ML20087M079
| ML20087M079 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/23/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | CAROLINA POWER & LIGHT CO. |
| References | |
| OL, NUDOCS 8403280351 | |
| Download: ML20087M079 (24) | |
Text
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- 9 .
. C h a u; m m . I D,C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKfTED
" C i
'84 hag gg yy ;39 BEFORE THE A'!OMIC SAFETY AND LICENSING BOARD Glenn O. Bright
- J N' Dr. James H. Carpenter N, James L. Kelley, Chairman In the Matter of CAB 0 LINA POWER AND LIGHT CO. et al. )
(Shearon Harris Nuclear Power Plant, Units 1 armi 2)
)
Wells Eddleman's General knterrogatories 6pd .Li to Apolicants Carolina Power & Light g al. (w +uwN$ T;
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FKr-93 + 3-fo-93 N Memorandu Under 10 CFR 2.7h0, 2.7k1 and the Board's g
9-22-82 and OrdedhWells Eddleman reouests Applicants to answer separately 4
and fully in writing, under oath or affirmation, each of the following interrogatories, and to produce a permit incesction 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~ continuing in nature, l
and I reguest each answer to be prorsptly supplemented o* anended as ancrouriate unde
- 10 CFR ?.714d(e), should CPAL, NCEMPA, .any othe" )
or any contractor or consultant to any, sone or all of those, i 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 (w list genera ("Them" nterrogatorie refe=s te the . Theprecedingor reauest nro$ duction ng(s)) of documents-is also continuing and recuests Applicants to eroduce cromutly if
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. not inmediately any additional documents the Applicants and others acting on their behalf or employed by them, as lis'ted in the previous
' 8403280351 840323 gDRADOCK 05000 0 % 03
ocntenco, obtain which cro rocyonsive to tha raquast(s) for nroduction .
of documents 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, following information as apylicable:
author (s), date of writing or of nublication or both, addressee, date aproved, by whom aproved, and the name and address of the versens ha'ing normal custody of tha document, and name and address of any yerson other than the preceding having actual possess!nn of the document. When identifying documents in resoonse to these interroEatories and reguests, please state the portion or portiens of the document (e.g. sections, chafrs, pages, lines) upon which Applicants rely or wl.ich Ap{licants swear or affirm is/are responsive to the applicable interrogatory or vequest.
DEFINITIONS herein:
" Harris", " Harris Plant", "SENPP", or " plant" where not specified otherwise, all mean the Shearon Harris wuclear Power Plant.
I " Applicants" means all of the persons, emoloyees, 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 *enort.
"ER" means the Harris Environmental Fenort.
t ype,
" Document @" means all writinEs and records of ever7 including electronic and emuter records, inthepossessien, control licarts' or custody of Aplicants or any individual (s) actin 6 on A behall, including, but not linited to: venorts, books, memorande, corresnondence, notes, minutes,paghlets, leaflets, magazines, articles, surveys, maps, bulletins,photogranhs, speeches, transcripts, l
. 3
- veico recordings, com7ut ,r printouts, information stored in coyuters or comnuter peripheral devices such as disks, drums, etc. , voice recordings, microfilm, microfiche and all other writings or scordings of any kind (s); and conies of any of the preceding even thouF h the original (s) are not in the possession of Aplicants or in their custody or control. Document (s) shall be deemed to be within the any control of Aplicants or individual's) acting on their behalf ossession, or custody of the document (s) if they have ownership, ,
or a co y thereof, or have the right to secure the docutgent(s) of a copy thereof, from any person or public or private entit7 having ph7sical possessien thereof.
Each definitton given above a lies within all other definitions above.
G5NEGAG la)TEf R06ATDW G1 (a) Wich contentiens of Wells Eddleman do Applicants agree are now admitted in this croceeding, N*C Deckets 50-1400/1401 0.L.?
(b) for each such contentien, provide for any answers to interrog-stories by Wells Eddleman which Acolicants have previously or cresently received (except those suspended by Board order, if any), the following information:
(c) Please state the name, present or last known address, and cresent l or last known emoloyer of each person whom Apolicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) unon whom Applicants relied ( other than their attorneys) in making such answer.
(d) elease identify all facts concerning which each such nerson iderHfied in resconse to 01(c)(1) above has first-hand knowledre.
(e)pleaseidentifyallfactsand/ordocumentsu{onwhicheach nevson identified in response to G1(c)(2) above relied in protiding informationtorespondtotheinterrogatory,includingtheparts l of such docunents relied ueon.
-. -- -_ _ . _ = _. . . _.- - -- . __
ov- (c l(E d @
licants .
(f) Please identify any other document (s) used/by A in responding to the interrogatory.
(g) Please state which specific fact each docunent, identified in rosnonse to G1(e) and 01,(f) above, sunports, in the oninion er belief of Annlicants, or which Aunlicants allege such document supnerts.
l (h) Please state specifically what information each nersen identified in resnonse to G1(c)(1) or G1(c)(2) above trovided to If any or for Anplicants' affiant in answering the intenogatory.
of this information is rot docunented, nisase identify it as "undocunented" in resnonding to this sect'.on of General Interregato7 I
G1.
l 02.a)*1 ease state the nane, present or last known address, 1
title (if any), and nresent or last known e 7 oyer, and econonic interest (shareholder, bondholder, contractor, owlo7ee, etc. ) if or other any (beyond exnert witness fees) such nerson or expectholds in Applicants each nerson you intendg t o cell as an . expert or an7 of them, for witness or a witness in this proceeding, if such information has not vreviously been supnlied, or has changed since such information j
was last sunplied, to Wells Eddlenan." This spplies to Eddlemen by Aunlicants.
and Joint Contentions as admitted'EteStfon t nulated regardirt which each (b). Messe identify each co i
l I such person is exnected to testify.
(c) Please state when you first contacted each such nerson with regard to the possibility of such norson's testifying for Apulicants, if you have contacted cuch norson.
(d) Please state the subject matter, separately for each contention as to which each such person is expected to testify, whicheachsuchpersonisegoctedtotestifyto.
(e) Please identify all documents or narts thereof unon which each such witness is expected to, nians to, or will rely, in testifying or in preparing testimony.
_g.
- 03(c) Plsoso idsntify omy other souvee(s) of information which Applicants have used to resnond to any inteyrogatory identified under 01 above, stating for each such source the interrogatory to which it relates, and what information it provides, and identifying wheve in such source that information is to be found.
