ML20087J513
| ML20087J513 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/19/1984 |
| From: | Eddleman W EDDLEMAN, W., JOINT INTERVENORS - SHEARON HARRIS |
| To: | CAROLINA POWER & LIGHT CO. |
| References | |
| CON-DSB-53 OL, NUDOCS 8403220265 | |
| Download: ML20087J513 (24) | |
Text
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REtfJED CORRM 00 P{C U
UNITED STATES OF AMERICA NUCLEAR BEGULATOBY COMMISSION 34 m g}2 MPl BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of J
Docket 50 400 OL CAB 0 LINA POWER AND LIGHT CO. et al.
)
(Shearon Harris Nuclear Power Plant,
)
Units 1 ani 2)
)
)
Jowt DMrveNors' General Interrogatories Gpd Ed E&
to Apolicants Carolina Power & Light et al.
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(FlRST Set )
7-fr-Q & 3-10-93 I
Under 10 CFR 2.7h0, 2.7h1 and the Board 8 s 9-22-82 Memorandun W and Orderh 7omt INtere,$ recuests Applicants to answer separately and fully in writing, under oath or affirmation, each of the following interrogatories, and to produce a permit insnection and conying of the original or best copy of all document's identified in resnonse to interrogatories as set forth below.
These interrogatories are intended to be continuinF in nature, w e_
and reouest each answer to be cromotly su plemented on anended as b
10 CFR P.714 (e), should CPAL, NCEMDA,,any othe=
anorooriate unden or any contractor or censultant to any, sone or all of those, Apolicant, Aor any em loyee of any or some or all of them, or any individual acting on behalf of any or some of all of them, obtain or create any new or differing information resnonsive to these (wkut("Them" refe=s to the precedingor Droduction of documents-list $ng(s))
general nterrogatorie.
The reouest is also continuing and reouests Applicants to produce promptly if not inmediately any additional documents the Applicants and others acting on their behalf or employed by then, as lis'ted in the previous 8403220265 840319 j]p PDR ADOCK 05000400 C
2 sentence, obtain which ora rocyonsivo to the raquast(s) for nroduction of docunents below.
Where identification of a document is re{uested, clease briefly describe the document (e.g. book, notebook, letter, memo, report, notes, transcript, minutes, test data, log, etc. ) and provide the document name, title, number, followinginformat'enasspylicable:
author (s), date of writing or of oublication or both, addressee, date approved, by whom ayyroved, and the name and address of the eersens ha'ing normal custody of tha document, and name and addeess of any yerson other than the preceding having actual possess?on of When identifying documents in resconse to these the document.
interroEatories and reguests, please state the portion or portions i
of the document (e.g. sections, chafrs, pages, lines) upon which Applicants rely or which Ap{licants swear or affirm is/are responsive to the applicable interrogatory or veguest.
DEFINITIONS herein:
" Harris", " Harris Plant", "ShTPP", or " plant" where not specified otherwise, all mean the Shearon Harris Wuelear Power Plant.
" Applicants" means all of the persons, emuloyees, consultants, contractors and corporations as listed in the first sentence of the second paragraph on page 1 of this document, above.
"FSAR" means the Harris Final Safety Analysis *eoort.
l "ER" means the Harris Environmental Penort.
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" Document (s)" means all writings and records of ever7
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including electronic and cemuter records, in the posessien, control licarts' or custody of Aplicants or any individual (s) act$ng on A behalf, including, but not linited to: venorts, books, memorande, corresnondence, notes, minutes, pamphlets, leaflets, magazines, articles, surveys, maps, bulletins, photogranhs, speeches, transcripts,
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voice recordings, com7utsr printouts, information stored in coyutors or comnuter peripheral devices such as disks, drums, etc., voice recordings, m* crofilm, microfiche and all other writings or scordings of any kind (s); and cooles of any of the preceding even though the ori inal(s) are not in the possession of Applicants or in their E
custody or control.
Document (s) shall be deemed to be within the any control of Aplicanta or individual's) Ecting on their behalf the document (s) if they have ownership, ossession, or custody of or a co y thereof, or have the right to secure the document (s) or a copy thereof, from any person or public or private entity having ph7sical possess 1.cn thereof.
EPCh definit [on given above a lies within all other definitions above.
G5NF.AAL I*) TEM 06ATDW G1 (a) Yhich contentiens of Wells Eddleman do Applicants agree are now admitted in this croceeding, NSC Dockets 50-400/401 0.L.?
(b) for each such contentien, provide f or any answers to interrog-stories by Wells Eddleman which Aeolicants have previously or uresently received (except those suspended by Board order, if any), the following information:
(c) Please state the name, present or last known address, and cresent or last known encloyer of each Derson whom Aeolicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) uoon whom Applicants relied (
other than their attorneys) in making such answer.
