ML20085A724
| ML20085A724 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/30/1983 |
| From: | Carrow H CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | CONSERVATION COUNCIL OF NORTH CAROLINA |
| References | |
| ISSUANCES-OL, NUDOCS 8307070092 | |
| Download: ML20085A724 (16) | |
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C 4[f 4 s UNITED STATES OF AMERICA D '
NUCLEAR REGULATORY COMMISSION - g196 33 $0
- 9. re BEFORE THE ATOMIC SAFETY AND LICENSING %q, In the Matter of g_ /f CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN MUNICIPAL )
POWER AGENCY , )
) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant. ) 50-401 OL Units 1 & 2) )
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APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR CONSERVATION COUNCIL OF NORTH CAROLINA (SECOND SET)
Pursuant to 10 C.F.R. SS 2.740b and 2.741 and to the Atomic Safety and Licensing Board's " Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference)" of September 22, 1982, Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that Intervenor Conservation Council of North Carolina answer separately and fully in writing, and under oath or affirmation, each of the following interrogatories, alid produce and permit inspection and copying of the original or best copy of all documents identified in the response to interrogatories below.
Under the Commission's Rules of Practice, answers or objections to these interrogatories must be served within 14 t'ays after service of the interrogatories; responses or objections to the request for pro.luction of documents must be served within 30 days af ter service of the request.
8307070092 830630 PDR C ADDCK 05000400 PDR 3 503
These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. S 2.740(e), should you or any individual acting on your behalf obtain any new or differing information responsive to these interrogatories. The request for production of documents is also continuing in nature and you must produce immediately any additional documents you or any individual acting on your behalf, obtain which are responsive to the request, in accordance with the provisions of 10 C.F.R. S 2.740(e).
Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, transcript, report, handwritten notes, test data) and provide the following information as applicable: Document name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person or persons having possession of the document. Also state the i
portion or portions of the document (whether section(s), chapter (s), or page(s)) upon which you rely.
Definitions. As used hereinafter, the following definitions shall apply:
The "ER" is the Environmental Report - Operating License Stage for the Shearon Harris Nuclear Power Plant, as amended.
The "FSAR" is the Final Safety Analysis Report for the Shearon Harris Nuclear Power Plant, as amended.
" Applicants" is intended to encompass Carolina Power & Light Company, North Carolina Eastern Municipal Power Agency and their contractors for the Harris Plant.
' " Document (s)" means all writings and records of every type in the possession, control or custody of Conservation Council of North Carolina or any individual acting on its behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings and all other writings or recordings of
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i any kind; " document (s)" shall also mean copies of documents even though the originals
- thereof are not in the possession, custody, or control of Conservation Council of North Carolina; a document shall be deemed to be within the " control" of Conservation Council
! of North Carolina or any individual acting on its behalf if it has ownership, possession or l custody of the document or copy thereof, or has the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.
i GENERAL INTERROGATORIES i
1(a). State the name, present or last known address, and present or last employer of each person, other than affiant, who provided information upon which you
, relied in answering each interrogatory herein.
l (b). Identify all such information which was provided by each such person and the specific interrogatory response in which such information is contained.
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l 2(a). Identify all documents in your possession, custody or control, including i
j all relevant page citations, upon which you relied in answering each interrogatory i
herein.
(b). Identify the specific interrogatory response (s) to which each such document relates.
f 3(a). Identify any other source of information, not previously identified in t
I response to Interrrogatories 1 or 2, which was used in answering the interrogatories set forth herein.
l l (b). Identify the specific interrogatory response (s) to which each such source i
of intormation relates.
INTERROGATORIES ON CONTENTION 12 12(2d)-1(a). Do you contend that Jordan Lake Dam may break (fail)?
(b). If the answer to (a) is affirmative, please state in detail all the facts which support your allegation that Jordan Lake Dam may break (fail).
(c). If the answer to (a) is other than affirmative, explain in detail ho response is consistent with CCNC Contention 12.
12(2d)-2(a). Have you and/or your experts reviewed or analyzed the des construction of Jordan Lake Dam?
(b). If your answer to (a) is affirmative, please state in detail your conclusions and results from such review or analysis. Your answer to th should include, but snould not be limited to, the reasons based upon your results as to why you believe Jordan Lake Dam may fail.
(c). If you answer to (a)is affirmative, please provide the dates and loc (on the dam) of each such review or analysis and the identities of those pe ng each review or analysis.
h 12(2d)-3(a). What difference in elevation between the Cape Fear River SHNPP reservoir main dam crest is sufficient to preclude any effects m on the from' a flood resulting from a break in Jordan Lake Dam? i (b). Please state in detail all facts supporting your answer to (a) f
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12(2d)-4(a). Have you and/or your experts reviewed or analyzed the ifd construction of Buckhorn Dam? _
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o (b). If your response to (a) is affirmative, please state in detail your conclusions and results from such review or analysis.
