Affidavit of Lh Martin Supporting Util Summary Disposition Motion Re Eddleman Contention 64(f) on Spent Fuel Shipping Cask Pressure Relief Valve.Target Rock 73-J Valve Will Be Replaced W/Rupture Disk Prior to Spent Fuel ShipmentML20024E906 |
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Harris |
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Issue date: |
08/31/1983 |
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From: |
Martin L CAROLINA POWER & LIGHT CO. |
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ML20024E900 |
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ISSUANCES-OL, NUDOCS 8309070192 |
Download: ML20024E906 (13) |
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Category:AFFIDAVITS
MONTHYEARML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc ML18016A8191999-02-12012 February 1999 Affidavit of G Thompson Re Application by CP&L for Amend to FOL NPF-63 & NRC Review of Application & Proposes to Determine That Amend Request Involves No Significant Hazards Consideration ML20209A9071987-01-28028 January 1987 Affidavit of JW Mckay.* Provides Minor Corrections to 861017 Affidavit.Corrections Should Be Made to Allegation on Undercut Tolerances for Holes Drilled to Receive maxi-bolt Anchors.Certificate of Svc Encl ML20214S1271986-09-25025 September 1986 Affidavit of Tw Brombach Re Allegations Raised in Ps Miriello 860728 Affidavit Concerning QA Filed in Support of 860915 Motion to Reopen Record.Allegations W/O Factual Basis.Util s to Jn Grace Re Insp Encl ML20214S1051986-09-25025 September 1986 Affidavit of SA Brown Re 860728 Affidavit of Ps Miriello Concerning Radiation Exposure,Filed in Support of Motion to Reopen Record.Allegations Re Exposure to High Levels of Radiation Unsupported ML20210B6471986-09-13013 September 1986 Affidavit of Ps Miriello Re safety-related Welds That Never Received Preservice Insp ML20205F3771986-08-0606 August 1986 Affidavit of Tw Brombach Re Issues Raised in 860702 Request for Institution of Proceeding Per 10CFR2.206,specifically Allegations on Inservice Insp of Piping Welds.Insp Rept 50-400/85-48 Encl ML20210E0171986-07-28028 July 1986 Affidavit of Ps Miriello Re False Dose & Const Records Constituting Threat to Public Health & Safety ML20210B6961986-07-28028 July 1986 Affidavit of Ps Miriello Stating That QA Quality Check Program Not Used as Intended at Facility ML20210U7691986-05-16016 May 1986 Affidavit of Ps Miriello Re Failure to Act on Issues of False Dose Records,Intimidation & Unsafe Radiation Practices Until After Contention W-4 Produced ML20210U7751986-05-15015 May 1986 Affidavit of Ps Miriello Re Health Physics Supervisors Ordering Author to Agree W/False Radiation Rept & to File NRC Form 4 in Agreement W/False Radiation Rept ML20204A4921986-05-0606 May 1986 Affidavit of SA Browne Re Results of Review of Ps Miriello 860403 Affidavit in Support of Conservation Council of North Carolina & W Eddleman Request for Admission of New Contention WB-4 ML20210K7041986-04-0303 April 1986 Affidavit of Ps Miriello Re Falsification of Exposure Records.Related Info Encl.W/Certificate of Svc ML20154N2091986-03-10010 March 1986 Suppl to HR Goodwin Affidavit on Timing of Weather Alerts, Per ASLB Request.Info on Precise Times That Weather Alerts Transmitted Unavailable.Certificate of Svc Encl ML20205K6031986-02-24024 February 1986 Affidavit of RW Fell,Supporting NRC Response to Aslab Question Re Conservation Council of North Carolina Contentions 16,17 & 18.Certificate of Svc Encl ML20137P5991986-01-30030 January 1986 Affidavit of Ti Hawkins,Supporting Nrc/Fema Response to Applicant Motions for Disposition of Eddleman Contentions EPX-2 & EPX-8.Certificate of Svc Encl ML20137F4171986-01-13013 January 1986 Affidavit of W Ethridge Re Contention EPX-2.Minor