ML20090F609

Third Set of General Interrogatories & Interrogatories on Contentions 75,80,83,84,64f & 67

ML20090F609
Person / Time
Site:	Harris
Issue date:	07/02/1983
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
References
ISSUANCES-OL, NUDOCS 8307060159
Download: ML20090F609 (20)

Text

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Tl UNITED STATES OF AMERICA a q NUCLEAR BEGULATORY COMMISSION q ~

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n. 3, 2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD O

' O Glenn O. Bright Dr. James H. Carpenter h Y s _.

James L. Kelley, Chairman v In the Matter of J Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 arxi 2) )

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Wells Eddleman's General Interrogatories 6pd IdYBfv8fMuW to Apulicants Carolina Power & Light et al. (ede,vhms 7hkjf6[p (TH lM) Set ) g f ogj 97 Under 10 CFR 2.7h0, 2.7h1 and the Board's 9-22-8? Memorandum and Order, Wells Eddleman recuest6 Applicants to answer senarately and fully in writing, under oath or affirmation, each of the following interrogatories, and to produce a permit inscection and conying of the original' or best copy of all document's ider.tified in resnonse to interrogato"les as set forth below. .

These interrogatories are intended to be continuinF in nature, and I reouest each answer to be promotly suplemented on amended as acorooriate unde" 10 CFR ?.7hd(e), should CPA L, NCFMPA, .any othe*

or any contractor or consultant to any, some or all cf those, Apolicant,por any emnloyee 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 resconsive to these (wh listing (s))

genera ("Them"refeastotheprecedingororoductionofdocuments-nterrogatorie . The reouest is also continuing and reouests Applicants to uroduce promotly if not immediately any additional documents the Applicants and others

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acting on their behalf or employed by them, as listed in the orevious F307060159 930702 l PDR ADOCK 05000400 0 PDR m503 ,

sentence, obtain which are responsive to the request (s) for nroduction of documents below.

Where identification of a document is reauested, nicase briefly describe the document (e.g. book, notebook, letter, memo, renort, notes, transcript, minutes , test data, log, etc. ) and provide the following information as acolicable: document name, title, number, author (s), date of writing or of nublication or both, addressee, the

! date annroved, by whom annroved, and the name and address of eersens haing normal custod* oc tha document, and name and addvess l

t of any nerson other than the preceding having actual nossession of the document. When identifying documents in resconse to these l

_nterroEatories and reauests, please state the nortion or nortions of the document (e.g. sections, chaders , nages, lines ) uron which Anolicants rely or which Aenlicants swear or affirm is/are resconsive to the acclicable interrogatory or veauest.

DEFINITIONS herein:

" Harris", " Harris Plant", "SENFP", or " plant" where not snecified otherwise, all mean the Shearon Harris wuclear Power 51 ant.

"Apelicants" neans all of the persons, emoloyees, consultants, contractors and co-norations as listed in the first sentence of the second paragraph on page 1 of this document, above.

"FSA9" means the Harris Final Safety Analysis "ecort.

"ER" means the Harris Environmental Fenort.

" Document ($" means all writings and records of everv true, including electronic and ccmmuter records, in the nossessien, control or custody of Annlicants or any individual (s) act$ng on Anelicarts' behalf, including, but not linited to: venorts, books, memoranda, corresnondence, notes, ninutes, namehlets, leaflets, magazines, articles, surveys, naps, bulletins, chotogranhs, sneeches, transcrints,

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voice racordings, com7utsr urintouts, information stored !n connutovo or comnuter veripheral devices such as disks, drums, etc., voice reco= dings, microfilm, microfiche and all other writinEs or rscordings of any kind (s); and cocies of any of the nreceding even though the ,

l ori Einal(s) are not in the possession of Acclicants or in their custody or control. Document (s) shall be deemed to be within the i any control of Acclicants or individualfsl acting on their behalf if they have ownershin, nossession, or custody of the document (s) or a cony thereof, or have the ~'ght to secure the docu-ent(s) of a cooy thereof, from ary nerson or nublic or arivate entity hav'rr phve! cal nossessfrn thereof.

Each definit? on given above annlies within all other definitions above.

GSi f EhAG lW& k050Y G1 (a) Which contentiens of Wells Eddleman do Aprlicants agree are now admitted in this croceeding, NoC Dockets 50-400/kO10.L.?

(b) for each such contentien, provide for any answers to interrog-stories by Wells Eddlenan which Acolicants have creviously or nresently received (except those suspended by Board order, if any), the following information:

(c) P1r ise state the name, present or last known address, and cresent or last known ennloyer of each verson whom Aeolicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) unon whom Apelicants relied ( other than their attorneys) in making such answer.

(d) elease identify all facts concerning which each such nerson idantified in resconse to 01(c)(1) above has first-hand knowledF e.

(e) olease identify all facts and/or documents utan which each i

nevson identified in resconse to G1(c)(2) above relied in protiding information to resnond to the interrogatory, including the navts of such docunents relied uron.

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1 ty rel(tA 4D0 (f) Please identify any other document (s) used/by A licants in responding to the interrogatory.

(g) Please state which specific fact each document, identified in resnonse to G1(e) and GL(f) above, sunports, in the ouinion er belief of Anolicants, or which Aunlicants allege such document supnorts.

(h) Please state specifically what information each nerson identified in resnonse to G1(c)(1) or G1(c)(2) above nrovided to or for Anplicants' affiant in answering the interrogatory. If any of this information is rot docunented, nisase identify it as "undocunented" in resnonding to this sect".on of General Interregato-y G1.

present or last known address, G2.{a)*1easestatethenane, title (if any), and present or last known emoloyer, and scenonic interest (shareholder, bondholder, contractor, emeloyee , etc. ) if or other any (beyond exnert witness fees) such persen holds in Aunlicants or expect nn arv nf them, for . each nerson you intend to ce.11 es an . errert witness or a witness in this proceeding, if such informetion has not oreviously been supnlied, or has changed since such information was l ast suoplied, to Wells Eddlenan. This s9nlies to Eddlenen by Anolicants.

and Joint - st nulated (b).Contentions as admitted Please identify each cdStentfon regarding which each such person is expected to testify.

(c) Please state when you first contacted each such person with regard to the possibility of such nerson's testifying for Apolicants, if you have contacted such norson.

(d) Please state the subject natter, separately for each contention as to which each such person is expected to testify, which each such person is exnected to testify to.

unon (e) Please identify all docunents or parts thareof which each such witness is expected to, nians to, or will rely, in testifying or in preparing testimony.

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tv (ehtA y (f) Please identify any other document (s) used/'by Applicants l l

in responding to the interrogatory.

(g) Please state Which specific fact each docunent, identified l f

in resoonse ta G1(e) and GL(f) above, sunports, in the ouinion er belief of Aeolicants, or Which Aonlicants allege auch document supuerts.

(h) Please state specifically What information each nerson identified in resnonse to G1(c)(1) or G1(c)(2) above urovided to or for Anplicants' affiant in answering the interrogator 7 If any of this information is rot docunented, clease identify it as "undocunented" in resnonding to this sect'.on of General Interregato=y Gl.

G2.a) *1 ease state the name, present or last known address, title (if any), and nresent or last known encloyer, and ecenonic interest (shareholder, bondholder, contractor, emoloyee , etc. ) if or other any beyond exnert witness fees) such nerson helds in Aunlicants or exnect errert i nw ar.v n e them, for . each nersor you intend to ce.11 as an witness or a witness in this proceeding, if such informe. tion has not nreviously been supnlied, or has changed since such information i

was l ast sueplied, to Wells Eddlenan. This s9nlies to Eddlenen by ADolicants.

and Joint Contentions as admitted,o= sticulated 1

(b). ? lease identify each contention regarding which each such person is expected to testify.