(c). Please provide the dates and locations (on the dam) of each such review or analysis and the identities of those performing each review or analysis.
12(2d)-5(a). If not contained in your response to Applicants' Interrogatories to CCNC (First Set), please identify all studies, reports, or analyses by date, author, and title which you and/or your experts have performed on the effects of a flood on the Cape Fear River.
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(b). For each study, report, or analysis identified in (a), please state in detail all assumptions used and all conclusions and results reached.
12(2d)-6(a). If not contained in your answers to Applicants' Interrogatories to CCNC (First Set), please identify all studies, reports, or analyses which you and/or your experts have reviewed, analyzed, or studied on the effects of a flood on the Cape Fear River.
(b). For each study, report, or analysis identified in (a), please state in detail all assumptions used and all conclusions and results reached.
(c) Please provide the identity of your experts who reviewed, studied or analyzed said studies, reports, or analyses identified in answer to (a).
~ 12(2d)-7(a). Have you and/or your experts reviewed or analyzed the design and construction of SHNPP Main Dam?
(b). If your response to (a) is affirmative, please state in detail your conclusions and results from such review or analysis.
(c). Please provide the dates and locations (on the dam) of each such review or analysis and the identities of those performing each review or analysis.
1 12(2d)-8(a). Have you and/or your experts reviewed or analyzed the design and construction of SHNPP Auxiliary Dam?
(b). If your response to (a) is affirmative, please state in detail your conclusions and results from such review or analysis.
(c). Please provide the dates and locations (on the dam) of each such review or analysis and the identities of those performing each review or analysis.
12(2d)-9(a). Have you and/or your experts reviewed or analyzed the design and construction of Cape Fear River intake structure?
(b). If your response to (a) is affirmative, please state in detail your conclusions and results from such review or analysis.
(c). Please provide the dates and locations of each such review or analysis and the identities of those performing each review or analysis.
12(2d)-10(a). Do you contend that designing the SHNPP Main Dam for the probable maximum events such as the probable maximum flood and the probable maximum hurricanes is not adequate?
(b). If your answer to (a) is affirmative, please state in detail all facts which support your allegation that designing the SHNPP Main Dam for the probable maximum events such as the probable maximum flood and the probable maximum hurricane is not ade'quate.
(c). If the answer to (a) is affirmative, for what events should the SHNPP Main Dam be designed?
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12(2d)-ll(a). Do you contend that designing the SHNPP Auxiliary Dam for the probable maximum events such as the probable maximum flood and the probable maximum hurricanes is not adequate?
(b). If your answer to (a) is affirmative, please state in detail all facts which support your allegation that designing the SHNPP Auxiliary Dam for the probable maximum events such as the probable maximum flood and the probable maximum hurricane is not adequate?
(c). If the answer to (a) is affirmative, for what events should the SHNPP Auxiliary Dam be designed?
12(2d)-12(a). Do you contend that designing the Cape Fear River intake structure for the probable maximum events such as the probable maximum flood and the probable maximum hurricanes is not adequate?
(b). If your answer to (a) is affirmative, please state in detail all facts which support your allegation that designing the Cape Fear River intake structure for the probable maximum events such as the probable maximum flood and the probable maximum hurricane is not adequate.
(c). If the answer to (a) is affirmative, for what events should the Cape Fear River intake structure be designed?
12(2d)-13(a). Please state in detail what is meant by adverse effects on the SHNPP reservoir Main Dam and Cape Fear River intake facility as stated in Contention 12.
(b). Please state in detail all facts whic. support your response to (a).
12(2d)-14(a). Have you completed your analysis referred to in your Response to Applicants' Interrogatory 12-4(a)?
l (b). If your answer to (a) is affirmative, please provide that analysis and your response to 12-4(a), (b) and (c).
(e). If your answer to (a) is other than affirmative, please provide the status of that analysis, the reason it is not yet complete, and the expected completion date.
12(2d)-15(a). Have you completed your analysis referred to in your Response to Applicants' Interrogatory 12-5(a)?
(b). If your answer to (a) is affirmative, please provide that analysis and your response to 12-5(a), (b) and (c).
(c). If your answer to (a) is other than affirmative, provide the status of that analysis, the reason it is not yet complete, and the expected completion date.
INTERROGATORIES ON CONTENTION 14 14(2d)-1. Please state in detail all the facts which support the following statement made in response to Applicants' Interrogatory 14-1(b): "Long distance dispersal [of hydrillal is accomplished by waterfowl...."
14(2d)-2. Please identify the exact locations where hyorilla was reported in Delaware, Iowa, and Wisconsin, and the documentation on which your answer is based.
