ML20024E862

Second Set of Interrogatories

ML20024E862
Person / Time
Site:	Harris
Issue date:	08/31/1983
From:	Eddleman W EDDLEMAN, W.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20024E830	List: ML20024E829 ML20024E832 ML20024E834 ML20024E840 ML20024E846 ML20024E850 ML20024E853 ML20024E856 ML20024E858 ML20024E862
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8309070145
Download: ML20024E862 (10)

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- . i2 UNITED STA E S OF AMERICA SYM 3)

NUCIEAR REQUIATOBY COMMISSION Q '. ' 1983

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BEFORE THE A'!OMIC SAFETY AND LIOES$6SMMin{'

Glenn O. Bri BR m s Dr. James H.ght Carpenter James L. Kelleys Chairman In the Hatter of Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. at al. 50.401 OL (Shearon Harris Nuclear Power Plants ASLBP No. 82-h68-01 Units 1 and 2) OL Wells Eddlentn's Interrogatories to NRC Staff (M . Set)

Wells Eddleman hereby requests the NRC Staff to answer the following interrogatories before Sept g .,1983 or such other date as counsel for the Staff and I agree on.

These interrogatories are submitted under 10 CFR 2 720(h)(ii) and inquire into the studies, information, and knowledge of Since NRC staff withread I cannot respect to my contentions, on which discovery is now open.

the minds of the staff, and this information is not contained in documents which the staff has provided to ne, I an unable to obtain this inforr.ation by other means. Were the information is contained in a document I can obtain from NRC (Public Document Room, etc) I still need the identification of the The staff has resources and document in order to obtain the information.

information tich exceed what I have, and as a party,' their position and information are necessary to making my case in this proceeding. These interroga-tories are continuing in nature and should be supplemented when answers change.

GENEP.AL 11CERROGATORIES (FIRST Sli)

For each of contentions . .

2 Eddlenan conte.ntions k2-

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please provide the following information by answering each of these questions.

1. Wat is NRC Staff's understanding of the , subject matter of this f contention?

I li n into,(a) this contention (b)

2. Has NRC Staf the subject matter of this contention (c) the allegation (s) i in support of this contentiont 3

For all parts of your response to Interrogatory 2 above for who which your made answer is affirmative, please provide the following information:

the analysis, inquiry, study or investigation; what was being considered in such analysis, inquiry, study or investigation ("AISI"); the content of the AISI, the results of the AISI, whether the AISI has been completed, whether a date for completing _ the AISI has been established if it is not complete, what that date is, all documents used in the AISI, all persons consulted 8309070145 830831 gDRADOCK 05000400 PDR

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j in the cours] cf the AISI, an doounents containing infcrma ult cf tha .

l or analysis or study or information developed duringtd er lts cs a res AISI (identify each such documentlledand state dat t ntion,  !

or further AISI needs or may need to be undertaken on this con e as '

and Wether any persons participating in the the AISI ifstaff isAISI itare to be not is ca conplete.

witnesses fcr the Staff in this case,and eat questions intended 4.

to answer and what information NRC ataff it seeks to d  ;

yone answer is other than affirmative, please state (a) his contention whether on J J

plans to perform any AISI on this contention. di such AISI, (b) t e (even though it has not been made) (c l on this contention include a date for beginning or for ffen ng) Wat AISI desires r (d) those dates, for an affirmative answers tol (c)dabove on (e NRC staff will undertake on this contention (f)  !

this contention if none is planneddone yet on this contention of NRC staff with respect to this contention are.

h Staff's opposition of this contention, and any specific ) upon which facts Staff not to admission of such contention (already filed in this case relied in making such opposition. to 6.

Identify an documents not identified in Staff's interrogator Wens Eddle'.an or to Joint Intervenors (to presen 7

Identify by name, personal or business address, NEC staffNRC staff p lted or title (if any), and telephone number (if known) eachi personby NRC staff on r to or consultant to NRC staff .or known to NRC Staff l isor consu in the staff's analysis of the subject matter of was performed hy that person. ified in 8.

