ML20087K812

Interrogatories & Request for Production of Documents Re Eddleman Contentions 9 & 11 (Second Set).Certificate of Svc Encl.Related Correspondence

ML20087K812
Person / Time
Site:	Harris
Issue date:	03/23/1984
From:	Swiger M CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	EDDLEMAN, W.
References
CON-DSB-104 OL, NUDOCS 8403260327
Download: ML20087K812 (14)

Text

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00, TED RELATED CORRESPONDENCQ

Bk'%R 26 All :48 UNITED STATES OF AMERICA'.Ft r;,c nr er, NUCLEAR REGULATORY COMMISSION ' J' Before the Atomic Safety and Licensing Board In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AC?NCY ) 50-401 OL -

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO WELLS EDDLEMAN CONCERNING EDDLEMAN CONTENTIONS 9 and 11 (SECOND SET)

Pursuant to 10 C.F.R. 5 2.740b and 2.741, Applicants Carolina Power & Light Company and North Carolina Eastern Mu-nicipal Power Agency hereby request that Intervenor Wells Eddleman answer separately and fully in writing, and under oath or affirmation, each of the following interrogatories, and pro-duce and permit inspection and copying of the original or best copy of all documents identified in the responses to the inter-rogatories below. Under the Commission's Rules of Practice, answers or objections to these interrogatories must be served within 14 days after service of the interrogatories; responses or objections to the request for production of documents must be served within 30 days after service of the request.

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1 These interrogatories are intended to be continuing in na-ture; and the answers should promptly be supplemented or I

amended as appropriate, pursuant to 10 C.F.R. $ 2.740(e),

should Intervenor or any individual acting on his behalf obtain any new or differing information responsive to these interroga-tories. The request for production of documents is also con-tinuing in nature; and Intervenor must produce immediately any additional documents he, or any individual acting on his be-half, obtains which are responsive to the request, in accor-dance with the provisions of 10 C.F.R. 5 2.740(e).

Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, tran-script, report, handwritten notes, test data) and provide the following information as applicable: document name, title, num-ber, 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 documer.t. Also state the por-tion or portions of the document (whether section(s), chap-ter(s), or page(s) upon which Intervenor relies.

Definitions: As used hereinafter, the following defini-tions shall apply:

The "FSAR" is the Final Safety Analysis Report for the Shearon Harris Nuclear Power Plant, as amended.

The "SER" is the Safety Evaluation Report related to the operation of Shearon Harris Nuclear Power Plant, Units 1 and 2, NUREG-lO38 (Nov. 1983).

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" 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 Intervenor or any in-dividual acting on his behalf, including, but not limited to, memoranda, correspondence, reports, su rveys , tabulations, charts, books, pamphlets, photographs, maps, voice recordings and all other writings or recordings of any kind; " document (s)"

shall also mean copies of documents even though the originals thereof are not in the possession, custody or control of Inter-venor; a document shall be deemed to be within the " control" of Intervenor or any individual acting on his behalf if Intervenor or the individual acting on his behalf has ownership, posses-sion or custody of the document or copy thereof, from any per-son or public or private entity having physical possession thereof.

General Interrogatories

1. (a) State the name, present or last known address, and present or last known employer of each person, other than affiant, who provided information upon which Intervenor relied in answering each interrogatory herein.

(b) Identify all such information which was provided by each such person and the specific interrogatory response (s) in which such information is contained.

2. (a) Identify all documents in Intervenor's posses-sion, custody or control, including all relevant page cita-tions, upon which Intervenor relied in answering each interrog-atory herein.

(b) Identify the specific interrogatory response (s) to which each such document relates.

3. (a) Identify any other source of information, not previously identified in response to Interrogatory 1 or 2, which was used in answering the interrogatories set forth here-in.

(b) Identify the specific interrogatory response (s) to which each such source of information relates.

Interrogatories on Contention 9 (Environmental Qualification of Electrical Equipment) 9-10. (a) In your answer to Interrogatory #9-2 in Wells Eddleman's Response to Applicants' Interrogatories Concerning Contentions 9, 11 and 132(c)(2), dated March 7, 1984, you iden-tify " inadequate treatment of systems interaction" as a defi-ciency in Applicants' program for environmental qualification of electrical equipment for the Shearon Harris Nuclear Power Plant ("SHNPP"). Describe in detail what you believe to be the relationship between systems interaction and environmental qualification of electrical equipment at SHNPP.

(b) Identify all electrical equipment and components at SENPP not included in Applicants' equipment qualification program which you believe should be included in the program

under the definitions provided in 10 C.F.R. 6 50.49(b). As to each such item, describe in detail the bases for your answer, including the reasons for identifying the item.