'14(2d)-3(a). Do you contend that a valid comparison can be made between a reservoir in Rodman County, Florida, and the SHNPP reservoirs in regards to the spread of hydrilla?
(b). If your answer to the preceding interrogatory is affirmative, please explain in detail what that comparision is.
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(c). Please state in detan all the facts on which that comparison is based. I (d). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with your response to Applicants' Interrogatory 14-2(b).
14(2d)-4(a). Do you contend that hydrilla will flourish in North Carolina to the same extent as in Florida?
(b). If your answer to the preceding interrogatory is affirmative, please state in detail all the facts which support your allegation that hydrilla will flourish in North Carolina to the same extent as in Florida?
(c). If the answer to (a) is other than affirmative, explain in detail how your response is consistent with your response to Applicants' Interrogatory 14-2(b).
14(2d)-5(a). Please state in detail all facts which support the following statement contained in your response to Applicants' Interrogatory 14-2(b): "In Sycamore Lake in Umstead State Park, after only a few years of growth, 70% of the lake surface is covered, with vegetation extending from the lake bottom to the surface."
14(2d)-6(a). Please state in detail all facts which support the following statement
, contained in your response to Applicants' Interrogatory 14-2(b): "
...the mass of hydrilla is near that of water...."
- 14(2d)-7(a). Do you contend that hydrilla will totally occupy a given volume and displace all the interstitial water, thereby producing a mass of hydrilla equal to approximately 90% of the mass of that water?
(b). If the answer to (a) is affirmative, please state in detail all the facts which support your allegation that hydrilla will totally occupy a given volume and
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displace all the interstitial water, thereby producing a mass of hydrilla equal to approximately 90% of the mass of that water.
(c). If the answer to (a) is other than affirmative, explain in detail how your response is consistent with your response to Applicants' Interrogatory 14-2(b).
14(2d)-8(a). Do you contend that hydrilla in an area one meter square in two meters (depth) of water would weigh 90% of the weight of two cubic meters of water?
(b). If the answer to (a) is affirmative, please state in detail all the facts which support your allegation that hydrilla in an area one meter square in two meters (depth) of water would weigh 90% of the weight of two cubic meters of water.
(c). If the answer to (a) is other than affirmative, explain in detail how your response is consistent with your response to Applicants' Interrogatory 14-2(b).
14(2d)-9(a). Do you contend that the standing crop of hydrilla in a reservoir would be 3,973 pounds / meter27 (b). If the answer to (a) is affirmative, please state in detail all the facts which support your allegation that the standing crop of hydrilla in a reservoir would be 3,973 pounds / meter27 (c). If the answer to (a) is other than affirmative, explain in detail how your response is consistent with your response to Applicants' Interrogatory 14-2(b).
1 1*4(2d)-10(a). Do you contend that the standing crop of hydrilla can exceed 2,500 grams /m2 in Wake County, North Carolina?
(b). If the answer to (a) is affirmative, please state in detail all the facts which support your allegation that the standing crop of hydrilla can exceed 2,500 grams / meter2 in Wake County, North Carolina.
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(c). If answer to (a) above is other than affirmative, explain in detail how your response is consistent with your response to Applicants'Interrogabry 14-2(b).
14(2d)-ll(a). Do you contend that water near shore or in shallow areas of SHNPP reservoirs will move in sufficient velocities to carry hydrilla from any and all areas of the lake to the intake structure?
(b). If your answer to (a) is affirmative, please state in detail all the facts which support your allegation that water near shore or in shallow areas of SHNPP reservoirs will move in sufficient velocities to carry hydrilla from any and all areas of the lake to the intake structure?
(e). If your answer to (a) is affirmative do you contend that the water in these areas will move, as a parcel, to the intake, carrying along the hydrilla in it?
(d). If the answer to (c) is affirmative, please state in detail all the facts which support your allegation that the water in these areas will move, as a parcel, to the i take, carrying along the hydrilla in it.
(e). If the answer to (c)is other than affirmative, explain in detail how your response is consistent with your response to 14(2d)-11(a) above.
14(2d)-12. Please state in detail all facts which support the following statement contained in your response to Applicants' Interrogatory 14-2(b): "The travelling screens would be required to lift, for each unit, 24 tons of wet plant material per minute...."
You'r answer should include, but not be limited to, all facts and data which show that sufficient biomass of hydrilla wo ld accumulate in depths where hydrilla is known to grow ;
i (in Piedmont area of North Carolina) to produce 24 tons per minute of hydrilla at the i cooling tower make-up water intake structure. I
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14(2d)-13(a). Do you ~ntend that significant quantities of hydrilla in SHNPP reservoir (s) will grow in depths greater than 2.5 meters?