(b) Please identify any other source @of information not urev$cusly identified upon which any witness identified under G2 above, or or exhibits other witness, has used in urenaring testinenp/, or exnects to use 4 in testimony or exhibits, identifying for each such source the witness who is expected to use it, and the nart or part(s) of such notree (if applicable) which are expected to be used, and, if not (or both) creviously stated, the fact (s) or subject matter to which such source relates.
and which G4(a) please identify all documents,guages or sections thereof Applicants int =nd 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 Aonlicants believe they relate to, and nake the document (s) available for inspection form intent 2
and cocying as soon as possible after Applicants decide orp ximmd 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 me. l 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 hav, available to them experts, and information, on the subject matter of the contention.
(b) If the answer to (a) abEve is odaer usan affirmative, state whether Anolicants expect to be able to obt&in exeertise in the subject matter, and information on it, and if not, why not.
.h- -
4 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 supelied:
l (i) date of the document (ii) title or identification of document i
(iii) all authors of the document, o= the author (iv) all qualifications (professional, technical) of each author of the document i of the document, (v) the specific parts, sections or nages, if any, unon i
i which Aunlicants rely (vi) the specific information each nart, section or nage identified in resnonse to (v) above contains.
. (vii) identify all documents used in trenarinF 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 expert ouiniors contained in the document, upon which Anolicants rely, or identify each such opinion.
(x) identify the contention (s) with resnect to which Annif cants rely upon (a) the exnert oninions (b) the facts identified ,
l in the docunent (xi) state whether Apolicants now emnicy any author (s) l of the document, identifying each such person for each document.
(xii) state whether Applicants have ever emnloyed any authdis) of_the document, 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 01(a), or (ii) is the subject of interrogatories in this set; please state for which contention or contentions each exhibit will be or is exnected to be offered.
(b) Please identify all documents which Anplicants nian, expect or
- intend to use in cross-exanination of any other perties' witnesses or joint intervanor witness in this proceeding, with resnect to (1) Eddleman contentions identified under G-7(a)(i) (or G1-(a ))
above, or any other Eddleman contention which is the subject of 4.nter-rogatories in this set; (ii) each Joint contention now adnitted in this proceeding; (iii) per our agremnent of h-8-83, each contention of each other party to this nroceeding which is cu*rently adnitted.
Please identify for each such document the witnesses, or witness, and all contentions with resnect to shom (or which) that document is planned, expected, or intended to be offered or used.
! (c) Please identify which of the documents identif5ed in resnonse (i) to (b) above will be offewad into evidence by Aunlicants , and (ii) which of the same documents Apulicants exnect to offer 9 nto evidence orintendtoofferasevidenceorexhibitsinthisproceeding.
G-10(a )
Odbf0'( SPC$k (N Where the above general interrogatories, or any of them, W U call for identification of documents, (1) and no documents are identified, is that the sane as Apolicants 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 as Anplicants stating that the identified
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documents are the only ones presently known which are responsive to the interrogatories? (iii) If your answer to G-10(a)(ii) is
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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, each please state for i each such response all qualifications ofA_ . 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 (1) above is other than affirmative, please state which oninions, if any, given in response to interrogatories (general or suecific) herein is the opinion of an expert, identify each expert whose opinion you used in response to 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 resnonses, 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 documented in your resnonse(s), stating what the fact is, and at what page, place, chapter or other specific part the document contains such fact. ,
9 G-11 For each answer to each interrogatory herein (or any subpart or part thereof), please identify each iten of infornation in possession of Applicants (including facts, opinions of experts, and documents) which (a) contradicts the answer you nade, (i) in whole (ii) in part (please identify each such part for each iten of infornation identified); (b) casts doubt on your answer (i) in whole (ii) in part (please identify each such ncrt for
' each iten of information 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 fcr in (a) or (b) above. Please identify for each such docunent what infernation iten(s) it contains and what answer $)
each such iten is related to.
'l
Interrogatories on Eddleman 9 9-1. Please provide a c ony of the current 10 CFR 50.h9.If you believe it is different fron that cited in my responses, clease state whether it is being fu-ther anended or changed in any way to your present knowledge, or if such changes have been uronosed, so state.
91-2. Please identify each and every iten of electrical equinnent at Harris that you believe (a) is fully environmentally qualified under 10 CFR 50 A spendix A General Design Criterion 1 and/or GDC h and/or 10 CFR 50 49 and/cr NUDEG-0568 (0588), stating under which you believe it is fully qualified (you may say "all" if you so believe);
(b) is required to be environnentally qualified for accident conditions by NRC rule, regulation or regulatory nosition (snecify which), but has not been fully qualified.
(c) For each item identified under either (n) or (b) above, please state exactly what accident conditions are nostulated for that item, and all reasons why those conditions and not any nore severe ones are nostulated, and ,
(d) state what enxact tests were done on (i) that iten (ii) a similar item (iii) anything, which te.sts' results were used to establish, in your view, that the item is environnentally qualifie d. Include all test conditions in your response, or reference them urecisely.
(ea) identify all documents containing the results of any tests identified in resnonse to (d) above. Please note all tests which any iten (or any item similar to an iten used at Harris) failed.
(f) Have there been any failures, in tests you know of, of (i) items to be used at Harris (Rii) itens similar to those to be used at Harris, in or under environmental conditions (na) as severe
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(bb) nore severe (cc) less severe (dd) different, than the conditions you believe the iten (or similar iten) to be used at Harris must be environnentally qualified under? Please identify all documents relating to each such failure not already identified above. Please also (ee) state for each such failure any rationale, reasoning or-argument or information which you believe means such failuwe woula not be a reason to environmentally disqualify. the iten of similar item at Harris, based on the failure of each such iten or sinilar iten in the test (s).
9-3(a) State (or state where it is stated) all actions Applicants have tdken to conply with the criteria of 10 CFR 50.h9 for each iten of electrical equipment located in a harsh environment at Harris. (b) define the tern " harsh environment" as you use it in your interrogatory 9.5(a). State whether this is the sane definition used (1) in 10 CFR 50.k9 as presently pronu1 gated (ii) in NUDEG-0586 (iii) in 10 CFR 50 Appendix A. (c) State which equipment at Harris has been qualified under NUREG-0588 in your opinion, and to the extent not already set forth above (in other resucnses to the abcve), state for each iten all reasons why you think it is qualified under NU"EG-0588 and identify all documents concerning its qualification and/or testing.
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- 9-4(c) State when, if ever, CP&L plant to conolete environmental qualification a for the Harris 1 plant. (b) What work needs to be done between now and your conpletion date (or November 30, 1985
'if you think this date applies regardless of your comuletion date) to qualify all the electrical equipment at Harris that must be qualified. Please identify all documents, includin6 work schedule s, l
test programs and/or schedules, critical path studies or diaFrams, and/or plans, which relate to the comnletion of the environmental qualification of electrical equinment at Harris. If a schedule only anulies to sone equipment, identify all equipment for wFich that schedule applies.
