ML20084A755
| ML20084A755 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/19/1984 |
| From: | Eddleman W EDDLEMAN, W., JOINT INTERVENORS - SHEARON HARRIS |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8404250264 | |
| Download: ML20084A755 (7) | |
Text
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7' EuTED CORRESPONDENT U
Anril 19, 198h UNITED STATES OF AMERICA DOCKETED U990 NUCLEAR BEGULATORY COMMISSION i
'84 APR 25 A10:21 BEFORE THE ATOMIC SAFETY AND LICENSING BOAED Glenn O. Bright
[g(($fh Dr. James H. Carpenter esANc8 James L. Kelley, Chaircan In the Matter of
)
Docket 50 400 OL CAROLINA PCWER AND LIGHT CO. hl.
)
(Shearon Harris Nuclear Power Plant,
)
Units 1 ani 2)
)
ASLBP ro. 82-h68-01
)
OL Joint Intervenors and Wells Eddleman's Response to Staff's 3-15-84 Interrogatories.
JOINT INTERVENORS RESPONSE 38.
See SECY-82-72 & 82-72A.
We have not been able to search for more specific references successfully.
More files will-be reviewed.
We are also asking our exnerts about tube failure analyses.
WELLS EDDLEMAN's RESPONSES 1.
The. burden of nroof is not on an intervenor.
I have consulted with a nonwitness exnert on Eddleman 11, but withhold that identity and OBJECT to revealing it because Staff has made no showing for need of the identity of this. person, nor that Staff cannot obtain Ott::
information or opinions on this subject by other means.
I do rely on
$O gg some documents concerning Eddleman 11 and 116, urincipally studies by oL 0111en, Clough, et al, and the FSAR.
See responses to Anplicants' av SO interrogatories, n<
Ih 2.
See the napers of Gillen, Chough, et al.
I'm not sure L a.o who wrote the FSAR re 116 (fire protection).
The nonwitness exnert is in a field x related to Eddleman 11, but Staff shows no need to know
-this (and probably can't) so my.0BJECTION is the same as in 1_above.
- %$O3
. 3 See items refersnced in 1 and 2 abovo r2 11; for 116, I do not rely on the PSAR analysis but on its failmings, omission,s shortcomings, etc.
See the contention itse1xf and responses ta Applicants re 116.
4 Other than as identified in the paners and docunents referenced above or in responses to Applicants, I'm not sure.
I also object that it is burdensome to dig out this indformation.
It's as easy for your staff to read the documents as it is for me, and you have more people.
- 5. N/A now, but when more documents are identified, I will.
t You have the FSAR and the other Daners I believe, since most are NUREGs.
6.
None identified yet.
- i,8: Will supplement when identified, or in testimony profiled.
9.
Yes.
10.
Objection as to work of nonwitness expert, to the extent it may be covered by this interrogatory.
Wells Eddleman.
11.
See responses to Applicants; objection as to providing all such since they are not filed in such a way as to be readily findable.
12.
Yes.
You have a copy of response to Applicants, and if you want more information I'll work with you to supply it informally, without the burden and time wasting of formal interrogatories.
- 13. Wells Eddleman. 718-A Iredell St. Durham NC 27705, 919-286-3076.
RESPONSES ON EDULEMAN 11
- 50. Insulation used on large diameter ' conductors, e.g. wire gauges (or equivalent diameters) 6 or below.
- 51. Discovery reouired to answer.. Apnlicanta A claim there is none but I'm not sure they're right in saving this.
52.
Longer periods of time than used in the material tests, particularly times extending over years, weeks, or many hours, and also times which extend over (or are comnarable to) the estimated 25 to 40 year operating life of a nuclear plant, which I think mAy be an overestimate of n-plant operating life.
s l
53 See the work of Gillen, Clough et al as referred to above.
See also Bonzon et al as referenced in Union of Concerned Scientists petition for emergency and remedial action (supplemental petition) filed 2-7-84 with NRC, re environmental qualification.
54 Not sure pending discovery.
hot sure it's relevant as long as the dose rate is le ss than in the tests.
