Texas a.

Pipe welder.-

E.

April, 1979 to February, 1980 1.

3rcun & Root, Roxboro, 5. C.

a.

Welding engineer.

F.

March 3, 1980, to Present l

-1.

Carolina Power & Light Cc=pany a.

March 3,1980 - E= ployed as Cens:ru::i:n Specialis: in the

-Ha,rris Site Managenen: Section of the Power Plant Cons:ruc-tion Department.

Located at the Harris site, New Hill, 5. C.

b.

Nove=ber 15, 1980 - Reclassified to Engineer in the Harris Site Management Section of the Power F* ant Construction Department. ~ Located at the Harris site,

'.'ev Eill, K. C.

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P Da' tid R.-Timberlake I l

1.

Januiry 31, 1951 - Ke:rgani:::1:r - Depart:en: rena:ed :o

uclear Plant Ccnstructien.

4 d.

March 5, 1983 - Promoted to Senior Engineer in the Harris Site Management Section of the Nuclear Plant Construction Department.

Located at the Harris site, Ne - Eill, N. C.

IV.

Professional Societies:

A.

American Welding Society Rev. 2/14/83 O

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t GEORGE ORMAND WHITE, II l

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Project'Enginear BIRTH DATE: January 12, 1944 I.

EDUCATION A.

Bachelor of Science Degree, Mechanical Engineering, North Carolina State University - 1965 B.

Masters Degree, Materials Engineering, North Carolina State

' University - 1976 C.

Teaching Assistant in Graduate School - North Carolina State l

University II.

EXPERIENCE A.

August 1967 to December 1968 1.

Ford Motor Company,

Dearborn,

Michigan a.

Employed as a design engineer in vehicle component design.

This work included stress analysis, fatigue

~

life prediction, etc.

B.

January 1969 to July 1971 1.

Baldwin-Lima Hamilton, Wrightsville Basch, N. C.

1 a.

Worked as a test engineer, supervising the operation and maintenance of a desalting plant at a government test facility.

C.

September 1971 to 1973 1.

North Carolina State University, Raleigh, N. C.

a.

Entered Graduate School at North Carolina State University full time.

4 D.

October 1973 to May 1975 1.

Hercules, Inc., Wilmington, N. C.

a.

Worked as a Project Engineer, carrying out numerous plant modifications from design through estimating and construction.

e-.,

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,-n a.

f

. George Ormand White, II h

Page 2 E.

June 1975 to October 1975 1.

Warren O. Stiles and Associates, Wrightsville Beach, N. C.

a.

Worked as a consulting Project Engineer on a variety of engineering problems.

F.

November 1975 to March 1976 1.

Institute of Marine Research, Wilmington, N. C.

I t

a.

Worked temporarily as a research associate to Dr. Brauer during preparation of a research proposal for a deep ocean aquarium system.

G.

July 19, 1976 to Present 1.

Carolina Power & Light Company a.

Employed as a Quality Assurance Engineer in the Engineering Quality Assurance Section of the Power Plant Engineering Department. Responsibilities involve review of engineering documents to ensure inclusion of applicable quality ls assurance requirements. Activities also included QA surveys s/

of engineering programs of the engineering groups at CP&L j

Power Plant' Engineering Department, the architect / engineer, and steam supplier firms.

I b.

November 1976 - Transferred to the Technical Services Department, QA Engineer, Engineering & Construction QA Section.

c.

April 1977 - Transferred to the Power Plant Enginedting Department, Engineering Pool Section, Materials / Codes Unit.

d.

June.1978 - Promoted to Senior Engineer in the Materials / Codes Unit, Engineering Pool Section~. Responsibilities include

-new power plant design activities involving materials

'(metallic and nonmetallic), design specification, fabrication processes (welding, forming, heat treating, inspection, tests, etc.).

Responsibilities also' include ensuring that applicable codes, standards and regulations are invoked in design specifications.

In addition, performs' failure analyses as I

related to materials design and fabrication on special assignments and assists the Operating Plant Engineering Support Section on request.