(b) If the answer to (a) is affirmative, please state in detail all facts which support your allegation that significant quantities of hydrilla in SHNPP reservoirs will grow in depths greater than 2.5 meters? If any measurements are included in your answer, please identify the person making those measurements and the date, time, and location those measurements were made.
(c). If the answer to (a)is other than affirmative, explain in detail how your response is consistent with your response to Applicants' Interrogatory 14-6(a).
14(2d)-14(a). Do you contend that over time hydrilla will continue to grow in increasingly deeper water in the Piedmont area of North Carolina?
(b). If the answer to (a) is affirmative, please state in detail all the facts which support your allegation that over time hydrilla will continue to grow in increasingly deeper water in the Piedmont area of North Carolina.
(c). If the answer to (a) is affirmative, do you contend that hydrilla (without sexual reproduction) can genetically evolve to this new condition?.
(d). If the answer to (c) is affirmative, please state in detail all the facts which support your allegation that hydrilla (without sexual reproduction) can genetically evolve to this new condition.
I'4(2d)-15(a). Do you contend that hydrilla is barely attached to the substrate by delicate threadlike roots?
(b). If the answer to (a) is affirmative, please state in detail all facts which support your allegation that hydrilla is barely attached to the substrate by delicate threadlike roots.
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(c). If the answer to (a) is affirmative, do you contend hydrilla can grow where water velocity is 5.4 fps? '
(d). If the answer to (c)is affirmative, please explain in detail how hydrilla in the SHNPP reservoir could break loose and be carried to the intake structure where the n$aximum water velocity is .5 fps.
(e). If the answer to (a)is other than affirmative, please explain in detail how your response is consistent with your response to Applicants' Interrogatory 14-6(b).
14(2d)-16. With regard to your response to Applicants' Interrogatory 14-7(b), please provide the following information:
(a). The location in Crabtree Creek where velocities of 5.4 fps were recorded.
(b). The amount of hydrilla observed at this location.
(c). A description of all measurements of hydrilla made at this location.
(d). A description of the hydrilla observed at this location including the height (length) of the plants, their color, and whether they were healthy or dead.
(e). A description of the methods utilized for all measurements taken of hydrilla at this location.
(f). A description of allinstruments utilized in those measurements.
(g). If those instruments were calibrated, the identity of the persons who calibrated them.
REQUEST FOR PRODUCTION OF DOCUMENTS Applicants request that Conservation Council of North Carolina respond in writing to this request for production of documents and produce the original or best copy of each
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of the documents identified or described in the answers to each of the above interrogatories at a place mutually convenient to the parties.
Respectfully submitted,
, Hill Carrow Attorney CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6839 Thomas A. Baxter, P.C.
John H. O'Neill, Jr.
SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D. C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North arolina 27602 Date: / 30 1994 i
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..l UNITED STATES OF AMERICA y_ dQ ~
NUCLEAR REGULATORY COMMISSION L ' b.
0 1933 BEFORE THE ATOMIC SAFETY AND LICENSING BO
' In the Matter of )
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CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN MUNICIPAL )
POWER AGENCY )
) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ) 50-401 OL Units 1 & 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Interrogatories And Request For Production Of Documents To Intervenor Conservation Council of North Carolina (Second Set)" were served this 30th day of June,1983, by deposit in the U. S. mail, first class, postage prepaid, to the parties on the attached Service List.
Hill Carrow Avvw)
Attorney CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 27602 t
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SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Conservation Council of North Carolina 307 Granville Road Washington, D. C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U. S. Nuclear Regulatory Commission Post Office Box 12643 Washington, D. C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U. S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D. C. 20555 Charles A. Barth, Esquire Mr. Wells Eddleman Myron Karman, Esquire 718-A Iredell Street Durham, North Carolina 27705 Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Thomas A. Baxter, Esquire John H. O'Neill, Jr.
Docketing and Service Section Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Office of the Secretary Washington, D. C. 20036 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Phyllis Lotchin 108 Bridle Run Mr. Daniel F. Read, President Chapel Hill Anti-Nuclear Chapel Hill, North Carolina 27514 Group Effort Post Office Box 524 Bradley W. Jones, Esquire Chapel Hill, North Carolina 27514 U. S. Nuclear Regulatory Commission Region Il Deborah Greenblatt, Esquire 101 Marietta Street 1634 Crest Road Atlanta, Georgia 30303 Raleigh, North Carolina 27606 Karen E. Long, Esquire Ruthanne G. Miller, Esquire Staff Attorney Public Staff Atomic Safety and Licensing Board Panel North Carolina Utilities Commission Post Office Box 991 U. S. Nuclear Regulatory Commission Raleigh, North Carolina 27601 Washington, D. C. 20555 i
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