Highway Patrol Radio & Telephone Communications Delays During 850517-18 Exercise Were Due to Priority Assigned to Messages & Emergency Operations Ctr.Difficulties Being Resolved ML20137J0731986-01-13013 January 1986 Affidavit of Ah Joyner in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys.Certificate of Svc Encl ML20137F4101986-01-13013 January 1986 Affidavit of Dh Brown Re Contention EPX-2.Relay Procedure Is Normal Operating Procedure for Radiation Protection Section Communications & Causes No Significant Delays or Addl Inaccuracies ML20137F6491986-01-13013 January 1986 Affidavit of M Scott Re Contention EPX-2.Chatham County Responded Appropriately & Effectively to Experience Gained During 850517-18 Exercise.Addl Dispatchers Will Assure Response to Radio Traffic Levels.W/Certificate of Svc ML20137F6161986-01-13013 January 1986 Affidavit of Ah Joyner Re Contention EPX-2.Corrective Actions Being Taken to Resolve Communications Problems Experienced During 850517-18 Exercise.Resolutions Expected Prior to Full Power Licensing of Plant ML20137J0591986-01-10010 January 1986 Affidavit of R Capps in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys ML20136F6401985-12-31031 December 1985 Affidavit of Dn Keast Re Correction to 851104 & 05 Oral Testimony on Eddleman Contention 57-C-3.Certification of Svc & Notice of Withdrawal Encl ML20137L7951985-11-26026 November 1985 Affidavit of Wj Hindman Re Info on Age Distribution & Gender of Daniel Intl Corp Employees & First Line QA Inspectors at Facility.Certificate of Svc Encl ML20135H8321985-09-23023 September 1985 Affidavit of SL Burch Re Undercover Drug Operation at Facility.Related Correspondence ML20135H8371985-09-19019 September 1985 Second Affidavit of SL Burch Re Drug Investigation at Facility.Related Correspondence ML20137L6741985-09-0606 September 1985 Affidavit of P Miriello Re Drug Abuse Observed at Facility Const Site.Certificate of Svc Encl ML20134H4261985-08-23023 August 1985 Affidavit of Wp Haass Re ASLB Questions Concerning Whether Public Disclosure of Info Voluntarily Submitted to NRC Would Impair NRC Future Ability to Obtain Similar Info.Notice of Appearance of Ga Berry & Certificate of Svc Encl ML20135C0421985-08-23023 August 1985 Affidavit of Wp Haass Addressing Series of Questions Propounded by ASLB Re Whether Public Disclosure of Info Contained in Certain Applicant Documents in ASLB Possession Would Impair Staff Ability to Obtain Info ML20134E7891985-08-14014 August 1985 Affidavit of Wj Hindman Responding to SL Burch 850731 Affidavit Re Undercover Drug Investigation During Fall 1984 ML20134E7761985-08-14014 August 1985 Affidavit of MW King Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7661985-08-14014 August 1985 Affidavit of DG Joyner Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7831985-08-0909 August 1985 Affidavit of ML Plueddemann Re Fall 1984 Undercover Drug Investigation at Site ML20133A1111985-07-31031 July 1985 Affidavit of SL Burch Re Assertions in King Affidavit & Undercover Operation of Facility Concerning Drug Abuse. Intelligence Indicated Drug Dealings & Abuse Widespread. Certificate of Svc Encl ML20129H1061985-07-11011 July 1985 Affidavit of Nj Chiangi Re Allegation in Conservation Council of North Carolina Contention WB-3.QA Program Provides Necessary Steps to Ensure Safe & Reliable Power Plant.Certificate of Svc Encl ML20129H0941985-07-10010 July 1985 Affidavit of Wj Hindman Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const ML20129H0821985-07-10010 July 1985 Affidavit of Pb Bensinger Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const.Biography Encl ML20129H0911985-07-0909 July 1985 Affidavit of Jd Ferguson Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Cp&L Adopted Drug & Alcohol