(c) Please state when you first contacted each such verson I

with regard to the possibility of such norson's testifying for i Apolicants, if you have contacted such person.

(d) Please state the subject matter, separately for each contention as to which each such person is expected to testify, Which each such person is exnected to testify to.

r ueon (e) Please identify all documents or carts thereo which each such witness is expected to, nians to, or will rely, in testifying or in preparing testimony.

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-5 G3(a) Please identify any other souwce(s) of information which Applicants have used to rescond to any intevrogatory identified under G1 above, stating for each such source the interrogatory to which it relates, and what information it nrovides, and identifying wheve in such source that information is to be found.

(b) Please identify any other sourceh)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 in testimony or exhibits, identifying for each such source the witness who is excected to use it, and the nart or part(s) of such so urce (if applicable) which are expected to be used, and, if not (or both) creviously stated, the fact (s) or subject matter to which such source relates, and which Gl;(a) please identify all documents,quages or sections thereof A-51*.c ant s irtand on exnect tn use in evoss-examinatien of any witness I call in this hearing. For each such witness, clease urovide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject natter Aeolicants believe they relate to, and nake the document (s) available for insuection form intent and cocying as soon as oossible after Aeplicants decide or irtwrd I to use such document in cross-examination.

(b) please identify any undocumented information Applicants intend to use in cross-exanination of each such witness for ne.

G5 (a) for each contention Apolicants state or admit is an admitted Eddleman contention under G1(a) above, or an admitted joint intervenor contention, please state whether Auplicants have available to them experts, and information, on the subject matter of the contention.

(b) If the answer to (a) above is odher dian affirmative, state whether Aeolicants exoect to be able to obt&in exnertise in the subject matter, and information on it, and if not, why not.

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G-6(a) for each document identified in resnonse to any interrogatory herein, or referenced in response to any interrogutory herein, please supply all the following information which has not already been supulied:

(1) date of the docunent (ii) title or identification of document (iii) all authors of the document, o= the author (iv) all qualifications (professional, technical) of each author of the document of the document, (v) the specific narts, sections or nages, if any, unon which Aonlicants rely (vi) the specific information each nart, section or nage identified in resnonse to (v) above contains.

(vii) identify all documents used in urenaring the docunent, to the extent known (and also to the extent not identified in the doc unent itself)

(viii) state whether Ann 11 cants nossess a co y of the doc ument (ix) state all exnert oniniors contained in the document, upon which Annlicants rely, or identify each such opinion.

(x) identify the contention (s) with resnect to which Ann 1? cants rely upon (a) the exnert oninions (b) the facts identified x6th-Rax in the docunent (xi) state whether Apolicants now ennloy any author (s) of the document, identifying each such person for each docunent.

(xii) state whether Anplicants have ever encloyed any authdis) of the docunent, identifying each such nerson 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.

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. a G-7(a) Please identify all documents which Applicants plan, exnect or a intend to offer as exhibits (other than for cross-exanination) with

! I respect to each Eddleman contention admitted in this proceeding which l

(1) is included in your current resnonse to G1(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) Flease identify all documents which Anplicants nian, e7nect on intend to use in cross-exanination of any other narties' witnesses or joint intervenor witness in this proceeding, with resnect to (1) Eddlenan contentions identified under G-7(a)(1) (or G1-(s))

above, or any other Eddleman contention which is the subject of inter-rogatories in this set; (ii) each Joint contention now admitted in this nroceeding; (iii) per our agreenent of h-8-83, each contention of each other party to this nroceeding which is cu=rently admitted.

Please identify for each such document the witnesses, or witness, and all contentions with resnect to whon (or which) that document is planned, expected, or intended to be offered or used.

(c) Please identify which of the documents identided in resnonse (i) to (b) above will be offerad into evidence by Annlicants, and (iil which of the same documents Anolicants exnect to offer into evidence or intend to offer as evidence or exhibits in this nroceeding.

G8 (a) Please identify, for each Eddlenan contention which is the subject of this or an earlier set of interrogatories, all inforna-tion not previously identified which was (i) used or relied on in preparation of Anplicants' resnonses to that contention and all contentions superseded by it (ner transcrint of July 1982 anecial prehearing conference, the Board's Sentember 1982 order adn'ttting contentions, or stipulation by Apolicants or W.E.), with respect to i any facts alleged therein, identifying for each such fact the l

specific source (s) of information used or relied unon.

0-8(b) Please identify all persons who supplied information relied on or used in Applicants' response to each contention for which information a

is requested in G 8(a) above. (ii) Please identify for each such person what information was supplied, and with respect to which conten-each iten of tion (s) thuk information supplied was used. (iii) Please state all known qualicications of each such verson with respect to the subject matter of the annimmitan each contention for which that person supolied information.

G-9(a)Please identify all information not identified in resnonse to the above general interrogatories, including all documents, which Applicants rely on or ftend to use in naking their case or carrying their burden of proof in this proceeding, ._-.. .

with respect (1) to each Eddleman contentien which is the subject of this or an earlier set of Eddlemati interrogatories to Anulicants; (ii) with resnect to each joint contention on which discovery is now open unde" the Bnard's March 1983 order, or on which discovery has been open under said order establishing a discovery schedule. (The uhrase "or on which discovery has been onen" is intended to keen this interrogatory current and continuing for information and documents which Auplicants rely on or fovm intent to use after the formal close of discovery.

I interpret Apolicants' continuing interrogatories to aunly continuously from their date of subnission to me, and I intend these to apply likewise.)

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8 Eddleman interrogatories to Applicants (2d set,1st round). Please note that the general interrogatories supplied with the first set are continuing, as writt en, _

andapplytoconthons as discovery on then cones open under the Board's 3 10_ 883 order; however I am supplying a copy of the general interrogatories (revised per my 4-B 83 discussion with Applicants' attorneys 0"Neill and Carrow) at Applicants' request here "because (they) don't like to conpare documents" and intend to continue to do so, assuming thereby that the general interrogatories and first group of sps other interrogatories on a given contention together conprise the "first round" under that order. I therefore assure responses to the general interrogatories in a set are not due until the responses to given other interrogatories (first group on a given contention) are due, and hereby grant that tine to Applicants to respond even if I should inadvertently fail to insert the general interrogatories in any future set of interrogatories. Please note that nothing here affects or impairs the continuing effectiveness of my general or other interrogatories to Applicants.

FURTHER INTERP03ATORIES (2d set,1st round, environnental contentions and those on which Applicants seek sunnary disposition):

NR.as used below, " monitor" includes the neanings " detector" and " detection device" 29-1(a)/Please identify all radiciodine monitors at Harris which will continuously sample levels of any radioactive isotope of iodine, or any co .bination of such isotopes, which is located (i) on the upstrean side of any filter or device which is designed, or claimed by Applicants, to remove radiciodines fron a gas or air stream at the Harris plant; (ii) directly on the downstreae side of any such filter or device per (i) above; (iii) on the downstrean side of any '

such filter or device per (i) above before such stream of gas or air (including any contaminants and radioactive materials) merges or mixes with any other vent, duct, roon, space or other strea. or source of air or gas which originates within the Harris plant containment, spent fuel building, auxiliary building, or other area into which the FSAR or ER contemplates or states that radio-iodines can be present during normal operation (including by leaks or accidental transoort which does not cause the plant to cease operation); (iv) at any other point downstresn of any such filter or device per (i) above but before the release of the air or gas strean (including any contaminants or radioactive material it may include) to the environnent; (v) located outside any enclosure or building or vent at Harris but within 10 meters of any designated release point for radiolodines per the FSAR or an n currently revise &t (v1/ Auc.ted hm.

more than 10m 'uut, Asee th.n 190 n fron any designated release point per (v)

(Yii.) located more than 166 meters from any designated release point per (d above; (viii) located between two op anore such designated release points per (v) above or within 100 meters of more than one release point, giving for each such continuously sampling nonitor its distance fron each release point it is within 100 neters of; (ix) located outside the exclusion area for Harris; (x) located at the boundarynot the Harris exclusion area.

