ML20087M075
| ML20087M075 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/26/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| CON-DSB-165 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8403280347 | |
| Download: ML20087M075 (16) | |
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RElliTED CORRESPONDENCE 1C ~D UNITSDOSTAEES OF AMERICA (cfhAlS8rWICf.
NUCIEAR TORY COMMISSION h'b
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BEFORE THE ATOMIC- SAFETY AND LICENSING BOARD a 01enn~0.. Bright hQ h N
! IV.%7ames M. Carpenter James L. Kelley, Chairman / hff W & W b )q In the Matter of W COhh Dockets 50 400 OL CAB 0 LINA POWEB AND LIGHT Co. at al. 6 (Shearon Marris Nuclear Power Plant, Units 1 and 2) ASLBP No. 82-h66-01 OL a % A E M hveaoa )
Wens Eddlen n's Interrogatories to MRC Staff
. Set) >
Wens Eddleman bereby requests the NRC Staff to answer the following or such other date as counsel for the Staff interrogatories and I agree on.
before '/pnf 141989Ihese interrogatories are subritted under 10 CPR and inquire into the studies, information, and knowledge ofSince EC staff withread I cannot respect to my contentions, on which discovery is now open. l
' the minds of the staff, and this information is not contained in documents which the staff has provided to rie I an unable to obtain this inforsation by ether means. W ere the information is contained in a document I can obtain l
i
! from NRC (Public Document Room, etc) I stin need the identification of the l document in order to obtain the information. The staff has resources and r information dich exceed eat I have, and as a party,' their position and information are necessary to making my case in this proceeding. These interroga-tories are continuing in nature and should be supplemented when answers change.
OEKliRAL IICERROGAIORIES (FIRST SEI)
For each of contentions 70/M1, E adck Eddlenan contentions.N / Ikk l
l O/ s I$provide Il please '132(c)(i 65 we foI)Iowing information by answering ends of these quest
- 1. Wat is MRC Staff NsIan n th , subject matter of this sententiont i n into,(a) this contention (b)
- 2. Bas NRC Staffna an'Wnybis the subject matter of this contention (c) the anegation(s) in this contention (d) the basis of this contention (e), the information relied upon by intervenor(s) in support of this contention?
- 3. For an parts of your response to Interrogatory 2 above for dich your answer is affirmative, please provide the fonowing informations who made the analysis, inquiry, study or investigation; dat was being considered in such analysis, inquiry, study or investigation ("AISI"); the content of the
- AISI, the results of the AISI, whether the AISI has been oompleted, tether a date for oonpleting the AISI has been established if it is not complete, what that date is, au documents used in the AISI, an persons consulted 8403280347 840326 PDR ADOCK 05000400 0 PDR 3
l . . .
en in tho ocurse cf the AISI, an docun:nts containing infcrmaticn disc 3verad or analysis or study or information develsped during cr es a result cf tha .
AISI (identify each such document and state what information or results it contains), t ether staff believes additional analysis is w and Wether any Persons participating in the AISI are to be caned as 1
witnesses for the Staff in this case,and dat questions th
- 4. For au responses to parts of (2) above for dich RC staff's answer is other than affirmative, please state (a) dether EC staff plans to perform any AISI t ether on thisplans contention, (b) wh
- - E C Staff for.AISI (even though it has not been made) (c
' on this contention include a date for beginning or for ending)such W at AISI AISI, i
(d) those dates, for all affirmative answers to (c) above, (e RC staff will undertake on a uthis contention reasons
to undertake on this contention (g)(h) an reasons why no AISI has been ,
this o ntention if none is planneddone yet on this contention if none ha of RC staff with respect to this contention are.
- 5. Identify an documents the Staff relied on in opposing the admission of this contention, and av specific facts not stated in the Staff's opposition to admission of such contention (already filed in this case) upon which Staff relied in making such opposition. l
- 6. Identify an documents not identified in Staff's interrogatories to Wens Eddleman or to Joint Intervenors (to present -- a continuing interrog upon sich the Staff relied in making each such interrogatory.
l
- 7. Identify by name, personal or business address, B C staff position or title (if av), and telephone neber (if known) each person on RC staff or consultant to RC staff or known to EC Staff or consulted by BC staff in the staff's analysis of the subject matter of this contention prior to (a) its filing (b) its adnission; state for each such person what analysis i
was performed ty that person.
) 8. State au professional qualifications
' 1.4.
of each person identified in response to interrogatories 7,, ' "
i
- 9. Provide ag statements of the analysis made by persons identified l in response to interrogatories 3,4, or 7m above, and identify an documents l' oontaining such information or statements not previously identified.
- 10. Give the identifier maber, date, souros, and title of all documents
' identified in response to interrogatories above, Wich are available through RC PRE (Public Document Room).
H. Min RC Staff make available copies of documents identified in response to the above interrogatories to visus Eddleman for inspection and copying, for documents not available through RC's Pmt
- 12. Identify ty name, BC staff position if ag, address and telephone namber each person som BC staff intends to azz use or can as a uitness in this proceeding.
- 13. State fully the professional qualifications of each person identified in response to interrogatory 12 above.
- . _ _ _ _ . __ *W*T**vwe,n,_ - ~ ~ - - . _ _ _ }
3 14 Sumarise the position (or picnned testimony) with respect to '
each contention on which such person is expected to testify, for each person identified in response to interrogatory 12 above.