4 e.

December 1, 1979 - Transferred as Senior Engineer to the Harris Plant Engineering Section of the Nuclear Power Plant Engineering Department.

I i

Giorgs Ormand White, II Pagn 3 December 2h,1980 - Promoted to Project Engineer -

f.

h Mechanical in the Harris Plant Engineering Section of the Nuclear Power Plant Engineering Department.

Located at the Harris Site, New Hill, NC.

III.

PROFESSIONAL SOCIETIES A.

Licensed Professional Engineer - North Carolina - 1972 B.

ASME Society i

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' ATTACHMENT H 1

i JOHN FERGUSON Education p.S.,

General Engineering, United States Military t

Academy, 1972 i.

University of Kentucky, Ft. Knox extension, under-graduate and post-graduate coursework in psychology.

1 Experience June 1972 - July 1977: U.S. Army.

Positions included Platoon Leader, Executive Officer, Squad Personnel Office, Brigade Assistant Personnel Officer and Troop Commander.

1 i

September 1977 - Present: Carolina Power & Light company.

During this period, held various Personnel positions with CP&L.

In May 1983, named Director --

}

Personnel, Harris Plant, with' responsibility for evaluating the qualifications of potential employees, performing unescorted access screening, 4

and interpreting and evaluating personnel policies in light of employee concerns.

i l

}

i

Attachment I David Bidwell Watcra Principal Eugineer - Operations April 8, 1940 1

i

_ Education _(e Training l

5, 5. Degree in Engineering Physica - Ohio State University - 1963.

M. 5. Degree in Nuclear Engineering - Carnegie Institute of Technology - 1967.

Professional Sociotles American Nuclear Societ Prof essional Engineer yNorth Carolina - 1975 Society *of Fira Protection Engineers Zyperience April,1963, to April,1972, Senior Engineer, Westinghouso Electric A.

Corporation, Pittsburgh, PA 4

5.

May,1972, employed as a Senior Engineer in the Nuclear Generation

)

Section of the Bulk Power Supply Department.

Located in the 4

Ceneral Office.

)

June,1973, employed as a Project Enginear in the Nuclear Generation i

Section of the Bulk Power Supply Department.

Located in the General Office.

July,1974, employed as s' Principal Engineer - Operating Nuclear Plants in the Nuclear Generation Section of the Bulk Power Supply Department.

Located in the Goneral Officc.

January,1977, employed as a Director - Startup and Technical in the Ocneration Services section of the Generation Department.

Located in the General Office.

i September,1978, employed as a Principal Engineer - Nuclear Ocneration in the Nuclear Generation Section of the Generation Department.

Located in the General Office.

Nay,1979, employed av a Principal Specialist - Regulatory Compliance in the Ceneration Services $cction of the Conaration Department.

Located in the Daneral office.

- - - - --~ " ~~ ~'~' ' ' ~ ~

~ ~ ~ ~

~~

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hwid Biduell Waters,.

November,1979, employed as a Principal Specialiac - Special Projects in the Nuclear Operations Administration Section of the Nuclear Operations Department, Located in the General Office.

February,1981, employed an a Principal Specialist - Special Projects in the Nuclear Operations Administration Section of the Teclaiical Services Department.

Located in the Ceneral Office.

February,1982, eriployed as Principal Engineer - Operations, at the $hearon Harris Nuclear Power Planc, located in How 11111, North Carolina.

S h

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i i

ROBERT WAYNE PRUNTY, JR.

Principal Engineer j

BIRTH DATE: August 3, 1948 I.

EDUCATION:

A.

B.S. Degree in Electrical Engineering from University of South Carolina, Columbia, South Carolina - 1971 II.

EXPERIENCE:

A.

August 1971 to June 1979 1.

U.S. Navy a.

Student in Nuclear Power School -

August 1971 to September 1972 b.

Nuclear Submarine Officer -

October 1972 to September 1974-c.

Student in Submarine Officer's ' Advanced Course - October 1974fto April 1975 d.