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Further specific interrogatorios to Apolicants, third set. This ends the first round for Eddleman 6kr, 67, 75, 80 and 83/8h, all of which are environnental contentions excent 67. Applicants and I have agreed to serve our second sets of fnterrogatories on Eddleman 29 and 373 on each other July 20, 1983 With agreenent of Annlicants' counsel Baxter and Flynn, Sta cf counsel Baath , and Judges Bright and Caroenter, this set of

• nterroFatories may be filed as latem as July 2,1983 and still be considered tinely.

INTERROGAT09IES RE 6h(f) 64-10(a) Does the consolidated safety analysis renort (CSAR) for the IF-300 series cask consider the possibility of the valve box (1) being crushed (ii) being sheared (iii) being sheared off (iv) being nenetrated by a solid object (v) being nenetrated by a long object being innacted, such as a steel bean, rail, or re'nfor-cing bar (vi) having die cask roll over onto it, causing damaFe?

(b) for each nart of (a) above for which your answer is affirnative, niease state at what nages the CSA9 considers such nossibility, and state all additional views Annlicants hold conce=ning such nossibility (which aren't in the CSAD), stating in detail the technical o= othe=

basis for each such view and all facts that underly it, identifying all documents in which such view or the basis for it or nart of the basis for it is contained. (c ) Do Appli cants agree that if the valve box were open to the outside or without integrity (e.g. due to events such as are inquired about in (a) above ), the valve could be directly exnosed to flanmable fluids in an accident? (d) If your answer to (c) above is other than affirnative, niease state in detail all basis for your view, identifying all docunents and expert opinions upon which you rely in holding such view.

64-11(a) Are there at:y other nethods for providing cask internal pressure relief, besides a pressure relief valve, currently approved by D.0 for use with the IF-300 cask? (b) If your answer to (a) is affirnative, please list each such nethod, describe it in detail, and reference the CSAR pages Brdany other documents which describe such nethod. Please also cite and identify each NRC docunent which approves each such nethod.

64-12(a) Has the integrity of the pressure relief valve on the IF-300 cask ever been tested under (i) actual (ii) sinulated accident conditions?

(b) If your answer to (a)(i) or (a)(ii) is affirnative, for each such affirnative answer please state the following: (i) all conditions of such test or accident, including internal cask heat generation rate, whether a fire bu ned outside the cask, the tenperature and du-ation of each such fire, Wether the valve box wascrushedduringtheaccident/ test,whetherthevalveboxwaspenetrated during the accident / test, the speed of inpact if any, whether the cask rolled over, whether the valve seating was positively known at all tines during the accident /

test (and if not, for what tines it was known), whether the valve unseated during I the accident or test, the naxinun tenperature inside the cask during the test /

accident, the naxinu . pressure inside the cask during the test / accident, whether thetest/ accident,whetherany-1 any thingfission productsfron was released were inside the caskthe caskthe during during/

test accident, t at any such released naterial was released fron (if known), the date of such test, the conductors of such test, the date of such accident, all docu-ents centaining report (s) or analysis of such test / accident, and whether any persons working for CF&L were involved in the test or accident in any way (and if so, how).

64-13(a) 'h.at is the nelting point of the Rulon naterial used in the IF-300 ressure relief valve (i) at 1 atnpsphere pressure (ii) at 375 psig?

p(b) what is the nodulus of elasticity of Rulon (i) at 1 atn pressure and 200 c (ii) at 375 psi pressure (ga,uge) and 4000 F (iii) at any other pressure and tenperature at which its nodulus of elasticity has been deter .ined?

(c) what is the nodulus of conpressibility of Rulon (i) at 1 atn and 20*C (ii) at 375 psig and 400 F (iii) at any other temperature and pressure for which its nodulus of conpressibility (bulk nodulus) has been determined?

(d) what is the shear nodulus of Rulon ? (e) has the shear nodulus of Rulon 0 F7 ever been tested at a tenperature over 100 If so, what tenperature was it tested at and what was the shear nodulus -- please list the results of all such tests known, and all shear noduli deternined for Rulon at elevated tenperatures.

(f) Is Rulon enbrittled by (i) neutron exposure (ii) ga .na radiation (iii) heat (iv) continuous pressure on it? (g) for any part of (f) for which your answer is affirnative, pelease state the conditions and degree of enbrittlenent which have been found. (h) If Rulon has not been tested for enbrittlenent under each agent identified in (f) above, please so state, for (i) neutrons (ii) ga na radiation (iii) heat (iv) pressure. (j) does internittient pressure entrittle Rulon to any extent? How nuch, under what pressure and conditions of internittency? (k) please identify all docunents which contain infornation concerning the above-asked properties of vulnerabilities of Rulon, stating for each which response above it relates to, and what facts it contains that are responsive to each part of each question above, if any.

6414(a) If a rupture disk were used on the IF-300 cask, and it ruptured, would there be any valve that could be used to stop the escape of naterials fron the cask cavity through the broken rupture disk? (b) please identify any such valve, its CASAR reference if any, all docunents describing such valve, and what would have to be done to use it to close off the escape of naterial through a ruptured rupture disk on the IF-300 cask.

- l 0' interrogatories on E-67 67-5(a) nicase identify every iten which Annlicants exnect or believe will be disnosed of from the Harris plant as low-level radioactive waste (LLPW). A descrintion w'11 suffice for items that cannot now be identified, e.g. c1 caning materials, contaninated narts removed in renairs, etc. (b) Are Annlicants willing to have a license cendition on Har=is (in the overating license) that restricts disuosal of the itens identified as LLoW in res,orse to (a) above so that they can only be disnosed of as LLPW o" as high-level wasto under NRC rules? (c) If answer to (b) is other than af#irmative, please state in detail all reasons for vour answer, and state if there are any items not included in response to (a ) above which may be disntsed of as LL9W from Harris, and list all such itens, g.