Interdepartmental Procedure.Resume & Procedure Encl ML20129H0991985-07-0909 July 1985 Affidavit of AR Pannill & Gw Flowers Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Employees Subjected to Preemployment Background Verification ML20129H0871985-07-0909 July 1985 Affidavit of MW King Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Use Widespread & That Mgt Failed to Control Drug Use During Const.Resume Encl ML20128M0401985-07-0808 July 1985 Affidavit of TS Elleman Supporting Util 850709 Application for Withholding Final Rept Shnp QA/QC-Const Inspector Review Panel, Per 10CFR2.790.Certificate of Svc Encl. Related Correspondence ML20128M0331985-07-0808 July 1985 Affidavit of HR Banks Supporting Util 850709 Application for Withholding Documents,Including Quality Check Rept,Concern/ Allegation Followup & Quality Check Procedure Investigation Rept,Per 10CFR2.790.Related Correspondence ML20116N7771985-05-0202 May 1985 Affidavit of Ti Hawkins in Support of Applicant Suppl to Motion for Summary Disposition of Eddleman Contention 213 Re Emergency Planning.Certificate of Svc Encl ML20116D0091985-04-25025 April 1985 Affidavit of Jf Myers Describing Recent Change to Provisions for Official Transportation Assistance for Persons in Emergency Planning Zone Needing Assistance in Event of Plant Emergency.Related Correspondence ML20112K0061985-04-0505 April 1985 Supplemental Affidavit of RG Black on Eddleman Contention 213.Provisions for Alert & Notification of Persons on Harris Lake Obviate Measures Suggested by Contention ML20112K0131985-04-0505 April 1985 Supplemental Affidavit of MR Bassiouni on Eddleman Contention 213.Rept of Proposed Siren Configuration & One Oversize Map Encl.Aperture Card Available in PDR ML20100B1011985-03-22022 March 1985 Supplemental Affidavit of Eh Harris Re Rev of School Evaluation Procedure Which Would Reduce Number of Students Riding Buses & Use of Buses Kept on Property During School Hours.Certificate of Svc Encl.Related Correspondence ML20107M5111985-02-27027 February 1985 Affidavit of Ti Hawkins in Support of Motion for Summary Disposition of Eddleman Contention 30.Emergency Response Plan Provisions Fully Comply w/NUREG-0654 ML20107K0411985-02-26026 February 1985 Affidavit of Ti Hawkins in Support of Applicant Motion for Summary Disposition of Contention EPJ-4(c).Prof Qualifications Encl.Certificate of Svc Encl 1999-04-05
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] |
Text
P-r e .
September 1, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
AFFIDAVIT OF LOUIS H. MARTIN
-IN SUPPORT OF
SUMMARY
DISPOSITION OF INTERVENOR WELLS EDDLEMAN CONTENTION 64(f)
STATE OF NORTH CAROLINA )
) SS:
COUNTY OF WAKE )
LOUIS H. MARTIN, being duly sworn according to law, deposes and says as follows:
- 1. I am the Manager - Nuclear Fuel Section of Carolina Power & Light Company. My business address is 411 Fayetteville Street, Raleigh, North Carolina 27602. A summary of my professional qualifications and experience is attached hereto as Exhibit A. I have personal knowledge of the matters stated herein and believe them to be true and correct. I make this affidavit in support of " Applicants' Motion for Summary Disposition of Intervenor Wells Eddleman's Contention No. 64(f)" in this proceeding.
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i 8309070192 830901 PDR ADOCK 05000400 0 PDR
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. 2. Carolina Power'& Light-Company ("CP&L") owns.a model IF-300 stainless steel encased, depleted uranium shielded rail shipping cask ("IF-300 Cask")
manufactured by the General Electric Company. The IF-300 cask is licensed by the Nuclear Rigulatory Commission for the shipment of spent nuclear fuel by Certificate of Compliance No. 9001 attached hereto-as Exhibit B.