- 15. Mas EC Staff, any witness identified in response to interrogatory
- 12, or agone acting in behalf of the Staff or such a witness or at their direction, made any calculation or analysis (not identified in response to interrogatories 1 through 4 above) with respect to this contention?
- 16. If the answer to interrogatory 15 above is yes in any case, provide the name, business or personal address, telephone number and professinnal qualifications of each person who has made such calculation or analysis, i stating for each Wat contention it relates to, what person (or Staff) it was nade for or at the direction of, and identifying an docunents containing such calculationer analysis and an docunents used in r.aking such calculation or anlysis or relied upon in it or supplying intornation used in it.
17 Provide a sumary of each AISI, calculation or analysis idum for which the answer to interrogatory,15, or interrogatory 2 above, is yes.
- 18. Please give the accession nunber, date and originatbr of each doeur.ent identified in response to interrogatory 16, which is available at the KRC PE.
s Win RC Staff make available to Wens Eddlenan for inspection and 19 ,
copying all doenents identified in response to interrogatory 16 above which are not available through the PET
- 20. Identify each person, including telephone number, address, and field y
of expertise and qualifications (cor.plete) (if any) fa who answered interrogatories with respect to this contention; if note than one person contributed to an answer, identify each such person, providing the infornation requested above in this interrogatory for each such person, and state what each such person's contribution to the answer was, for each answer.
- 21. Identify an documents dich the Staff proposes or intends to use as exhibits with respect to this contention during this proceeding, including exhibits of Staff witnesses (identifying the witness for each, if such a
~
witness has been designated), and exhibits to be used during cross-exa-dnation of witnesses of a v party (stating for each which uitness it is to be used in cross-exanination of), and identifying for each the particular pages or chapters to be used as exhibits.
- 22. Identify an docunents which RC staff relied upon in answering interrogatories with respect to this contention, which have not been identified in response to interrogatories 1 through 21 above, stating for each which answer (s) re dich contention (s) it was used for, and each specific fact and page number therein on dich EC staff relied or which EC staff used in answering such interrogasto y.
- 23. Please give the accession number, date, and originator of each document identified in response to interrogatories 21 or 22 above which is available through the EC PE.
- 24. Will MRC Staff provide Wells Eddlenan with ocpies of the documents
$dentified in response to interrogatory 21 or 22 above Wich are not available at the P E , for inspection and copying?
- ,e.-
h
- 25. Idcntify any other information or sourco of information not identified in response to the the above interrogatories 1 thru 2h upon which any member of NRC staff reliefd, or which any such i member of staff used, in answering each interrogatory with respect i to this contention, naming the contention and response in which !
each such source was used, and the location of the information l used or relief on in such source (e.g. page number, section, chapter, etc).
26 (a) Does the Staff now agree with the contention? (b) Does the ;
Staff now agree with any part of the contention?
27 If answer to (b) above is affirmative, which part(s) and why?
INTERROGATORIES ON JOINT SEVEN (Steam Generators ) l 128. Identify each tube failure analysis which (a) the Staff relies on l l
(b) you rely on (c) the Staff allows CP&L/NEEMPA to rely on, for the l Shearon Harris Nuclear Power Plant steam generators. Identify all documents (d) containing (e) concerning each such analysis, and (f) concerning Applicants' reliance on each analysis.
129. Identify each tube failure analysis you believe Applicants (a) rely on (b) have used, re Harris stean generators. Please identify all documents containing each, and all documents re Staff AISI re each.
130. Identify all constituents of the Harris loose parts nonitoring system (s) for each Harris steam generator. Indicate which are safety grade. Provide a copy of each diagran, bluenrint, safety analysis, analysis, or other AISI concerning each constituent or comoonent of each such systen.
131. Please identify all studies you possess, or which have been done by or for the NRC or its staff, concerning (a) corrosion in steam generators with AVT water chemistry (b) conrrosion in steam generators with carbon steel support plates, where (i) the steam generator uses Inconel-600 tubes with the sane heat treatment used on the stean generator tubes at Harris (ii) the steam generator uses Inconel-600 tubes (iii) the steam generator is a Westinghouse D-4 (iv) the steam generator uses Inconel-600 tubes and the condenser uses aluminum bronzexm components (v) the steam generator uses Inconel-600 tubes and the plant is not cooled by salt or brackish water, or (vi) the steam generator is a Westinghouse D-h and the plant is not cooled by brackish water. Please senarately identify each document which apolies to each of (i) thru (vi) above.
NSSS 132. The VC Sumner plant is similar to Harris in design and stean generators. (c) Dom you sgree with this statement? (b) What is VC Sumner's present lifetime capacity factor in commercial operation?
(c) How long did VC summer spend in testing between receiving a fuel load license or low power license, and beginning commercial operation? (d) How much of the time of testing was attributable to tests ordered on the steam generators at Summer? (e) What are the
, model numbers of each stean generator at VC Summer (i.e. are they l D-hs, D-3s, D-5s, or what?)
133 (a) What do you consider the maxinum credible accident involving steam: generators at Harris? (b) What do you consider the maxinum i
credible accident involving steam generator tube (i) leaks (ii) failures at Harris (Shearon Harris Nuclear Power Plant)? Please state all reasons
5 for your answer and identify all documents concerning each such accident and/or any Staff AISI or such an accident either at Harris or at any other plant with similar steam generators. Please also identify any generic analysis in your possession or of which you know, concerning each such accident.