(d) Fo= each item identified in rescorse to (a) above, please state raiv0

$1) the expected average, (ii) the expected maximun, and (iii) the maximum allowed (under tech soecis as pronc sed, Noc regulati ons, or any other limitation known to Annlicants): (aa) weight (bb) volune (cc) content of each radionuclideVIh 10 C"R part 20 and i ts annendices, as a ninimum and a naxinum, $n (c[-a) cuvies new unit volune (cc-b) curies ner unit weiF bt (cc-c) total curies (cc-d) curies ner unit of the item (cc-e) mass of such radienuclide (cc-f) any other terns wh! ch Apnlicants have used to characterize the radioact'vity of such item. (NOTE, milli, micro, nano, n' co curies etc car he used in answers to this nart -- it doesn't ask =ecalculation into cuwies);

(dd) number of such itens ner year in nornal opernt'on (ec) nunber of such itens to be disnosed of over the lifetime of (i) one Harris unit (ii) both units; (ff) nunber of such items which Aurl! cants olan to disnose of as LI9W (ff-a) new year of operation te= Harris unit (ff-b) over the lifetime of each Harris unit (ff-c) over the enerating lifetine of both Harris units (ff-d) as a result of accidents and other events beyond nornal naintenance (ff-e ) a s a result of retai-s to Harris unit 1 (ff f) as a -esult of renairs to Harris unit 2; (gg) max

• nun limit, if any, of such items wh' ch can be disposed of from Harris as LLRN, in (gg-a) number of itens (gg-b) cuantity of radioactive material contained in such itens, list!ng the number of snuch items, and the radioactivity of each radionuclide contained in each iten or the total (naxinum) nunbe= of itens; (hh) a description in full of the storage o" care of each iten from the t'ne it becomes radioactive or is contaninated with radioactive material, to any on-site storage, to shipment to any offsite disnosal site (including packaging)(and loading), the arrangenents made by Annlicants to nonito= such material when u"oduced, when identif$ed as LLOW, when l it has not yet been stored as LL94 at Harris, while in stoaage as LLRW at Harris, during cackaging for shipment off-site fron Harris, during loading for such shionent, during such shionent, at the l receiving site, and at disnosal; any arrangenents nade by Arn1' cants to contain the radioactivity of such naterial du=!ng any of the preceding states ("when produced ... and at dis,osal") listed above, including the ecuinment used, its method of containing such radio-activity, its efficiency (hh-s) by test (hh-b) as celculated, F i ving in full a'l suonorting calculations and *nformation, ard identifying all documents wherein such infornation is found or such calculation (s) have been nade (hh-c) in actual oneration, identifying the site of such ooeration, the nethod of assessing such efficiency, all reasons for the choice of such method of assessing efficiency, and ident*fying all documents which include information on the test veouested in (hh-a) above, or the actual operatinn fron which determinat'en was made.

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67-5(d)(hh) continued

" Efficiency" as used here'n meens eithev "4 containment of each radionucl.ide, or the total cu"ies of all radionuclides, in the LLRW (items of aggre6 ate) " or "any meesure of the amount centained, the amount tranned, or the arount released" o* rad

• oactivity in 1 LLRN, known to Annlicants and ann 11ed by them to such method of containing the radioactivity of LL*W. (hh-d) Do Annlicants know

! of any information requested above in part (hh) and its subparts, or any part thereof, which was determined or . .a is known to someone other than Annlicants? (hh-e) If answer to hh-d above is

. .I afffirnative, nicase identify all documents Annlicants i nossess that contain such information, and identify all other such information. (hh-f) Please state which part(s) of nart(hh) above each item of information or document identif$ed in response to (hh-e) above contains informat'on resoonsive to, statinF the information if possible. (jj) Are there any facilities at Harris for storage of such itam, i.e. dedicated to storinr that iten on1v: (kk)

Are there any facilities at Harris for storage of such ite9 together with othew LL9W? (11) Are there any facilities at Harris for storage of such iten (aa) with other radioactive wastes or snent fuel (bb) with nonradinactive itens (cc) with other rad *oactive matewials, j e.g. fresh fuel, radioactive items in swoke detectors etc in use at the plant, radioact!ve items in instruments in use at the olant i

("in use" includes itens stored for possible use at Har=is or for use elsewhere, if such storage is at Harris), "nedium l evel" radio-

active wastes? (mm) for each facility identified *n resncnse to any

of jj, kk, 11 above, please state (aa) the locat'en of such facility (bb) the maxinun volume of waste (LL'W) which can be stored in such facility (cc) the maxinum volume of Stens othe= than LL9W which can be stored in such facility while it contains any LLSV (dd) the volune of such facility (dd-a) internal (dd-b) external (ee) whether the facility. is continuously monitored for rad *artion levels, and if so how, identifying all instrumants used for such and their locations and how they are read (ff) whethe* the fac*1ity is cort'nuous)y i monitored for le vels of each radi onuclide listed

• n 10 CF7 vart 20 and its anpendices, in air in the facility, in water or l' quids in the faci 1*ty, or in cny other content of the facility including i the LL9W itself, stating for each nucl'de nonito"ed continuously the forns it may take (particle, gas, dust, solid, l' ouid, solut! cn, etc )

the method and instrumentation used for such nonitoring, how such monitors are read, who reads then, and how often such reading is reautred (gg) whether the facility is monitored in any way other than continuously for radiat'on (hh) if answer to (gg) is affirmative please state the identify and location of all such nonitoving ecuinnent, tha nue' ides and/or forms of radiation such mon'toring equiument can detect, the lower and unner thresholds of such detection, how such nonitoring equinment is read, how often, by whom, and how often it is required to be read, and whether it determines the rad'o-nuclides nresent in LL*W stored *.n or nassing th"ough the facility (jj) what Monitors or nethods are used to detect rad!ractive naterial escaning from such facility (a) along exnected routes of renoval, e.c..through air ducts, drains, vents, etc (b) thveugh leaks o" abnormal escapes or alonE rr tes other than those radi.cactivity is expected to escane th"ough ' (c ) through unauthorized removal of radioactive naterial by nersons (d) through renovaal of radicac+1ve material by other.livinF creatures, e.g. mice, ratsg identifyinF i

fo" and each it a suchtomonitor tNvity

• itsQlocat'on, kcF r M s?" ale"ningsegum Wi 7 ogaeage}opf,1 levels if any

I ;L -

67-5(d)(nn) continued and for each radionuclide to which it is sensitive or wh*ch it can detect. (end of (mn))

$nn) Please identify any othe" cortrel, ncnitoring, or containment nethods for Harris LIoW not ident'fied in res,orse to the ebove questions or narts. For each, niease state whe"e and how it is used, describe it, and state whether 't can detect o" r" event LLFW at Harris being released to the envi"ennent, g'v'ne tha baris of such resn( nse in detail and icentifying all document s conta* n' nc such information or sunnorting this resm nse or any nart of it.

(oo ) Please state exactly what technology for storare and conta'nnent of LL9W is used for each faci.lity identified in resnonse to (jj) (kk) or (11) above (not part jj under part nn) by Anclicants, what sites other than Harris Anolicants know the same technology *. s use d a t ,

what sites othe" than Harris Annlicants krow that c' nilar technolo67 is used at, whether there have been any releases of radioactive nateric1 into the environnent from LLT4 at each such s'te (stating the t'~n, data, and n-runt released if known, identifvinc wh'ch site the release was f=o . if known).

(e) Do Anplicants contend that landfil)s will not leak within the (i) halflife (ii) 20-halflife pe"iod (iii) 30 half-1'ee neriod of (aa) Cesium-137 (bb) St 00) (ce) nlutoniun-210 (dd) nickel do (ee) niobiun -9h (ff) Icdine-129, if rad'onctive waste (LLow) centaining any o= all of such materials is disposed *n them.

(f) niease answer all narts of (e) above assum'tr a ra'-fall of 50 inches pe" year cf wate" on the 3 cndf!11 and a clay can (g ) please answer c1] narts of (e) above assun'rf a ra'rfall on the landfill of 50 incher per yea" and a clay ca" ar.d a clastic cover belcw that, over the Inndf'1] .