- 3. CP&L has safely transported 304 PWR assemblies in 44 shipments from the H.B. Robinson Plant near Hartsville, South Carolina, to the Brunswick Plant near Southport, North Carolina, using the IF-300 cask. These shipments were all made without incident or radioactive release in excess of Federal regulations or the cask license.
- 4. In the event that Applicants are authorized to store spent fuel from CP&L's Robinson and Brunswick Plants at the Harris Plant, such shipments of spent fuel from CP&L's Robinson and/or Brunswick Plants to the Harris Plant in the forseeable future are likely to be made utilizing CP&L's IF-300 rail cask.
- 5. The IF-300 cask is equipped with one pressure relief valve connected to the cask cavity. The pressure relief valve presently installed on the IF-300 cask was manufactured by the Target Rock Corporation (" Target Rock 73-J pressure relief valve") . The purpose of the pressure relief valve is to provide controlled venting under design basis accident conditions for wet shipments and to be leak tight at all other times.
- 6. In 1981, General Electric Company was notified by the Target Rock Corporation that a spare 73-J pressure relief valve being fabricated for use on an IF-300 cask had failed to meet all of the specified leakage requirements following an operational test performed at the Target Rock Corporation.
General Electric Company notified CP&L of the failure of the Target Rock 73-J
F' pressure relief valve to meet certain test specifications, and on June 24, 1981, CP&L informed the NRC and withdrew its IF-300 cask from wet shipment service.
- 7. Certificate of Compliance No. 9001 was amended on 4/6/82, to permit only dry shipments with the IF-300 casks.
- 8. CP&L intends to remove the Target Rock 73-J pressure relief valve and replace it with a " rupture disk" prior to any future spent fuel shipment. CP&L does not intend to use the Target Rock 73-J pressure relief valve or another
-valve of that particular design on its IF-300 cask in the future.
- 9. The rupture disk is made of nickel material and marked per ASME code i
Section VIII, Division I requirements. The stamped bursting pressure of each rupture disk is between.350 and 400 psig consistent with the requirements of Certificate of Compliance 9001. For dry shipments of spent fuel the maximum allowable heat load is 40,000 btu / hour. As conservatively calculated in Section 6.3.20.4 of the Cask Safety Analysis Report, the maximum cavity
~
pressure generated under accident conditions for dry shipments is 248 psig.
The design pressure of the IF-300 cask itself is 400 psig. Since the maximum cavity pressure generated under accident conditions is well below the cask's design pressure, the cask will not vent and, therefore, a cavity pressure relief valve is not needed for over-pressure protection for dry shipments.
- 10. Neither the rupture disk nor any other component on the IF-300 cask, which is used as an integral barrier to the cask cavity, utilizes any " plastic component."
- 11. In the event CP&L elects to ship spent fuel from its Robinson and/or Brunswick Plants to the Harris Plant, any such shipments in the foreseeable future would be dry. CP&L is presently not authorized to use the IF-300 cask
I-9 for other than dry shipments, pursuant to Certificate of Compliance 9001. An alternative pressure relief system must be developed and approved by the NRC-before the Certificate of Compliance could be amended to permit wet shipments.
Because CP&L has a significant inventory of spent fuel which has been discharged from a reactor for three years or more, dry shipments of spent fuel are adequate to meet CP&L's requirements for the near term. CP&L is not, at the present time, pursuing an amendment to Certificate of Compliance 9001 to permit wet shipments.
- 12. Pursuant to the Nuclear Waste Policy Act, and 10CFR Part 961 48. Fed.
R m 16, 590 g seq (April 18, 1983), Carolina Power & Light Company, on behalf of Applicants, entered into an agreement with the U. S. Department of Energy (DOE) on June 3, 1983. DOE is responsible for shipments of spent fuel from the Harris Plant to a nuclear waste repository, in accordance with the terms and conditions of that contract which are substantially identical to the standard contract found at 10CFR Part 961.