Nuclear Submarine Officer - May.1975 to May 1977 e.

Staff Instructor, Naval Nuclear Power School - June 1977 to. june 1979 B.

July 1979 to Present 1.

Carolina Power & Light Company a.

Employed as Senior Engineer in the Engineering Pool Sectic". of the' Power Plant Engineering Department b.

December 1, 1979 - Transferred as Senior-Engineer to the Harris Plant l Engineering

'Section of the Nuclear Power Plant' Engineering.

Department c.'

April 5,-1980 - Promoted'to Project' Engineer -

Harris _ Plant Engineering Section Nuclear Power-Plant Engineering Department-located at New Hill, N.C.

d..

August 8, 1981.- Promoted to-Principal-Engineer-Electrical in the Harris Plant Engineering Sec-tion, Nuclear Plant Engineering Department, New Hill, N.C.

Attachment K KININ W. SHAW HARRIS PLANT FEGINEERING SRCTION M7R111 DATE: April 6, 1960 EDUCATION AND TRAINING A.

nachelor or Science Dogtco in Mechanical Engineering -

rurdue University, Deccabor 1982 M,

Nuciaar Orientation and Introduction to Power Plants -

nachtal Power Corporation, Los Angeles Power Division,. Tuna 1981 C.

Qual 2 fy ASSuranco Codes and Standards Couras - Carolina Power &

7.1Rht Company, February 1954 PROFESSIONAL SOCIRTIER American society or Macnanical Eng2neera EXPERIENCE June 1979 livAC inutullation/ service - R1swinaki Nesting & Air Conditioning, Inc., Hammond, Indiana January 1950 Co-op student engineer a Nechanical Section, Rechtel Power Corporation, Norwalk, California June 1951 Co-op student cugincor - Mechanical Section, Bechtel Power Corporation, Norwalk,- Calif ornia June 1982 Co-op student cagineer - Mechanical Section, Bechtoi Power Corporation, Norwalk, California j

.lanuary 1983 Enginear - Mechantcal Section. Mochte). Power Corporation, Norwalk, California October 1983 Associate ingineer - Harria Plant Enginaaring Section, Hechanical IInit Carolina Power & T.ight Company, Shearon Narris Nuclear Power P3 ant, New !!f11, North Caro 1And i

ATTACHMENT L t

g MICHAEL G GACL2ARDI Mechanical Supervising Engineer EXPERIENCE

SUMMARY

~

j Responsible for providing technical and administrative direction to a team of mech-anical engineers and designers.

Maintain current knowledge of technical industry I

developments, conditions, problems and state of the art methods as related to the team area of responsibility.

Coordinate own activities with those of team. and i

other groups within the department and other disciplines in areas of mutual a

concern.

Provide interpretation of engineering design criteria.

also includes training and development of employees under my direction requirementsRe to enhance their potential for advancement to more responsible positions.

Prepare employee performance evaluations and provide guidance and counseling.for future assignments and job growth.

Coordinated team activities with specified project g

goals and schedules and most recently integrated the start-up and testing schedules p

of the project into the overall plant construction activities.

Familiar with CPM, PERT and MBO scheduling techniques.

Responsibilities have included establishment, review and interpretation of balance of plant and NSSS system design criteria from the project contract, heat balances, departmental guides, codes, standards and NSSS System designs.

Develop flow dia-h grams and piping layouts for balance of plant and NSSS Systems.

Prepare system de-sign descriptions and component design specifications.

Responsible for the preparation of bid documents, negotiations and evaluation 'of commercial and technical aspects of approximately one hundred (100) mechanical contracts.

instrumentation and control logic diagrams as they relate to system function and Review operation.

Prepare and maintain all calculations associated with system design and

(

component selection.

Familiar with pipe stress and support & restraint design elements for nuclear power plants.

Worked with dynamic and static methods for calculating and evaluating pipe stress analysis and support restraint information.

Working knowledge-of the ASME B&PV Code, and B31.1 Power Piping f

Code.

