ML20087M071

Response to Applicant Interrogatories Re Eddleman 116. Related Correspondence

ML20087M071
Person / Time
Site:	Harris
Issue date:	03/23/1984
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
References
CON-DSB-177 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8403280344
Download: ML20087M071 (6)

Text

"

mTED CCRRMOND ,

e' COLKETED tlsW UNITED STATES OF AMERICA March 23, 1984 NUCLEAR REGULATORY COMMISSION '84 MAR 28 All :30 ,

LFF.LE OF SEU. :

DOChETING & SD N BEFORE THE ATOMIC SAFETY AND LICENSING BOARDBRANCH Glenn O. Bright ^

Dr. James H. Carpenter 4

James L. Kelley, Chairman In the Matter of

) Docket- 50 400 OL CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Units 1 ani 2) ) ASLBP No. 82-k68-01

} OL Wells Eddleman's Resnonse to Applicants' Interrogatories Re Eddlenan 116.

,-1(a).

G I relied on the FSAR, see 5-lh-82 filing and 6-28-82 amendment. I also rely on comnon sense and reasonable logic, and .

and exnerience f

onthetrainingingive-exnlosionsafetyandanalysisIhave.

(b) See (a). (c) See 5-14-82 filing, 6-28-82 anendment, and Board 1-11-83 order admitting Eddleman 116.

2 (a ) N/A (b ) , (c ) , (d ) N/A. The Board order of 5-27-83 does not require identification of nonexuerts -- it requires assertion of some other privilege if they are not identified.

3(a),(b),(c). No experts identified yet for witnesses. Parts (c)

(ii) and (iii) are irrelevant and would be objected to.

h(a) The FSAR section 9 original version; I haven't had time to do a search to see which undates to it I possess. See 6-28-82 amendment ,

re Eddlenan 116. (c) See the contention.

(b) Eddleman 116.

5(a) Will be identified in snecific resnonses below. (b) see (a).

6(a) Will be identified in snecific resnonses below.

l 7(a) None identified yet; however, the FSAR, CD&L filings, M(evdc (b) sec (a).h and' 10 CFR 50 Appendix R are likely to be used. (h)Nd (kMB (f

! 8403280344 840323 PDR ADOCK 05000400 g C3 0 _

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cpecific interrogatory responses 116-1(a). Yes. (b) Not to my knowledge. See 6-28-82 amendments to 5-14-8? petition to intervene. (c) N/A.

116-2(a) I don't have a complete list, and am still analyzing and will also ask discovery of you re this, and will ask the Staff. Please note that just complying with regulations does not guarantee Harris plant cafety (or the health and safety of the public) in the event of a fire.

10 CFR 50 Appendix R obviously applies.

116-3(a) I don't Know. (b) N/A (c) N/A. (d) Not analyzed yet.

116-4(a). I have not recently re-analyzed this section, but as I recall when I was putting together the 6-28-82 amendments I could find no reference to " fire resistive" or " fire resistant" that was not vague or otherwise unsatisfactory for (1) figuring out what it meant in practical terms, and (2) assuring safe shutdown or operation of Harris in the event of fire.

(b) I haven't had time to do an extensive search for this letter. I haven't located it, so I don't know now.

116-5(a). Look at the FSAR. I may have parachrased in writing the 6G28-82 amendments. (b) See FSAR. I haven't had time to re-analyze to find the references yet. (c ) I don't know. (d) I don't know. I have not located this document yet (see 4(b) above). I have located an

August 2, 1982 CP&L 9 response" re fire etc which does not have nage numbers I suspect that the fire barrier ratings would be based on tests not l

l reflecting the actual possible fire conditions and/or actual behavior of materials and/or fires, and/or actual positions of the barriers or materials as installed. This is true of standard flame arread and (e) fire tests for building materials and insulation in my experience. N/h, (f) I have a document Serial # NLS 8h-090 from McDuffieg CP&L to Denton NRC dated 2-248-84 which provides some handwaving, totally unsupported Neither the analyisis of by specific references to items present, etc.

fires or the " justifications" for exemptions therein, nrovide any factual references ofr justification beyond blanket unsunnorted statements. The analysis is faulty from the word "go" (or is it the word " fire" in a crowded nuclear plant?), see e.g. at p.2:

"In general .. . one can assume that the plant 's defense in denth fire protection amuruwe features will limit fire damage to the extent that unaffected plant systems will be able to attain safe shutdown'" This assumption is unsupported by analysis. The defence in depth should be specifically shown adequate to deal with fires and in all cases limit fire damage so thet unaffected plant systens will be able to attain safe shutdown. ,

! CF&L, of course, doesn't want to really work on such an analysis:

P.2 continues immediately after the above: "An extensive effort would be required to identify the effects of nostulated fires in all potential clant locations on all the olant systens which are normally

" Cpk1 won't do that, they say.

available to sunport safe shutdown.