(d) elease identify all facts concerning which each such nerson idetified in resconse to G1(c)(1) above has first-hand knowledge.
(e) olease identify all facts and/ov documents u on which each nerson identified in response to G1(c)(2) above relied in pro #iding informationtorespondtotheinterngatory,includingtheparts of such docunents relied uoon.
ov- (chfd yM (f) Please identify any other document (s) used/by A licants in responding to the interrogato=y.
(g) Please state which specific fact each docunent, identified in resnonse to G1(e) and GL(f) above, sunports, in the oninion er belief of Aeolicants, or which Aunlicants allege such docunent supeorts.
(h) Please state specifically what information each nerson identified in resconse to G1(c)(1) or G1(c)(2) above orovided to or for Anplicants8 affiant in answering the interrogatory.
If any of this information is not docunented, clease identify it as "undocunented" in resnondin6 to this sect *.on of General InterreFato y G1.
present or last known address, G2.{a) *1 ease state the name,
title (if any), and oresent or last known employer, and econonic interest (shareholder, bondholder, contractor, emolo7ee, etc. ) if or other any (beyond exuert witness fees) such nerson holds in Applicants or expect or an7 of them, for. each verson you intend to ce.11 as an, exrert j
witness or a witness in this proceeding, if such informe. tion has not vreviously been supnlied, or has changed since such infomation was last suoplied, to Wells Eddlenan.
This applies to Eddlemen bv ADD 11 cants.
and Joint Contentions as admitted *0te tfon reEardirg which each
- 4 nulated (b). ? lease identify each co such person is expected to testify.
(c)
Please state when you first contacted each such person with regard to the possibility of such verson's testifying fcr Apolicants, if you have contacted such verson.
(d)
Please state the subject natter, separately for each contention as to which each such person is expected to testify, whicheachsuchpersonisegectedtotestifyto.
(e)
Please identify all documents or narts thereof ueen which each such witness is expected to, nians to, or will rely, in testifying or in nreparing testimony.
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-5 03(a) Please identify any other sou"ce(s) of informatior which Applicants have used to resnond to any inteprogatory identified under G1 above, stating for each such source the interrogator 7 to which it relates, and what information it provides, and identifying where in such source that information is to be found.
(b) Please identify any other sourceh)of information not urevicusly identified upon which any witness identified under G2 above, or or exhibits otherwitness,hasusedinurenaringtestinenp/,orexnectstouse in testimony or exhibits, identifying for each such source the witness who is exnected to use it, and the nart or part(s) of such so urce (if applicable) which are expected to be used, and, if not (or both) treviously stated, the fact (s) or subject matter to which such source relates, and which Gh(a) please identify all documents,gnages or sections thereof Applicants intand or expect to use in cross-examination of any witness I call in this hearing.
For 'each such witness, please trovide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject natter Aeolican'.s believe they relate to, and nake the document (s) available for inspection form intent and conying as soon as possible after Applicants decide orjiF umd t
to use such document in cross-examination.
(b) please identify any undocumented information Applicants intend to use in cross-exanination of each such witness for ne.
G5 (a) for each contention Apolicants state or admit is an admitted Eddleman contention under G1(a) above, or an admitted joint intervenor contention, please state whether toplicants have available to them experts, and information, on the subject matter of the contention.
(b) If the answer to (a) above is other dann affirmative, state whether Anolicants expect to be able to obtain extertise in the subject matter, and information on it, and if not, why not.
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G-6(a) for each document identified in resnonse to any interrogatory herein, or referenced in response to any interrogator 7 herein, please supply all the following information which has not already been supplied:
(1) date of the document (ii) title or identification of document (iii) all authors of the document, o= the author (iv) all qualifications (professional, technical) of each author of the document of the document, (v) the specific narts, sections or pages, if any, uoon which Aunlicants rely (vi) the specific infornation each nart, section or oage identified in resnonse to (v) above contains.
(vii) identify all documents used in overaring the docunent, to the extent known (and also to the extent not identified in the docunent itself)
(viii) state whether Applicants possess a co y of the doc ument (ix) state all exnert ouiniors contained in the document, upon which Anolicants rely, or identify each such opinion.
(x) identify the contention (s) with resnect to wh*_ch Annif cants rely upon (a) the exoert opinions (b) the facts identified in the docunent (xi) state whether Apolicants now ennloy any author (s) of the document, identifying each such person for each document.
(xii) state whether Auplicants have ever emoleyed any authdis) of the docunent, identifying each such person for each document.
(xiii) identify all sources of data used in -the document.
Answers to all the above may be tabulated or grouned for efficiency.
G-7(a) Please identify all documents which Applicants plan, exnect or a 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 resnonse to G1(a), cr (ii) is the subject of interrogatories in this set; please state for which centention or contentions each exhibit will be or is exnected to be offered.
