ML20105B952
| ML20105B952 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/30/1983 |
| From: | Read D CHAPEL HILL ANTI-NUCLEAR GROUP EFFORT |
| To: | CAROLINA POWER & LIGHT CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8307070076 | |
| Download: ML20105B952 (9) | |
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HELAh U C RRESPONDENC8 jg N-af SN Dockeed UNITED STATES OF AMERICA
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JUL 51963 > -l
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NUCLEAR REGULATORY COMMISSION cffice orthesse, v
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of
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Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al.
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50 401 OL (Shearon Harris Nuclear Power Plant,
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Units i ani 2)
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BEQUEST FOR PRODUCTION AND INTERROGATORIES TO APPLICANTS OF INTERVENOR CHANGE /ELP
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Intervenor CHANGE /ELP hereby requests that Applicants answer the following interrogatories in accordance with the appropriate schedules established by Part 10 of the Code of the Federal Regulations, by order of the Board in this proceed-ing, or as may subsequently be agreed. These interrogatories are continuing in nature and should be supplemented when answers change or when Applicants discover new information which would go to answering them. CHANGE /ELP requests that Applicants answer each interrogatory separately and fully and in writing, and under oath and affirmation, and produce and permit inspection ani copying of the original or best copy of all documents iden-tified in the responses to said interrogatories or otherwise requested herein.
i 8307070076 030630 PDR ADOCK 0500 G
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- o Page GENERAL INTERROGATORIES NUC Responses to these general interrogatories shall be given for each contention, along with the responses to each specific RE M interrogatory.
(1) State the name, present or last known address, and present or last known employer of each person known to Applicants to have first-hand knowledge on which the responses are based, for a h of the contentions which are the subject of this set of in-PO'G R r
terrogatories.
(2) Identify those facts concerning which each such person has first-hand knowledge.
(3) State the specific basis or facts which support each response.
To the extent that Applicants rely solely upon documents for their response ( s), please indicate the documents by their title, date, venor' follo author, and location. Please identify also relevant page citations.
- eschel (4) State the name, present or last known address, and present I
tl Red or last known employer of each person who provided information may :i upon which Applicants relied in answering each interrogatory luing i herein.
ange c (5) Identify all such information which was supplied by each such
- o anst person and the specific interrogatory response in which such
- h inte information is contained, oath E (6) State the name, address, title, employer, and educational and 1g of 1 professional qualifications of each person Applicants intend to the rc call as an expert witness or as a witness relating to any conten-herrir tion which is the subject of this set of interrogatories.
(7) Identify the contention (s) regarding which each person ident-ified in interrogatory (6) is expected to, testify, and the subject
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Page matter as to which each such witness is expected to testify.
(8) Identify all documents in Applicants' possession, custody or control, including all relevent page citations, pertaining to the subject matter of, and upon which the Applicants relied, in formulating responses to, each contention which is the subject of this set of interrogatories.
(9) State the specific response to each contention or interroga-tory which Applicants contend each document supports.
(10) Identify all documents in Applicants' possession, custody, or control, including all relevant page citations, upon which Applicants relied in answering each interrogatory herein.
(11) Identify all other sources of information, not identified 4
in responses to General Interrogatories 5, 8, and 11 herein, which were used in answering each interrogatory herein.
(12) Identify all documents which Applicants intend to offer as exhibits during this proceeding to refute contentions which l
are the subject of this set of interrogatories.
DEFINITION As used herein, the word " study" or " studies" shall not mean only documents titled as such, but it means such documents j
and other documents or activities involving critical examination l
and investigation of a subject, see New World Dictionarv of the 1
American Lantuage, 2d College Edition, 1974.
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SPECIFIC INTERROGATORIES CHANGE contention 9 ( transportation of suent fuel to SENPP)
CHAUGE contention 9 was accepted by the Board's order of 1
September 22, 1982, at 23. Please answer the following inter-rogatories with respect to this contention, in accordance with i
the conditions heretofore set forth.