(h) nicase state whethen there is any leval of ra'nfall less than

$0 'nches ner year that would charFe vour answerr te e' the" (f ) or (g) above, stating what chanres would result at wi 'ch level of rainfall on the landf*11; (i) please state whether there is an" k'rd oc landfill liner in ec7mercial use for wh*ch vour answer to any na"t o c (e) above wculd be affirmative, stat'ng fo" each such line* its manu*actu"e"(s),

what it is nane of, the 1cngest it has been used in any LLOW 1andf'.11, whether any landfil] using such liner leaks , to the n"esent date,

( th '. s is c continuinr interrogatory, of course: late" leaks should be noted when Annlicants les"n of then), which nart(s) of (e) above tre answered affirmative 1" for such 1.iner, and identifying all basis fo such answer including all docunen+ s , s t udies and ' nforma t' on uhich sunnert your answer.

(j) please state whether there 's any cerbination of landf'31 locat'on, liner, cover, f'115ng prodcedure, o" other landf'1] characteristics (and/o" tha n"ncadd rg cha" set er'stics) wl ' ch $ n Appli carts v4 ew guarantee that a LLD'1 landfil] vill net leak (1) during ' ts onerat'nr life (ii) within 100 years (iii) with'n 500 years (iii iv) with'n 1000 yeare (v) within 20 halfliver of Pu-230; (vi) w* thir 20 halflives of I-129 (vii) within any other snecific tire neriod.

(k) If answer to (j) above is affirmative, niease state the combinnt'en of landf'll character'.stics recu' red, 'r detail, and ri ve a]' bas's, analysis and informat.'or which surnorts your answer. identifyinr all docunents which conta* n such infermati n or analys's, studies, etc.

(n) please list all violations or devint* nns or noncomeliances with nackag.'.ng reculations or other a reEulations for the trans ovt of LLFW which CP&L (1) has been cauFht in by Nvc (ii) has committed but oYe?tY0k & kokebo b (Wr$ TOY"Wo TW z

67-5(n) continued beyond the requ".=ed notificat' r'n deadline for such v* cla t! "r ,

deviation or nonconnliance.

(n) claase state the nax' nun numben or cu*ies of LL"W wh* ch CDhL has ever shinned for disne. sal as:one ite. (ii) one shinnent (111) total shinned throuFh IP-31-82 fren all CD&L nucles" fac l$ ties: i (iv) total sh".noed to date.

(o) Has CD&L heen shinned any ra d' onctive m t e"' al (LL"W) wM eh arrived at a disposal sit e o~ othe= authov* zed =ece* ver (i) lenk!nr (ii) with a radioact* vit" level at or at a pf ver. distence fron its surface in v!alation of transnort reculat'ons cor LLW on in excess of that newn'tted for the tyne' of sbirnent II, II, III, etc) made?

(u) If answer to (o) above is affirmative, nieare list aach such and state the conditicn it ar=*ved in.

(q) has any shionent fre CDFL to any LLDP s! te even been rejected for dfsnosal in such site?

(r) If answer to ( c. ) is aff$ rnative, niease list each such shit"mnt, the reason F iven for its reject'on, and wheve and how such sh *nnert was disnosed (or where it i s nov stored), ierc=ibing ' ts contects and radioactiv'tv 'n as much deta".1 as CDFL knows (i) a+ the f I

tine of shionant (ii) at arrival at the site (iii) at the t i.ne cf rejectirn (iv) at nresent, if known.

67 6(a) Do Applicants have any plans for (1) L E : storage at Harris (ii) other options for lee. disposal, amt (iii) reducing the a~ount of LE.: produced at Harris, which they have (aa) considered (bb) planned (cc) adopted for use in the event that the State of NC does not ratify a conpact with other states for LLW disposal or fails to develop its own LLR5 disposal site while having not ratified a conpact with another State or States for LL Jc. disposal?

(b) please list each such plan, state which (if ag) of the following it involves: (i) LE storage (ii) expanded LLEi storage areas (iii) lei l incineration (iv) LLR.i pulverization (v) lee.' compaction (vi) reducing the amount of lev produced, (vii) disposal of LLRW at sea (viii) disposal of LLRU in other countries (ix) other options for disposal of LLRJ, identifying each such.

(c) please state whether each plan listed in response to (b) above is (i) now adopted (ii) proposed for adoption (iii) sonething CP&L or Applicants have considered (iv),an option forCP&L or Applicants (v) considered too expensive, listing cost (vI) considered to engender citizen opposition.

(d) Has CP&L considered any illegal nethods of LEJ disposal for use at Harris?

If so, please state each such and whether it was approved or rgjected, by whon, and when, giving the anount of LLRd disposed thereby, if any.

(e) Does CP&L or Applicants have any arrangement or agreement or understanding with any other utilities for storage, incineration or disposal of LE4 by the other utilities (of any of then) for Harris LLcl.a _ ... . . -

N

- '.  :? (f) If answer to (e) is affirmative, please list each such arrangenent, agreenent or understanding, all other parties to it, what it provides for, what conditions it cones into effect under, and how nuch LL"Je. can be handled under the arrangenent, agreer.ent or understanding (by volu .e, curies, or any other neasure involved in such arrange .ent, agreement or understanding). If there is no upper linit on the a-cunt of LIB involved, please so state. .. (g) does CP&L hasve any plan or arrangenent for diseosal of L E i other than shipment to an approved site for disposal, and the ones listed in response to interrogatories and parts thereof above? If so, please identify each such plan or arrangerent, all docu .ents condtaining such plan or arrangenent, and specify all details of such plan or arrangenent. (h) please identify all documents containing infornation inquired about in parts (a) through (f) above (or any .part or subpart thereof), stating which subpart(s) each has infor .ation about in it.

, 75 INTERR03ATORIES ON EDDL H "

Has the 3runswick nuclear plant ever experienced any difficulty 75 with6(a)its EHR systen which resulted fron organis~.s growing inside a heat exchanger? (b) If answer to (a) is affirnative, please describe ihm each such incident in detail and identify all docu-ents in CP&L's possessio 2 which (i) describe such incident (ii) deal with its causes (iii) deal with its safety significance (iv) deal with neasures to prevent its recurrence (v) deal with costs associated with such incident (vi) describe repairs nade or to be nade as a result of such incident, for each such incident.

(c) Did failure to chlorinate have anything to do with any incident of(d) If ansue organisns gorwing in heat exchangers at Eranwsuick?is affirnative, ple CP&L has sent to URC concetrning such incident, all documents relating to chlorination as it applies to such incident, and how lonc chlorination was not perforned prior to the discovery of the growin; organis.s in eachtosuch 1 applicable Unit incident.

2 Please list incidents applicable to Unit 1 an' incidant.

separately unless the incident involved M b unli,r, in which case so state, other cart ofplease.

(e) For thic each incident interrogetory identifici above, ... rceronse please state to li) (d) above er whether CPEar had a c1"1orination before the incident, which plan included water in which the organis.:s were found growing (ii) whether CP&L had any other biofouling control plan for the equip-cent involved in the incident, before the incident, and (iii) state all details of each such plan and identify all decrents which detail or include such plan.

(f) for all instances in which chlorination was not perfor-ed prior to an incident listed in response to (d) or (b) above, please state all known reasons why the chlorination was not perforned, and please state if failure to perforn such c11erination vaated any CP&L plcn (including any identified in response to (e) above), policy or procedure at Erunswick. (This can te answered Yes or Xo unless you're net sure, for the last part, i.e. whether any plan, procedure or polic/' was violated by failure to chlorinate. )

75-7(a) Does CP&L plan to use arg nethods besides chlorination (b) If answer to (a)toisprevent affirnative, Corbicula from living in the Harris plant?

please identify each such nethod, state how it will b identify all docrents and state all expert whic" support your raswer, and identify all docu-ents which contain descriptions cf each such plan or any such plan.