(b) Please identify all documents which Auplicants nlan, expect or
- intend to use in cross-exanination of any other parties' witnesses or joint intervenor witness in this proceeding, with resnect to (1) Eddleman contentions identified under G-7(a)(1) (or G1-(e))
above, or any other Eddleman contention which is the subject of inter-rogatories in this set; (ii) each Joint contention now adnitted in this proceeding; (iii) per our agreenent of h-8-83, each contention of each other party to this nroceeding which is cu=rertly admitted.
Please identify for each such document the witnesses, or witness, and all contentions with resnect to whom (or which) that document is planned, expected, or intended to be offered or used.
(c) Please identify which of the documents identided in response (1) to (b) above will be offewad into evidence by Annlicants, and (ii) which of the same documents ADD 11 cants expect to offer into evidence orintendtoofferasevidenceorexhibitsinthisproceeding, ad/v(speafic ;dfeggalana.s bdca#
G-10(a)
Where the above general interrogatories, or any of then, i
call for identification of documents, (1) and no documents are identified, is that the same as Apnlicants stating that there are no documents resnonsive to this general interrogatory, in each case where no documents are identified?
(ii) and documents a_re identified, is that the same cs Applicants stating that the identified I
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.3 documents are the only ones presently known which are responsive to the interrogatories ?
(iii)
If your answer to G-10(a)(ii) is other than affirmative, please state all reasons for your answer.
(iv) If your answer to G-10(a)(1) above is other than affirmative, please state all reasons for your answer.
(b)
Where any interrogatory, general or specific, herein, calls for factual information (i) and an opinion is stated in response, is that the expert opinion of any person (s ) identified as having contributed information to that responce? (ii) and facts are given or identified (or a fact is) in resnonse, but no documents are identified, does that mean Applicants have no documents containing such fact (s)?
(iii) If your answer to (1) above is affirmative, please state for each each such response all qualifications of -
. expert upon whom Applicants rely for each such answer.
The qualifications need be stated only once for each such person if they are clearly referenced in other answers. (iv) if your answer to (i) above is other than affirmative, please state which oninions, if any, given in response to interrogatories (general or snecific) herein is the opinion of an expert, identify each expert whose oninion you used in response te each interrogatory, and state in full the qualifications of each such expert.
(v)
If your answer to (i) above is other than affirmative, please identify all opinions of non-experts used in your resconses, and identify each non-expert whose opinion is included in each answer herein.
(vi) If your response to (ii) above is other than affirmative, please identify each document which contains a fact not previously I
documented in your resnonse(s), stating what the fact is, and at l
what page, place, chapter or other specific part the document l
cor.tains such fact.
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_9 G-11 For each answer'to each interrogatory herein (or any subpart or part,.thereof), please identify each iten of information in possession of~ Applicants (includirg facts, opinions of experts, and document-s ) which (a) contradicts the answer you nade, (1) in whole (ii)?in part (clease identify each such part for each iteri of information identified); (b) casts doubt on your answer (1) in wholo (ii) in part (please identify each such nart for each iten of infornetion identified). (c) Please identify all docunents not already identified in resnonse to narts (a) and (b) above (and ~their subparts) which contains any iten of information asked for in (a) or (b) above.
Please identify for each such document what information iten(s) it contains and what answeg) each such iten is related to.
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. SPECIFIC INTERROGATOPIES ON JOINT VII (Joint 7) 7-1 Do Applicants, their employees, consultant (s ) cr subcontractor (s )
or contractor (s) dealing with stean generators have any documents relating to (a) vibration problems in Westinghouse model D-h stean generators (b) tube cracking in Westinghouse stean generators which have AVT water chemistry and (1) Inconel-600 tubes (ii) carbon steel sunport plates (c) damage caused by loose metal or other loose objects in stean generators (d) stean generator tube failure analysers?
(e) For each affirmative answer to each of the above parts or subparts, (f) please list all such documents.
Please also list all documents relating to (i) detection of loose parts in steam generators (ii) detection of loose metal in stean generators (iii) detection of other foreign objects in stean generators, which any or the above possess.
(g)
If not already stated, please state who nossesses each document identified in resnonse to an7 of the above interrogatories.
7-2 (a) Have Applicants ever used $1) AVT water chenistry (ii) any other water chenistry similar to AVT, in a nuclear power plant?
(b) For each affirmative answer above, please identify the plant or nlants, define and/or specify the water chenistry used, identify all documents in your nossession specifying such water chenistry and/or its naintenance and/or its effects, and state from what date to what date auch water chenistry was used in each such plant for stean generators.