LOUIS H. MARTIN Sworn to and Subscribed before me, this the 3 } " day of Ou.cu d , 1983 5A ~
Notary Public My Commission Expires:
/
M8 D 108
i
' ' EXHIBIT.A Louis H. Martin Manager - Nuclear Fuel October 31, 1942 Education and Training A. BS Degree in Nuclear Engineering - North Carolina State University -
1965 B .' MBA Degree in Business Administration - University of South Carolina -
1971 Prof essional Societies A. Member of American Nuclear Society B. Registered Professional Engineer - Nort h Carolina - 1975 Experience A. Savannah River Plant - Savannah, Georgia e
- 1. 1965 to 1970
- 2. Various nuclear engineering and reactor operating positions B. Carolina Power & Light Company ,
- 1. April 1972 - Employed an a Senior Engineer in the Fuel Section of the Bulk Power Supply Department. Located in the General Office.
- 2. July 1973 to January 1977 - Principal Engineer in the Fuel Section of the Bulk Power Supply Department. Located in the General Of fice.
l l
- 3. January 1977 to May 1977 - Principal Fuel Analyst in the Fuel Analysis l Unit of the Fuel Department. Located in the Cencral Office.
l i 4. May 1977 to Present - Manager of the Nucicar Fuel Section in the Fuel
! Department. Located in the General Office, i
{
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! - - - - - - , - . . . . ~ . . _ , , . . . . . - _ - _ , , _ _ _ _ , _ _ _ _ _ _ . ___ _ _ _ _ _, _ _ _ _ _ _ .
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a
3 UNITE] STATES a . /j ocq%, NUCLEAR REGULATORY COMMisslON EXHIBIT B
[Y ,. , [" k WASHINGTON, D. C. 20555
- 3. s ,38,/ }
s o.m , ~~
MAR 2 21983 1 FCTC: RHO k b b b f Y [is 71-9001 W 28 1983
' General Electric Company RA0l0 LOGICAL & CHEMICA ATTH: fir. D. M. Dawson, MC-861 SUPPORT SECTION 175 Curtner Avenue San Jose, CA 95125 Gentlemen:
As requested by your application dated October 21, 1982, as amended, enclosed is Certificate of Compliance No. 9001, Revision No.15, for the Ebdel No. IF-300 shipping container. This certificate supersedes, in its entirety, Certificate of Compliance No. 9001, Revision No.14, dated
. September 30', 1982.
Changes' made to the enclosed certificate are indicated by vertical lines in the margin.
Those on the attached list have been registered as users of this package under the general license provisions of 10 CFR 571.12(b) or 49 CFR 5173.393a.
This approval constitutes authority to use the package for shipment of radioactive material and for the package to be shipped in accordance with the provisions of 49 CFR 5173.393a.
Sincerely, Charles E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle ahd Material Safety
Enclosures:
- 1. Certificate of Compliance No. 9001, Rev. 15
- 2. Approval Record cc: w/encls Mr. Richard R. Rawl Departmen* of Transportation
r _-.
e
' - Model No. IF-300 Packaoino USA /9001/B( )F g
J
..iAR 2 21903 Addressees: w/encls Ltr. d td :
Commonwealth Edison Company ATTN:
- Director of Nuclear Licensing P. O. Box 767 Chicago, IL 60690 Carolina Power & Light Company ATTN: Mr. B. H. Webster Route 1, Box 327 New Hill, NC 27562 General Electric Company ATTH: . Mr. D. M. Dawson, MC-861 175 Curtner Avenue San Jose, CA 95125 Nebraska Public Power District ATTU: Mr. Jerry V. Sayer P.O. Box 98 .