75-e(a) Does CP&L believe that it is possible to prevent Corbicula fron living in the Harris cooling lake? (b) Does CP&L believe that it is possible(c)toDoes prevent Corbicula fron living in the Harris auxiliary cooling lakc?

CP&L agree that Corbicula are present in the CapeM Fear River near their site for a Harris punping station? (d) does CP&L agree that Corticula(e)are present does CP1L in Euckhorn Creek below the nain dan for the Harris nain lake 7 know of any way to absolutely assure that Corbicula do not get into (i) the nain Harris lake? (ii) the auriliary Harris lake? (iii) the Harris cooling systen?

(f) If your answer to either (a) or (b) above is affir .ative, please state for each such affirnative answer all reasons, authorities and inforcation you rely l Please identify all docunents which contain on to support each such answer.

such infornation, nane any expert whose opinion you rely upon to support such answer or any part of it, state all qualifications of such expert, state whether such expert is employed by CP&L or Applicants, and describe in detail the reasoning you use to support your answer fron such infornation, authorities or expert opinion, identifying each specific fact you rely on and its source.

INTERROCATOL.IES ON EDDLE:AN 80 80 4(a) To Applicants' knowledge, for how long has lack of ability to nodel rainout accurately been acknowledged to be a problen with radiation dispersion (or diffusion) studies (1) for reactor accidents (ii) for routine operation of reactors where radioactive material is being released? (b) Do Applicants know of av modeling technicues or conputer prograns which can nodeWrainout

. dry deposition of radioactive material (iii) snow deposition of radioactive (iN' material (iv) entrainnent of radioactive naterial in hail (v0 deposition of l

radioactive caterial in any other forn(s) of precipitation? (c) identify each model you know of for each part of (b) above for which your answer is affirmative.

Please list for each such model its author (s), title, date and what it nodels.

Please state for each such .odel whether you know of any deterninations of the accuracy of that nodel versus av test data, and if so, what test data, identifying all docunents in which the test data or the determination of accuracy of the model is contained.

80-5(a) For each docunent previously made available to ells Iddlenan re contehtion 80, please state (i) whether CP&L or Applicants rely on any facts or fact in the docunent (i$) identify each such fact, and on what page(s) it appears in the document (iii) whether Applicants rely on any opinion expressed or quoted in the docunent (iv) identify each such opinion and the page(s) on which it appears. (b) Please answer each part of (a) above for the docunent

" Dispersion in the Vicihity of Buildings" (your response to 1st set of interrogatories, p.24) when you locate it.

80-6(a) Do Applicants know of any atnospheric diffusion or dispersion tests where the results were within 17,of those predicted by any nodel? (b) please identify each such test, its date, and all docu.ents centaining the model predictions and/or the results of each such test. (c) please state for each such test whether it was done at the site of (i) a naclear power plant (ii) a nuclear facilitt of any kind (iii) a CP&L plant (iv) a CPil nuclear plant ,

where CP&L plants include those co-owned with NCD:PA and/or others.

80-7(a) What is the accuracy of prediction of atnospheric diffiusion nodels relied on by Applicants, conpared to actual tests of i diffusion? Please identify the nunerical accuracy (plus or minus percent) of each such nodel, which test estahlished such accuracy, and how such accuracy was calculated and whether it applies to all predictions of such nodel. (b) Do Applicants know any reliable way to assess the accuracy of at .ospheric diffusion or dispersal nodels m*lrwr as conpared to actual test results? (c) If answer to (b) is affirnative, describe each such way, identify what nodel it is applicable to, what test results such way is applicable to for each such nodel, and whether CF&L uses the nodel in question, mz and whether "RC Staff uses the nodel in question --

"nodel in question" neaning any model you identify a way as applicable to.

If a way is applicabic to more than one model, ann:er each pert of (c) for each such nodel; if nors than one way exists, please list models to which each way applies, separately u . der each uny. Then for each such snedel answer each part of (c) above.

(d) for each way of assessing accurtcy of nodels identified above, please give all reasons and epinions you rely en for your state.cnt that this way (i) is accurate (ii) is cpplicable to each nocel for uhich you say it is applicable (iii) is accurate for each such nodel.

1

-16_

l 80-8(a) Have (i) Applicants (ii) anyone working for Applicants (iii) NRC (iv) aryone else known to Applicants (state who if identity is known) actually

g. , testeL(1) any gases (2) Kr-85 (3) non-radioactive tracer gases (4) non-

' radioactive particles (5) radioactive particles (6) radioactive gas other than Er-05 (aa) the (7)Harris non-radioactive plant site aerosols (8) radioactive (bb) the Harris aerosols cooling tower (ce)etw thereleased Harris 1 from turbine deck (dd) the area of the Harris turbine (ee) the Harris steam vents (ff) the Harris radwaste stack (gg) the Harris containment (hh) any other part of the Harris plant -- please specify in detail which part -- (jj) any part of CP&L's Brunswick plant ($kk) any part of the Robinson plant at Hartsville SCf (b) for each part of (a) above for which your answer is affirmative, please list each such test, the date, location of release (each location if more than one release point ) what was release fron each release point, who did the test, who collected the data from the test, Wat protocols, plans, and measurements were used in making the test, what sampling equipment was used, whete it was located, all specifications for test methods, releases and sanpling equipment used in the test, and identify all documents containing the test plan, test results, spedifications of equipment used during the test, including sampling and detection equipment, protocols for data couection, sampling or detection of material dispersed, and the duration of the test.

(c) identify each person known to Applicants who performed a each test identified in response to (b) above, state their qualifications, Wat each such person did concerning the test, W ether that person evaluated any test data (and if so, when), and state how such evaluation was performed.

(d) For each test identified in response to (b) above please state whether the test results were compared with the predictions of any nodel, and if so, what model, d at predictions, what the results of the comparison were; please also identify all docunents for each test in which such comparison (s) are made, and all docunents Wich contain the prediction (s) of the model which were compared, and all documents which contain the specifications of the model which made those predictions. Please give the date of each such document, for each model and for each comparison, if known.

80-9(a) Have Applicants or anyone working for them made any study of rainout of radionuclides, or any investigation into rainout of radionuclides?

(b) If answer to (a) is affirmative, identify please all the documents in which such study or investigat$on is contained, each author of each such document, the date of each, indicate whether Applicants possess a copy, and state the opinions or facts in each such document on which Applicants rely, if any.

(c) Are Applicants aware of any other studies or investigations into rainout of radionuclides other than those identified in response to (b) above?

l (d) If answer to (c) is affirmative, please identify each such study, or investigation, all documents which contain each such study or investigation, and specify all information and all opinions therein upon which Applicants rely. Please also indicate if Applicants possess a copy of each such document.

80-10(a) Are Applicants aware of any study or investigations of entrainment of radioactive gases in rain, snow, hail, thunderstorms or other precipitation?

(b) if answer to (a) is affirmative, please identify all documents containing each such study or investigation, its results, its author (s), and state what facts or opinions therein Applicants rely upon, if any.

1 INTERROGATORIESONEDDu! MAN 83/84 83/84-8(a) Have Applicants or agone working for then made any study of trihalomethane (1) concentrations (ii) formation (a) in the Cape Fear River (b) in water supplies drawn from the Cape Fear River, or in chemical treatment thereof for use as drinkable water (c) in the Harris cooling lake (d) in the Harris plant cooling system as now designed, taking account of the chlorination to be done in it (e) in the Harris plant cooling system taking account of addi-tional chlorination to control Corbicula (f) that asht could or might be formed in the Harris cooling lake due to Harris plant chlorine releases into that lake?