(d) If you have used any other uk water chemistry than those identified above at a nuclear plant for stean generators, please state (i) why you used it instead of AVT or something-like AVT; (ii) all specifications of this other water chemistry (iii) the identifi-cation of all documents in your nossession related to this other water ehenistry, particularly those related to corvosion, cracking, denting, formation of " crud", "~ green grunge" or other corrosion nroducts,
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. 7-2 continued effects of this water chkmistry'on Inconkel-600 alloy, effects of this water chenistry on any ot!her steun generator tube material in use at that nuclear plant, effects of this water chemistry on other netals (e.g. those of tube suprort plates) used in the steam generators at that plant, and tube failure analyses and/or tube failu"e experience at plant (n) using this water chemistry.
(iv) If you had used AVT or something like it (see (a)(ii) above) at this plant prior to using this water chemistry, please (ala) state all reasons why you changed from AVT or AVT-like water chemistry to this w9ter chemistry (bb) identify all documents related to the change in water chemistry, recommendations for it, any CP&L or CD&L contractor or consultant or subcontractor analysis of the change in water chemistry, or any predictions of the effects on (bb-a) cracking (bb-b) corrosion (bb-c)
(bb-d) tube failure, of changeing to this water chemistry or (bb-e) using this water chemistry.
(v) If there is more than one plant for which the answer to any part of.. (n) above is affirmative, or more than one water chemistry for which any part of (a) above has an affirmative answer, please answer the above subparts (b) thru (c )(iv)(bb-e) separately for each plant and for each water chenistry.
7-3 (a) Form each nuclear plant and each water chemistry you identify or-specify in response to any part of 7-2 above (or any subpart(s )
l thereof), please state (1) the predicted rate of tube failure (ii) the predicted (aa) rate (bb) number of cracks formed in tubes (iii) the predicted rate of tube co'rrosion (iv) the uredicted maximum tube wall thinning that was associated with thak water chemistry (v)'the maximum predicted rate of tube wall thinning associated with that water chemistry _(vi) the predicted average rate of tube wall thinning associated with that water chenistry (vii$ whether any synergistie
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. 7-3 continued corrosion effects as of any kind were predicted with that water chemistry, and particularly (aa) synergisms associated with the water chemistry (bb) synergisms associated with the metal (s) used (cc) syndrd sms associated with the metals in the in the condensers i
other steam piping of that plant (dd) synergisms associated with the metal of the turbine blades of that plant (ee) synergisms associated with the metal of the turbine shaft of that plant (ff) synergisms associated with conta&&nants in the (ff-a) primary side (ff-b) secondary side of the s team generator. (viii) For any of the above subparts of (vii) missesmaaxsplamgilmmamassexprettstied:p lict all other than synergisms effects paredicteg4 or taken into account in decidinF to use that water chemistry, which are associated with the matter inquired about in that subpart.
(b) For each item inquired about above, please state (i) all actual observed instances or rates or occurrences of it which CP&L is now aware of, specifying which plant and which water chemistry each relates to (ii) identification of all documents in youramman possession relating to the actual occurrence or rate of that item.
(PS please recall what John O'Neill has said about synergisms being arguable by us.)
estimates or calculations or (c) Were any predictions made concerning the amount of radiation exposure to be incurred in $1) inspecting (ii) maintaining (iii) cleaning (iv) repairing (v) replacing steam generators at any CP&L nuclear plant?
If so, for each area idertified above, for each such plant (e.g. Harris, calculation or prediction Robinson 2), please state (aa) the date of the estimate (bb) who made it g
(cc) all qualifications of that eerson or verson(s) to make it (dd) a list of all documents and work papers referenced or involved in making it, or in which that estimate, calculation or prediction is made.
. f 7-3 continued (d) Does CP&L maintain any records of (i) individual radiation exposure (ii) internal radionuclide exposure (iii) total person-rems of exposure, involved in (aa) inspecting (bb) maintaining (cc) cleaning (dd) repairing (ee) replacing steam generators at Robinson 2?
(iv) for each subpart above for which your answer is affirmative, please list all such records and produce (you may substitute numbers for nanes and/or identifying information in individual records) copies of the information, statning which or the 3 x 5 (15) subparts above i
the information relates to.
(e) Por each of the itens in (d) above (19 items) few which CD&L does not maintain records, (1) does the NRC have records of it for Robinson 2 to your knowledge?(ii) do you keen any information other than records concerning this item?(iii) Please list all documents containing (aa) NRC information (B3) other information you nossess, concerning this item.
(f) Do you poases.- any information on radiation exposure associated with (i) steam generators (ii) S.G. inspection (iii) S.G. maintenance (iv) S.G. cleaning (v) S.G. repairs (vi) S.G. replacement, at kother nuclear plants (aa) in the US (bb) outside the US?
Please list all documents containing such information that you possess for each of the 2 x 6 (12) things inquired about above.
(g) Do you have any comparisons of radiation exnosure associated with CP&L steam generators versus radiation exnosure associated with any other nuclear utility's or utilities ' or plant 's or plants '
steam generators, not identified above?
If so riease identify all documents containing such conparisons and state where the comnarisons are in each such document.