Prepared System Interaction Study for the Power Authority of the State of New York f

for the Indiam Point 3 Nuclear Power Plant.

an interdisciplinary team of engineers and designers in developing metho criteria and field walkdown activities.

Participated in the _ presentation of the k

study to the NRC and ACRS and provided expertise in responding to. questions and Reviewed and commented on PRA study performed for IP-3.

comments.

f Responsible for the technical and administrative coordination of a group of pipe rupture analysis engineers and designers.

implementation of the Nuclear Regulatory Commission's StandardThe prime responsi Review Plans. 3.6.3 and 3.6.2.

In addition, regulatory guides and standards were continuously ~ reviewed and their impact evaluated.

Analysis. requirements included the application of a detailed dynamic study of the thermo-dynamic and fluid-dynamic properties of high energy and moderate energy piping systems.

Analytical tools used in the development of data include RELAP 3 & 4 Coordinated a corporate task force responsible for developing procedures and guide-lines for pipe rupture analysis.

Activities included pipe whip, jet ' impingement, environmental and flooding procedures.

Assisted in the development of structural guides for pipe rupture restraint - design and load calculation methods.

Provided review of industry technique state of _ the art methods for evaluation of the ' effects of pipe ruptures.

i m

. MICHAEL G GAGLIARDI (Cont'd)

REPRESENTATIVE EXPERIENCE Client Project Size Fuel Support Carolina Power and Shearon Harris Nuclear 1 Unit Nuclear Supervising Light Company Power Plant 950 MW Mechanical Engineer Carolina Power and N B Robinson i Unit Nuclear Project Light Company 700 MW Engineer f

Power Authority of Indian Point Unit 3 1000MW Nuclear Project i

the State of New York Engineer EMPLOYMENT HISTORY Ebasco Services Incorporated, New York, NY; 1973 - Present F

Principal Engineer, 1980 - Present Senior Engineer, 1978 - 1980 Engineer, 1977 - 1978 Associate Engineer, 1975 - 1977 i

Assistant Engineer, 19/3 - 1975 Port Authority of New York and New Jersey; 1971 - 1973 Junior Mechanical Engineer (Coorporative work-study program)

EDUCATION I

Pratt Institute - BSME - 1973 PROFESSIONAL AFFILIATIONS ASME - Member ANS - Member w

ATTACHMENT M DEAN SHAH LEAD SYSTEMS ENGINEER t

EXPERIENCE

SUMMARY

Eleven years experience as a Mechanical Engineer, Lead Systems Engineer, Lead Pipe Rupture Engineer and Piping Stress Analysis Engineer for power plants.

Currently serves as Lead Systems Engineer in Mechanical Engineering Department.

Duties include supervision and administration of systems group preparing sched-ules, work assignments, and providing technical assistance and directions of other engineers in the group.

Responsible tor engineering and design of balance of plant systems and developing and reviewing flow diagrams for balanca of plant systems.

Prepara systems design descriptions, design specificatiers, perfora design calculations for sizing pipes, pumps and other sechanical cosponents of fluid systems, selection and sizing the valves, safety related calculations to guarantee systems operations, review other disciplines work for system functions such as Instrumentation and. Control logic diagrams, specify components, interface with other disciplines and vendors.

Also responsible for some of the mechanical equipment procurements.

Assisted with interpretation and implementation of NRC IE Bulletins, SRP, Reg-ulatory Guides and other criteria.

Have written and reviewed FSAR sections and have prepared reply to NRC questions.

Have prepared or reviewed safe shutdown analysis. Also worked to evaluate Appendix R requirements.

Worked as a Project Enginear for Seismic Qualification of the Auxiliary Feedwater Systems as required by NRC Ceneric Letter 81-14 Worked as Lead Pipe Rupture Engineer.

Duties included coordinating and responding to all matters relating to pipe rupture, pipe whip and jet impingement analysis and evaluation of other consequences such as flooding due to pipe rupture.

Lead a special task force set up to resolve complete jet impingement interaction analysis.

This task force approach has proven to be the most efficient and systematic way to complete the jet impingement effort.