9-5(a) Please provide a copy of FSAR Amendnent 4. (b) Please state why you believe compliance with the format requirements of 10 CPR 50.49 (if any -- see your interrogatory 9-7(a)) would be relevant to this contention. (c) Please state why you believe conn 11ance with the format requirements of 10 CFR 50.h9 (if any -- see your interrogatory 9-8(a)) would be relevant to this contention.
(d) please explain why I shculd tell you what changes you need to nake in a figure (3 11.1-2) in your FSt.R, in order to conply with 10 CFR 50.h9. Please also state whether or denonstrate figure and the information in it does comply (you believe that connliance with) 10 CFR 50.49, and if so, why (state all reasons) and please also state whether NRC staff agrees with your view.
(CF.your interrogatory 9-8(c))
9-6(a) State what criteria of NUREG-0588 you believe you have (i) completely (ii) ravtially connlied with. Give all basis for each answer. Identify all docunente you believe support your answer to the above parts, and all documents you believe support your answers to (b) through (d) of 9-5 above.
9-7(a) Do you believe there are inadecuacies in SFR sect'on 3117 (b) If so please detail each such inadequacy. Identify all documents
, and/or exp,ert opinions supporting your opinion that each is an inadequacy in f act.
9-8(a)What information requested in KK SER op 3-h9 through 3 --51
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has CDhL (i) Kl=eady nrovided to "*C Staff (ii) committed to provide to WRC Staff (iii) refused or otherwise declined to provide to NRC Staff (iv) not yet urovided to NRC Staff? Please identify all items of equipment for which you have not yet provided information reouested by the Staff, either information requested as detailed in the SER pp 3-49 through 3-51, or any other informat5on reauested (specify).
9-9(a) Is there any equipment in your (1) Brunswick (ii) Robinson 2 nuclear plants which is not environmentally qualified and which should be or must be environmentally qualified under 10 CPR 50.h9, NUREG-0588, or. other applicable NRC rule, requirenent or regulation
, (please specify)? If so, when do you plan to qualify each such item i of equipment (list all -- if no date, say "no date to qualify")?
(b) Do you believe that operating either plant with such equinment
. (i) has (ii) will (iii) might compromise safety of that plant?
Please give all reasons for your answer and identify all documents l you believe supnort your answer, including any documents submitted to NRC to justify continued operation of either Robinson 2 or eithe r or both Brunswick units with unqualified electrical equipment.
1
j 9-10 (a) What flooding analysis have you done for eouipment ins 2_,de the Harris containment? Please identify all documents containing such analysis. (b) Do you have any Anaconda flexible conduit in j use anywhere at Harris? If so, is it in a place or use that you believe should require it to be environmentally qualified under I 10 CFR 50.49, NUREG-0588 or other annlicable regulation, rule or position of NWC (elease snecify)? ' lease identify all such uses and/or locations of Anaconda flexible conduit.
(c) Are any of the itens mentioned in Union of Concerned Scientists' l
February 7,198h petition to N3C re environmental qualification l
of electrical equipment, in use or planned to be used or installed l at Harris? (d) What equipment in use at Harris, if any, can perform l
its required functions while subnerged? What equipment at Harris j has subnergence included in its environmental qualification requi"enents
- (i.e. has a qualification environment that includes beirg submerged)?
! (e) Please list all equipment at Harris which you think (1) is
- electrical equipment that could be subnerged during an accident, i e.g. a TMI-type accident or small-break LOCA where coolant overflows i or flows out intoe ontainment, but cannot be removed fron containment
! either (ac) because it is tooo radioactive, or (bb) because containnent '
is isolated; (ii) is electrical equienent that has bo be environmentally qualified for being submerged in (aa) water (bb) highly contaninated ;
water, e.g. a high radiation field with water. Please identify all bases for your answers and all documents concerning these natters.
(f) Have you analysed the effects of plateout of radioiodines etc on the radiation fields to which electrical equipnent at Harris may be exposed during an accident? Please identify cli documents I concerning such analysis by you or by anyone else. Identify also any documents analyzing this questinn in general (plateout effects i on radiation' fields in nucisar niant accidents as this affects
! electrical equienent or may affect it) or for other nuclear v1 ants t j or for military nuclear systems, which you know of.
l 9-11(a) What maintenance procedures for Harris assure that environ-
- 9entally qualified electrical couinnent at Harris is always kent
, in the sane condition or state of renair and/or readiness it was .
I qualified under? Please identify all documents concerning such naintenance,or maintenance orograns for environnentally qualified electrical equipment at Harris. (b) Are there any items that must be environmentally qualified for several conditions (e.g. radiation, steam spray and'innact) which were not tested under all those conditions at once? Please identify each such iten or describe which items were not so tested. (c) Have radiation fields in .the auxiliary building at Harris under (i) MSLB (ii) high energy line' break outside containment (iii) EFW faflure (iv) AFW failure (v) break 1
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in steam line to steam - driven nunp (vi) fire in the auxiliary building, been analyzed for determining conditions under which electrical equipment in the Harris auxiliary building must be environnentally qualified? Please identify all documents concerning -(aa) such analysis (bb) any reasons for not doing such an analysis for any or all of the situations inquired about above.
9-12(a) Please. provide copies of (i) actual test. data (ii) analysis,
! used or submitted by CP&L to show electrical equinment at Harris l 'is or will be environnentally qualified, for all items of electrical ecuipment at Harris . Aich (aa) you believe must be environmentally qdalified (bb) such tests.or anklysis have been:done and you have a copy of the test results or analysis
- Please-pr vide used in each such test ahd all documents gkving SaEales.o al l or bas!s Erocedu ux usedes
_..__._.._2 _ . _ ~ . _ _ _ _ _ _ . _ _ _ _ _ ,_ ___
4 .
. . in each such analysis.
Interrogatories on Eddleman 11 11-1(a) What information (1) polyethylene do you possess (ii) polyethylene conolymerconcerning) the effects (iii neoprene on (iv) cny other insulation used on (aa) cable (bb) wiring (cc) other j equinment, at Harris, of (cc) radiation delivered at a dose rate of (cc-a) under 1 rad per hour (cc-b) I rad per hour to 5 rads / hour (cc-c) 5 rads / hour to 20 rads / hour (cc-d) 20 rads / hour to 100 rads / hour (cc-$e) hour (cc-g) 100 rads 2000 / hour radsto /500 hourrads to/ 10,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> (cc-f) 500 rads drads/ hour10,Q00 (cc-h)/
radshour / hourto 2000i to 50,000 rads / hour (cc-1) 50,000 rads / hour to 200,000 rads / hour
- (cc-j) 200,000 rads to 5 megarads/ hour cc-1) /(hour over 5tomegardds 1 mcgarad per hour per hour? (cc-k)
Please 1 megarad/ ho identify i
1 all documents containin6 such information which you know of.