134. Please identify all documents in your nosasession concevning steam generator tube cracking (i) at any plant with Westinghouse D-4 steam generators (ii) at any nlant with Westinghouse steam generators and AVT water chemistry (at any time) (iii) at any plant using AVT water chenistry which has carbon steel tube support plates and Inconel-600 tubes (iv) at any niant w$ th West? nghouse D-k steam generators, AVT water chemistry, and Inconel-600 tubes subjected to the sane heat treatment the Inconel-600 in the Harris steam generators was subjected to.
135 Have you made any analysis of (a) the amount of radiation exposure (b) the total person
- rem, (i) actually (ii) projected, which would be incurred or is incurred in (c) insnecting (d) cleaning (e) maintaining (f) flushing (g) repairing (h) plugging tubes in (j) replacing, steam generators made iy Westinghouse, e.g. Dwhs, at (k) Harris (1) any other nuclear plant. Please identify each such analysis and each plant it applies to. If you have made any generic studies of radiation exnosure associated with steam generators re any of the items (c) thru (j) above, please identify each such study. If you possess any generic studies of the natters inquired about above, please identify each such study.
136. What projection, if any, was made re radiation exuosure to personnel working with steam generators for (a) Krako (b) Ringhals 3 (c) McGuire 1 (d) McGuire 2 (e) Catawba 1 (f) Catawba 2 (g) VC Sunmer (h) Byron 1 (i) Byron 2 (j) Harris 1, prior to each such unit's actual or planned commercial operation? Please state which of the above projections you consider accurate, and why each is accurate or inaccurate in your opinion. For those where the estinates are considered inaccurate, please provide any estimate you believe is more accurate.
137. Please identify each renort otr document by Sciance Avnlications INC (SAI) concerning steam generators or problems with then, which you possess. Please state which, if any, of the recommendations in each such renort the Staff will require H arris to innlenent prior to commercial operation. Please state, for each such reconnendation, all reasons why you (i) will, or (ii) will not, or (iii) are not sure if you will, require such recommendation to be innlenented at Harris.
138. Please identify all documents concerning the kinds of foreign objects (1) that have been found in steam Generators or asscciated
$1 ping at nuclear power plants in the US (ii) that can be detected by the loose parts monitoring devices to be installed at Harris ("i) j that have been found in stean generators where nonitoring devices of the same types or models to be used at Harris are in place, particulavly those found without being detected by the loose parts monitor (iv) which cannot or probably would not be detected by the loose nartas mohitoring devices or systems now planned to be installed at Harris, 139.
Please state what the effect of SG minxm tube exuaision per NUnEg_
1014 will be on tube (a) wall thickness (b) residual stress (c) integri y
(d) resistance to corrosion (e) resistance to cracking, in your i opinion. Please give all reasons for each such answer. 1 (f) Please state all modifications Applicants have stated they (i) have performed (ii) will perform on Harris steam generators, the date for each, and which dates are prior to exnected commercial operktion.
140. Please identify all analyses of tube vibration in Westinghouse
. D-h staan generators with which you are fa&iliar or which you know of.
Please state which are based on actual observations, and which are
, theorentical. Please state which of these analyses, if any, would be applicable to Harris. Please identify any analysis of tube vibration in t he Har=is stean generators which has been nade by anyone.
Please state your opinion as to the (i) validity (ii) reliability, of each such analysis.
Interrogatories on Joint I 141. Please identify all docunents in which NRC has inouired of its inspectors concerning the capcbility of CP&L management to safely or properly manage (a) Harris (b) Brunswick (c) Robinson 2.
Please produce a cony of each answer to each such inquiry, giving the date of each and the name of each insnector responding, if 1 known (Joint Intervenors will consider measures to urotect the 4
privacy or identity of such versons if Staff so desires).
Ik2. Please state each fine (a) proposed (b) levided against l CP&L for nuclear operations. Please identify all documents concerning each such fine, including the reasons for it, CP&L's resuonse to the notice of violation involved, CP&L's response '
to the pronosed fine, any appeals of the fine by CP&L, and/or any changes in the fine. (c) Please state your oninion of the quality of managenent that each such fine indicates. (d) Do you have any otinion as to whether (i) the number (ii) the severity (iii) the number and severity (iv) all aspects of, these fines casts any doubt upon the capability of CP&L management to assure that its nuclear plants are.onerated safely at.all times? .If so, please state your ouinion and give all reasons for it.
(c) Do you have any opinion concerning whether any or all aspects of these fines cast any doubt upon the capability of CP&L management l to operate Har-is safely at all tfres if Harris 1 is licensed to run?
If so, please state your'oninion and give all reasons fo" it.
143. Please list all the things -that' are necessary in your view to safely axi manage the operation of a nuclear plant. Please list for each any doubts any member of the Staff has concerning CP&L's canabilities .
i re that thing for operating Harris. (See J.I. interrogatories to Applicants, 2/23/84, at I-48, for examples of what we 're asking about. )
144 Has CP&L ever had a problem at a nuclear plant in operation that relates to or was partly or entirely caused by inadequate (a) QA/QC (b) design (c) maintenance (d) management? Please identify each prob 1cm and the plant it occurred at and the date(s). it occurred.
145. Has anyone on the Staff done any. followup on the problens identified bv F.S. Cantrell in his testinony in the Harris CP renand of 19797 If so, identify each such person and state all results of each such <
.'l
followup. Please identify all documents concerning each.
146. -Please identify all documents, including SALPs, in which ,
the Staff identifies a need for improvement in management of any CP&L nuclear facilities or facility.
