ML20082B516

Answers to Second Sets of Interrogatories on Contentions 8F1 & 15AA

ML20082B516
Person / Time
Site:	Harris
Issue date:	11/15/1983
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
Shared Package
ML20082B518	List: ML20082B516 ML20082B540
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8311210223
Download: ML20082B516 (12)

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2 UNITED STATES OF AMERICA November 1 19 3 NUCLEAR BEGULATORY COMMISSION 33 $ g A10:

29 BEFORE THE A'!OMIC SAFETY AND LICENSING BOA g' ?

Glenn O. Bright -

h~f' Dr. Janes H. Carpenter James L. Kelley, Chairman In the Matter of

) Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 ani 2) ) ASLBP No. 82-L68-01

} OL Wells Eddleman's Answers to Anplicants ' Second Sets of Interrogatories on Contentions 8F1 and 15AA These resnonses are provided under an extension of time agreed to by Applicants and the Board in a telenhone conference call last week which was not transcribed.

RESPONSE TO GENERAL INTERROGATODIES: The response, including all objections and information/ objections incornorated by reference, to the General Interrogatories is the same as for the first set of Applicants' interrogatories on 8F1.

RESPONSES ON 8F1: 114(a ): I am not sure: may have submitted and would have to search.

comments and/or otherwise participated; I have no records, (b) See (a);

if any such information is in my nossession, it is not filed in air quality or other related files; an extensive search might turn up little or nothing, and would be burdensome. OBJECTION: as to information and testimony not related to particulates, this is irrelevant.

c 15(a): OBJECTION: This information is irrelevant, since the contention concerns actual health effects. ANSWER: I think so, but have no records accessible to detail such. (b) See (a); I am not sure that I have any copies of written communications, and do not recall the substance of any verbal communications. I have no list.of advisory committee members _and thus cannot answer that part of the question.

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PDR ADOCK 05000400

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8FL (2d)-16 and 17: OBJECTION: This request is irrelevant (NRC has no power to compel EPA or Congress to protect the nublic health and safety fromnair particulates; the contention is about weighing i

1 ths health effects of particulates from coal-fired nower plants.

This request'is also unduly burdensome: I would take a couple of books to answer it in detail.

8F1-18: Source of statement is NY Times News Service; rule proposed in July 1983, re aresenic emissions, e.g. from Tacoma WA smeter.

See also 19:

8F1-19. Source of Statement is NY Times News Service: Fule proposed in September 1983 (active uranium mills). I believe for both of these the pronosals can be found in the Federal Register but I have not obtained copies of them yet. Printed in 9/18/83 Raleigh News and Observer, page 3A, is the written statement.

8F1-20: See analyses submitted in 1982-83 NC Dent of Natural Resources and Community Develonment rulemaking on earticulate emissions:

Duke Power (and I think nerhaps CD&L) submitted information to the Department indicating that 5 times the particulate emissions of their existing plants, or more, would not violate'the ambient air quality standard for total narticulates. The 1,154 metric tons l of particulates ner 45Mwe (Table s-3 of 10 CFR 51.20) value, though, corresponds to 18,464 metric tons ner year ner 720 MWe unit, a greater level of particulate emissions than presently allowed for all CP&L coal-fired units, for example. Since CP&L's coal-fired system-comprises more than 5 times 720 MW (i.e. more than 3600 MW), emissions at this level would very likely violate the ambient air quality standards for particulates. The other particulate loadings:in NC are not severe, and if higher levels of particulates from other sources were present, the level of coal

• fired nower plant narticulates needed to viblate the ambient air cuality standard for particulates would be less, as the standard relates to total MASS of particulates in air

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The methods of analysis are set forth in submissions in this rulemaking, which I understand CP&L possesses. I do not necessarily endorse all the methods and analysis so used, but do  !

believe it urovides a conservative estimate of the level of particulah emissions fron coal-fired nower plants needed to violate the ambient air quality standards. I believe the emissions needed to violate this standard could well be less than those given in the above and above-referenced analyses. When you multinly the source term, you multiply the loadings, particularly the loadings close to the source.