See Gillen, Clough et al's conclusions.
55 Assuming you have some comoetent scientists, I will attempt to dig this information out of the info provided by Applicants.
Note in my resnonses to them that I think any cables or wiring exeosed to radiation at Harris can be subject to this dose-rate effect of increased degradation (of various kinds) when exnosed to radiation and other environmental factors such as air, oxygen, nitrogen, heat, steam etc.
56.
Gamma radiation in the plant will be released (above background) ei from the nuclim of radiarimmoactive atoms in the olant, including those in the core, the primary coolant system, the secondary coolant, the containment atmosphere, plateout in the containment at any point, in-cluding on cables or wiring or the conduits or trays or sunports holding or near or touching them, and from filters, decay tanks, and from radioattive material circulated to or released into other places at Harris,
- g. the auxiliary building.
See resvorses to Auplicants for more details.
57.
Analysis not performed yet.
More information cominc ou discovery will aid in this analysis.
Attenuation by shielding could also result in greater proportional degradation by reducing radiation dose rate, so that the degradation per rad of radiation received is moare. Also, radiation not fully absorbed in the insulation could have damaging effects, and I believe it does.
58.
The desradation is a continuous orocess but I have not been able to yet quantify the time of breakdown.
Its risk is there, especially
O
-f-under accident or other stressful conditions which could lead to breakdown of insulation, and also it is there with time as degradation increases.
- 59. See response to 53, and info referred to therein.
There is no interrogatory 60.
61.
Anything above zero would begin the effect.
Padiation levels, I
l not reactor nower levels, are most relevant.
6m2.
Impaired signal transmission, erroneous signal forms or extraneous signals, short circuits, failure to transmit recuired power or information, circuit failure.
Safety functions related to each such cable, wire or part.
Impairment could range from modest to total.
This is not easy to quantify for each cable, and I susnect that the degradation of the total system's reliability and nerformance will be the greatest oroblem, not just the failure of one or more parts (though that could have serious consecuences depending on the parts: e.g.
if it's wiring to the SCRAM systems or power supplies thereto, you could have ATWS and lose eastern Nordi Carolina and then some 64 See responses to Apulicants.
65 Try the NRC PD9 or any good technical library.
I believe some copies of technical articles of theirs are in the Duke and NC State U. engineering and/or chemistry libraries.
- 66. Discovery request pending.
Applicants seem to say no. I don (t know.
67.
Eusnonse is not Yes at this time.
RESPONSES ON 45 68.
OBJECTION-- question is vague and does not identify the requirements.
Do they mean rules, regulations, practices? What? ANSWER:
See responses to Applicants.
69,70:
See answer to 68.
71.
No citations are given in Eddleman 45.t Tully comnleke.o See resnonae t
Applicants re relevant NU M s.
Analysis no
_ f_
RESPONSES ON 67 72.
I have seen the bill enacted by North Carolint.
I don't know about SC but I believe SC has enacted n similar bill.
73.
I don't know.
Harris LLRW shipments could be foreclosed by violation of SC regulations, NRC regulations, or by executive order.
See Applicants' discovery documents re their LLPW shipment violations in SC.
MESP0"SES ON 116.
7h.
Analysis incomplete.
Waiting on discovery documents and time to finish it.
FSAR has been revised.
75 As far as the PSAR when I reviewed it last re this, all of them, except as identified otherwise in past discovery responses.
76.
The contention does not require me to prove that things will be innaired, but the function of almost any item of electrical equinment can be imnaired by fire e.g. from thermal effects on resistances, degradation or burning of insulation, from shorts or changes in resistivity due to smoke or smoke particles in or on it (See e.g. Bonzon et al as cited by UCS in 2-7-8h supnlemental petition for emergency and renedial action on enviro. qualification),
from spurious signals induced by heat or smoke or warnage. of or thearmal gradients across or in or of connonents, from distortion of signals due to any of the above or combinat$ ons of thmesex and other factors, from quantun effects in semiconductors and other microelectronic equipment induced by heat or caused or contributed to-by short circuits, power surges, power shutoff, waveform distortdon, spurious or distorted signals, etc.; failure to transnit needed power or signals to either operate safety-related equipment, or to monitor the cnndition of systems, equipment and radioactive releases in or from Harris; degradation of mechanical equipment or things including combustion, melting, loss of strength or other vital mechanical prouerties
4
-g.
e.g. sealing, insulation, isolation of components.