147. Please state how many times FRC Staff has met with CP&L (a) plant management (b) senior management (VPs or higher-ranking-offiedrs), concerning problems at CP&L nuclear plants. Please give the date of each such meeting, who met with whom, which were the CP&L people, whether a transcript or notes of the meeting exist, j the identification of all documents concerning what went on at the meeting, including transcript (s) or notes or recordings, and please also state whether management or improvements needed in management and/or mabagement attention were discussed. Viease identify all documents and state what problem (giving the agenda of each such meeting,s) were discussed in 1k8. Please identify all documents in your possession concerning (a) Staff turnover at Brunswick (b) Staff turnover at Robinson 2 (c) Staff turnover at Harris (d) turnover in CP&L nuclear management
, at corporate headquarters. (e) Please state when, if ever, NRC 4 staff or any member of it has conmusidered turnover in staff at (i) Brunswick (ii) Robinson 2 (iii) Harris (iv) CP&L cornorate nuclear management, to be (aa) a problem (bb) a serious problem (cc) a manux cause of problems (dd) a factor connounding other problems.
Ih9. Please state if there is any nuclear management in the US involved with commercial nuclear power plants, concerning which (1) the Staff (ii) anyone on the Staff, holds the opinion that that management is (aa) unqualified to operate nuclear power plants safely (bb) doubtfully qualified to operate nuclear power plants safely.
150. Does the NRC Staff or anyone on it have any documents concerninF management weaknesses at nuclear power plants or mana6ement weaknesses of nuclear power utilities (or any nuclear utility)? If so,'please identify all documents containing such information, nost snecifically I any such information concerning CP&L not identified in response to the above inter =ogatories, any information comparing management of <
nuclear utilities and/or nuclear power plants, or assessing the l management competence of any nuclear utility (e.g. Metronolitan Edison, GPU Nuclear,-CP&L).
i 151. Please state all reviews WRC Staff has undertaken of the (a) qualifications (b) actual competence, of '(i) engineering (ii) operating (iii) maintenance (iv) management personnel at any CP&L nuclear plant.
For each plant please identify all documents concerning each such review. Please state the results of each such review.
152. Has NRC Staff ever done the analysis of the linited appearance statement of Wells Eddleman in the Harris CP remand hearing of 1979 4 which ASLB Chairm Ivan Smith' stated to Staff attorney Reis would be I sought by the Board? If so, please identify all documents concerning such ' analysis.
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, i 153 Is there any member of N90 Staff who believes that CP&L l (a) is incapable (b) myay not be capable, of safely managing, building, engineering, operating, and maintaining the Harris 1 plant over its entire expeicted operating life? A If so, please identify each such person (person) and produce that person as a witness in the management hearing scheduled for Septenber 1984 (or any other hearing on management capability on rescheduling of that hearing).
154 Has anyone studied the number or severity of core-damage accident precursors which have occurred at CP&L's nuclear plants? If so, i
i' state who, when the study was done, and what precursors were identified and what hazard (s) each posed. Please state your oninion of the adequacy of CP&L management, design, cnd operation and maintenance related to each such precursor. Please state your orinion of the adequacy of CD&L senior management's response to each such precursor.
t Ple ase identify all documents containing or concerr.ing each of the things inquired about above, in this interrogatory.
155. Do you know of any nuclear-related management in this country which is sufficiently incompetent that NRC (i) wcu1( not suonort (ii) might not support, issuing a nuclear operating license to j such management, or issuing an order allowing such managenent to onerate a nuclear power plant? If so, identify each such management and compare it with CP&L as to its adequacy and characteristics.
156. Has WRC Staff undertaken any review of the statements made by CP&L witnesses in the 1979 Harris CP remand hearinrs on management canability? If so, clease identify each such review, when it was made, and identify all documents 'concerning it, who wvote it, and what use, if any, NRC Staff has yet made of it. Indicate if it has been shown to anyone working to CP&L and, if so, whether that person or persons were or included senior management (ie those with rank of Vice President or higher), and when it was shown to each. Please identify each person at CP&L you have sent a cony of each such review to.
157. Have you ever caught a nuclear utility odr.er than CP&L innroperly disposing of low-level radioactive wastes offsite in (a) landfills (b) scran yard (c) scrcy recycling oueratiens? If so, please identify each such utility. If not, please indicate what your o, inion is as to CP&L management's capability in light of the improper disposal of LLH;I at Brunswick.
Interrogatories on Eddleman 9 158. (a) Does NRC Staff state on pp 3-49 thru 3-51 of the Harris SER, cdrtain information it will require CP&L to subnit re environnental qualification of electrical equipnent? (b) For each iten of information l listed on pp 3-49, 3-50 or 3-51 of the Harris SER, have you stated all the reasons for requiring that iten to be subnitted? If not, please
- state all additional reasons, including any rule or nolicy or regulation I
which requires the submission of the infornatich, why you require each
! such iten(s) of information to be subnitted.
159.
iten (Has
- 1) onCP&L submitted p.3-50 any (tor iten lists (1)) ofofthe equipnent identified Harris SER? Please under vrovide a copy of each such list.
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-9 160. .Wh n does the Staff cstimate its ravicw of tha onvironnontal qualification of electrical equipment at Harris will be completed?
I 161. Does the resolution of the case UCS V. NRC, DC Circuit Court of Appeals 6-30-83 (this is the correct date, not fall 1s483 as stated in past interrogatories to Apulicants) have any effect on your review of the environmental qualification of electrical equipment at Harris? If so, please state what effect, reasons for it, and please identify all documents concerning each such effect.