Also coordinated a task group that helped to develop a technical directive from the department.

Worked as a Senior Engineer in Applied Mechanics. Department.

Duties included per-forming and checking stress analysis of power plant pipelines as per A5ME B&pV Code Section III, 331.1 Power Piping Code and FSAR requirements, locating anchors, restraints and snubbers on piping systems.

Have performed and checked thermal expansion, static and dynamic seismic analysis and buried piping analysis.

Have checked valve operability and equipment nossle loads, hangers and restraints de-tail designs.

Have also developed load combinations for seismic restrants.

Have prepared reply to NRC questions related to piping -analysis and seismic re-quirements. Written sections of FSAR.

Site experience involves three sonths at a nuclear power plant performing an on-site audit of piping systems for seismic requirements I

i

DEAN SHAH (Cent'd)

REPRESENTATIVE EXPERIENCE Client Project Size Fuel Position Carolina Power &

Shearon Harris Units Nos.

Light Company 1-4 960MW Nuclear Lead Each Japan Atomic Power (PWR)

Company Tokai No. Unit 2 1100MW Nuclear Suppore Public Service (BWR)

Company of Colorado Fort St. Vrain 330W Nuclear Support g*.

Virginia Electric (HTRC)

Power Company Surry Unit No. 2 934MW Nuclear Support Toyko Electric (PWR)

Power Company Fukushima Unit 6 1100HW Nuclear Support Power Authority of (BWR) 4 The State of New York Indian Point Unit 3

': i 1000HW Nuclear Lead y

(PWR) k EMPLOYMENT HISTORY h

Ebasco Services Incorporated New York, NY; 1974 - Pre sent d

Senior Enginest. 1978 I Present Engineer, 1975 - 1978 g

Associated Engineer, 1974 - 1975 Stone & Webster Engineering Corp, Eoston, MA; 1973 - 1974 l

Stress Analyst Warner & Swasey, Co; Worcester, MA; 1972 - 1973 Designer EDUCATION Worcester Polytechnic Instituto, MSME - 1973 REGISTRATIONS Professional Engineer - New York.

PROFESSIONAL AFFILIATIONS ASME - Hamber Have participated in Special Working Group - Dynamic A nalysis ASME (Section III).

i

=

t t

=

k

Att:achment N l

JORN STEVEN HARDY FNCINEERING T)5GRNICIAN BIRTH DATE: December 23, 1958 1.

EDUCATION A.

A.A.S. Degree in Hechanical Danign from Forsyth Technical Institute. Winston-Ralem, North Carolina - 1979 TT, EXPERIENCR A.

May 1979 to Present 1.

Carolina Power & T.ight Company

.i.

From May 1979 to JanuAPy 1980, coordinated the review of the PSAR and ER.

b.

From January 1980 to the precent, directly involved with the review of all fire protection-ralsted items, auch nu specifications, ravinfons, drawing changes, ifcanning commitments, safe shutdown analysia, etc.

- ~- -

ATTACHMENT O l

MARCARETA A. SERBANESCU Principal Engineer EXPERIENCE SLMMARY Graduate Mechanical Engineer with 18 years diversified experience in engineering and design of fire protection,

plumbing, HVAC and waste treatment / water pollution control systems of fossil and nuclear fueled electric generating stations and industrial projects including administrative and/or technical s@ervision of fire protection engineers, mechanical and/or buildings engineering designers.

Responsibilities included developing, fire protection, plumbing and other mechanical water system desians and basic design criteria, preparing system flow diagrams, calculations, Input criteria for physical design drawings, economic analysis of equipment options, procurement specifications, purchase requisitions, bid evaluati.ons, selection -

of equipment, recommendations for purchase, swervision of installation, coordination with other engineering disciplines, clients and authorities having jurisdiction.

In addition, for nuclear fueled electric generating stations, prepared preliminary, final and special safety analysis reports.

As senior engineer was assigned Lead Fire Protection Engineer and was responsible for the entire fire protection system / program of the project as described above, including licensing s@ port, manpower planning and coordination with project needs.