(c) Applicants were unable to find, after a diligent search, the quotation which you attribute to G. J. Boyd, et al., " Systems Interaction Methodology Applications Program" (December 21, 1979) (published as NUREG/CR-1321 in April 1980),

at 33. Provide the correct citation for this quotation. In addition, provide a citation for " Recommendation 9," which you also attribute to the above report.

9-11. (a) Describe in detail what you mean, in your an-swer to Interrogatory #9-3, by "the use of comparison to other systems in the testing."

(b) Identify all systems, electrical equipment and components at SENPP which you believe are affected by the al-leged deficiency referenced in (a) above. As to each such item, describe in detail the bases for your answer, including the reasons for identifying the item.

9-12. (a) Describe in detail what you mean, in your an-swer to Interrogatory #9-3, by the statement that "the tempera-ture inferences for equipment are in error."

(b) Identify the "past response (s) on another con-tention" in which you explain the alleged deficiency referenced in (a) above.

(c) Identify all electrical equipment and components at SHNPP which you believe are affected by the. alleged

e deficiency referenced in (a) above. As to each such item, de-scribe in detail the bases for your answer, including the rea-sons for identifying the item.

(d) Identify the supplier of the RTDs which experi-enced steam penetration during testing as documented in L. L.

Bonzon, et al. "An Overview of Equipment Survivability Studies at Sandia National Laboratories (SNL)."

9-13. (a) Describe in detail what you mean, in your an-swer to Interrogatory #9-3, by the statement that " estimation methods not applicable to actual or anticipated accident or normal operation conditions are used (see FSAR)."

(b) Provide specific citations to the FSAR and explain in detail why Applicants' estimation methods are not applicable to actual or anticipated accident or normal op-erating conditions.

(c) Identify all electrical equipment and components at SENPP which you believe are affected by the alleged defi-ciency referenced in (a) above. As to each such item, describe in detail the bases for your answer, including the reasons for identifying the item.

. 9-14. (a) Describe in detail what you mean, in your an-swer to Interrogatory #9-9(2d), by the statement that " test procedures understate radiation effects." Identify each and every way in which you believe radiation effects are l

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(b) Identify all electrical equipment and components at SHNPP which you believe are affected by the alleged defi-ciency referenced in (a) above. As to each such item, describe in detail the bases for your answer, including the reasons for identifying the item.

9-15. (a) Describe in detail what you mean, in your an-swer to Interrogatory #9-9(2d), by " lack of similarity between equipment tested & that installed."

(b) Identify all electrical equipment and components at SENPP which you believe lack similarity to equipment tested.

As to each such item, describe in detail the bases for your an-swer, including the reasons for identifying the item.

9-16. (a) Descrioe in detail what you mean, in your an-swer to Interrogatory #9-9(2d), by " failure to consider config-uration & orientation effects."

(b) Identify all electrical equipment and components at SENPP which you believe are affected by the alleged defi-ciency referenced in (a) above. As to each such item, describe in detail the bases for your answer, including the reasons for identifying the item.

9-17. (a) With respect to each and every alleged defi-ciency, error, omission, inadequacy or other criticism of envi-ronmental qualification of electrical equipment contained in your answers to Interrogatories #9-1 through #9-9(2d),

including criticisms contained in the documents (other than the SER) which you cite as bases for your answers, state whether 1

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i the criticism specifically addresses SHNPP's program for envi-ronmental qualification of electrical equipment.

(b) As to each criticism identified in response to (a) above which specifically addresses SHNPP's program for en-vironmental qualification of electrical equipment, state what aspect (s) of the program are being evaluated and identify the documents on which the. evaluation is based.

(c) As to each criticism identified in response to (a) above which does not specifically address SHNPP's program for environmental qualification of electrical equipment, state whether the criticism addresses the adequacy of NRC regulatory standards. If your answer is other than affirmative, describe in detail the bases for your answer.

Interrogatories on Contention 11 (Polyethylene Cable Insulation Degradation) 11-13. (a) In your answer to Interrogatory #11-1(d), you state that "[i]f the conductors or parts of sheathing or other things in contact with the insulation are intact, they may in-crease the (dose-rate] effect by such means as free radicals, chemical reactions, and emissions from induced radicactivity or secondaries from impacts of radiation into them." Describe in detail how free radicals might increase radiation dose-rate ef-fects.

(b) Describe in detail the chemical reactions which you believe might increase radiation dose-rate effects.

(c) Describe in detail what you mean by "emis-sions from induced radioactivity" and explain how such emis-sions might increase radiation dose-rate effects.

(d) Describe in detail what you mean by "sec-ondaries from impacts of radiation" and explain how such "sec-ondaries" might increase radiation dose-rate effects.