77.
Contention 116 was nremised on the documents identified 5-lh-82 and the 6-28-82 amendments.
Its basis is those documents.
I'm not sure what you mean by " premised".
I am going to review some additional documents; see also resnonses to Apolicants.
78.
For example, Harris uses ionization smoke detectors, whereas photoelectric detectors would be better at detecting smoldering fires, e.g. in wiring, cables, debris or otherwise.
The simple meeting of a standard does not guarantee actual performance. Flame suread tests are otorious for their inaccuracy in this regard.
Fire barrier tests and etc will be investigated when discovery info and documents both available.
Analysis is incomplete now.
79.
See responses to Anplicants.
Analysis inccr.nlete.
78 (second) (there is no interrogatory 80, but 78(second) annears agf ter 79)
This may not be clear, but it's CP&L's way of doing things.
81.
Review not anywhere near hacomnlete.
This is k extensive volumes and I haven't had time to go through it concrehensively.
82.
Define requirements, how about it?
Analysis incomplete, see 81.
PRODUCTION OF DOCUMENTS.
Appi Staff asks only for documents re 11 and 116 for some reason, but documents re the above w!11 be provided for insnection and conving where identified and not in the nossession of NRC Staff or NRC.
ATTEST s
The above are true to the best of my present kpowledge and
[///2 belief, 4-19-84.
/
j%%lng n =
v Wells Fddleman
p I
i UNITED STAITS OF AMERICA NUCLFAR REGUIATORY COMMISSION In the matter of CARoLIKA POWER k LIGHT CO. Et al. )
Docket 50-1400 Shearon Harris Nuclear Power Plant. Unit 1'
__d 0.L.
CERTIFICATEoF SERVICE J int Intervenors and Wells Eddleman's I hereby certify that copies oi, Responses to NRC Staff Interrogatories 19 April 1981,bydepositin HAVE been served this day of the US Mail, first-class postage prepaid, upon all parties whose i
names are listed below, except those whose names are marked with including a copy an asterisk, for whom service was accorrplished by of 4-17-84 Joint Intervenors postcard to Board re Joint 7 ngegotiations re protective order (Board, Applicants and NRC DkS already served).
Judges James Kelley, Glenn Bright and Jams Carpenter (1 copy each)
Atomic Safety and Licensing Board US Nuclear Regulatory Corstission Washington DC 20555 George F. Trowbridge (attorney for Applicants)
Shaw, Pittaan, Potts & Trowbridge ILuthanne G. Miller 1600 M S c. NW ASLB Panel Washirgton, DC 20o36 USNRC Washington DC 2055 5 i
4
- offi:e of the Executive Legal Director Phillis Lotchin, Ph.D.
Attr Docke ts 50-400/hol 0.L.
105 Bridle Run USKFC Chanel Hill FC 2751h 1
Washington DC 2o555
- Dan Read Docketing and Service Section (3x)
CEA!LT/FLP Attn Dockets 50-hoo/hol o.L.
Raleigh,Sto7 waveross office of the Secretary NC 27606
. Unda W. Mttle da neton DC 20555 Governor's Waste Mgt. Bd.
hb Ud
- John Runkle I"
8 Granville Rd Chapel Hill No 2751h
~
Bradley W. Jones Robert Gruber USNRC Region II
- Travi s Payne Exec. Director 101 Marietta St.
Edelstein & Payne Public Staff Atlanta GA 30303 Blox 12601 Box 991' Raleigh NC 276o5 Raleish BC 27602 Richard Wilson, M.D.
Certified by h
729 Hunter St.
Apex NC 27502 l
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