8F18-21: I don't know; health effects of narticulate emissions are not just direct, but also denend on interactions of particulates with gases (e.g. sulfur and nitrogen oxides, etc.) in the air.

l 8F1-22(a) Yes. (b). Please look at the docunents provided to you ond discovery, in which these connounds and elenents are listed. It is burdensome to dig the information out, and you can do it as easily as I can. (c) I don't know.

8f1-23(a) I have numerous studies of the EPA's redent history which I believe support this assertion. See Sierra Magazine, Nov/Dec 'S3 issue (which I possess but can't locate just now), for a sumnary of history under Administrator Ruckelshaus in in983 Pronosing standards that allow numbers of deaths as high as 2 in 100 (armsenic) or 1 in 1000 (uranium milling) do not in my ouinion protect the health and safety of the nublic, but sacrifice it deliberately.

(b) I don't know. I don't keen these studies filed by their connection; there may be a lot.

(c) No, I would make the same objection to having your neonle working in my personal files that you made re Eddleman h1 and 65:

It would disrupt ongoing work; I can't snare the time and haven't the personnel to watch you; I need to use my files; the info is not

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-h-filed in this way, and finally, the information sought is irrelevant to the contention excent as it addresses health effects of narticulates (including their interaction with other nollutants). However, I will nake available cooles of whatever studies I do find readily (e.g. I believe I have a Conservation Foundation renort which I think deals with this issue)OE.*NThe part on Air Quality does.to Anplicants for inspection and conyin OBJECTION: As stated above, to permitting Annlicants to search my documents.

8F1-24(a). I may, but have not located any. If I do, I will provide you with the original or a cooy for insnection and conying.

(b) See (a). (c) OBJECTION, same as to 23(c). I will orovide copies or original for inspection if I located any, f

8F1-25(a). I am not sure of the intent of the question " working with you or for you in any capacity". I do work with some persons who may be considered experts in the health effects of coal-fired nower plant emissions, but I have not deternined the extent of such expertise and our relations are informal. (b) I don't know, see (a).

If" working for"ne means ennloyed by me, the answer is None.

CE9TIFICATE OF NEGOTIATIONS I spoke with Hill Carrow of CP&L by phone on 11-15 and relaydd the substance of my objections and answers re relevancy to him. He J

agreed to examine the objections when received and see if they gave him problems. I called later to dis' cuss my objections re 23(c) and 24(c) and he indicated it would be satisfactory to provide copies of documents I could locate. This.I am doing. Examination of the Conservation Foundation Renort Air Quality Section indicates

it does treat this issue. /

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-5 RESPONSES ON 15-AA:

14-(a)0bjection, as to non-witness exnerts being identified, as set forth in detail in previous objections [0-2, G 'k re 75 and 83/8h),

is renewed here as if fully set out at this point, including all pleadings in resnonse to nast Motion to Connel by Anplicants.

Wells Eddleman answered these interrogatories.

(b) Objection, as t o identifying norsons who sinnly nass sa information, mail it, etc.: their identification is irrelevant.

Objection, as to identifying nonwitness exnerts, see (i) above.

Answer will be nrovided as a eseudonym for any nonwitness exnerts in resnonses below.

15(a) No, the size of the plant, its design, Murnhy's Law and other factors (e.g.biofouling of heat exchangers or condensers, possible restrictions on operation due to (1) accidents at similar nuclear nlants (2) safety or environmental nroblems not yet identified (3) construction defects not yet identified, which may be due to contractors (e.g. Daniel International, e tc) which CP&L didn't detect, and quite nossibly others. Please consider this answer a sunnlement to orevious response. CP&L mismanagement is more than nurnorted: it 's real.

