ML20082F725

Supplemental Responses to General Interrogatories & Interrogatories on Contention 67 Re Shipment of Radioactive Matl in Unsafe Containers to Disposal Sites.Certificate of Svc Encl

ML20082F725
Person / Time
Site:	Harris
Issue date:	11/23/1983
From:	Oneill J CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Eddleman W EDDLEMAN, W.
References
ISSUANCES-OL, NUDOCS 8311290216
Download: ML20082F725 (8)

Text

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1, November 23, 1983 UNITED STATES OF AMERICA RC NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 13 NW 28 N0:57 CFFICE OF SECRED# '

• C0CKEiihG & SEHVD.

In the Matter of ) BRANCH

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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) )

APPLICANTS' SUPPLEMENTAL RESPONSES TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES AND INTERROGATORIES ON CONTENTION 67 TO APPLICANTS CAROLINA POWER & LIGHT CO, g al.

(THIRD SET)

Pursuant to the Board's Memorandum and Order (Ruling on Discovery Disputes), at 8 (October 6, 1983), Applicants Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby submit the following supplemental responses to

" Wells Eddleman's General Interrogatories and Interrogatories on Contentions 75, 80, 83/04, 64 (f) and 67 to Applicants Carolina Power & Light et al. (Third Set) ," dated July 2, 1983.

INTERROGATORIES ON CONTENTION 67 INTERROGATORY NO. 67-5 (o) . Has CP&L shipped any radioactive material (LLRW) which arrived at a disposal site or other authorized receiver (i) leaking (ii) with a radioactivity level at or at a given distance from its surface in violation of transport regulations for LLRW or in excess of that permitted for the type of shipment (I, II, III, etc) made?

ANSWER: Yes.

INTERROGATORY NO. 67-5 (p) . If answer to (o) above is affirmative, please list each such and state the condition arrived in.

ANSWER: (1) On November 14, 1979, fourteen 55-gallon drums inside a cask arrived at the Barnwell waste disposal site for burial.

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During incoming surveys a 3 by 3-inch area on the side of the cask measured radiation levels in excess of Department of Transportation limits.

Reference:

Memorandum from B. H.

Webster to B. J. Furr dated November 26, 1979.

(2) On November 3, 1982, two 55-gallon drums of low-level waste shipped to the Barnwell site were found to be leaking.

References:

(a) Letter from H. G. Shealy, Chief, Bureau of Radiological Health, South Carolina Depnrtment of Health and Environmental Control, to R. B. Starkey, Jr., Plant Manager, H. B. Robinson Plant, dated November 9, 1982. (b)

Letter from L. W. Eury, Senior Vice President, CP&L, to H. G. Shealy, dated November 29, 1982. (c) Letter from R. B. Starkey, Jr., to H. G. Shealy, dated January 28, 1983. (d) Letter from J. P. O'Reilly, NRC Region II, to E. E. Utley, Executive Vice President, CP&L, dated December 3, 1982 (enclosing a Notice of Violation and Inryec-tion Report No. 50-261/82-40). (e) Letter from E. E. Utley t-J. P. O'Reilly dated December 31, 1982.

i INTERROGATORY NO. 67-5 (q) . [H]as any shipment from CP&L to any LLRW site ever been rejected for disposal in such site?

l ANSWER: Yes.

INTERROGATORY NO. 67-5(r). If answer to (q) is affirmative, please list each such shipment, the reason given for its rejection, and where and how such shipment was dispoced (or where it is now stored).

ANSWER: The shipment of drums described in answer to Inter-rogatory No. 67-5 (p) (2) above was returned to the H. B. Robinson Plant for reprocessing and repackaging. The shipment was returned because of the discovery of unsolidified sludge and leaking drums.

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The reprocessed and repackaged waste is presently stored at the H. B. Robinson Plant awaiting shipment.