As Principal Engineer continued the activities of Lead Fire Protection Engineer continuing to be resposible for the entire project fire protection systems and program, as described above, and prepared Company fire protection standards.

In January of 1981 was assigned to-supervise the Fire Protection Engineering grow and was responsible for technical and adriinistrative fire protection engineering operations in New York and Lyndhurst offices.

Supervised the engineering, design and other activities on fire protection of all projects nuclear and fossil assigned to these offices, zusponsible for the development of company fire protection technical standards and standard specifications, and ensured these activities were performed in an efficient and timely manner, in accordance with company procedures / guides to provide a high quality product.

EPRESENTATIVE EXPERIENCE Client Project Size Fuel Louisiana Power &

Waterford SES 1165 NW NJelear Light Company Unit No. 3 conbustion Engineering Pressurized Water Reactor Unit i

e n

,.- MARGARETA A. SERBANESCU REPRESENTATIVE EXPERIENCE (Cont'd) 4 Client Project Size Fuel Washington Public WPPSS Unit No'. 3 1300 MW Nuclear Power Supply Combustion System Engineering Pressurized Water Reactor Taiwan Power Chin-Shan Unit 600 MW ea Nuclear Company Nos. 1 & 2 GE i

Boiling Water i

Reactor Units 4

Carolina Power Shearon Harris 900 MW es Nuclear

& Light Co.

Nuclear Power Plant Units 1 & 2 Westinghouse Pressurized Water Reactor Units Iowa Public G Neal Unit No. 4 576 HW Coal

[

Service Co.

j Houston Lighting &

Allens Creek Nuclear 1200 MW Nuclear Power Company Generating No. 1 General Electric Boiling Water Re-l actor Unit Limestone Electric 750 MW es Lignite 1

Generating Station i

Unit Nos. 1 & 2 i

t I

i Ora e and 1.cVett Station 200 MW es Coal Rock Coal Conversion Utilities Inc.;

thit Nos. 4 & 5 Florida Power &

St Lucie Powe'r 890 MW Nuclear

& Light Co.

Plant Unit No.1 i

and St Lucie Power 80 MW NJclear Plant Unit No. 2 Combustion Engi-neering Pressurized Water Reactors e

12020

Y 3

s.s MARGARETA A SERBANESCU REPRESENTATIVE EXPERIENCE (Cont'd)

Client Project Size Fuel i

~

Comision Federal Laguna Verde 675 MW en Nuclear de Electricidad Pbwer Plant Unit de Mexico Nos. 1 & 2 General Electric Boiling Water Reactor Reactor s

sd Consolidated Arthur Kill Unit 200 W/

011 to Edison Company Nos. 2 & 3 300 MW Coal Re-i of New York Respectively ccnversion Knolls Atomic knolls Facilities

~

Nuclear Power Laboratory Modification Program s

s x' j

Clark 011 and Feasibility Study

~f -

Synthatle Refining Corp.

of Producing s f-Gasoline from Coal

\\

x s

i.

Arkansas Power &

Coal to Medlun K-Synthetic Light Co.

Btu Gas

+

)

HNG Synfuels The River Plant.. '

Synthetic j

Company, Texas Coal to Methenol j

Inc.

Virginia Electric Surry Unit Nos. 3 & 4

. 930 MW se Nucientx and Power Co.

Babcock & Wilcox

'l'-

Pressurized Water l

Reactor Units J

Power Authority Astoria Unit No. 6 830 MW.