Brownville, NE 68321 G
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ISirm NRC418 U.S. NUCLEAR REGULAT6RY COf.tMlWIM S
- CERTIFICATE OF COMPLIANCE cR 1 -
For Radioactive M:terids Packages
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Certi8icate %moer 1.(b) Revision No. 1.tc) Pacmace luentification No. 1.(d) Pages No. 1.(el Total No. Pages 15 USA /9001/S( )F 1 6 c001
- 3. FnEAMBLE 2.f al This certificate is issued to satisfy Sections 173.393a 173.394,173.395. and 173.396 of the Cepartment of Transportation Hazardous Materials Regulations (49 CFR 170189 gno 14 CFR 103) and Sect 4cns 146-19-10s and 146-19-100 of the Ceoartment of Transportation Dangerous Cargoes Regulations (46 CFR 146-149), as amendea.
2.lb) The packaging and contents described in itera 5 below, meets the safety standaros set forth in Subpart C of Title 10, Code of Federal Regulations, Part 71. ** Packaging of Radioactive Materials for Transport and Transportation of Radioactive Material Urider Certain Conditions."
2.(c) This certifieste does not relieve the consignor from compliance with any requirement of the regulations of the U.S. Geoartment of Transportation or other applicable regulatory agencies, including the government of any country through or into which the package will be transported.
- 3. This cartificate is issued on the basis of a safety analysis report of the package design or application-3.fa) Propered by (Name and address): 3.tbl Title and identification of report or application:
General Electric Company General Electric Company application dated 175 Curtner Avenue October 8, 1979, as supplemented.
San Jose,,CA 95125 3.(c) Docket No. 71-9001 4 CONDITIONS This certificate is conditional upon the fulfilling of the reouirements of Suboart O of 10 CFR 71, as applicable. and the conditions specified in item 5 below.
- 5. Description of Packaging arid Authorised Contents. Model Number, Fissile Class, other Conditions. .rt*
References:
(a) Packaging ,
(1) Model No.: IF-300 (2) Description A stainless steel encased, depleted uranium shielded cask. The cask is cylindrical in shape, 64 inches in diameter and a maximum of 210 inches long with maximum cavity dimensions of 37-1/2 inches in diameter by 180-1/4 inches long. Shielding is provided by 4 inches of depleted uranium, 2-1/8 inches of stainless steel and a mininun of 4-1/2 inches of water.
Two closure heads are provided for the shipment of BUR and PWR fuel assemblies. The heads are 304 stainless steel forgings and end plates which encase the 3-inch thick depleted uranium shielding.
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The closure heads are secured to the cask body by means of 32,1-3/4 inch studs and nuts. The cask is sealed with a netallic ring gasket.
The cavity is penetrated by a vent line at the top and a drain line at the bottom. These lines are sealed by bellows seal stainless steel globe valves and valved quick-disconnect couplings. The vent line is also equipped with a 375 psig relief valve or a 350-400 psig rated rupture disk. All valves are housed in protected boxes on the cask exterior.
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? age 2 - Certificate No. 9001 - Revision No.15 - Cocket No. 71-gC01
- 5. (a) Packaging (continued)
(2) Description (continued)
Neutron shielding is provided by a liquid-filled, thin-walled, ccrrugated containment on the cask exterior. This cylindrical structure is separated into two longitudinal compartments, each equipped with two expansion tanks, fill and relief valves. The fill line from each compartment is terminated by a stainless steel globe valve in a protected box (separate .from cavity boxes) on the cask exterior. The vent line from each compartment goes to an expansion tank which is provided with a pressure relief valve set at 200 psig.
The cask has two types of fuel baskets which can be interchanged to accommodate various fuels. The PWR basket holds 7 assemblies, the BWR basket hold 18 assemblies. The BWR fuel basket may be provided with supplementary shielding (depleted uranium) near the cask closure.