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-1k-7-4 (a)
Who invented AVT water chemistry?
(b) Is AVT water chemistry ever used in non-nuclear boilers?
If so, where, when, or in what types of boilers?
(c) Does CP&L use AVT water chemistry in any non-nuclear boilers?
Which ones?
For how long?
(d) Has CP&L ever used AVT water chemistry in a non-nuclear boiler where you don't use it now?
If se, why did you chango?
(e) Please identify all documents not identified in response to interrogatories above, which describe AVT water chemistry, its uses, its problems, and/or its advantages if any.
(f.)
Do you know anything about corrosion rates in non-nuclear b611ers using AVT water chemistry?
If so, please state what you know and identify all documents concerning such corrosion rates p you possess, and identify also all documents on which you roly in stating what you know about corrosion rates in non-nuclear boilers with AVT water chemistry.
(g) please state all differences known to you, including pressures, flow rates, t emperatuures, metals used, other components used, etc. between non-nuclear boilers of each type stated in response to (b) above, and the Harris steam generators.
7-5(a) Do you have any information or know anything about Westinghomuse recommending changing away from AVT water chemistry for PWRs at any time?
(b) Please state what you know and identify all documents related to any such recommendation for any PWR or PWRs,ix which information or documents is/are in you possession, (c) Do you have kny information of know anything about Westinghomuse recommending changing from any other water chemistry (or chemistries) to AVT for PWRs at any time?
If so, please state each water chenistry from which as switch to AVT was recommended, when it was recommended, and identify all documents concerning each such recommendation for each such water chemistry, and all documents specifying each such water ehemistry or predicting its effects or effects that wouldn't or shouldn't happen with it.
original 7-6(a)
Did Westinghouse make any warranty for the Robinson P steam generators?
Ifxmax (b) Did Westinghouse give any prediction or projection of the useful life of the original Robinson P stean generators?
(c) Who manufactured the replacement Robinson P steam generators?
When did CP&L order those replacement steam generators?
Why did you order then?
Who made the decision to order daem?
What 2d they cost?
Was that over or under the budge for their cost?
(d) did the maker of the Ro inson 2 replacenent stean generators b
make any warranty for them?
(e) did the maker of the Robinson 2 replacement steam generators give any prediction or projection of their useful life?
(f) For each affirmative answa" to (a),(b),(d$ or (e) above please (i) identify all docunents relating to the warranty or projection / prediction of useful life (ii) state the length of the (aa) warranty (bb) projected / predicted useful life (g) Please identify all docunents related to CP&L's decision to replace the Robinson 2 steam generators, in particular statenents or letters or menos from Robinson 2 plant management to CP&L senior nanagenent concerning the stean generators' (i) leaks (ii) deteriovation (iii) replacenent (iv) repair, including radiation exposure associated with it (v) inspac. tion or cleaning, including radiation exposure associated with either or both (vi) repair (vi) inspection (vii) clearning (viii) maintenance (ix) radiation exposure associated with maintenance, and also the minutes of any Board of Dibectors meetings at which steam generators at Robinson 2 were discussed and all documents signed by senior management related to renlacement of the Robinson P steam genevatows on the need th erefor.
(h) Has CP&L or any lawyer or spokesperson for CP&L or any senior official of CP&L ever stated that the Robinson 2 steam generators would n_ot have to be replaced, or should not have to be renlaced in the useful please list them all, stating If so gwho said what, and when?
Please identify all life of that plant?
g documents you possess concerning each such statement.
. 7-7(a) Where (or from whom) did CP&L get the idea of using AVT water chemistry fram for the Harris steam generators (S.G.s)?
(b) When did you get this idea?
(c) Please identify all documents relating to CP&L's decision to use AVT water chemistry for the Harris abeam generators.
(d) Please state when CP&L first planned to use AVT water chemistry at Harris for the S.G.s (e) Has CP&L ever had any plants to use a water chemistry other than AVT for the Harris steam generators?
If so, please state when, what water chemistry, and all reasons why you nlanned to use it instead of AVT.
(1)
Please identify all documents relating to your planms to use a non-AVt water chemistry (for each such water chemistry you planned to use, (ii) if more than one was planned for)mixxxpttima and alco a11 documents n
relating to changing your plans to using AVT.
(iii) please also identify all documents (aa) specifying (bb) predicting or estimating or calculating or setting forth the effects of (ce) recommending each non-AVT water chemistry you have ever planned to use at Harris.
(e) Did CP&L get the idea to use any of the above-identified non-AVT water chemistries at harris from anyone?
If so,who, and when?
Please answer separately for each different water chemistry.
(f) Has CP&L ever done any research concerning AVTw ater chemistry in steam generators?
If so (1) when (ii) who did it (iii) what were the results (iv) who ordered it (v) identify all documents concerning or containing or reviewing this research, which you or your consultant (s),
contractor (s) or subcontractor (s) possess.