(b) It is innossible to identify every such fariable, particularly so for those not yet known; nevertheless, unanticipated (or denied, but real) problems have adversely affected nuclear nower plant perfroarmance in the past and no doubt will continue to. Size of plant: See NUREG-0030, CP&L PSAR and FSAR for size; for effect see Page/ Eddleman studies in NCUC dockets E-100 sub h0 and sub h6, which CP&L nossesses, re effect of size on canacity factor; for design, see e.g. renort of water hammer incident ab Maine Yankee (1983),

report of steam generator "fix" by WOG (CP&L nossesses cony) recently filed in this proceeding, Joint Contention VII

and information sunnorting it. The continuous use of the auxiliary feedwater system invites breakdowns and water hammers. For biofoudling, see documents and responses re Eddleman 75 It is important to understand that any or all of these factors, and the others listed in (a) which are I think self- explanatory, CAN affect the Harris 1 (or 2 for that matter, if it were ever built) capacity factor adversely. Most of them are locked into the plant since its size, design, construction so far, ownershin and oneration, being a nuclear plant (thus subject to safety : regulation) are relatively fixed factors. Comnlete listing of documents is burdensome as I have not assembled all such yet. When I do, will make then available for inspection and copying. See also rnsponse to 16, below.

15AA-16: VC Sunner unit 1 (basis: FSAR of Harris, re NSSS; discussion with persons familiar with SCE&G, names not recalled).

Beaver Valley Unit 1 (basis: NCUC Order in Docket E-2 sub 203 licensing construction of Harris); slightly less similar than these two:

North Anna 1 and 2 (Basis: NCUC Order, NU9EG-0020 data); for steam e.g. Krsko generators: Dhsj are most similar, D's are also similar; all Westinghouse steam generators are more similar to Harris' t han B&W or C-E stean generators. Details would be burdensone to list and I do not have a list. See the Critical Mass bookalet Tube Leaks for description of problems, including adverse effect on canacity factor, for steam generators.

17(a) Both Westinghousegulants; both with model D steam generators.

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Listing of generic similarities is most burdensome. (b) McGuire is 9

a. larger reactor (1180 MWe vs 200 DER); listing of differences is likewise large and burdensome and therefore objected to.

18. June,1983, McGuire CF 77 39%; July not located; August 1983, 42.08%; McGuire,4 months May, June, July, August 1983 combLned:

49.65%; McGuire,12 months ended 8-31-83:33 50%. k P f M d

. 15-AA-19 : McGuira l's poor parformanco is dus to stsan genorator design and (please . consider this a sunnlement to question 3(c)) ,

I being put on-line in a hurry for economic reasons (which it seems  !

will apply to Harris as CP&L is committing to rush construction to i

meet a June 1985 or earlier fuel load date. Brunswick was also rushed to completion with adverse effects on its construction and onera3bility), Murphy's Law (e.g. McGuire electrical generator flooding, December 1981, due to water hammer) etc. The other factors were not mentioned snecifically for McGuire, > 1t may apply.

Steam generator problem similarity: Basis is nower restrictions on VC Summer and Krsko; corrosion nroblems (see, e.g. HB Robinson 2)

For adverse effects of rush on-line, see e.g. testimony of FS Cantrell in 5C..-400 remand hearing of 1979 (Brunswick); Eddleman testimony in NCUC Dockets E-7 sub 314 and sub 335; for Murnhy's Law, consider LERs (McGuire had most in nation for 1981, I believe), connare Brunswick (high in LERs). McGuire also has had more events of safety signiacance than many plants; likewise have Brunswick and HB Robinson. It would seem obvious that such problems adversely affect canacity factor

the safet-sig&ificant problems require nore analysis, more outages, more caution, and more regulatory action.

20(a) Westinghouse plant (NSSS), same generation of designs as Harris, virtually sane size (885 MWe); detailed listing of similarities burdensome. (b) I'm sure there are, but have no list.

Documents for (a): NUREG-0020, E-2 sub $203 NCUC Order.

21. I don't have the current CFs. As of mid '83 I believe Robinson's was about 63. %, and the 2 North Annas were about 56 and 60 percent respectively-if I recall correctly.