(b) for each subpart of (a) above for which your answer is affirmative, please list the date and title of such study (if workpapers, or untitled, so state),

identify an documents containing such study (or workpapers), identify all information sources used in making such study, a n documents containing such information sources for each such study, an qualifications of each author of each such study, and an facts in such study upon which Applicants rely.

(c) Are Applicants aware of any studies or investigations by anyone esise which address tr13alomethanes (concentration or formation) in any of the places asked abvat ih subparts (a) through (f) or any of them, as set out in 8(a) above?

(d) If answer to (c) is affimative, please identify all documents containing each such study, state whether it deals with trihalomethane concentrations, formation, or both (state "both" if it is both, " concentrations" if only that,

" formation" if only that), state whether Applicants possess a copy of such document, state which of the waters or water systems (subparts a through f of (a) above) it deals with, and identify each specific fact or opinion therein on which Applicants rely, for each such document.

(e) Are Applicants aware of any other studies of trihalomethanes (i) at nuclear plants (ii) in nuclear plant effluents (iii) in NC water supplies (iv) in water supplies (v) as regards their toxicity (vi) as regards their carcinogenicity?

(f) for each part of (e) above for which your answer is affirmative, identify please all documents which contain such studies, state whether Applicants possesas a copy of such document, give the author (s) and all qualifications of each author that you know, and state specifically which facts and which opinions, if any, therein you rely upon.

83/84(9)(a) Have Applicants made any study of the effects of chlorination on (1) metals (ii) ionization of metals (iii) carcinogenicity of metals (aa) in the Cape Fear River ( Ibb) in the Harris plant condenser (s),(cc )

in the Harris cooling water piping (dd) in the Capet Fear Riverf (This question is for each part separately, i.e. there are 12 parts to answer, 14,re metals in aa thru dd, 5-8 re ionization of metals in aa thru dd, and 9-12 re carcinogenicity of metals in as thru dd. *83/848(a)above is designed in the same way, and has 12 parts (2x6))

(b) for each subpart of (a) above for which your answer is affirmative, identify please an documents which contain such study, and identify an facts and opinions therein on whsich you rely, for each such document. -

(c) Have Applicants made any study of the effect of (i) acid rain (ii) acid precipitation (iii) emissions from the Cape Fear power plant on (aa) the pH of the Harris cooling lake (bb) chlorine reactivity in the Harris cooling lake (cc) chlorine reactivity in the Cape Fear river (dd) chlorine /

reactivity due to lower pH resulting therefrom?

(d) Are Applicants aware of any study by anyone else which addresses any of the matters inquired about in(a) or (c) above or any subpart thereoff (e) for each affirmative answer to (d) or any subpart of (c) above, identify please an documents in which such study is contained, state whether Applicants E$c$* spice NcI$k Sh$nbn eI*chshshy*k"pkiNk's h'u .

ILT.THER INTERROCATORIES ON EDDLE!:AK 67 67-7(a) Do Applicants agree that NC nay withdraw fron the radioactive waste conpact if it is ratified (^E conpact)? (b) Is there a provision in the KC compact legislation that provides for such withdrawal if another state refuses to take a site for IIR" disposal? (c) Is there any other much provisien in the legislation for KC ratifying the compact which pernits withdrawal by KC7 (d) for each answer to any of a,b or c above which is other than affirnative, please state in detail all reasons for your answer and all facts which support your answer, giving the source of each such fact or opinion or reason.

(e) please state all contingency plans Applicants have if 50 withdraws fron the SE conpact, or identify all documents containing such plan:,giving the title, author and date of each.

(f) does CP&L have any plans to reduce L'JJJ generation at Harris (i) if EC does not ratify the SE LLE i conpact (ii) if !!C withdraws fron such conpact at a future date?

(g) for each affirnative answer to any part of (f) above, please identify all documents which include such plan (s), the author (s), title and date of each.

(h) Does CP&L have any plans to prevent EC fron withdrawing fron the SE LIE.

compact? (j) If so, please identify any docunents containing such plans or infornation about such plans.

REQUEST FCE P.'.07JCIIO:: CF DCCUZEK!5 I hereby request that Applicants nake available te ne, within 30 days of the date hereof (7 2-83) for inspection and copying, the original or best ecpy of each document identified in respense to the above interrogatories, at a place and tine nutually agreeable, and that ! h giv)a the opistien of borrowing docr.ents to copy then :.t ..y expense and return sane within 24 to 4C hours, in the sane way that I a:. nakinu dccu.ents available to CP&L. ~

// n j /{ = Db,h.

'!sils Eddlev n 2 July 1953

7

,4. .

GPU Nuclear g g7 P.O. Box 388 Forked River, New Jersey 08731 609-693-6000 Writer's Direct Dial Number:

June 30, 1983 Mr. Dennis M. Crutchfield g j //l Operating Reactors Branch #5 Division of Licensing pv i U. S. Nuclear Regulatory Ccmmission Washington, D.C. 20555

Subject:

NUREG 0737 Items II.F.1.4 Containment Pressure Monitor II.F.1.5 Containment Water Level Monitor II.F.1.6 Containment Hydrogen Monitor The purpose of this letter is to forward the additional information requested in your telecopy of June 1, 1983, to Jim Knubel, Manager of BWR Lic ensing . In this subnittal we are providing, as requested, error information for mild environment, even though the instruments installed in acccrdance with these NUREG 0737 items are for post accident monitoring. Should you require any further information, please contact Jim Knubel at (201) 299-2264.

Very truly yours, Q fD Peter B. Fiedler 7

Vice President and Director n, Oyster Creek PBF:jal Enclosure cc: Regional Administrator Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 NRC Resident Inspector .

Oyster Creek Nuclear Generating Station Ok Forked River, NJ 08731 g g Foo7060139 030630 f5DR ADOCK 05000 l

P GPU Nuclear is a pa.t of the General Public Utilities System i

F

- F ,

f .,.

The response to NRC request for information is presented by items listed in the NRC letter.

(1) GPU Nuclear does not take any exception to NUREG 0737 items II.F.1.4, II.F.1.5 and II.F.1.6 for Oyster Creek Nuclear Generating Station.

(2) II.F.1.4 - Pressure Monitoring System (PMS)

(2a) The PMS block diagram with important data is given below. The redundant loops are identical, therefore the following applies to both the loops.

Pressure Pressure / Level Transmitter Indicating Recorder

! Manf. Rosemount Manf. Tracor Model 1153AB7 Westronics Model: D4E-1-780-780-000-5-1-10-0 Location: Rx Bldg. el. 51'3" Control Room Span Limits: 0-50/0-300 psia N/A i

Time Const.: 0.20 secs. 0.352 secs.*

Cal. Span: 0-260 psia 0-260 psia Post Accident Errors 7

Radiation 2.2 X 10 l Rads TID: 8.0% URL N/A (Located in mild environ.).

LOCA/IIELB: I (4.5% URL + N/A (Located in mild environ.) l 3.5% cal. span)

Stability: 0.25% URL for 6 None

' Mos. **

+

Accuracy: Incl. in LOCA/HELB 0.5%

• The time constant for Westronics recorder has been computed from the actual trace furnished by the vendor for D4E series recorders.

• • The PMS transmitters will be calibrated every six months.

l (2b) The parameters which describe the uncertainty in the transfer functions of the moduleo in PMS system, are listed in item (2a) above.