State au professional qualifications of each person ident response to interrogatories 7,,

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f d ts Provide any statements of the analysis made by persons in 9response to interrogatories 3,4, orl 7m above, and ident identified.

containing such infornation or statements not previous yd ments l ble through identified

10. in response to interrogatories abo NRC PRE (Public Document Room).

n. Win NRC Staff make available copies of documents for inspection response to the above interrogatories to Wells PET Eddleman i

and copying, for documsnts not available through NRC's l hone 12.

Identify by name, NRC staff position ifn any, address and as a witness number each person tom NRC staff intends to axa use or ca in this proceeding. identified

13. State funy the professional qualifications of each person in respense to interrogatory 12 above.

14 Susesarise th] position (er planned testimony) with r spect to each oontention on dich such person is cxpected to testify, far occh person identified in response to interrogatory 12 above.

13. Has BC Staff, ag witness identified in response to interrogatory 12 or agone acting in behalf of the Staff or such a witness or at their direction, made av oalculation or analysis (not identified in response to interrogatories 1 through 4 above) with respect to this contention?

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16. If the answer to interrogatory 15 above is yes in av osse, provide the mane, business or personal address, telephone nunber and professinnal qualifications of each person to has made such calculation or analysis, stating for each d at contention it relates to, what person (or Staff) it was nade for or at the direction of, and identifying an documents containing such omiculationer analysis and an documents used in making such calculation or analysis or relied upon in it or supplying infornation used in it.

17 Provide a summary of each AISI, calculation or analysis Adam for which the answer to interrogatory,15. or interrogatory 2 above, is yes.

18. Please give the accession number, date and originat'or of each document identified in response to interrogatory 16, which is available at the E C PE.

19. '.un EC Staff make available to Wens Eddle .an for inspection and copying an documents identified in response to interrogatory 16 above which are not available through the Pmf

20. Identify each person, including telephone number, address, and field of expertise and qualifications (cr.plete) (if av) fa who answered interrogatories with respect to this contention; if more than one person contributed to an answer, identify each such persor, providing the information requested above in this interrogatory for each such person, and state what each such person's contribution to the answer was, for each answer.

21. Identify an documents dich the Staff proposes or intends to use as exhibits with respect to this contention during this proceeding, including exhibits of Staff witnesses (identifying the witness for each, if such a witness has been designated), and exhibits to be used auring cross-examination of witnesses of av party (stating for each which witness it is to be used in cross-exanination of), and identifying for each the particular pages l

I or chapters to be used as exhibits.

l l 22. Id'entify an documents dich EC staff relied upon in answering interrogatories with respect to this contention, tich have not been identified in response to interrogatories 1 through 21 above, stating for each which answer (s) re dich contention (s) it was used for, and each specific fact and page number therein on dich EC staff relied or which RC staff used in answering such interrogastory.

23. Please give the accession number, date, and originator of each document identified in response to interrogatories 21 or 22 above which is available l through the EC PE.

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24. Will E C Staff provide Wells Eddleman with copies of the documents l identified in response to interrogatory 21 or 22 above Wich are not available l

I at the PE, for inspection and copyingt I

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25. Identify ag other information or amouros 26) uponof information which EC staff not idsn l

in response to the above interrogatories (1 through t i

relied, or which NRC staff used, in answering interrogatories with respe to this contention, and the contention and response in which it was and the location of the relied upon information in such source.

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26. Does the staff now agree with (a) the contention (b) a v part o contention?

27 If response to 26(b) above is affirmative, which part(s)?

, Note:

INTERROSATORIES RE EDDLDW 00NTENTI ii be held up for response until the Board rules on Eddleman i 15 and it and additional contentions '. re IT 8.menderant

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4. if the Staff des res.)J g excepF 30,

. t 28 Has the staff predicted or estimated or proj to operate in the US?

29 Has the Staff estinatad, projected or predicted t in thetheUSTadditional capacity to be delivered by any reactor now licens 30 Has the Staff estinated, projected or predicted l t (c)versusany fuel savin versus coal fueled power plants (b) versus oil fired power p an s hydroelectric power plants, in its DEIS or FES or ES or FEIS for nuclear power reactor now licensed to operate in the US7 31.