(g) If CP&L has ever planned to use a non-AVT water chemistry for Harris, who gave you the idea to switch to AVT (or switch back to it)?
When?
If anyone gave CP&L a recomnendation concerning switching to AVT or using AVT at Habris, please identify all documents concerning such recommendation.
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7-8 (a) Has CPkL eva" received any infornatten or recommendation NOT to use AVT water chenistry in (1) any PWR (ii) Harris?
If so, from whom, and when?
Please identify all documents concerning each such recommendation.
(b) Has Westinghouse played any role not described in the above answers, in CP&L's decisions or actions concerning water chemistry at (i) Robinson L (ii) Harris?
If so, for each, what was that role? Please identify all documents concerning that role.
(c)
Are you aware of any differing professional (or other) opinions i
(i) within CP&L (ii) at Westinghouse (iii) among other subcontractors or consultants you have who work with steam generators, concerning the (aa) use of AVh water chemistry at Harris (bb) the efficacy 1
of AVT water chemistry at Harris in preventing leaks (cc) the j
efficacy of AVT water chemistry at Harris in preventing tube cracking (dd) the efficacy of AVT water chemistry at Favvis in p"eventing tube l
wear from being excessive or occurring in more tubes than is acceptable
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(ee) the efficacy of AVT water chemistry at Harris in preventing tube I
failure?
If any answer to any of the above subparts is affirmative, please state the dissmenting or differing opinion, who holds it, and identify all documents you possess related to it or efforts to refute it or action taken or proposed to be taken against the l
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person who holds or held it.
7-9 (a) Does CP&L keep any records of the (i) amount (ii) total amount of corroded material flushed or otherwise removed from the Robinson 2 original steam generators prior to their removal frenthat. plant?
(b) If anhwer to any part of (a) above is affirmative, please produce a copy of all such recofds and explain how the amount of corpoded material is determined, calculated or recorded.
(c) Do you possess any record, estimate or calculation of the amount of corvoded material removed in cleaning, flushing, sludge lancing or' otherwise from any steam generators usirg AVT and having (1) Inconel 600 tubes 4r (ii)
. 7-9 continued carbon steel support plates?
If so, please identify the plant or plants, the information, estinate or calculation, and identify all documents containing each such record, estimate or calculation.
7-10(a)
Do you know if anyone has nrepared any estimate of r s '.a ti on exposure to tne nublic from the Robinson 2 stean generators (ori inals)
F being removed from that plant and stored?
(b) If so, who has prepared such estinates, when, give each such esti.nate and identify all documents and workpapers in your possession concerning each such estimate.
(c) Exactly how are the original Robinson 2 steam generators to be (1) satored (ii) ultimately disposed of, after they have been removed from Robinson 2?
Where will such (i) storage (ii) disposal, take place, if you know.
Please identify all documents in yourpossession related to (i) stovage (ii) ultimete disposal of Robinson 2's original steam generators, including any which estinate radiation exposure therefrom to (aa) workers (bb) the public.
(1)
(d) What sort of radiation nonitoring (ii) monitoring for leake of radimoactive material (iii) radiation shielding (iv) weather orotection is being provided for the Robinson 2 steam generators onace they are removed?
Please specify all such in detail and identify all documents concerning each of the itens (1) thru (iv) inquired about above.
7-11(a) What modifications have been made to the Harris steam generators so far? (b) Please identify all documents concerning the (1) planning (ii) execution (including log books and work records)
(iii) results of mask each such modification or set of modifications.
(c) Exactly what modifications described in NUREG-09266 (SER for D2/D3 Steam Generator Design Modification, does CP&L plan to mkke at Harris?
Pleaseidentify all documents related to each clanned modification (d) Exactly what modifications described in NUREG-1014 (SER for Westinghouse Dk/D5/E steam generator modification) does
, q4 coWh94 CP&L plan to make at Harris?
Please identify all documents, plans, blueprints and other information related to your plans for each such modification or set of modifications.
(e) What modifications are now in progress on the Harris steam generators?
Please identify all i
documents related to each such modification.
(f) Please identify all documents describing or setting forth or giving reasons for the test program pronosed for Harris steam generators xduring startup (preoperational testing, power ascensions, e tc ).
(g) Please identify all changes made to your S.G. startup test program for Harris which relate to S.G. modifications or test the results thereof. You may supply a startup test plan for the S.G.s which you made before the S.G. problems at Ringhals and/or Kr;ko were discovered, instead of identifying all the changes.
Please also identify all documents 1
which plan or describe changes needed or to be made in the Harris preoperational test program as a result of (or related to) s team generator modifications.
(h) when were the Harris steam generators delihavered to the Harris site?
(i) How were the Harris 1 steam generators stored before installation in Harris 1?