(2c) The parameters of item (2a) above, are combined to get overall l system uncertainty, using ROOT-SUM-SQUARES (RSS) method.

The overall system error for post accident condition is 12.69238% of the full scale display.

l NOTE: The overall system error analysis is performed using the 7 transmitter errors reported after irradiations to 2.2 X 10 rads TID and LOCA/HELB exposure to Temperature Pressure conditions shown in the Temperature Pressure Profile of Figure 1. However, the worst case post accident radiation andthegaximumtemperatureatthetransmitterlocationare 6.0 X 10 rads TID @ 10.0 rads /hr. and 223 F, respectively.

Therefore, the overall PMS error will be much less than the value given above.

The error analysis for the transmitter location accident conditions could not be performed because the transmitter error information for these conditions is not available.

The overall system error for mild environment condition is I 0.6291% of full scale display.

(2d) The time constants for both the modules are listed in item (2a) above.

The response time analysis is performed using the method outlined in Mr. Peter S. Kapo's memorandum to Mr. Walter R. Butler, Chief, Containment Systems Branch, DSI dated April 12, 1982.

A computer code is developed and used for the time constant analysis.

A listing of the computer code is included in Appendix A.

The response time analysis is performed assuming both the transmitter and the recorder to be first order systems.

The overall time constant of the PMS is 0.5861. A copy of the computer run is included in Appendix A-1.

(2e) CPUN has developed their own computer code and the results given in item (2d) above.

(3) II.F.1.5 - Water Level Monitoring Syste (WTM4)

(3a) The WIMS block diagram with important data is given below. The redundant loops are identieel, therefore, the following applies to both the leops.

Level Pressure / Level Transmitter Indicating Recorder Manf. Rosemount Manf. Tracor Westronics Model 1153DB5 Model: D4E-1-780-780-005-5-1-10-0

.=,

7 Location: Rx Bldg El (-) 19'6" Control Room Span Limits: 0-125/0-750 inches of H 2O N/A (Located in mild environ.) l Cal. Span: 12-204 inches of H 2O 12-204 inches of H 2O Post Accident Errors Radiation 2.2 X 10 Rads TID I 8.0% URL N/A (Located in mild environ.) t LOCA/HELB (4.5% URL + 3.5% span) N/A (Located in mild environ.)

Stability I 0.25% URL for 6 mos*** None l Accuracy Incl. LOCA/HELB 1 0.5%

• • • The WLMS transmitters will be calibrated every six months. l (3b) The parameters which describe the uncertainty in the transfer functions of the WLMS modules, are listed under item (3a) above.

(3c) The parameters of item (3a) above, are combined to get overall system l uncertainty, using ROOT-SUM-SQUARES (RSS) method.

The overall system error for post accident condition is I37.710124% of the full scale display.

NOTE: The overall system errer analysis is performed using the trans-mitter errors reported after irradiation to 2.2 X 107 rads TID and LOCA/HELB exposure to temperature pressure conditions shown in the Temperature Pressure Profile of Figure 1. However, the worstcasepostaccidentradiatiogandthemaximumtemperatureatthe transmitter location are 5.6 X 10 rads TID @ 10 rads /hr and 160 F, respectively. Therefore, the overall WLMS error will be much less than the value given above.

The error analysis for the transmitter location accident conditions could not be performed because the transmitter error information for these conditions is not available.

The overall system error for the mild environment condition is 1.1252% of full scale display.

(4) 11.F.1.6 - Hydrogen Moniter System (HMS)

(4a) The HMS block diagram is given below. The redundant loops are identical, therefore, the following applies to both the loops.

SAMPLE LOCAL H2 /02 REMOTE H 2 /02 POINT ANALYZER PANEL ANALYZER PANEL l

Location: Top of Dry- Rx Bldg El 75'-3" Control Room l Well Dome

r

~q

~

< s .-

(4b) The Hydrogen Monitoring System is procured as a packaged system and error information is furnished by the vendor for the entire system.

The system vendor is COMSIP, Inc.

(4c) The overall system error for a reading at the recorders is I 5.0%,

and that at the indicators is 6.0%.

(4d) There is one sample point for each of the HMS systems. Both the sample points are located on the top part of the drywell dome as indicated in Figure 2.

(4e) There are no obstructions which would prevent the Hydrogen escaping from the core from reaching the sample points quickly. Due to the fact that Hydrogen is a light gas, the possibility of it accumulating in the top part of the drywell dome is highest. However, the l drywell air recirculation fans will always keep the drywell air thoroughly mixed.

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pp3Y -11 1 UNITED STATES OF AMERICA s

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2 NUCLEAR REGULATORY COMMISSION

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3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARDLn,_'l 4

In the Matter of ARIZONA ) Docket Nos. STN 50-529 5 PUBLIC SERVICE COMPANY, et ) STN 50-530 al., )

6 )

(Palo Verde Nuclear Generating) 7 Station, Units 2 and 3) )

)

8 Joint Applicants hereby respond to West Valley 9

Agricultural Improvement Council's, Inc.'s Request for Produc-10 tion of Documents as follows:

11

1. The documents requested in Request No. 1, i.e.,

12 those identified by Joint Applicants in response to West 13 Valley's First and Second Set of Interrogatories, along with 14 thone documents identified in Supplemental Responses to such 15 Interrogatories, will be provided to West Valley on or before 16 July 15, 1983, except to the extent that the documents identi-17 fied include proprietary documents which were identified as 18 such in response to the Interrogatories. Joint Applicants object 19 to the production of those proprietary documents.

20

2. Joint Applicants object to Request No. 2 on the 21 grounds that any documents not identified in response to West 22 Valley's First and Second Set of Interrogatories, or in Supple-23 mental Responses thereto, were not identified because they 24 constitute attorney work product. As such, those documents are 25 26 8307060151 830701 PDR ADOCK 05000 l!

g D3

1 not subject to production. Joint Applicants identified all 2 documents, including proprietary ones, which are not attorneys' 3 work product.

4 DATED this day of July, 1983.

5 SNELL &

6 7 By //

Arenur wr cent 8 Warren . Platt Charle A. Bisch f 9 Vaughn A. Crawford 3100 Valley Center 10 Phoenix, Arizona 85073 Attorneys for APS 12 13 14 15 16 17 18 19 20 21 22 23 24 25 l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ a

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

)

ARIZONA PUBLIC SERVICE ) Docket Nos. STN 50-529 COMPANY, et al. ) STN 50-530

)

(Palo Verde Nuclear )

Generating Station, )

Units 2 and 3) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of " Joint Applicants '

Response to West Valley's Request for Production of Documents" have been served upon the following listed persons by deposit in the United States mail, properly addressed and with postage prepaid, this 1st day of July, 1983.

Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman, Maricopa County Board of Supervisors 111 South Thir6 Avenue Phoenix, AZ 85004 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert M. Lazo, Esq.

Chairman, Atomic Safety and Licensing Board o U.S. Nuclear Regulatory Commission Washington, D.C. 20555

l' Dr. Richard F. Cole Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Dixon Callihan Union Carbide Corporation P.O. Box Y Oak Ridge, TN 37830 Lee Scott Dewey, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Edwin J. Reis, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Lynne Bernabei, Esq.

Government Accountability Project Institute for Policy Studies 1901 Q Street, N.W.

Washington, D.C. 20009 Kenneth Berlin, Esq.

Suite 550 2550 M Street, N.W.

Washington, D.C. 20037 U