If the answer to any part (or all ) of 28,29 or 30 above is affirm rediction please list each such resc. tor and each estimate, projection or p made for it.

32. For each reactor listed in response b) to 31 abovel '

answer to 28 whether information on the('hetual operating capacityk factor demand

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1 actual operating cap u city at the time of summe (f) number actual operating fuel savings (d) O&M costs (e) repair costs for shutdowns of LERS (g) time of shutdowns and length of and (1) in the NRC PM (ii) otherwise within the KRC.

33 Please identify all documents containing the theabove PIR. information, aiving the accession number and date for each that is at i

34. Exactly how did the S t aff estimate Harris' capacity factor at 55% for the DEST Please state (1) what plant specific data for Harris the Staff examined (a) in preparing analysis or material for the DES (b) in making its analysis, (both parts, re Harris capacity factor); (2) what data, if av, on the performance of (a) other Westinghouse Pas (b) VC Su.mer nuclear station (c) North Anna nuclear units 1 or 2 or 1 and 2 (d) other Pas whether designed by Westinghouse or not (for Nuclear Stean Supply Systen) (e) other reactors whether PNRs or BRs, the 2 Staff (i) examined or reviewed (ii) used in its analysis of Harris capacity factor (3) state av equations, and reference or describe fully in detail any statistical or other models used by the Staff in preparing its estimate of Harris capacity factor (4) info to identify all docunents containing any of the above information (5)whether the Staff relied on agone's opinion (s) re the likely capacity factor of Harris, and if so, whose and what qualifications they have for estimating

likely capacity factor (6) any other method or information the Staff used in preparing its estimate of Harris capacity factor, identifying all documents containing such nethod(s) or information that the Staff possensses.

35. Did the Staff use any information on perfornance of Westinghouse PWRS outside the USA in making its estimate of Harris capacity factorf

36. If answer to 35 is affirnative, please identify all data used, all docunents containing it, and explain exactly how it was used, including all models, equations and methods used, in assessing likely Harris capacity factor.

37 DLd the Staff u., its own track record (estimates made by the Staff for nuclear plant capacity factors, as conpared with actual performance of those 1st 5 years plants (i) to date operation of commercial (ii) for any)etcperiod, please with actual specify the perfornance ofperiod, e.g.

l- any nuclear plants for which the Staff has estimated capacity factors in the past, in any way in preparing its estinate of Harris capacity factor I which is in the DES 7 l 38. If answer to 37 is affirmative, please explain what track record i was used, list all plants, estinates and a cLual perfornance used, and explain exactly how this data was used in making the Staff's DES estimate or projection of Harris nuclear CF of 55%.

39. If answer to 37 is negative, explain why inot.

, 40. If answer to 37 is not explained fully in response to 38 or 39 above, please give a fully explanatory statement why your answer to 37 is as it is.

41. Did the Staff review any estimates by anyone else of Harris CF in preparing or making its estinate of Harris CF of 55%7

42. If answer to 41 is =Mr=wethan affirmative, please list all such estinates and state for each the nature and results of staff review of it.

43 Is the Staff capacity facator based on the Design Electrical Rating for Harris of 900 MWe?

44. If answer to 43 is other than affirmative, please state the basis (plant output) on which the 55% Staff Capacity Factor (CF) is made.

45 Does the Staff agree that (plant output) x (CF) x 8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br /> (1 year) equals expected annual output of a power plant, given an expected value of CF (Capacity Factor)?

46. If response to 45 is other than affirmative, please state what definition of CF Staff was using in the DES and give all reasons why Staff used that definition.

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47. Did the Staff exa .ine or includa cny (i) cffset (ii) cstinata, cf (a) additional regulations by NRC (b) de-regulation by NRC or federal govt (c) fewer regulations by NRC (d) need for power (e) load forecasts (f) likelihood of nuclear accidents (g) repairs at Harris (h) shutdowns at Harris l l

(j) performance of other CP&L nuclear units (k) performance of Robinson x2 (1) perfornance of Brunswick nuclear station or Banswick units (m) CF&L's )

fines from NRC (n) shutdowns of CP&L units ordered by NRC (o) shutdowns of CP&L nuclear units resulting fron any other cause (p) estinated tine of Harris refueling and (q) length of refueling cycles for Harris units (r) ,

effect of nuclear accidents elsewhere on operation of Harris, e.g. thru l backfit requirenents such as resulted fron T.'I 2 accident for units in operation or under construction at the time of that accident or later (s)