(b) Do any of the documents identified in response to the above interrogatory also discuss the effects of (i) heat (ii) pressure (iii) steam (iv) oxygen (v) surface area (vi) nitrogen (vii) particulates (e.g. soot from fires, radioactive particulates) (viii) conduit (ix) cable configuration (x) insulator position or configuration (xi) other materials used in conjuntion with insulation (xii) insulation stripped from conductors (xiii) mekchanical stress (xiv) fire (xv) i submergence (xvi) imoact of objects (e.E. shraunel from exnlodin pump, line break, etc) (xvii) pipe whip (xviii) vibration (xix) g seismic forces (xx) explosions (xxi) hydrogen burns or ranid deflagrations
! (xxii) other factors, in conbination with radiation, on the (aa) insulating ability (bb) integrity (ce) properties (specify)
(dd) resistivity (ee) strength (ff) tensile strength (116C) volume (hh) elasticity (33) bulk modulus (kk) other characteristics (please I specify))oftheinsulationorofpolyg$dyinnene,polyethylenecopolymer (PE co-P , neoprene, or other insulating material used or to be used at Harris for cable or wiring or other electrical equipment insulation?
Please identify what of the abcVe is discussed in each document, and identify all docunents not identieied in response to the above which discuss any of the above factors or properties under conditions of radiation exrosure dombined with any of itens (i) thru (xxii) above.
(c) Please identify any documents or other info"mation which you believe indicates that,4nsulation in a conduit (snecify what the l conduit is made of) isWhielded from, or (ii) not subject to, degradation effects such as those alleged in Eddlenan contention 11.
(d) Please state the lowest (1) ganna (ii) total, radiation dose rate at which you believe the effects alleged in Eddleman contention 11 (i.e. accelerateddegradation of insulation) (aa) cannot occur (bb)
- will not occur (ce) probably will not occur (dd) night not occur.
Please give all bases for each of. your answers and identify any and all documents containing inaformation you believe supeorts your answe".
l l (e) Please state the highest (1) ganma (ii) total, endiation dose rateaat which you believe the acceldrated degradation of insulation described (e.g. ) in Eddleman 11, NUREG/CR 2763, NURFG/CR 2877, etc.
(ac) cannot (bb) does not -(cc) probably will not (dd) night not, occur.
l Please give all basis for your answer, including identification of l all documents containing infornatirn you believe supnorts-your answer.
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4, .
!. (f) .Please state if there is any radiation dose a rate or total
! integrated radiation dose (suecify which, and what dose or dose rate) obove which insulation (e.g. polyethylene, neoprene) cannot be degraded or is not degraded in such a way that its function or the safety function of ene*gy o~ signals insulated by it will not be imeaired.
Plance state all such doses or dose rates and all bases for your i conclusion that they exist and/or are at the level (s) stated, statin which type (s) of insulation (e.g. polyethylene, PE- co-P, neoprene) g l
cach such dose rate applies to, and identifying all documents cohtaining :
j informatton you believe supports each such total dose or dose rate or >
. answer you have made.
(g) state which, if any, total integrated (i) gamma (ii) total, radiation
' dose rate axists below which degradation of the type alleged in Eddleman 11 and/or described in NUREG/CR P156, 2157, P763 or 2877 (specify which one(s)) (aa) dpes not occura (bb)cannot occur.
Please state all basis for each of your answers, including identification of all documents containin answer (s) or any of then specify (g any which).
information you believe sunnorts youar (h) Please identify all radiation dose rate levels which you believe (1) exist in normal operation of Harris, or would exist in normal ope *ation of Harris, in any zone or area through which insulated l cables or wiring or other insulated equipnent insulated with poly-i ethylene or PE co-P, pass (ii) exist or would exist during normal
- shutdowns at Harris in any such area (iii) enist or would exist 4
during refueling or other prolonged outages at Harris in any such area (iv) exist or could exist during any accident (specify #he accident) in any such area. Please also provide (v) naps, drawings or diagranc showing the areas of given radiation dose levels for Harris (vi) all assunctions and caldulations, including computer runs and progrnnns and assumptions and inout data for each such run (and a listing of the source code for each program so used), used to figure those radiat$on dose levels, snecifying for which zone (s) nr area (c) they each was used.
Please nrovide this in#ornation for the auxiliary building and all other areas in which cables or wiring insulated with Polyethylene, PE co-P l
or neoorene, or other equipnent so insulated, could be exposed to l radiation. ,
(j) Have you, or anyone else, performed any analysis of the ability ,
of (1) all (ii) any (specify) wiring, cable or other electrical equipment insulated with (aa) polyethylene, (bb) PE co-P (ce) neoprene (dd) other. insulation, to perforn its safety-related fuhetions and/'or to avoid suprious signals or short circuits, under the degradation effects described in (ee) Eddlenan contention 11:(ff) NU'EG-CR-P156 (gg) NUREG/CR-2157 (hh) WU'EG/CR 2763 (jj) NUREG/CR 2877 (kk) other studies of radiation effects or synergistic effects of corditions including radiation, on'such insulation? Please identify all such studies you (11) possess (nm) know of. .
(k) Are you able to analyze all instances in which (i) cable (ii) wiring (iii) other electrical equipment at Harris, might fail 'under the influence of degradation effects such as are discussed in any of the documents or contention 11' listed. in (j)(ee) through (j)(kk) above?
If so present and identify any such analysis you have done for.
equipment at Harris which is insulated with (aa) polyethylene -(bb) PF co-P a (cc) neoprene (dd)~ other insulating material, i
i.
4 (1) Please state all features ,) procedures, or requirements of(cc) test progra your Harris (aa) inanection (bb maintenance i
I which provides or provide for (i) inspection (ii) testing (iii)
' replacement, of cable or wiring insulation Which may have becone degraded. Please specify (dd) how you plan to inspect insulation
' inside conduit (ee) how you plan to inspect insulation inside bundled wiring or cables (ff) how you plan to inspect multiconductior cables or wires (gg) how you plan to test the insulation on wiring or cable inside conduit (hh) how you nisn to test insulation inside bundled l
wiring or cables (jj) how you identify Please plan to all test insulationrelating documents inside nulticonduc-to each I bor cables or wires.
of the above subparts or the matters or items inquired about in each.
ll (m) Identify each specific property or property you beli- ors cable (i) ,
always 9(11) usually (iii) somethines necessary for wiri:
j insulation to perform its safety function. Define the su ety function i
oxf (iv) wirin6 (v) cable (vi) other electrical, insulation at Harris.
l Specify the level or range of each property identified in verponse to l
(i),(ii) or (iii) .above which is necessary in your opinion for
' the insulation to nerform its safety function. State all basis for :
each of your answers and identify alik documents containing information l
used in vour answers or Which you believe supnorts any of your i
answers isnecify which you believe it sunnorts).
i
- (n) Are there any performance-based acceptance If so, specify criteriaeach for insulation such at criterion Harris to for perform eachitsanplicationsafety (function?e.g. ECCS power sunnly wiring) for which insulation is used at Harris. Identify. all documents giving descriptions of or basis for or information relating to such acceptance criteria.