Please identify all documents relating to such storage er any violation, deficiency, nonconformance, noncompliance or failure to follow procedure or failure te have a procedure for such storage.
(j) What is being done with the Harris 2 stean generators?
Are they being retained for possible replacement use at harris 17 have they been sold for scrap?
If they are still being stored, please state how, and please identify any documents relating to such storage or violations or noncompliances j
with any CP&L regulation or procedure or any NRC rule or regulation concerning such storage.
(k) Who manufactured the Harris 1 steam generators?
The Harris 2 steam generators?
When was each nanufactured?
)
(1) What heat treatment, if any, was used on the Inconel-600 tubes in the Harris 1 steam generators?
Please identify all documents
. 7-11 continued concerning the heat treatment of the tube material in the n mis 1 steam generators.
(m) What heat treatment, if anyk, was useu on the tubes of the Harris 2 steam generat. ors?
Is it the same as for the tube material of the Unit 1 steam generators?
Please identify all documents concerning the heat treatn.ent of the Unit 2 steam generator tubes.
(n) Do you know if Westinghouse or anyone else is (1) offering (ii) reconnending any other heat treating orocess (besides those used on Harris 1 SG tubes already) for Inconel - 600 steam generator tubes?
If so, please describe that process, state who (11)(1) offers it (ii) recomnends it, and (iii) identify all docunents concerning it, and (iv) state whether that process will be used on Harris l's SG tubes, and if not, why not, giving all your reasons in detail.
(o) Are the Harris 1 steam generator tube support plates made of Carbon steel?
Are Harris 2's?
(p) Please state exactly what alloy the tube sunport nlates for (1) Harris 1 (ii) Harris 2 steam generators are made of.
(q) What samples, if any, of the Inconzel-600 used in Earris 1 steam generator tubes, have (i) been retained (ii) been tested in (iii) please identify all documents concerning such a samples any way?
and/or any test (s) of any of them.
(iv) Will CP&L or Westinghouse or the other custodian of such samples make any of them available to Joint Intervenors for testing or inspection?
If so, which ones, and for what (testing, inspection, or both) (you should nesume destructive testing may be included but you would get back the remains of any samples destructively tested).
(r) What ASME or other codes, of what date(s) were used in manufacturing the Harris (i) 1 (ii) 2 steam generators?
D) you possess a copy of such codes of that-date?
If so, please list them.
(s) What differences between the ASME or
-21 other codes used to manufacturethe Harris SGs, and the current codes applicable to SG manufacture, are there?
Do you have a copy of the current codes applicable to SG manufacture?
If so, please list all such codes you have a copy of.
(t) What degree, percent, or amount of thinning of S.G. tube walls do you anticipate (1) on average (ii)as a maxinum for a typical tube, (iii) as a maximun for any tube, as a result of expansion of the (dft) tube (s) inqthe Ex Westinghouse S.G. "fix" described in liUREG-101h (bh) any other S.G. modification now planned or considered for Harris.
Please provide or identify all documents concerning your answer and all workpapers and documents relied on in calculating or wwww+=tx arriving at it, for each item above (2 x 3, or 6 itens).
(u) What amount of corrosion or expansion of tube support plate naterial would be necessary to begin denting the Harris SG tubes (i) as they are now (ii) as they are projected to be after being expanded?
(v) Do you have any monitoring data concerning vibration of steam p
y.
y-v-
generator tubes at (i) Krsko (ii) VC Sumner (iii) MCguire (iv) Ringhals 3 (v) Almaraz ( ? spelling ) ?
If so, for each plant, identify what data you possess, specifying which of it was recorded af ter the SGs at sucn plant were modified.
For each plant, also identify which SG modifications have been nade and when, if you know.
If you know how many tubes have (%) fa!iled (N) been plugged ((6) cracked (dd) been dented (ee) shown indications on eddy current testing, at any of these plants, please state how nany have what problem at each. plant.
Please identify all docunents concerning tube rupture, tube failure analysis, or any of the above tube problems at each plant listed in v-(i) thru v-(v) - above.
(w) Will there be a loose parts monito ggn (i) the hot leg (ii) the cold leg (iii) the secondary side, of nh S.G. at Harris 17 If so please identify the monitor, its maker, all documents.concerning its
. performance (actual or projected), and its location, giving all details of its installation.
Please also state, for each monitor, if that monitor (or that type of monitor) has ever been used at (aa) Oconee (bb) Point Beach (cc) Kewaunee (dd) Ginna (ee) Robinson P (ff) Krsko (gg) VC Summer (hh) Finghals 3 (ii) Almaraz.
Please identify all documents related to the use of each such monitor in operating nunclear plants (or any operating nuclear plant).
Please state for each monitor the model number, its s % ifications, and any instructions of the manufacturer concerning its installation, maintenance, and/or reliability.