They identify, they clain, a minimum set of shutdown equitnent.

But then on the next page (3) they say they assune no ciece of equipment required for safe shutdown is assuned to be out cf service for maintenance. At p.h they do not explain why no postulated fire can prevent reactor trips. What about cable fires? What about a fire 1 that releases particles that foul terminal blocks or switches or relays? (e.g. jamned relays at Salen; DS-416's failing to operate ).

CP&L in its analysis assumes systens are operable rather than sh_owing how they can be kept operable in spite of nossible fires ( s e e e . g. pn 2-11 l

of this " anal? sis"). I an reviewing this docunent further and may .

have other updates to make re it (etc) later.

3 M

_h-116-7(a) First, it's not clear that Applicants have identified the maximum credible Afire for each area. Their" analysis"I reviewed for the 6-28-82 amendment was mostly just assertions. I am still analyzing this question. Of course "maximun credible" is an Achille s heel of the nuclear industry because y'all usually don't consider credible things that actually can hapoen or have hanpened.

116-8(a) I believe 10 CFR 50 App R. section L requires such capability, logically. I an still analyzing obher rules re this, & other regs, requirements, publications, etc. will be looked into when I have time.

Obviously if there's a reactor tr'ip during a fire, the trip may be due to an acciddnt. The firefighting capability necessary to maintain safe Whutdown capability i is required by Anpendix R section L whenever the reactor is scranmed or otherwise shutdown.

I presune this means shutdowns during accidents, too, as accidents are not specifically exempted from this requirement in Section L.

Moreover, the question shows CP&L's attitude toward safety, i.e.

"if there's no rule requiring us to fight fires during an accident, o you can't make us get ready to do it" as I would phrase your apparent I

position. Protection of the public health and safety logically l

requires that you be ready to fight fires whenever they threaten the public with radiation releases, and fires during accidents, especially those which threaten the equipment needed to keen the reactor safely shut down or get it shut down, obviously pose such a threat.

10 CFR 50 Appendix a A General Design Criterion 3 says you shall minimize the effect of fires. No excepticn for fires during accidents is in that criterion. (b) See above. (c)N/A l

-5 116-9. Applicants scy in thet rasnonse that "SHNPP will have a procedure which provides for a fire brigade as per IAW BTP CMEB 9.5-1 Section C.3.b"~ This response is not verified (no statement under cath attached) and provides for a procedure, not for the bridade itself.

CP&L is known for its failures to follow procedure (see E.g. pp 6-9 of .*.CRS subcommittes on Harris, Jann 3,1984, transcrpitmt).

116-10. The following unverified statement is the entire response to 280.h in your attachment A: "SHNPP will equip its fire brigade km.igaSa with the minimum equipment listed in BTP CHES 9.5-1 Section C.3.c." ,

116-11. The following unverified statement is the entire response to 280.5 in your attachment A: "SHNPP will have procedures which will require fire brigade drills as discussed in IAW BTP CMEB 9.5-1 Section C.3.D.7". Noticex this says procedures, not drills. See 9 above re failure to follow procedure. Also, CP&L had procedures requiring leak rate tests on the Brunswick containment, or should have ha'd them since the tests were required, and still didn't do the test for 4 years. CP&L's assertion, even if it said what you cal &im it does (it doesn't) is worthless because of such behavior by CP&L in the past. The respohse (unverified) says nothing about drills at regular intervals. It says "as discussed".

VEPIFICATION

• Wells Eddleman hereby affirms that the above responses are true to the best of his present knowledge and belief.

3-23-84 // @ ~

Wells Eddleman PP.0 DUCTION OF DOCM!ENTS.

I believe the only documents referred to above are ND.C documents or are a'1 ready in your possession. Please contact me if there are gdae others you need, and we'll find a mutually agreeable time & place to f4A" M

l NOTICE RE DOCUMENTS ON l JOINT SEVEN (Stean Generators) and j Joint ONU (Managenent Incapability)

Wells Eddleman has received numbers of documents relevant to Joint Seven, and some others relevant to Joint one, within the last two weeks. He has not catalogued then yet. They can be made available for inspection and conying at a mutually agreeable time by contacting him.

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