(o) Are there any other acceptance criteria for insulation to be used in areas at Harris where it can or w ill be exposed to radiation?
Please identify each such criterion and give all basis for it and state to what insulation o* what areas or what items it ann 11es.
Identify all documents listing or describing the areas or items -
where each such accettance criterion annlies, and also identify any documents listing or describing areas or itens for whicha each accentance criterion identified in response to any part of (1)(m) or (n) above- anplies or why it applies to that area or item.
l (p) If not.already stated, give the rkdiation levels in each-radiation zone (and a d escription or drawings locating each such zone) at Harris in full-power " normal" operation (as you define " normal"), -
including (1) ganna dose (ii) neutron: dose (iii) total radiation dose including alpha, beta, gamma, nettrons, . etc.
(q) Can neutrons or other radiation at Harris. create activation l products (radioactive atoms) in (1) insulation '(ii) conductors (iii) i other components of wiring or cables -(iv) electrical equiument (v) electrical equipment holders, boxes or cabinets (vi) conduit
~
(vii) ~ air (viii) water (ix) steam, at Harris? Have radiation doses or dose rates to insulation on aakka (aa) cable (bb) wiring (cc) other electrical equipment, due to such' activation nroducts, been -
analysed for (x) Harris (xi) any other nuclear plant you know of?
Identify all documents you know of contai nin6 such analysis.- l Please give all reasons for not doir g such analysis if you haven't l done it or .it hasn't been done.
> - , , w -. y-, e-- --
- - , - - , , - , - - . , - . _ . - , , , - - - , , nn-, no,, -w..-e -m--- ,s, ,- --,,e,~ ,,--,w +cer --w.-- -e, + -
L l
(r) state the number of hours par year of " normal onsration" (en .
average or tynical year will do) in which the level of radiation l
- in each rcdiation zone at Harris is greater than or equal to (1)
(v) 50.001 M/hr R/br(vi) 10 (ii)*/hr 0.10(vii)
R/hr Po(iii)
- /hr10.01 (viii R/)hr (iv) 1.0 P/hrFo */hr (ix) l (x) 200 R/hr (xi) 500 R/hr (xii) 1000 R/hr 000 (xiii)R/hr2000 R/hr (xvii $ 50,000 R/hr l (xiv) 5000 R/hr (x1x) 100 000 R/h(xv) r (xx) 200,000 10,000 R/hr R/hr(xivi)
(xxi)20,500,000 R/hr (xxii) l 1 megarad/,hr (xxiii) 2 MR/hr (xxiv) $ MR /hr (xxv) 10 M9/hr (xxvi) 100 M*/hr ,
Please also state or give a radiation level profile of each radiatichs zone at Harris showing tyuical radiation levels, location of all wiring or cables in that zone, stating what cables or wirirg are inconduit (and what the conduit is av.ade of and how thick it is and
' all its dimensions), the hours per year at each radiatfon lev &l, and the total integrated radiation dose received by each wire, cable or electrical insulator in the zone for which you have thus far (or ever) conputed at total integrated radiation dose.
- Also give the radiation dose rate at each wire, cable er other j olectrical insulator for which you have connuted a radiation dose rate. If this dose rate varies, specify how it varies and what levels you expect it to be at for what fractions of the tine, hours I ver year, etc.
(s) specify all " unacceptance criteria" by which degraded cables or j wiring at Harris will be renoved from service and/or renlaced when i
they meet the " unacceptance criteria" or any of them.
- (t) explain how you will renlace wiring or cable with degraded i insulation at Harris. Please x discuss in detail the relevance, 3 if any, to this of the cable pulling problens identified by Paul Benis NRC Pegion II to the AC9S subconnittee on Harris, Jan a andh l 148b at Anex NC. Please give all details including eenlecement j procedures, accentance criteria, solicing o* connection criteria and/or procedures, and identify all documents containing information discussed or asked about in each nart of this subsection (s).
l Please also identify all documents in your possession concerning l
cable pulling nroblems at Harris thus far. Please exulain how cable pulling would differ when the plant is " hot" (radioactive 5 or under operating conditions, ' compared to conditions under which CP&L has so far tried cable pulling at Harris.Please state all reasons why CP&L has stopned cable pulling at Harris each time you storped, and state which reasons would apply in the event of cable or wiring replacement at Harris.
(u) Please identify all studies or documentation or informat!on which you have re wiring, cable or electrical insulation at Harris which accounts for radiation dose-rate effects (acf. your interrogatory 11-12(a))
t (1) Please identify all NRC staff. " evaluation"s of Arnlicants '
! program for environmental qualification of electrical equipment with respect to radiation dose rate effects on insulation. (cf. your interrogatory 11-12(b)). (ii)' Please identify any other studies of l
radiation dose-rate effects on insulation you know of that have not been identified in resnonse to above interrogatories.
11-2. Please identify all cables or wiring at Harris which you believe (1) is environmentally qualified L(ii) must be environnentally qualified, with respect to radiation dose-rate effects on insulation.
Please state what' radiation zone each is in. Please also state which
such cables, wiring, ote. havo bocn acconted cp;cifically by N90 staff as environmentally qualified for Harris. Please identify all documents related to sadh such qualification, testing, analysis, ,
or acdeptance, as regards radiation dose-rate effects. l 11-3 Please identify all electrical eouinnant at Fawnis that is ernosed to radiation end which is insulated with volyethylene or polyethylene conolyner (snecify which).State State which is which is exposed exuosed to low dose rates of radiation.
tok any radiation dose rate or total dose (suecify) at which you believe dose-rate-velated adegradation effects can occur.
State and identify all docunents in which you nake or renort all analysis of radiation dose-rate rx effects on the insulation of each such iten of electrical equipment. If you consider this irrelevant to Eddlenan 11 please answer it as an interrogatory re Eddleman 9.
Interrogatories on Eddleman 5 kly N bCS82 DM WO! f*~ [A)[8 41-20. Please ansuer the interrogatories numbered 16h through 195 (cony attached) which were nosed to NDC staff re Eddlenan kl.