22. What this means is, when you linearly regress capacity

factor against unit size .for Westinghouse PWRs as Dr. Page and I did, l the best fit line is an "all other things being equal" line, i.e. it

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does not take into account factors of design, management, construction, and so on, but only size of unit. The calculation was performed by " weighting" capacity factor for years of operation by entering each data point once for each half-year (or nerhans year) of commercial operation, and was done by Dr. Page's connuter. It is simple linear regression of the data points (size - MWe DE9 , CF (lifetime, DED))

and is a standard statistical orodedure (least squares) for determining the best-fit line. Because there is substantial variability around this line, it is an "all other things being equal" fit. The data were from NUREG-0020 as explained in ny sunnlemental testimony in NCUC Docket E-100 sub 46, which CP&L nossesses. I believe I have i some connuter printouts Dr. Page orepared, which Fi ve the results of the conputer calculations. Reactors under 400 MWe were excluded from the calculation. I believe that an adjustment was nade in some of the calculations to allow for refueling of North Anna 2 and one other unit not yet refueled, but I don't hink such an adjustment was made for McGuire 1, which is yet to be refueled. Data from NU9PG-0020, 23(a). All you have to do is look at the data. CP&L was very little involved with Robinson 2 (turnkey plant built by Westinghouse),

and it is (so far) about average in CF for a PWR, and right on the line best-fit Dr. Page and I found for CF versus unit size.

For Brunswick, JA Jones of CP&L testified (50-400 remand hearing,1979) that CP&L had been much more involved with t he construction. Brunuswick units 2 and 1 respectively have the worst and second worst canacity factors of any BWRs in the United States, as of mid-1983 (DER basis).

CP&L rushed construction of Brunswick for financial reasons (Jones testimony, ibid, 1979). Brunswick's canacity factor is far below the best-fit line Dr. Page and I found for BWRs. Since this line

' includes Brunnswick in its data base, the nerformance of Brunswick l

is actually even worse compared to other BWRs.

_9 (b) Asked and answered in the referenced interrogatories' resnonses and in resnonse to 22 above.

24(a). I'm not sure there is a generally accepted statistical methodology for so few data points; when billions of kWh ride on the answer, one should be conservative in estimating the Harris capacity factor. I believe it is generally accepted in statistics that the least biased estimate from a distribution is to use the mean to describe it; I am not aware of any studies of s tatistical distribution of CP&L involvement in construction of nower niants versus capacity factor other than my own. As to statistical validity, I think the sample size is too small to be able to use statistical methods successfully. On the other hand, the samnle size for Westinghouse PWRs (and for BWRS) is much larger and its use is statistically valid within the limitations of the data available.

What I have done should be termed a comparison, rather than a correlation; the statistics used were sinple averages (NERC) and simple least-squares correlations (Page/ Eddleman) of Canacity Factor vs. unit size. For validity of using the average as an unbiased estinate of a groun of data (e.g. as I used NEWC) and validity of least squares, you can consult textbooks of statistics, although from my past experience various bxts may differ in their treatment of these tonics, extrapolation (b) Not applicable. The procedure itself is not statistical.

Please note it was used to get a LOWER estimate. The method used is straight extranolation; with a sample size of only 3, I doubt it would be nossible to exclude extrapolation of this nature from validity with any statistical confidence.

15AA-25(a) Jacobstein is the consultant who testified for the Public Staff of the NCUC in Docket EQ2 sub 444 (CP&L rate case,1982)

CP&L possesses all his renorts filed in that case, and his testimony and a transcrint of his caress-examination, as CP&L is a varty to that case.

I have no further identifying info on Jacobstein to my knowledge now.

(b) I rely on Jacobstein's (and the Commission's) conclusion that CP&L mismanagement at Brunswick caused an additional 70-odd days of outage at that plant. See brief of the Public Staff and Order of the Commission for details. I do not K recall if Jacobstein discussed capacity factor directly, other than to' noint out the low CF Brunswick units had been achieving, but it is obvious that such mismanagement increases outages, and that outages would decrease capacity f actor because no power is nroduced during a full outage, and less is producted during a partial outage, and canacity factor is the ratio of actually oroduced nower to nossible production if the plant ran at full nower 100% of the time.

I do not recall any discussions with Jacobstein re 15AA. I have not gone back through kacobstein's voluminous testimony and exhibits to see what else he said that I might rely on, but instead relied on recollection of it as detailing extensive CP&D management problems at the Brunswick plant, which I believe reduce its capacity factor or tend to.