I 162. Is there any item of electrical equipment at Harris which, in your opinion, has not. et been demonstrated to be environmentally qualified as required by' .'UREG-0558 (b) 10 CFR 50.49 (c) 10 CFR 50 Appendix A, General Design Criterion 1 (d) 10 CFR 150 Appendix A, GDC 5 4 (e) any other NRC rule or regulation (specify)? If answer to any part above is affirmative, please state whether you can identify (1) all such parts (ii) any such part or iten (iii) all such itens, and identify those you can readily identify.
163. Has NRC Staff itself tested or had tested any of the e quipnent used as electrical equionent at the Harris plant? If so, pisase identify what equipment, who tested it, when, with what results, according to what procedure, who auproved the procedure f or the test (s), who ordered the tests, who evaluated the test requits, what the evaluation of the test results was, whether anyone else has evaluated the test t
result dare(s)(s),test andresult identify(s),
all documents analysis of concerning(s)he the result tests,
, and test nrodce-adequacy of the tesK,s) tr results.
i 164. Has anyone other than CP&L and N90 Staff tested er had tested any of the electrical equipment to be used at Harris 1? If so, please answer all parts of the second sentence of interrogatory 163 above concerning each such test.
165 Please identify all deficiencies vou are aware of in CP&L's (a) subnissions (b) dats (c) testing (d) testing renorted in submissions, concerning environnental quklification of electrical equienent at H,arris . Please identify which equipment each such deficiency applies to.
Please identify all documents concerning each such deficiency. ,
166. Has an (a) review (yone expressed b) analysis (c)any proconcerns re the adequacy of NRC's of electrical equipment for (i) grams, nuclear re power environmental plants (ii)qualification Harris?
(e.g. Sandia National Labs personnel). Please identify each such person and all documents expressing such concern (s). Please identify all documents written by the Staff resnonding to any such concern (s).
cQ.y plWE459 y soc 4 167. Is there unqualified electrical equipment in (a) the Brunswick plant, Unit 1 (b) the B"unswick nient, unit 2 ( ) the Brunswick plant
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common facilities (d) HB Robinson unit 2 (e) other facilities at Robinson, ,
at present, in your opinion? If so, what assurances can be given that pwaht== all man electrical equipment at Harris will be qualified l prior to (and/or during) operation? Please give all reasons for each of your answers.
168. Has CP&L stated any length of time it will take to submit the information requested in the SE9 pp. 3-49 thru 3-51? If so, whatdate is the last for submission of such information? Has CP&L resisted providing any information requested in the Harris SEP pp 3-49 thru 3-51?
If so, what information and why? Is the Staff still seeking any of this
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infomation? If so, what, and why9 169. Its there any other information not identified in the SER for Harris which CP&L must submit to NRC to denonstrate environmental i
qualification of electrical equipment at Harris prior to commercial operation? If so, what its that information, and has it all been submitted? If not, why not? Is the Staff expecting to receive any of this information? If so, which information do you expect, and when? Is there any required information which you do not
! expect to receive from CP&L? If so, what ,informatioh. If you know
- why CP&L hm==tixam is not providing it or hasn't provided it, please state why and identify all documents concerning such non-provision of into.
170. Has the Staff applied any of the questions or concerns in Union of Concerned Scientists (UCS) February 7, 198h sunplemental netition l concerning environmental cualification of electrical nouirment to I its review of enavironmental qualification of electrical equipmce+
for Harris 17 If so, which, and how and whmy? If not, for each which 4
you have not applied, why not?
171. Please identify all documents in which you review the environmental qualification of electrical equipment for Harris 1, including work papers, summaries and other reviews.
172. Please state whether you consider the FSAM for Harris to have l completely documented adequate environmental qualification of electrical equipment for Harris 1 at present. Please give all f*{.*{*h "*[hde histNe COLN(4t82 af ffGms ? W INTE9PCGATORIFS ON EDDLEMAN 11. (. g g i 172rK Please identify all studies of accelerated degradation of l insulating materials including (i) polytethylene (ii) neoprene, when exposed to radiation at lower dosse rates instead of high l dosso rates, with wnich you are familiar, particulkrly any ccn ducted by any group including Ken Gillen or R. Clough or anyone else working for Sandia National Laboratories.
I 173 Please state what concerns, if any, anyone working with (a) NRC (b) Sandia National Laboratories (c) anyone else, has expressed re the effset of more ranid deterioration of insulating materials exnosed to the same total dose at low dose rates, connared to the deterioratiokn l resulting from the same total dose at high dose rates, as it applies to insulation used in safety-related eculpment and enuinment that can affect safety-related equinment in nuclear nower niants. Please identify all documents in which such concerns are expressed and any documents in which NRC staff analyzes or resnonds to such concern (s).
174 Do you know where at Harris polyethylene insulation is used on (a) cable (b) wiring (c) electrical equipment, as insulation, at Harris?
If so, please state where, including which elevations, which buildinEs, which radiation zones, etc, to the extent you know.
175. Has (a) the Staff (b) aryone, conducted any study or analysis of the or ineffect Eddleman of more 11 rapid deterioration (e.g. as exuleined in #17m3 above nuclear plants in) general. Please Harris on safety at (c) identify (all documents cond) cerning any nuclea or containing each such ' study and/or any Staff AISI or resnonses re
-each.~
176. Please dancriba c11 forms of degradation of nroparties or of the substance of polyethylene which occur when it is e xposed to nuclear radiation. Please identify all documents you know of concerning such forms of degradation (a) at low dose rates (b) at high dose rates (d) at any dose rates.