P4 ease consider that "you" neans CP&L or Anulicants in formulating your answers. Where an interrogatory asks re NFC/N WC staff only, please answer as if the question read "M90, NRC Staff, or CP&L or Applicants" instead of "NRC Staff 4 or "NRC".
41-21. Please provide access to all weld insnection renorts comnleted since May 1, 1983, for Harris.
41-22. D1 ease identify each change or innrovenent to k Annlicants' QA/QC vrogram at Harvis which has been made (i) wholly (ii) partly in response to problems with pine hanger insnection. Please identify all docunents requestning or apnroving or describing each such change.
bl-P3 Please state all reasons for each other chance in Applicants' QA/QC nrogran at Harris as it relates to nine hangers.
41-24. Please identify all persons who are involved in the 10044 reinspection of pine hangers at Harris. State the qualifications of each to (a) rexinspect pine hangers (b) perform any other work she or he performs in this reinspection.
h1-25. How many defects in pipe han6ers hr.ve been identified so far at Harris? Of these, how many remain.unrepaired? When do you anticinate that the last pine hanger needinF repair to make if fully accontable, will be repaired?
41-26. Provide copies of all Field Change -9equests, Permanent Waivers, of other changes in pine hanger ,accentance c*iteria, used or made since 6/1/83 Provide also copies of all analyces or apnroval docunents related to each such FCR, PW, etc.
l kl-27. When do Applicants anticipate finishing veinspecting all l palpe hangers at Hkrris?
41-28. Will NRC Staff be inspecting nipe hangers at Harris after j Ann'icants finish vour 100% reinsnection? If so, do you expect then to' find any defective hangers?
l 41-x29. How many pipe hangers renain to be (1) welded (ii) installed at
at Harrio? inton will thaso b3 cennletod?
When will the last of these be connleted?
hi-P9. Arc any pipe hangers being wcided or installed at Harris now?
If so, are the telds repairs /replaceaent only?
41-30. Is pipe hanger welding goin6 on at Harris at the present time or the recent past? If so, is it renair/renlacement welding, or are new hangers being welded?
hl-31. Has any additional training been required er set forth for pine hanger welders at Harris since the retraining Anplicantsx (or their contractor (s)) did nrior to 10837 If so, what training (identify all documents including texts and handouts concerning it) and who is required to take it?
41-32. Have weldin training since 9/3/g198207 irsnectors at Harris If so, receivedwas which training anyrelated additional to problems in specting pipe hangers at Harris? Please state the nnnes of persons (1) required (ii) invited to take such training, identify all docunents concerning it including course outlines or syllabus, text (s), zhandouts, or naterials used in teaching it.
Please state the grade (s) or result (s) for cach person taking such additional training.
41-33 Are there any text (s), handouts or information which was not 2 verbal and was sunulled to (a) welders (b) insnectors at Harris who were taking any retraining since 9/3/90, which has not been identified in response to above interrogatories or nrevious interrogatories on this contention? If so, please identify all such text (s), handouts or information, telling to whonn it was provided and when.
41-34 Please provide copies of any analyses of the clarity cf blueprints and specifications of welds on pipe hangens at Harris, which you possess.
hl-35 Please vrovide any studies of the blueprint reading ability of (1) engineers working with pipe hanger bluenrints (ii) weldere welding pine hangers (iii) welding insnectors insnecting unine hangers, at Harris. Please identih each nersen whose bluenrint-readinr ability (a) was studied (b) has been checked, at Harris, and the results of each such check or study for that nerson.
41-36. Please state how nany pine hangers have been OK'd (a) once (b) twice (c) three tines (d) nore than three tines, and then been found to be defective, at Harris. Please identify all welding insnectors who inspected each such hanger, and all welders who welded each such hanger.
INTERROGATORIES ON EDDLEIEN h5.
ei errogatories posed o NiiC Staff on Eddleman h5,
%kPleaseanswer substituting in each the words "CP&L and/or NRC Staff" for "NPC Staff" or
- " staff" or " Staff" in each.
h5-20. Exp&ain all reasons why you believe the Maine Yankee water i
hanner event of 1983 would not have any relevance to Harris, your answer where you rely on information that is docume#+8d- Docunent l
4 1
- Interrogatories on Eddleman 116.
i f 116-1(a) Please list all the undates to the FSAR and all other i rssponses to NRC which relate to fire protection, whife CP&L has made since 5-14-82. (b) Please state which items re fire protection
- at Harris the NRC considers open items, to your knowledge.
l (de) please identify all N90 regulatory guides, regulations,
~
publications, standards, staff positions, or other standards
' (including fire nrotection standards) you believe Harris must comnly with concerning fire nrotection. (d) Do you believe that Harris thould be able to fight fires during nuclear accidents?
If so, do you believe this ability should be present even when c6ntainment is isolated? Please give all bases for vouw arswews in detail.
116-2(a) Under what conditions can (i) control (ii) power, fail l, to any (aa) firefighting (bb) safety (cc) fire sunnression, equipment i at Harris? Please give all reasons for your answer (s) in detail and identify all docunents reinting to such failures or their possibility, torbability, inprobability, etc. at Harris.
(b) What is the last FSAR anendment that affected section 9.5.1.1.1?
(c) what other amendnents have changed section 29 5 1.1.1?
, (d) What analysis, test or other infornation is used to sunnort the ratings of each fire barrier at Harris? Please urovide copies of all such analysis, test (s) or information that is not in the
- FSAR at present. Please state where in the FSA9 such information 4
is foud3. Please ,nrovide copies of the actual test restu1>s, and conies of the test nrocedures, for each five barrier tested for Harris.
(e) Please nrovide conies of all actual test results re " fire resistant" or " fire resistive" naterials used at Ecrris. Please also provide conies of all test proMCEdures actually used in each such test.
Please identify each meterial and the test (s) annlied to it.
(f) If any analysis of fire resistance of any naterial used at Harris !
was made, urovide all worknapers and documents underlying each such analysis, stating what material the analysis is for and where in the Harris palant such material is used.
- (g) (cf your interrogatory 116-5(f)) PTense identify and nake available j all information under3ying or sunnorting each belief CF&L has that
- in any fire area (s) at Harris, it is "not feasible to use such fire barriers oriother means of separation of safety related cable."
(h) Please identify all tests of flame spread.(i) in (ii) between cabica of the tyne(s) used in any of the areas referred to in your interrogatory 116-5(f), and all other tests involving fires.$r such cables, that have been done to your knowledge. Please identify all documents refevring to such. tests or giving.the methods or result (s) of any such test (s).