The cask is shipped horizontally with the bottom supported in a tipping cradle between two pedestals and the upper end resting in a semi-circular saddle; the upper end is pinned to the saddle. The cask supports are welded to the framing of a 37-l/2-foot long by 8-foot wide structural steel skid. The skid also holds the cask cooling system which consists of two diesel engines driving two blowers which discharge into common ducting. Four ducts run the length of the cask and direct cooling air to the corrugated surface. Operation of the auxiliary cooling system is not a requirement of this package approval.
The entire cask and cooling system is covered by a retractable aluminum enclosure. Access to the enclosure is via locked panels in the side and a locked door in one end. Although the tiodel No. IF-300 cask can be transported for short distances on the highway, its principal mode of transportation is by railroad.
The gross weight of the cask is approximately 140,000 pounds. The skid and other external components weigh approximately 35,000 pounds.
l (3) Drawing The Model No. IF-300 shipping cask is described by the following General Electric Company Drawing No.: 159C5238 - Sheets 1 thru 2, Rev. 3; Sheet 3, Rev. 5; Sheet 4, Rev. 6; Sheet 5, Rev. 5; Sheet 6, Rev. 5; Sheet 7, Rev. 4; Sheet 8, Rev. 5; Sheet 9, Rev. 4; Sheet 10, Rev. 5; and Sheet 11, Rev. 2.
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' Fage 3 - Certificate E. 9001. - Revision flo.15 -- Occket tio. 71-9001 s '(ai '(4) Basic Ccmponents The Basic Components of the Podel tio. IF-300 shipping cask that are important to nuclear safety are listed. in Subsection 10.5.
(b) Contents - air as primary coolant (1) Type and form of material Irradiated PWR and BWR uranium oxide fuel assemblies. PWR assemblies may be shipped with or without control rods. Partial . fuel assembiies c that is, assemblies from which fuel pins are missing, must not be shipped unless dummy fuel pins are used to displace an amount of watcG equal to that displaced by the original pins. The specific power of each fuel assembly must not exceed 40 Kw/KgU and the burnup' of each fuel assembly must not exceed 35,000 MWD /f1TU. The mininum cooling time of each assembly mur,t be no less than '120 days. Prior to irradia the BWR and PWR fuel assemblies must have the following dimensions and specifications:
( i). Group I fuel assemblies PUR BWR Fuel form
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Clad U02 pellets Clad U02 pellets Cladding material Zr or SS Zr or.55 Maximum initial U content / assembly, kg 465 198 Maximum initial U-235 enrichment, w/o 4.0 4.0 Maximum bundle cross section, inches 8.75 5.75 Fuel pin array 14x14/15x15 7x 7 Fuel diameter, inch -
0.380-0.460 0.500-0.600 Fuel pin pitch range, inch 0.502-0.502 0.647-0.809 tiaximum active fuel length, inches' 145 146
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- Fag.e a, - Certificate Ho. 9001 ' Revision No.15 - Docket No. 71-9001 t .5.' (b): Contents - air as primary: coolant- (continued)
(ii) Group II fuel assemblies
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PUR BWR Fuel form Clad UO2 pellets . Clad UO2 pellets .;
Cladding material Zr or SS Zr-or SS Maximum initial U
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i content / assembly, kg. 475 198 l' Maximum initial U-235 l enrichment, w/o 4.0 4.0 i Maximum bundle cross section, inches 8.75 5.75 .
Fuel pin array 16x16/17x17 8x8 1 Fuel diameter, inch 0.376-0.400 0.475-0.505 )
Fuel pin pitch range, !
inch 0.496-0.507 0.630-0.645 !
I Maximum active fuel i length, inches 150 150 '
(2) Maximum quantity of material per package Maximum decay heat per package not to exceed 40,000 Btu /hr. Maximum 5,725 Btu /hr/PWR assembly. Maximum 2,225 Btu /hr/BWR assembly. l Seven (7) PWR fuel assemblies, or eighteen (18) BUR fuel assemblies. [
Above assemblies to be contained in their respective fuel baskets as l shown in GE Drawing No.159C5238 - Sheet 6, Rev. 5.