177. Please describe all forms of degradation of properties or cf the substance of neoprene which occur when it is ernosed to nuclear radiation. Please identify all documents you know of concerning such forms of degradation (a) at low dose rates (b) at high dose rates (c) at any dose rates (d) at the dose rates described in NU9EG/CR 2156, 2157, 2763 or 2877.
178. Has the Staff made any AISI of the effect of the degradation i effects described in (a) NUREG/CM 2156 (b) NUMERG/ CR 2157 (c) NU9FG/CR 2763 (d) NUREG/CR 2677 on (i) insulation at Harris (ii) safety of the Harris plant (iii) safety o.f any nuclear plant (iv) safety of nuculear power or nuclear power plants? If.so, please identify each such AISI, who did it, who ordered it done, when it was.done, and all documents containing any of the AISI.
179. Has the Staff retained concetent scientists to analyze the cable insulatirn at Harris? If so, have they analyzed any cable insulation yet? Have they reviewed the radiation sources inside the Harris clant? If so, what reviews have they done so far, and what have been the results. Please identify the documents concerning (1) the qualifications of each such scientist (ii) the analysis or review (.s) done by each. (CF your interrogatory 55).
180. Is utlyethylene copolymer used in any insulatien at Harris on electrical wiring or cable (e.g. in Anaconda flexible conduit)?
If so, what do you know about the degradation of n&lyethy3 ene co-i' polymer under conditions of long-tern radiation exuosu e at various dose rates including those described in NUREG/CR 2156, 2157, 2763, or 28777 Please identify all documents you know of concerning the degradation by radiation and/or other factors of nolytekthylene i copolymer.
181. Do you know what actions, if any, CP&L has taken in response to NRC IN 83-72 of 10-18-83, re Anacond Ifso,pleasestateallsuchactionsatgflexiblegonduit? runswick, hobinson 2, (c) Harris, and identify all documents concerning each such action.
i 182. Has (a) NRC Staff (b) CF&L (c) anyone else, to your knowledge, made any study of radiation dose rates exnected durinF (i) normal oneration (ii) accidents, at any locations inside the Harris niant where insulated cathaxaxble or mai wiring is used, or where l
polyethylene or neoprene insulation is used? If so, which of these studies (please identify then all) takes any shielding effects into account, and how? Which give actual measured dose rates to cable or wiring insulation in similar situations in other nuclear niants?
Which deal with radiation doses (iii) at various reactor vower levels (iv) during shutdowns once the system is past initial ~ criticality (v) during refueling or other outages .
183. Has'(a) NRC Staff (b) anyone else, ever examined samples of caibale or wiring insulation from actual operating nuclear power niants for degradation? If so, please identify all docunents concerning such exan-
!- ination -(or testing) of insulation including nolyethylene or neoprene. ,
-212-Interrogatories on Eddleman 41 (not relating to welder info just received) 184 Has CP&L completed its 100% reinspection of nine hangers at Harris? If not, when does CP&L tell you they expect to comnlete it?
185. Have you inspected any more pipe hangers at Harris since you last answered interrogatories? If so, which ones, with what results?
186. Please identify all documents pertaining to the matters and )
inspectione inquired about in interrogatories 184 and 185 above.
187 Has any (i) wielder (ii) wielding inspector, ever been fired or discharged or asked to resign from Harris because of (aa) naking (bb) apnroving, defective welds or defective pipe hangers? If so, please identify each such verson.
188. Has any (i) welder (ii) welding inspector (iii) other nerson, ever been (aa) disciplined (bb) laid off (cc) sent for retraining (dd) required to be betrained or to take further training, because of (A) making (B) approving, defective (iv) welds (v) pipe hangers, at Harris? If so, please identify each such person.
189. Have you ide_.tified any defective pipe hangers at Harris ,
which have not yet been repainred? If so, which ones?
190. Have you wvitten any evaluation or recommendations for improvenent (or has anyone working for NRC Staff or CP&L done so) for CP&L Harris QA or QC concerning their inspection of' pine hangers (a) ever (b) since 9/1/1980? If so please identify each document containing each such evaluation and or recommendation.
191. Have you contacted any of the welders identified to Wells Eddleman by CP&L in response to his interroEatories served in 1983?
If so, please describe the nature of each such contact and the infornation (a) you gave to (b) you received from, each such welder.
Please identify or state any statements, questions, or other things you have communicated orally or in writing to each such welder, and all response (s) you have received to each.
192. Please icentify all documents concerning reinspection of pipe hangers at Harris which have occurred since June 1, 1983 193. Please identify all documents concerning defects in nine hangers at Harris found since 1 June,1983, which (a) you nossess (b) you know someone else nossesses (please identify who nossesses it, if you know).
194 Has (a) CP&L (b) Daniel International (c ) anyone else including emuloyees of CP&L or Daniel, who worked at the Harris site, ever (i) made any false statement to NRC concerning pine hangers at Harris (ii) made any statement to NRC concerning ripe hangers at Harris, which was later shown to be false (iii) made~any statement to NRC concerning the imi pipe hangers or any pine hanger e t Harris, which was later shown to be inaccurate, misleading or incorrect? Please give all details and identify all documents concerning each such statenent.