L .116-2(a) define " maximum credible fire" as you use,the tern (i) in your Harris fire analyses (ii) fin your interrogatory 116-7.. 1
-20 (b) explain exactly hew tha " maximum credible fira" for each ,
tira arzn at Harris was "nostulated". .
(c) what consideration of combustible materials was madein postulating each such " maximum credible fire".
(d) what consideration have you made of simultaneous fires at Harris and/or your ability to fight them. Please identify all document a concerning simultaneous fires at Harris, stating on what page(s) or in which section(s) they deal with simultaneous fires.
116-3(a) Do you believe Harris 1 is required to (i) have (ii) maintain safe shutdown capability in the event of a fire? (b) is this requirement waived in any way by any NRC rule or regulation during a nuclear ,
accident? Please provide all bases for your answers. (
116-k(a) When do you exnect to finish providing NRC Staff with the s iditional information it has requested concerning fire hazard i analgses? (b) When do you expect to be able to test the fire control system at Harric? (c) Please identify all startup test nrocedures Please identify for fire control and/or firo. detection at Harris.
s1.1 documents containing such nrocedures and/or schedules for each or any or all of them.
Interrogatories on 132(c)(2).
Please answer the interrogatories posed to NRC Staff on 132(c)(2).
Where the word " staff" occurs in the interrogatory, answer as if it read "CP&L or NRC Staff" at that roint.
132-c-2-20(a) What analysis, if any, have you made of the number of onorators who can or should be uresent in the Harris control room during nuclear accidents, and what task (s) each wS11 have to cerforn? (b) What information must be identified from each pan'el numbered 1 thru 15 in each accident sequence you have analyzed for human factors and adequate procedures at Harris.
(c) Please identify all documents in which information ak inquired about in (a) or (b) above can be found. Please state where it ,
is in each such document, for which information, if you know.
132-c-2-21(a) Please provide actual locations of all dials, readouts, indicators or lights on each panel numbered 1,2,3, . . .through 15 in the Harris control room, stating whatinformation or thing each indicates. (Cf your interrogator $ 6(b) on this contention).
132-e-2-22(a) 'c1 hat signal density analyses have been made for Harris other than those "venorted" inthe DCRDR. (b) What smitudies or exper!ence with lighting in nuclear plant control rooms under emergency conditions are you aware of? (d) what studies of denth percention of Harris plant operators (1) have been made (ii) will be required? (c) What are the acceptance criteria-for (1) near vision'(ii) far vision (iii) depth perception (iv) field discrimination, for Harris operators?
132-e-2-23(a) What is your understanding of how GDC 1 anulies to the Harris control room? Suecifically, also state what role GDC 1 played in your Harris DCRDR. (b) What is your understandirg of how GDC 19 anplies. to the Harris control room? (c) What role did GDC 19 play in ) cur Harris DCRDR? (d) Did you misidentify interrogatory 132-c-II-6 in your interrogatory no. 14 on 162-e-2, or are there two 132-c-II-6's?
Production of documents: Wells Eddleman requests annlicants to nroduce for insoection and conving all docunents identified in response to these interrogatories and interrogatories incoreovated by reference henrein.
l tMCUMENT p
. -212-Interrogatories on Eddlenan 41 (not relating to welder info just received) 184 Has CP&L conoleted its 100% reinspection of nine hangers et Harris? If not, when does CP&L tell you they exnect to connlete 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 docunents pertainin6 to the matters and inspections inquired t bout in interrogatories 184 and 185 above.
1 87 Has any (i) wie; der (ii) wielding inspector, ever been fired or discharged or asked to resign fron Harris because of (aa) If naking so, (bb) annroving, defective welds or defective pire hangers?
please identify each such verson.
4 188. Has any (1) 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) makinE (B) annroving, defective (iv) welds (v ) pine hangers ,
at Harris? If so, please identify each such person.
189. Have you identified any defective vipe hangers at Harris which have not yet been repainred? If so, which ones?
190. Have you written any evaluation or recommendatiens for inprovenent (or has anyone working for NFC Staff or CP&L done so) for CP&L Harris QA or QC concerning their insnection of pine hangers (a) ever (b) since 9/1/1980? If so niease identify each document containing each such evaluation and/,or reconmendation.
191. Have you contacted any of the welders identified to Wells Eddlenan by CP&L in response to his interrogatories served in 1963?
If so, please describe the nature of each such contact and the infornation (a) you Save to (b) you received fron, each such welder.
Please identify or state any statenents, questiens, or other things you have connunicated orally or in writing to each such us1 der, and all response (s) you have veceived to each.
192. Please identify all documents concerning reinenection of pipe hangers at Harris which have occurred since June 1, 1983 193 Please identify all docuAents concovning defects in nine hangers at Harris found since 1 June,1983, which (a) you nossess (b) you know soneone else nossesses (please identify.who vossecses it, if you know) 194. Has (a) CP&L (b) Daniel International (c ) anyone else including enployees of CP&L or Daniel, who worked at the Harris site, ever (i) made any false statenent to NRC concerning eine hangers at Harris (ii) made any statement to NRC concerning rine hangers at Harris, which was l later shown to be false (iii) made any statenent 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 c11 details and identify all documents concerning each such statenent.
195 ta is la-)How as aserious breach do of you believe faith "OK"(b)gging with NFC of defective as a violcti on of pine hangers .
NRC regulations (c) as a threat to safety of the Harris ulant? Please give cil reasons for each of your answers.
d
- Interrogatories on Eddleman 45 196. Please identify all water hammer incidents in PWRs since 1-1-83 that (a) caused damage (b) caused a safety problem (c) were reported by NRC to Congress as significant events (d) were required to be reported. to Congress by the N90. Please state the relevance of each such incident to Harris and all information sunnorting your answer.
197 Have you evaluated the complete start-un test nrogran for Harris 1 as it involves wstew hanner in the systems mentioned in Eddleman 45? If not, why not? If so, please identify all docunents which (a) are drafte of your evaluation (b) contain your evaluation (c) contain infornation which would contradict or cast doubt en your ovaluatier. If CD&T. has not submitted a connlete sta-t-up test nrogram fror H arris concerning water hanner in tho systens meniationed in Eddleman h5, when will they do so?
198. I5entify all open'1tems re Harris that relate to (a) water hamner (b) effects of water hanners (c) deftection of water hanners (d) detection of situations in which water hanmers could occur o r are likely to occur (e..g. fornation of voids, leaking uites, etcT.
Please identify all documents relating to each such open iten.
199. If thern are any (a) confirmatcry iter.s (b) concerns expressed or : held (e.g. asby any memuer inquired aboutof in NRC Staff,)re itens (a water hanner or its effectsthru (d) in 198 abo I
l please state each and identify all documents concerning each.