011 of the State of New York

'l s

~s

'Sg,'

s y

Greene County

. 1300 MW '

'm Nclarar l

Nuclear Power Plant Babcock &

Wilcox Pressuriand Water Reactor Unit

\\ --

\\

Electra de Santillen Nuclear 1100 MW Riclear Viesgo, SA Spain Power Plant I

s.

j og d s

12020

+

~

'r y m:

w

--,___.__.._-----L.1**..._._._-_.-

... ~

Q'

.s

~4-MARGARETA A. SERBANESCU REPREMNTATIVE EXPERIENCE (Cont'd)

Client Project Size Fuel People's Republic Shiheng Power 300 MW Coal of China Plant Huai-Nan Power 600 MW Coal Plant Ebasco Nuclear Standard-1200 MW Nuclear ization Programs

<s GE Boiling Water s

Reactor Unit, Com-bustion Engineering Pressurized Water i

Reactor Unit, West-

)

inghouse Pressurized Water Reactor Unit

{

Ebasco Coal-Fired Reference 400 MW Coal Plants 600 MW Coal 800 MW Coal EMPLOYENT HISTORY

[<

Ebasco Services Incorporated, New York, NYi 1978-Present Principal Engineer - Supervisory Function,1/81-Present j

o i

- Lead Engineer 7/80-1/81 o

Senior Engineer

- Lead Engineer 1/79-7/80 1

- S@ port Engineer 7/78-12/78 Stone and Webster Engineering Corporation, New York, NY; 1973-1978 o

Engineer in Power Hydrctechnic Corporation, New York, NY; 1969-1973 o

Mechanical Design Engineer Spotnails, Incorporated, New York, NY; 1966-1969 1

o Mechanical Draftsman - Desiper

'1 Interzoo, Caserta, Italy; 1965-1966 i

I i

-_,--.---.------.------.-------G-

- - - ~ - - -

~

f

? '

MARGARETA A. SERBANESCU EDUCATION Polytechnic Institute of Bucharest, Master of Mechanical Engineering - 1965 Trane Educational Divis'-a, Trane Air Conditioning Clinic - Completed Course PROFESSIONAL AFFILIATIONS National Fire Protection Association - Member

/

6 k

/

V as i

4

DATE-QUALIFICATIONS TESTING DATE s.

INSPECTOR HIRED WHEN HIRED AND RESULTS "a

M.D.

Griffith 6/13/83 Weld Inspector - 5 years 7/15/83 Passed my C.W. Whatley 8/16/83 Mechanical Insp. - 1 year, 10/12/83 Passed 2 months S.

Rahe 9/26/83 Welder, Inspector - 152 weeks 10/28/83 Passed 4

S.

Russell 9/2/83 NDE, VT, RT, UT - 2 years 9/22/83 Passed 3 months M. Stephens 6/21/82 Weld Inspector - 1 year, 1 month 8/29/83 Passed J.D.

Storey 3/29/82 Welder - 2 years, 2 months 9/23/83 Passed R.

Cooper 8/16/83 Level II Welding 8/31/83 Passed Inspector - 3 years, 3 months J.

Zysk 2/13/84 Visual Weld Inspector -

2/22/84 Passed 2 years,'2 months

~.

e

... _.- =.._ -

EXHIBIT 2 r

Exhibit 6 Topic Outline Welding Procedure Training January 1984 i

1.

Permanent Marking of Site Material and Components l

2.

General Welding Procedure for Carbon and Alloy Steel Pipe Weldments 1-i n

h t

4 4

+

v 9

am.m

.o m

m m-

....m m.- L m

.m.

m

~

I HAND OUT WELDER CRAFT TRAINING August 1981 EXHIBIT 3 HIGHLIGHTS OF MP-06 and MP-07 General Welding Procedure for Carbon Steel and Stainless Steel 1.

Af ter thermal cutting, at least 1/16" shall be removed by grinding or machining.

2.

All internal and external surfaces 2" on each side of weld joint shall be cleaned prior to welding.

3.

Tools used on carbon steel shall not be used on stainless steel.

4.

No welding is permitted if it is wet, damp or raining.

5.

No peening is allowed on root pass or on final pass unless the weld gets post weld heat treatment.

6.

Marking of socket welds:

(1) Scribe a 1/2" mark on socket fitting face.

(2)

Bottom the pipe into the fitting and mark 1" on the pipe from the face of the fitting.

(3) Back the pipe out 1/16" minimum (3/16" maximum).

7.

All stainless steel butt welds get purge.