195is la)How serious do you believe "0K" tagging of defective pine hangers as a breach of faith with NRC (b) as a violation of NRC regulations (c) as a threat to safety of the Harris plant? Please give all reasons for each of your answers.
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Interrogatories on Eddicman h5 - l 196. Please identii'y all water hammer incidents in PWRs since 1-1-83 that (a) caused damege . (b) caused a safety problem (c) were reported by NRC to Congress as significant svents (d) were required to be reported to Congress by the NRC. Please state the relevance of each such incident to Harris and all information suoporting your answer.
197. Have you evaluated the conplete start-up test program for Harris 1 as it involves water hammer in the systems mentioned in.
Eddleman 457 If not, why not? If so, please identify all documents which (a) are drafts of your evaluation (b) contain your evaluation (c) contain information Which would contradict or cast doubt on If C5&L has not submitted a conolete start-up your evaluatior.
test program f2or H arris concerning water hammer in the systems menistioned in Eddleman 45, when will they do so?
198. Identify all open items re Harris that relate to (a) water hammer (b) effects of water hanmers (c) dettection of water hanners (d) detection of situations in which water hanmers could occur o r are likely to occur (e.g. formation of voids, leaking pipes, etcT.
Please identify all documents relating to each such open item.
199. If there are any (a) confirmatory iter.s (b) concerns exoressed or held by any member of NRC Staff, re water hanmer or its effects (e.g. as inquired about in itens (a) thru (d) in 198 above) at Harris, please state each and identify all documents concerning each.
l Please state if the nerson(s) who hold the concerns stated will ;
appear as witnesses if Eddlenan h5 goes to hearing. .
t
) Interrogatories on Eddleman 67 200. Has the Congress ratified the Southeast Interstate Low-Level Radioactive Waste Compact? (hereinaf ter, "the Compact")
201. Has South Carolina or any other state attempted to withdraw
! from the Compact ?
l l 202. Has any state attempted to withdraw fron any other LL4J compact?
203 Identify all. states for Which the answer to 202 or 203 above is affirmative and identify all docunents concerninF etch such withdrawal attemot.
20h. Has the Staff or anyone on it conducted any review of violations of LL9W shipping regulations by CP&L? If so, who did, When. and with What results? Identify a11' documents used in this review or containing statements of this review.
205. Are you aware of any legislation proposed or passed un in South Carolina concerning prohibition of disposal of wastes-in-S.C. from states which have no disposal d site for hazardous wastes?
205-B. Do you know that NC has no operating ~ 1andfills for hazardous waste disposal?
206. Does NRC possess copies of. any CP&LL contingency .nlants for fa storage alternate discosal- (c) alternate treatment of LL9W in) the event (b) t hat the SE compact is not ratified, or NC or 'SC withdraws from it, or offsite disposal'of Harris LL9W is' otherwise not allowed?
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Interrogatories on Eddleman 116.
i 207. Has the Staff conducted any reviews of CP&L's Harris fire i protection program other than those whose results are stated in
- the Harris SER pp 9-45 through 9-55? If so, please identify each such review.
208.
For each area (i.e. each iten underlined) in the SER pp
! 9-45 through 9-55, please provide a cony or identify all documents containing the actual work naners or review (including drafts or notes) made by the staff to reach the conclusions stated.
209.
Please state which of the onen itens identified on SE9 page 9-55 have been resolved, and for each state how and identify all documents concerning the resolution of the item.
210 Isn't it true that photoelectric smoke detectors are able to 4
detect combudion products from cable fires earlies than ionization smoke detectors such as are to be used at Harris? Please state all bases for your answer and identify all documents containing infourmation you used (a) in your answer (b)' as any basis for your answer.
211.
For each exception summarized on page 9-55 of the RSAR SER for Harris, please identify all documents (including worknaners and' notes and drafts ) concerning Staff's apuroval of an exept'on for each such deviation (seven deviations are listed).
212.
Has the Staff or anyone else ever actually tested the fire resistance of fire barriers inside an operating nuclear power plant?
If so, nieaso give all details of each such test. Identify all documents concerning each such test and its results.
- 213. Have any of the (a) fire barrier materials the tyne(s) plant? CP&L proposes to use at Harris, ever failed at any nuclear (b) fire b
- find out. If you don't know, please state whether you have'ever tried to If you do know, please identify all documents concerning such failure (s) or the lack of then, identifying each plant at which such a failure has occurred.
214.
a capabilityIsn't safet of the shutdown in the event of a fire required to be H arris plant?
or requirements which require such a capability.Please list all NRC rules, regulatio redundancy event of fireinisthe safe shutdown equipment to be kept onerable in thePlease state h required. Please identify all equipment which is required for safe shutdown in the event of fire, which night be or is allowed toorbepolic regulation, inoperable during plant operation- (a) by any NRC rule policy crproposed presently position)fory Harris.
or staff position (identify each .such rule,~ reg,,
215.
- iten re fire protection at Harris which it does not have resolve
! What item? does CP&L have to do to allow you to'connlete your review of each such What action (s) would CP&L have to do_to close each such open item?
Please iten identify all documents-concerning your' review of each-such'open the schedule for completing it,' and what : CP&L may need to do to close, the item or allow you to complete your' review of it .
1 15-216. Please identify all items (by number and paragranh) in NUF EG-0800, .
ofr in 10 CPR 50 Appendix R, which CP&L has not yet fully comolied with. !