(c) Unloaded package - contents and maximum quantity of material Greater than a Type A quantity of residual radioactive material consisting of mixed-fission and activation products adhering to interior cavity and fuel basket surfaces.
(d) Fissile Class I l
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The end of life total calculated residual' gas that -could become available 'from
- the' fuel pins must not exceed 0.23 lb moles for content 5(b) an'd individual calculated fuel pin pressure must not exceed 2,500 psia, at 900cF.
7.
The maximum gross weight of the cavity. contents must not exceed 21,000 pou
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For the contents described in 5(b), the cavity fill specifications must' include the following: An air void must be established such that not more than 1.0 cu f t of water (corresponding to a bulk water -tenperature of 70*F) remains in the cavity.
The licensee must take' sufficient time-temperature-pressure data to ensure that the cavity pressure will not exceed A5 psig, and that the average cavity wall temperature will not exceed 210 F during the 130*F day with no auxilary cooling.
For the contents described in 5(b) and (c) the air coolant is considered par The radioactivity limits specified in 10 CFR 571.35(a)(4) the package contents.
do not apply.
9.
Prior to each shipment, the licensee must confirm that the cask is properly sealed by ter'.ing as subsection 11.3.3.1.
- 10. The cask contents shall be so limited that under normal conditions prior tolus transport,111 times the neutron dcsc rate c will not exceed 1000 mrem /hr at a distance of (6) feet from the -
(10 feet from the cask center-line) .~
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The neutron shielding tanks anst be' filled with 'app Pay . .
- 12. to first use must meet all of the acceptance tests and Subsections 6.7. 6.2, ' 11.3.1.1, and 11. 3.1.7.
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13.
Each cavity relief valve, typical-glove valves, and typical shielding tank (barrel expansion tank) relief. valves must be tested as stated in Subsectio 6.5.3.3, 6.6.1.1, a'nd 6.6.1.2.
In lieu of the requ'irementsf of.10'CFR 571.5a(h), valve testing and maintenance frequency must be as stated ~in Subsections 6.5;3.a - 6.6.2.1, and during periods of cask inactivity. shipments, the ruptureDuring disk: device Subsection 6.5.8.2 in lieu of the requirements of 10 CFR 511.54(h) .
l inactive periods :the maintenance and testing frequency may be disregard that the package is brought into full compliance with tnese requirements pri to the next use of the package.
'14.
The cask cavity must be equipped with either (1) a The Target Rock valve 73J pressure is shown in relief va1ve set at a pressure 'cf 375 psig (450 F).
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l ' Target Rock Corporation Drawing i
$o.'73J-001, Rev. H, J, K, or L; or (2) disk device with a bust pressure f tnin the range of
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all tolerances.
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F lPagefl CertIMcaWe t (Nm
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4 ri5.
The uranium shielding material must be separated; from all steel surfaces with a m'inimum copper thicknessf of 4-mils, except that the stud bolts attaching the m
shield assemblies to top of sthe EUR basket must be coated ~with a minimum of 1/2-
~ mil'of copper.
11 6 . llo shuto'ff valve shall be installed between each neutron shield tank and its respet'tive' thermal expansio'n tank. -
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- 17. The package authorhed by the certificate is hereby approved for use under the general license provisions of 10 CFR 671.12(b).
$8. Expi rati on 'da te: 'OctoSer 31, 1984.
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'N REFEREllCES General Electric Company consolidated application dated October 3,1979.
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Supplements dated: May 12, July 21, and November 26, 1980; February 6 and *
.,Cece,mbe r 29,1981; March 15 and September 20, 1982; and March 18, 1983.
3ection XI, Quality Assurance-and Testing, is deleted from the application.
FOR THE U.S. tiUCLEAR REGULATORY COMMISSI0tl t'
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Charles E. fiacDonald, Chief Transportation Certification branch Division of Fuel Cycle and Material Safety Date:
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