Please identify all documents relating to any of the I
abovez items in the preceding sentence. For each monitor identified above, please state if it is Class 1 equipment, and if not, all reasons why not.
(x) Are tnere any loose parts monitoring devices now installed j
on the Harris SGs or piping leading to or from any of them?
If so, please identify each such monitor and give all information about it that is requested in (w) above for monitors to be installed onf Harris 1.
(jy) Please identify all documents related to performance of loose-parts monitoring devices far which can be used on steam generators or associated piping, which you possess but have not yet identified.
(z) Please identify any other loose-parts monitorinF (i) devices (ii) methods which you plan to use at Harris, and all documents related to each. Please answer all questions in (w) above re each such device, and give the location (s) in which you now plant to use the device.
7 ~2 (s dave you ever seen or possessed a copy of a report by a
ScienceApplicationsInc.titledinwholeorinpart"V{1ueImpact Analysis of Recommendations Concerning Steam Generator Tube Degradation and Rupture Events" or words to the same effect?
(b) If answer to (a) is affirmative, are you familiar with the recommendations in that report?
How many of them are there?
Which, if any of them, do you
-P 3 ~'
7-12 continutd (1) have implemented (ii) plan to inclement (iii) plan not to implement at Harris?
(c) For each such recommendation, please give all reasons why you (1) have implemented (ii) plan to implement or (iii) do not plant to implement it.
(d) Please identify all documents concerning your decision (s) to implement or not implement each such recommendation of the "SAI report" referred to above.
7-13 (a) What instrumentation have you installed in the Harris 1 SG3s to detect vibration in (1) the preheater (ii) the tubes (iii) other parts of the s team generator?
Please identify all documents describing such instrumentation, its preferred or proper conditions for oneration, its durability under conditions where it is or will be installed, the manufacturer's specification of it, its design, its annlicability to such monitorinF, of ita reliability under conditions where it is used or planned to be used.
(b) What other nuclear plants have (i) the identical (ii) similar instruments installed for (iii) the same (iv) similar purposes, as those you identified in resnonse to (a) above, to your knowledge?
For each, please state the similarities and differences in the instrument (s) and the curposes for which each is used, to the extent you knew them.
(c) what other nuclear plants use loose parts monitors of the types or models identified in response to 7-11(w),(x), or (z) above, to the extent you have not already identified all such plants?
Please state what monitor (model or type or both) each such plant uses, for what purpose.
7-14(a) Please identify all studies of corrosion in steam generators not identified in response to above interrogatories, concerning (1) Inconel-600 tubes and AVT water chamistv7 (ii) SGs with AVT water chemistry (iii) FWRs with aluminum bronze parts in their condensers (iv) PWRs with agoys containing copper in their condensers
- 2 14 -
(v) at Krsko (vi) at V C Summer (vii) at McGuire (viii) At any other PWR with Westinghouse steam generators (ix) at any PWR with Westinghouse Dl4 steam generators (x) at any PWR with Westinghouse D5 steam generators (xi) which involve analysis or estimates of tube failure (proahability, number, time, etc) (xii) which involve analysis ofr estimates of tube cracking (xiii) which involve estimates or analysis of how many tubes will have to be plugged (xiv) which innvolve * ; estimates which have proved to be correct (aa) 5 years later (bb) more than k 5 years later, cencerning corrosion, tube wall thickness, tube rupture, tube cracking, number of tubes that have had to be plugged, etc. (xv) which deal withik thinning of tube walls after expansion of tubes (xvi)dixich deal with corrosion of SG tubes during extended shutdowns (xvii) which deal with heat (afed b he iT 0MG SW SW R-\\b.ph*"e)?EEeEbs*5 "*c*ph<.**(ioSW 6GwW& %84M S"b?W f&
l TT not,f [$
7-15(a) Is the tube metal in the Harris SGs Incorel-600?
please identify the tube mdtal, and answer the above interrogatoriesc% k Rc Q "p* Gv substituting the correct identify of the SG tube metal wherever ubs the words "Inconel 600" occur.
(b) Will CP&L comit itself unconditiona ly to never use a. water chemistry other than AVT at Harris?
If Please give in detail all reasons for your answer, and identify all documents (A
Ltv and work papers you used or relied upon in answering and all expert h
(c) please identify f @g opinion (s) you relied on in nakning your answer.
all water chemistries other than AVT which you may consider for use at D Harrisandidentifyalldocunentsdescribingeachand/oritsadvantag 3,e c disadvantages and/or effects or claimed lack of effects.
(d) For each water chemistry identified in response to (c) above, please state all circumstances under which CP&L would (1) consider using (ii) use, it at Harris 1.
PRODUCTION OF DOCI"EITS Joint Intervenors hereby request CP&L to produce the ovi rival _ na most t
legible copy of each document identified in _ response to any of the above interrogatoriesforinspectionandcopyingatamutuall7apresabletime and place.
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