26(a) Thomas Lan is a Utilities Engineer with the Public Staff of the NC Utilities Commission. You know that as well as I do.

He testified concerning the Brunswick plant's 1982 outage due to failure to perform required tests (when the failure was finally discovered, the plant was shut down much of the summer for testing),

(CP&L 1983 general rate increase) in NCUC Docket E-2 sub 461.j His resume is in his testimony which you have.

It gives his address and describes his responsibilities.

(b) Lam's testimony about how CP&L management caused the 1982 outage at Brunswick (which was accepted by the Commission, see Order in Docket E-2 sub 461 which you possess) and his descriptions of

problems at the Brunswick plant. I have not made a list of his j documents, but you noassess the ones from this proceeding and those are all I have of his testimony re Brunswick unless there is some by him in E-2 sub 428 (I don't recall if there is or not).

Lam's testimony and documents (including exhibits) concern the effect of CP&L management on outages at the Brunswick plant.

I do not recall any conversations with Lam concerning the interrogatories on 15AA; we may have casually discussed the allegations of 15AA (i.e. that CP&L and NRC Staff overestimated capacity factors for Harris, or didn't do it conservatively enough, etc),

but I cannot recall any such specific conversations. I do not recall any specific assistance by Mr. Lam concerning 15AA, though it is possible I obtained some data from him at some time.

27. Asked and answered in nast interrogatories including 22 above, and in the E-100 sub 46 supplemental testimony and E-100 sub h0 testimony re these studies which you possess. NUREG-0020 and a computer program of Dr. Page's and printouts therefrom are the documents relied on. The calculations were done by connuter i

except I believe I did some averaging, rounding and minor adjustments by hand or in my head in preparing the testimony.

28.g)Look at the pronosed backfit rule. The increased regulatory requirements of the NRC is an ongoing trend, see, e.g. , Komanoff, Power Plant Cost Escalation; publications of the Atomic Industrial Forum; CP&L resnonses to my interrogatories re contention 22B, concerning how added NRC requirements mean they need more emnloyees to run Harris. I frankly don't have time to search all my documents

, for more sunnort of this. I believe I have a regulatory alert from i

the law firm of Harmon & Weiss concerning the backfit rule.

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(b). By " existing plants", nuclear plants now onerating is meant.

The pronosed backfit rule, as I understand it, would involve. comnarison of costs and benefits of a backfit. I believe such a trade of economic considerations for safety violates the Atomic Energy Act, but thtt objection aside, the result would be that in operating v1 ants, where the cost of replacement nower during ar . outage, and the added cost of repairs / refits on radioactive systens (which require many more workers in many cases, and more planning, health ohysics work, etc) are present, the econonic factor would be stronger against the backfit, than in a plant under construction, where no power is being nroduced (so none would need to be renlaced),

and the unit is not " hot" radioactively. Connare, for exannle, the cost of steam generator repairs on " hot" olants like McGuire and Krsko, versus costs for repairs of the sane nature on olants not yet operating. See ANPRM 48 /FR hh217; UCS conr.ents thereon; NCPIRG (adonted by Eddlenan) comments thereon.

29. This is my own estinate; it derives somewhat fron Komano e f's nuclear work (Power Plant Cost Escalation) which shows that the cost orgplants j increases in oronortion to the number of nuclear niants. Likewise, i

I the added safety requirements that account for much of the real l

! (inflation-adjusted) nuclear plant cost escalation, derive from new plants needing to be safer in o rder to keen overall nuclear accident risks lower (Komanoff). These added requirements and equionent tend to reduce capacity factor since they must all be fulfilled (or onerable) within certain limits for the nuclear plant to operate.

Another basis is the reduction in CF that followed the Three Mile Island accident. For example, the forced outage rate for 1980-82 (see p.1-4 of NUREG-0020, 8/82, for example ) is about 5% higher (nearly 15%, connared to under 10% for 1978) than before TMI.

this means a 2 t r Conservatively sffum. N0 1 we n ce wrn am,o 5%hdecrease g.M b M% r W'W in ca Nacity factor. h}