(e) Identify all documents, including relevant page citations, relied on in answering (a) through (d) above.

11-14. (a) In your answer to Interrogatory #11-1(e), you state that "[a] metal conduit, by creating secondary reradiation, and by induced radioactivity, would spread out ra-diation dose in time, increasing the [ dose-rate] effect. Sec-ondaries from other jacketing could also have this effect to some extent." Describe in detail what you mean by " secondary reradiation" and explain how such "reradiation" would increase radiation dose-rate effects.

(b) Describe in detail what you mean by "in-duced radioactivity" and explain how such radioactivity would increase radiation dose-rate effects.

(c) Describe in detail what you mean by

"[s]econdaries from other jacketing" and explain how such "sec-ondaries" would increase radiation dose-rate effects.

(d) Describe in detail what you mean by "would spread out radiation doce in time." Explain how such spreading would occur and why it would increase radiation dose-rate ef-fects.

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1 (e) Identify all documents, including relevant page citations, relied on in answering (a) through (d) above.

11-15. (a) In your answer to Interrogatory #11-7(a), you state that "[g]amma is not apparently the only radiation caus-ing degradation effects that vary with dose-rate." Identify all documents, including relevant page citations, relied on in making the above statement.

(b) State why you do not believe that dose-rate effects caused by alpha and beta radiation are bounded by dose-rate effects caused by gamma radiation. Describe in de-tail the bases for your answer.

11-16. (a) Describe in detail the bases for the state-ment, in your answer to Interrogatory #11-9(a), that

"[i]nspection should be very frequent as sudden insulation failures (e.g. cracking) are apt to happen randomly . . . .

Identify all documents, including relevant page citations, relied on in making the above statement.

(b) Identify all incidents of which you are aware in which there have been " sudden insulation failures" as a result of radiation dose-rate effects.

Request for Production of Documents l

Applicants request that Mr. Eddleman respond in writing to this request for production of documents and produce the origi-nal or best copy of_each of the documents identified or l

described in the answers to each of the above interrogatories at a place mutually convenient to the parcies.

Respectfully submitted, Waritalk &. IW Thom'as A. Baxter, P.C.

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

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn H. Hill Carrow CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 26602 (919) 836-7707 Dated: March 23, 1984 t

O March 23, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

j CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Interrogatories and Request for Production of Documents to Wells Eddleman Con-cerning Eddleman Contentions 9 and 11 (Second Set) ," dated March 23,'1984, were served this 23rd day of March, 1984, by deposit in the U.S. Mail, First Class, postage prepaid, to the parties on the attached Service List.

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Michael A. Swiger Dated: March 23, 1984

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFQRE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

i SERVICE LIST James L. Felley, Escuire John D. Runkle, Esquire Atr.ic Safety and Li nsine Board Ccnservation Council of Nor-h Caroli .a U.S. Nuclear Regulatory C2 mission 307 Granville Road Washington, D.C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, ~@e Atmu.c Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Camission P.O. Box 12607 Washington, D.C. 20555 Raleign, North Carolina 27605 Dr. James H. Carpenter Dr. Ric'.ard D. Wilson At:mic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatcry Cmmission Apex, Ncrth Carolina 27502 Washmgten, D.C. 20S55 Mr. Wells Eddlean Charles A. Barth, Esquire 718-A Iredell Street Janice E. Moore, Escuire Durham, Scrth Cr lina 27735 Office of Executive Legal Direct 0r

• .S. Nuclear Pagulatory C

  rmission o "- wd E. 2:nes, Es7;.c.re Wash = gten, D.C. 20555 V:.ce Pres:. dent a.ri Sen:.cr ::u .se; Carcima Pcwer & L:.gn: Cm=r.y Decketing and Service Section P.O. Box 1551 Office of the Secretary Raleigh, North Croina 275C:

U.S. Nuclear Pegulaccry Cx mission Washington, D.C. 20555 Dr. Phyl':.s . T.ccc =

108 3r:.dle Run Mr. Daniel F. Read, President Chapel Hill, North Carol =1 TU4 Q %NGE/E!.?

5707 Wayeress Street Dr. L:.rcia W. *ittle Raleigh, North Cr:1:.na 27606 Gcvernor's Wasta Managene.- h v 513 C.be arle Bu:.'d.=g 325 tbr n Salisbury Street Raleign, North Crolina 2 5 '- -

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-2 Bradley W. Jones, Esquire i U.S. Nuclear Regulatory Camission Region II -

101 Marrietta Street Atlanta, Georgia 30303 Ruthanra G. Miller, Esquire Atanic Safety and Licensing Board Panel U.S. Nuclear Regulatory Camission Washington, D.C. 20555 Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.O. Scx 991 Raleigh, North Carolina 27602 i

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