HIGHLIGRIS OF MP-05 (Stamping of Weldments) 1.

Marking of carbon steel and stainless steel 0.120" and less is done by banding or electrochemical etching.

2.

Marking of carbon steel and stainless steel greater than 0.120" and less than 0.250' is done by:

(a)

Banding (b) Vibraetching (c) Electrochemical etching 3.

Marking of carbon steel and stainless steel greater than.250" can be done by any of the following:

(a) Banding (b) Electrochemical etching.

(c) Vibraetching (d) Impression Stamping (e) Interrupted dot die Each welder is requ.'xed to put his stencil adjacent to the veld but not. closer than 1" after completion of the weld or at the end of the shift. This stencil shall be put at 3 ft. intervals or less.

p n--

pw-ww w

UNITED STATEB 0F AJtER2CA NUCLDAR RE6?LATchY CC9tISSION y

BEF0FJi: TER ATCMIC BAF2TY AND LICRNSING BOARD l

l In the Matter of

)

CAROLINA POWER & LIGHT COMPANY Docket Nes, 50-400 OL

&nd NORTH CARCLINA BASTERN

)

50-401 OL MUNICIPAL PCMIR AGENCY

)

(8hearen Harris Nuolsar Power

-)

3 t?nita 1 and 2)

)

Plant

_ AFFIDAVIT OF ROZAND M. PARjCNg County of Waka

)

as:

State Of North Carolina,

)

Roland M. Pargdna, being duly sworn AGOOrding to IAW, dOposes and says that he is Project General Manager - shearon Ihrris Ruclear Power Plant of Carolina Power A Light Company, that the answers to interrogatories on Edd1ssWLn Conbantion 41 con-bained in Applicants ' Responses to Wella Eddleman's General Interrogatories Ebd Interrogatories on Contentiona 9, 11, 41, 45,116 and 132C(II) to Aapplicanta Carolina Power & Light Campany, et si. (Eighth set)" are true a d sorrect to t.he best of bis information, knowledge and belief, and that the sources of his ibformatico arm offisers, amployees, agents and contractors of Carolina Power a Light Cotgpany.

~

fb

aryks u - _ 2

Rolabs o Parsons' Subscribed and sween to before me this. /2 W day of April, 1984

,,,1 h&fkA-Netary Publib~~

D E"uk N h ' f. /

$ ccanaise. ion ontpires

UNITED STATES OF AMNRJCA WUCLEAR REGULATORY COMMISSION nrou Tu ATOMIC SAFR3"t AM,,II,,J,1,C,EMSiNp, jlU,A)W in the Matter of

)

CAROLINA POVitR & LIGHT COWPANY

)

Docket Non. 50-400 OL AND WORTH C4kO!.IWA EASTERN

)

50-401 OL MUNICIPA), POWER ACENCY

)

(Shearon Harris Nucle.ar Power

)

Plant, Units 1 and 2)

)

AFFI_DAV,IT_OF LEONARD I. LOFLIN County of Waka

)

flLato of North Caro] ion

)

Leonard I. Loflin, being duly sworn according to law, deponen and nayn that ho Js Rumger - Engineering, Harris Plant. of Carolinu Power & Light Companyl that the answers to Interrogatories on Contentions 9, 11, 45, 116 and 132c(II) contained in " Applicants' Answers to wells Eddleman's Ceneral j

Interrogatories and Interrogatories on Contentions 9, 11, 41, 43, 116 and 132c(II) to Applicanta Carolina Power & Light Company,,e_c, a_,1,.

(Righth Sec)"

are trou und correct to the bout of bd.s information, knowledge and 1>ellaf; and that the sources of his information are offiocre, employcos, asents and contractora of Carolina Power & Light Company.

(

~ ' T,eonard 1. - Joflin Sworntoandag-eribedbeforaes,

//

, day of April,-1984.

/

this the

/x.,a,u.

d w.. s..e -

Notary EIislic

(.)

.My comm3aalon aupirest

'! d'6 - E }

.-

ML20083P525

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