Please state if the persor(s) sic hold the concerns stated will appear as witnesses if Eddle-un 15 goes to hearing.
Interrogatories on Eddlenan 67' 200. Has the Congress ratified the Southeast Interstate Low-Level Radioactive Waste Compact? (Lereinaf ter, "the Compact")
201. Has South = Carolina or any other state attennted to withdraw from the Connact ?
202. Has any state attenpted to'vithdraw fren any other LLUW comnact?
203 Idertify all states for which the= answer to POP or 203 above is n'firmative nnd identify all i 1.unents concern'nF er.ch such withdrawal attennt.
Has the Staff or w t wc.~ it conducted any review of violat?.ons 204 ,
, of LL9W shipping regplations by CD&L? If so, who did, when. and with l
what results? ' Identify all documents used $n this review or containing l statements of thiscreview.
205. Are you aware of' Uny-legislation pronosed or passed an in South Carolina concerning. prohibit'lon of disposal of wastes in S.C. from states'which have no disnosal i site for hazcrdous wastes?
205-B. 'Do you know. that No has no eneratins landrills for hazardous l waste disposal?
206. Dcos NRC possesk conies of any CP&L contingency ulants for fa storage (b) alternate discosal (c ) alternate treatment of -LL7W in) the' event that the',SE compact is not ratified, or NC or SC withdraws from it .or offsite disnosal of Harris LL9W is otherwise'not allowed?
4 .
) F777r{HMW B2(d(2)
J l(WS Tb ffffC 222. Has NRC Staff or anyone else done an analysis of what could happen if fires initiated at Harris actually spread? If so, please 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 l l
combustible materials at Harris, and all infornation concerning improper control of conbustible materials at CP&L's Robinson 2 and/or Brunswick plants (or any other nuclear power plant) in your N possession and/or of which you know.
222-A. Identify all documents concerning Harris t ability to fight terrogatories on 132(c)(2 sinultaneous fires, that you know of.
223 Do you possess readable documente or drawings which show what instrumentation is on the front of control roon nanels 1,2,3,h,5,6,7, 8,9,10,11,12,13,1h,and/or 15 at Harris? If so, will you nrovide conies of same?
2219 Has the Staff com71eted its DC9D9 for Harris I? If not, when do vou ex paphrs yoEect socoslete Iiave to it? P1In rar generated asIhis identieva review.ll documents and work 225. Has the Staff analyzed the uses that must be made during any (or all) credible Harris accidents, of the infornation apnearing on any panel listed in Eddleman contention Id2(c)(2)? If so, which accidentr., and which information on which panels? Please identify all documents concerning each such analysis.
226. Has the Staff any opinion concerning the cualificaticrf of the people who did the DC9D3 for CP&L (the " human factors exnerts")?
Does your opinion of the adecuacy of these nersons ' aualifications incorporate the views of the Licensing Board in Byron (196h)?
Plesse state your view of the sdequacy of these persons' qualifications if you have one.
227. What HEDs and HERSs for Harris has the Staff reviewed? Please idm tify all documents giving the results of your review of each.
223. What information needed by operators in accidents at Harris, which anpears on any of the nanels contention 132(c)(2) says cannot be seen fron each other (or by nersons standirg near each, whose view may be blocked by other nanels ), can be seen from a distance of (e) < feet (b) 10 feet (c) nore than 10 feet (d) nore than 2 feet, with sufficient reliability for accurate inte pretation end reading under high stress conditions such as would urevail in an accident, in your oninion?
229. Has the Staff nade any review of the visual blockages nossible in the Harris control room layout? If so, what docunents contain the results or your review? Please identify all work papers used in your review.
l 230. Does the Staff believe CP&L was (a) right (b) resnonsible, when it set into concrete in the Harris 1 control rcon floor the positions of the cabinets reconnended by its DCRDR consultants, urier to Staff connlet-ing its control room design review for Harris 1? Please give all reasons for your answer and identify all documents information fron uhich was used to make or sunport your answer.
PRODUCTION OF DOCMETS Wells Eddleman and Joint Intervenors hereby reouest K9C staff to make available for it.spection and copying all documents identified in resnonse to any of the above interrogatories. .fg ffpg4G77c# @ Wy
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UNITED STATES OF AMERICA *I NUCLTAR REGULATORY Co!MISCION In the matter of CAROLHA POWER k LIGHT CO. Et al. J) Docket 50-h00 Shearon Harris Nuclear Power Plant. Units 1 and 2 0.L.
CERTIFICATEoF SERVICE a 4p yg Q.g W.E. Response to Sum Disp on 83/8hB A I hereby certify that copies of WE A- TT Tat s " ?mn R e df ; E Trt: to Applicants on Contentions 9, 11, 45, 116, l'32(c)(2);JI Clarification re Dr. ddi 116
' HAVE been served this E day ofJohn Gorman; vn ,.rh WE Response 1, to Apps Interroggries the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are marked with ,
l (jgtl bow l an asterisk for whom service was a compli hed by '
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go o cA nu, + (Odb (& e6 w,fo Vfu, rutuk C & , M R O h p q p a d (ig M'.M f m 1 biowd hb f2 WlI4}(br' egw% }tlhyta) t)pHC (CQvilM iff4 J f. Ef M C% <5,Z 'd JudE es Jays Kelley, Glenn Bright and Jams Carpenter (1 egy each) /6%wg Atonic Safety and Licensing Board ##/Q US Nuclear Regulatory Comission c 8%g Washington DC 20555 c8dsk, cp ~
George F. Trowbridge (attorney for Applicants) (* v' Shaw, Pittman, Potts & Trowbridge R.uthanne G. Miller V 4 1600 M St. W ASLB Panel D )g i WashinEton, DC 20036 USNRC washington DC 2055 5j office of the Executive Legal Director PhyllisLotchin,Ph.D.m4]cg Attn Docke ts 50-400/k010.L. 105 Bridle Run i USNRC Chanel Hill NC 2751h N Washin6 ton DC 20555 HM/sj Dan Read f%
Docketing and Service Section (3x) CEAUCI/FLP 04 Attn Dockets 50-hoo/hol o.L. .
Waleigh, Fro 7NC waveross fxis.
Office of the Secretary h7606 g a t4 ton DC 20555 G e ra tt y John R d le -
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- t. h Granville Rd O, Chapel Hill Ne 2751h Bradley w. Jones Robert Gruber USNRC Region II 3D
'Travi s Payne Exec. Director 101 Marietta St. k.
Edelstein & Payne Public Staff Atlanta GA 30303 Blex 12601 Box 991 Raleigh NC 27605 Ra1.ish NC 27602 Richard Wilson, M.D. Certified by h 729 Hunter St.
Apex NC 275o2 k
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