9-1. Do Applicants contest that CHANGE contention 9 is a prop-erly accepted contention?
9 2. If the answer to 9-1 above is "Yes," please indicate Appl-icants' reason for such answer.
9-3.(a). In their " Answers to Conservation Council's Interroga-tories to Applicants (First, Set)," April 20, 1983, in response to Interrogatory No. 4-7(a)
Applicants indicated that " shipment of spent fuel from CP&L's Robinson and/or Brunswick Plant to the SBNPP site in the future is a possibility," Id. at 7. Do the Applicants have any definite plans to make such shipments?
(b). Have'the Applicants prepared any contingency olans for making such shipments (by " contingency plan" a fairly complete plan requiring only minor adjustments and scheduling and NRC approval is meant)?
(c). If the answer to either 9-3(a) or 9-3(b) is "yes",
please describe the routes and means of transportation selected.
(d). If the answer to either 9-3(a) or 9-3(b) is "yes",
please produce such plans for inspection and/or copying.
(e). Have Applicants designated any of their employees, entered into contracts, or otherwise arranged for the prepara-l tion of such plans for the shipment of spent fuel from other nuclear plants to SHNPP?
(f). If the answer to 9-3(e) is "yes", please indicate the names of such persons or firms and produce any letters or con-firmatory memoranda of such designation, contract, or arrange-
= ment.
9 4(a). Have. Applicants conducted studies of spent fuel pool storage capacity at Brunswick and/or Robinson and the need for shipment of spent fuel from those plants offsite?
(b). If the answer to 9 4(a) is "yes", please produce such studies'for inspection and/or copying.
- " INTERROGATORY NO. 4-7(a). Do the Applicants plan on trans-porting radioactive waste or spent fuel from other reactors to the SHNPP site?"
Pagn 5 (c) Please indicate projected dates developed in such stud-les when it would be reasonably likely that Applicants would need to ship such fuel offsite.
(d). Have Applicants conducted any studies, or contracted or otherwise arranged for such studies to be done, concerning the feasibility of constructing Independent Spent Fuel Storage Installations (ISFSI) at Brunswick and/or Robinson?
(e). If the answer to 9 4(e) is "yes", please indicate the results of such studies and produce them for inspection and copying.
(f) Have Applicants conducted any studies, or contracted or otherwise arranged for such studies to be done, concerning the feasibility of of rerackin measures at the Erunswick and/g, fuel pool expansion, or other or Robinson plants which would reduce or obviate the need to transport spent fuel to Shearon Harris?
(g) If the answer to 9 4(f) is "yes" please indicate the results of such studies and produce the studies for inspection and copying.
(h) Have third parties, such ah the Electric Power Research Institute, the Nuclear Regulatory Commission, the United States Department of Transportation, or other organizations or individ-uals independent of Applicants, to Applicants' knowledge pre-pared any studies such as those desc ibed in 9 4(a), 9 4(d),
or 9 4(f) above?
(i) If the answer to 9 4(h) is "yes" please indicate to the best of your knowledge document titles, accession numbers, authors and other pertinent information. To the extent that such documents are in Applicants' possession custody or cont-rol, please produce them for inspection and/o,r copying.
(j) Do Applicants plan to constuct ISFSI, rerack, expand fuel pools, or otherwise undertake measures at Robinson and/or Brunswick to obviate or reduce the need to ship spent fuel to SHNPP?
(k) If the answer to 9 4(j) is "yes," please describe such plans with particularity and produce them for inspection and/0r copying.
9-5(a). Do Applicants contest the assertion that rail shipments of spent fuel.from Brunswick to SHNPP will go through either Fayetteville or Raleigh?
(b). If the answer to 9-5(a) is "yes" please provide basis for your position.