PRODUCTION OF DOCUMENTS The documents identified in this Supplemental Response will be made available to Mr. Eddleman for inspection and copying at the corporate offices of Carolina Power & Light Company, 411 Fayetteville Street Mall, Raleigh, North Carolina, 27602. The documents will be made available during Carolina Power & Light Company business hours (or such other mutually agreeable time) .

Appointments to inspect the documents may be arranged by telephoning Hill Carrow at 836-6839, at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before the requested inspection. Applicants will maintain the requested documents assembled in Carolina Power & Light Company offices available for inspection by Mr. Eddleman, for a reasonable time (i.e., through December 23, 1983), after which they will be returned to their place of origin.

Inspected documents which Mr. Eddleman wishes to have copied will be reproduced by Carolina Power & Light Company on a schedule compatible with other demands for duplicating equipment. A Carolina Power & Light Company employee will be available during the inspection in order to receive any requests for copying. Copies of such documents

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e s will then be furnished to Mr. Eddleman upon payment of 7 cents per page, to meet Carolina Power & Light Company's cost of reproduction.

ubnfLtted y, Obdb.

Tho as A. Baxter, P.C/

John H. O'Neill, Jr.

SHAW PITTMAN, POTTS 6

, 10WBRIDGE 80 M Street, N.W. I Washington, D.C. 20036 Telephone: (202) 822-1000 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 26602 Telephone: (202) 836-7707 Dated: November 23, 1983

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i 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 B. H. WEBSTER County of Wake )

)

State of North Carolina )

B. H. Webster, being duly sworn, according to law, deposes and says that he is Manager - Radiological & Chemical Support Section of Carolina Power & Light Company; that the answers to interrogatories on Contention 67 contained in " Applicants' Supplemental Responses to l Wells Eddleman's General Interrogatories and Interrogatories on Contention 67 to Applicants Carolina Power & Light Company, et al (Third Set)" are true and correct to the best of his information, knowledge and belief; and that the sources of his information are officers, employees, agents and contractors of Carolina Power &

Light Company.

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/ kelister Sworn to and subscribed before me this g day of ,#983. ,

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

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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) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Supplemental Responses to Wells Eddleman's General Interrogatories and Inter-rogatories on Contention 67 to Applicants Carolina Power & Light Co, et al. (Third Set) " and " Affidavit of B. H. Webster" were served this 23rd day of November, 1983 by deposit in the U.S.

mail, first class, postage prepaid, to the parties on the attached Service List.

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John H. O'Neill, Jr.

DATED: November 23, 1983 U I

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

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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) )

SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Ccmnission 307 Granville Road ,

Washington, D.C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atanic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Ccmnission P.O. Box 12607 Washington, D.C. 20555 Raleigh, North Carolina 27605

- Dr. Janes H. Carpenter Dr. Richard D. Wilson Atanic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory O:mnission Apex, North Carolina 27502 Washington, D.C. 20555 Mr. Wells Eddleman Charles A. Barth, Esquire 718-A Irede n Street Janice E. Moore, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U.S. Nuclear Regulatory Ocnnission Richard E. Jones, Esquire Washington, D.C. 20555 Vice President and Senior Counsel Carolina Power & Light Ccrpany Docketing and Service Section P.O. Box 1551 Office of the Secretary Raleigh, North Carolina 27602 U.S. Nuclear Recfulatory Ccmnission Washington, D.C. 20555 Dr. Phyllis Iotchin 108 Bridle Run Mr. Daniel F. Read, President Chapel Hill, North Carolina 27514 GANGE/ELP -

5707 Waycross Street Dr. Linda W. Little Raleigh, North Carolina 27606 Governor's Waste Managenent Board 513 Albemarle Building 325 North Salisbury Street Raleigh, North Carolina 27611

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• s Bradley W. Jones, Esquire U.S. Nuclear Regulatory Ccmnission Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atanic Safety and Licensing Board Panel U.S. Nuclear Regulatory Ccmnission Washington, D.C. 20555 Mr. Dobert P. Gruber Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 e

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