CP&L's estimate of Harris capacity factor (t) any info supplied by CP&L supporting its estinate of Harris capacity factor (u) any analysis by Charles Kocanoff of nuclear capacity factors (v) any analysis by David Dinsmore Coney of nuclear capacity factors (w) NJRIG-0020 reports of nuclear capacity factors (x) relatig ve stringency of (aa) NRC regulations (bb) plant technical specifications, for Harris; (y) availability of nuclear fuel (z) LIRs, in making its estimate of Harris capacity factor for the DIS 7

48. For each part of 47 for which your answer is affirnative, please identify the effect or estimate, identify all docu~.ents containing it, and state how you used or included it in making your estinate.

49. Does the Staff believe Harris l's capacity factor can be less thant 55%7

50. Does the Staff agree that neither it nor CP&L'-guarantees the level of C.F.

t fron Harris to be 55% or above7(- .

51 (a) If your answer to 49 is other than affirmative (b) If your answer to 50 is other than affirmative, please state all reasons for each such answer.

52 If not stated above, please give all reasons for your responses to (a) 49 and (b) 50,above 53 Does the Staff believe that Harris would be environnentally superior as a forn of generation of power at (a) 55% CF (b) under 50% CF (c) under 40% CF (d) under 30% CF (e) under 20% CF (f) under 10% CF (g) under 4% CF (h) at zero CF compared to any other method of generating power used by CP&L7 54 Does the Staff believe that the benefits of Harris power outweight its environmental costs at or above any specific capacity factor (s)?

55 If a'nswer to 54 is affirnative, please stace that level. If it is zero, please so state.

56. Do any costs or economic factors enter in any way into the Staff's estimate of Harris capacity factor?

57 If answer to 56 is affirmative, please state all such costs and how they affect that esticate 58 Does the Staff believe that Harris' capacity factor depends in any way upon (i) NRC regulations during its period of operation (ii) CP&L's manage .ent of Harris (iii) repairs to Harris during its period of comercial operation, if any (iv) availability of low-level waste disposal sites for Harris (v) availability of disposal for Harris spent fuel (vi) availability of storage for Harris spent fuel (vii$ r ala in the condensers at Harris (viii) cerbicula 4

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in the RHR heat exchangers at arr sf

-7 59 If answer to any part cf 58 is effirnstive, pl asm stato what tha dependency is and wh ,ther Staff his cstinated er calculated it nun:rically.

If you have calculated please give the calculation. If you have cstinsted or otherwise considered it, please identify all docunents ag(work papers etc) in which you do so. Please state this for each part separately if the answer to each or av such part is affirnative 60 Will the presence or absence of nuclear intervenors be expected to If so, what way, and to what

, affect Harris capacity factor in any way?

extent if you know?

INTERROGATORIES ON 8F1 61 Why didn't the Staff include health effects of the coal pollutants (given in URC's Table S-3) in its DES for Harris?

62 Does the Staff know anything about the health effects of coal pollutants?

63 I Has the Staff estinated the effects on health of coal (1) enissions as given in Table S-3 (ii) enissions in any way (iii) particulate enissions (iv) gaseous emissions (v) sulfur oxide enissions (vi) nitrogen oxide emissions (vii) actinide emissions (viii) netal emissions (ix) nercury e .issions (x) POM (polycyclic organic natter) enissions (xi) PAH (polycyclic aronatic hydrocarbon)enissions (xii) netal emissions coating fine particulates (xiii) particulate enissions in the 0.2 to 2 nicron range, which tend to stay in human lungs (xiv) gasa aerosol complex (xv) any conbination of any of (iii) through (xiv). above (xvi) any other coal cycle arlssions, including leached seleniu , liquid effluents, etc, at any time in the past?