(c). If the answer to 9-5(a) is ano" please provide details
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of any communications between Applicants and responsible emer-gency personnel in Fayetteville and Raleigh regarding emergency training, response plans, and other matters, including names
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Page 6 of local emergency personnel, employees of Applicant, dates of memoranda and/or letters, etc.
9-6(a). Please describe Applicants' " response teams," see
" Answers to Conservation Council," suora at 10 (answer to interrogatory 4-10(b)), for transportation accidents.
(b). Please indicate training, equipment, staffing levels, notification procedures, additional duties, times of availabil-ity, proficiency testing procedures, state and federal qualifi-l cation requirements ani success at meeting such requirements, age, sex, physical parameters (hei ht, weight), success in 6
physical fitness examinations, geographic location (work and home) and other pertinent information for each such response team and for each member of such response team.
(c). Please describe communications links between such response teams and spent fuel carriers and between such response teams and appropriate state authorities and between such response j
teams and appropriate local authorities.
(d). Please indicate Applicants' best estimate of project-ed response time for an appropriate response team to be on site and fully equipped at an accident site along rail routes be-tween the Erunswick plant and SENPP.
(e), Please indicate how such estimate was arrived at.
(f). Please indicate the conditions under which Applicants would " deem it necessary and appropriate" (" Answers to Conserv-ation Coincil," suura, answer to Interrogatory 4-10(b)) to dispatch such response teams.
9-7(a). Have Applicants, their contractors, or other persons 2
known to Applicants prepared studies of the best route and/or transportation mode for shipment of spent fuel from Brusnwick and/or Robinson to SHUPP7 (b) If the answer to 9-7(a) is "yes", please identify who prepared such studies, the result of such studies, and produce such studies for inspection and/or copying.
CHANGE contention 44 (water level indicator)
CHANGE contention 44 was accepted by the Boards order of f
September 22, 1982, at 26. Please answer the following inter-rogatories with respect to this contention, in accordance with j
9 the conditions heretofore set forth.
44-1(a). At page 115 of.NUREG-CR-2628, " Inadequate Core Cooling Measurement Using Differential Pressure for Reactor Vessel level Measurement," it is stated that "There is an uncertainty in the measured level associated with the narrow range differential g
y pressure measurement (the most sensitive) of about 6% or + 2 5 2
ft." Do-Applicants agree that this uncertainty applies to SHNPP?
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Pags 7 44-1(b). If the asnwer to 44-1(a) is "no",
please state the basis for your position.
(b)(1). Does your answer "no" indicate simply that the margin of uncertainty will be different at SHNPP? If so, what do Applicants believe the margin of uncertainty will Be? What is the basis for this belief?
(b)(2). Is the basis of your answer "no" the result of modifications or alterations to the system described in NUREG/
CH 2628? If so, please describe all such modifications and/or alterations (diagrams would be helpful).
(b)(3). Is your answer "no" hased on a disggreement with the conclusion quoted from NUREG/CR 26287 If so, please specify the basis for your disagreement.
(c) If the answer to 44-1(a) is "yes", please indicate to what range the potential uncertainty will apply. In describ-ing such range, please indicate with particularity:
(1) The range of uncertainty for SHNPP, measured both in feet (to the nearest tenth of a foot) and in percent.
(2) For the figure in percent, indicate precisely over what range the percentage applies: for example, from the top of the reactor vessel to the bottom, hot leg centerline to bottom of vessel, etc. For distances measured from the top or bottom of the reactor vessel, please indicate whether this is measured from the inside or the outside of the vessel. Please state your measurement in feet (to the nearest tenth of a foot).
(3) Please indicate the height of the reactor vessel, from the lowest point on the inside to the highest point on the inside, in feet ( to the nearest tenth of a foot).
(4) Please indicate the height of the core, in feet (to the nearest tenth of a foot).
(5) Please indicate the distance between the bottom of the core and the bottom of the inside of the ractor vessel, in feet ( to the nearest tenth of a foot).