If CP&L has been granted any exception from any such iten or requirement t
not identified or discussed in your responses above, please identify i the item or requirement, and identify all documents discussaing the exception, the reasons for it, and reashns not to allow an exception re
- that item. If CP&L has been excused from connliance in any way you do not call an exception, please identify all documents concerning such excuse from conpliance, the reasons for it, and/or any reasons against it.
217. Please identify all documents listed in your interrogatories i dated 15. March, 1983, pp 5 and 6, numbers 7h through 82, which i (a) the Staff has connleted its review of entirely (b) the Staff has not yet comaleted its review of. For each document which the Staff has not completely reviewed, state what else you have to do to complete your review, what problems you have identified in your )
review so far concerning CP&L's fire protection for Harris, and when you anticinate finishing your review and what you need to finish it.
218. If a fire occurred during an accident while the contcinnent was isolated (a) Is there any rule or regulation of the NRC requiring Cp&L to be sble'to (1) fight the fire (ii) Drevent the fire from interfering 1 with the safety function of equinnent requived for (aa) shutting down Harris 1 (bb) maintaining Harris 1 in safe shutdown?
Please identify each such rule or regulation. (b) Does. the Staff or anyone en it'believe that CP&L should be able to fight the fire?
Please state who believes so and upon what basis, identifying all docunents supportingik that belief and indicating which person (s) i holding that belierf will be available as witnesses should Eddleman 116 !
go to trial (hearing).
219. Has (a) NRC Staff (b) anyone else, evaluated the actual performance of (1) fire barriers (ii) " fire resistive" materials i (iii) fire resistanzt materials, in actual fires, for those barriers
) and mater'icls to be used at Harris? If so, whct were the results ands please identify all documents concerning the evaluatien of the
- newformance of each such barrier or material in any actual fire, describing the actual fire and the conditions under which it occu= red, and/or containing any akalysis of the fire and/or the performance of the particular barrier (s) or material (s) that were exnosed to it.
l 220. Has NREC Staff or anyone else annlyzed failures or failure modes
!. of the automatic firefighting equipnent at Harris? If so, please
! identify all documents containing such analysis.
221. Has NRC Staff or anyone'else' analyzed the location of fire detection instruments, the re,sponse tines of such instruments and/or systens containing them, and/or the failure probabilities and/or i
failure modes of fire detection instruments and/or systems to be used at Harris, for the effects.of these matters en (a) fire detection times ,
(b)cfire detection urobability (c) fire brigade response times (d) spread of fires (e.) severity of- fires (f) causing nuclear accidents or maki'ng nuclear accidents mora severe, at Harris? . If so, nicase didentify i all documents containing such analysis, all reasons for the conclusions of such swuch anala alysi sis. s, .and sny information -uead in ~ making or supporting each I I % p
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1 l 222. Has NRC Staff or anyone else done an analysis of what could happen if fires initiated at Harris actually spread? If so, piense identify all documents concerning such analysis, and/or the influence control of combustible materials could have on fire spreading at
. Harris. Please also identify all documents concerning control of '
i combustible materials at Harris, and all infornation concerning
- improper control of combustible materials at CP&L's Robinson 2
! and/or Brunswick plants (or any other nuclear power plant) in your i possession and/or of which you know.
222-A. Identify all documents concerning Harris ' ability to fight i e
[Ynherrogatorieson132(c)(2)' simultaneous fires, that you know of.
! 223 Do you possess readable documente or drawings which show what l instrumentation is on the front of control roon panels 1,2,3,h,5,6,7,
- 8,9,10,11,12,13,1h,and/or 15 at Harris? If so, will you provide conies of same?
l 224. Has the staff conoleted its DCRD9 for Harris 17 If not, when i
papE$syE0*SavksoEEh*genehatebIS*Ihk!*Eeh[Iw" "*" * *" "
l 225 Has the Staff analyzed the uses that must be made during any t
(or all) credible Harris accidents, of thq information appearing on i
any panel listed in Eddleman contention id2(c)(2)? If so, which accidents, and which information on which panels? Please identify all I documents concerning each such analysis.
( 226. Has the Staff any opinion concerning the qualificatio# of the peonle who did the DC9D9 for CP&L (the " human factors exnerts")?
Does your opinion of the adequacy of these versons' qualifications incorporate the views of the Licensing Board in Byron (198h)?
! Please state your view of the adequacy of these persons' qualifications ;
j if you have one.
- 227. What HEDs and HERSs for Harris has the Staff reviewed? Please l ider.tify all documents giving the results of your review of each.
223. What information needed by operators in accidents at Harris, which copears on any of the panels contention 132(c)(2) says cannot be seen from each other (or by may be blocked by other panels) persons standing near each, whose view, can be seen fr (b) 10 feet (c) more than 10 feet (d) more than ? feet, with sufficient reliability for accurate inte*pretation end reading under high stress conditions such as would erevail in an accident, in your oninion?
229. Has the Staff made any review of the visual. blockages nossible in the Harris control room layoub? If so, what docunents contain the results or your review? Please identify all work papers used in your review.
230. Does the Staff believe CP&L.was (a) right (b) resnonsible, when it set into concrete in the Harris 1 control room floor the positions of the cabinets recociet.ded by its DCRDR consultants, crior' to Staff connlet-ing its control rots design review for. Harris 17 Please give all reasons for your answer and identify all documents information from which was use'd to make or support your answer.
PRODUCTION OF DOCWENTS
' Wells Eddleman and Joint Intervenors hereby reouest NRC staff to resoonse to any of the above interrogatories,make available y[_ pgj (Q for 5er./P inspection and copyin y+AC 6
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