(6) Please indicate Applicants' best estimate as to the average likely error (in feet, rounded to the nearest tenth of a foot) this uncertainty is likely to cause in water level readings during normal operation of SHNPP.
(7) Please indicate the basis for such estimate.
44-2. Assume a small-break LOCA in which the top of the core is within the range of uncertainty indicated above. Please answer the following questions:
(a) What other systems are available to provide operators with additional indication of the level of water inside the reactor vessel?
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Pags 8 (b) What are the uncertainties associated with each of these other systems?
(c) To what extent do other systems rely exclusively on the RVLIS system during such accidents?
44-3(a). NUREG/CR-2628 at p. 18 describes generally the set up of the RVLIS system. Please provide more specific details, par-ticularly diameter, composition, installation and finished interior appearance data for the capillary tubing. Describe how the capillary tubing will be attached to the reactor vessel, hot legs, etc. Describe the appearance of the capillary tube entrance as it would appear from the inside plane of the reactor vessel, hot leg, etc. Diagrams would be helpful.
(b). Have Applicants conducted, or has Westinghouse or its contractor (s) conducted, any studies concerning the effect of corrosion on the capillary tubing?
(c) Have Applicants or Westinghouse or their contractol(s) conducted any studies or analysis of the effects of corros&on on joints between the vessel, hot legs, etc. and the capillary tubing?
(d). Have Applicants, Westinghouse or their contractor (s) conducted any studies or analysis on blockage scenarios and the potential effect of blockage on the RVLIS system?
(e) If the answer to any of the preceding three questions (44-3(b)-(d)) is "yes," please indicate the results of such studies or analysis, the person (s) or organization (s) by whom they were performed, and produce doucmentary results for inspect-ion or copying to the extent that such documents are in Appli-cants possession, custody, or control. To the extent that such documents are not in Applicants' possession custody or control please indicate title, accession number (s), author, and other information necessary to locate same.
CONCLUSION Intervenor requests that Applicants respond in writing and under oath to these interrogatories and produce such documents as are requested herein at a place and time mutually convenient to both parties.
Daniel F. Read CHAliG June 30, 1983
, Box 524 Chapel Hill, NC 27514
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-2 UNITED STATES OF AMERICA gl 61983 :>
NUCLEAR ' REGULATORY COMMISSION E
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In the Matter of CAROLINA POWER & LIGHT CO.
o et al., Shearon Harris Nuclear Plant, Units 1 & 2 )) 50' g
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wy CERTIFICATE OF SERVICE I hereby certify that copies of keQCSU for hMudfNo O inffo[6 8 Aeohld nU were served this 3O M day of M Nd
, 198S, by deposit in the U.S. Mail, first-class postage prepaid, upon all parties whose names appear below, except those whose names are marked with an asterisk, for whom service was accomplished by hMd c(El f vfR4 Munide UWC' G,r.,per.n o1 (Lot'chon I James L. Kelley, Licensing BoardEsq./Mr. Glenn O. Bright /Dr. James Carpenter Atomic Safety &
(one each)
U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the Executive legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 gg gg g, Docketing and Service Section 3
7 Office of the Secretary U.S. Nuclear Regulatory Commission iDOMM MW Washington, DC 20555 wxhajtoo, pc '20036
'V^ Mr. John D. RunkleConservation Council of North Carolina $.Dr. Phyllis Lotchin 108 Bridle Run 307 Granville Road Chapel Hill, NC 27514 Chapel Hill, NC 27514 M. Travis Payne, Esq.
Mr. Wells Eddleman Edelstein and Payne 718-A Iredell Street P.O. Box 12463 Durham, NC 27705 Raleigh, NC 27605 Dr. Richard D. Wilson
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729 Hunter Street Apex, NC 27502 l
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1 Daniel F. Read President Chapel Hill Anti-Nuclear Group Effort P.O. Box 524 Chapel Hill, NC 27514
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