In particular, have you nade any such estinates in connection with (A) the DES (b) the FES (c) the hearings (d2) your analysis of health effects, for (aa) the VC Sunner nuclear plant (bb) the Catawba nuclear plant (ce) the Seabrook nuclear plant.(dd) the North Anna nuclear plant (ee) the Ecguire nuclear plant (ff) the Robinson 2 nuclear plant (gg) the Brunswick nuclear plant (hh) any other nuclear plant?

64 Does the Staff have any estinate of the health effects of the coal particulate enissions given in Table S-37 If so , what is that estimato?

65 Does the Staff have any current estinate of the health effects of the coal cycle emissions given in Table S-37 If so , what is that estinate?

Pleace detail additional (i) deaths (ii) illnesses (iii) work days or person days lost to illness (iv) innune systen danage (v) cancers (vi) other health effects- pplease specify -- which are included in that estinate; if your analysis is not current or not conplete for any of these effects, please 'say so.

66 Will al pdlutanti health effects be discussed in the FES? If so, where?

67 Will e cal pollutant health effects enter into the cost benefit analysis in the FES? If so, where and how and to what extent?

68 Has the NRC Staff exa .ined or obtained any data on actual enissions fron CP&L coal-fired power plants? If so, do you plant to use any of this data in esti .ating health effects of effluents in Table S-3 for Harris?

69 Does the Staff challenge in any way the effluent nu-bers for coal pollutants given in Table S-37 70 Please state in detail any disagreenents the Staff has with any of the coal enissions stated in Table S-3, giving in full any basis therefor and citing specifically (including page nunbers of chapters) all authorities and documents you rely on in having such disagreenent, for each disagree .ent.

71 Does the Staff believe the health cffcets cf coal emissions ara more serious than the health effects of the emissions from a melear plant

.(assuming both the coal plant and the nuclear plant generate the same energy and the emissions from the coal plant an as given in Table S-3)? I

72. Floase explain in deta.11 your answer to 71 and cite any authorities and identify argr documents on dich you rely.

l 73 An the health effects of coal pollutants (for a 45 rde coal fired plant as given in Table S-3) considered to be as much as (a) 10 times (b) 20 times (c) 30 times (d) 100 times (e) any other mmber of times, worse than the health effects of producing the same energy (45 rde for If answer to (e) a year) by nuclear energy, in the Staff's opinion?

is affirmative, please state the ninber of times.

Does the Staff believe it can challenge the coal emissions values 74.

of Table S-3 under NRC rulest o75 mat are the . _ h health effects of coal emissions as given in Table S-3 of 10 CR 51.20, in the Staff's view, if not already stated above in response to other interrogatories?

76.

Does the Staff believe that coal particulates (i) can be coated with cancer-causing metals or POMs or PAHs? (ii) can cause cancer (iii) can contribute to devenlopment of cancer (iv) can cause lung cancer (v) can kill macrophages in the lung (vi) can reduce im.une system response in the lung iby kming white blood cells?

l 77 Please give all reasons and identify all documents or authorities which you rely on in your answer to each part of 76.

Has NRC Staff ever accepted any coal firedwhat If so, planthealth as an effects environmentally of 78.

superior alternative to a nuclear plant?

coal emissions were included in the NEPA: analysis of riternatives th supported that conclusion?

Has NRC Staff estimated health effects of any coal plants larger than 79 r

45 Kuh?

(f, answer to 79 is affirmative, please identify all documents containing 80.

each such estimate made (i) in the year 1978 (ii) in the year 1979 (iii) in the year 1980 (iv) in the year 1981 (v) in the year 1982 (vi) in the year 1983 If. none in any year, please so state.

81. Do the Staff agree that the anount of effluents from a coal plant is prf:portional (at least to a decent appro&.ation) to the amount of coal I it consumes (burns)?

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82. If answer to 81 is other than affir=ative, please state all basis for your msponse

83. Do the Staff agree that the 118,000 metric tons of coal consumed in T^ble S-3 is the ooal consumed by the 45 Ede coal plant referred to in that tab l 84. If answer to 83 is other than affirmative, please state all reasons for your answer.

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-9 INTERROGATO'.IES 0118F2 85 Please state your asessnent of the health effects of the radiological effluents given in Tatle S-3 ,

86. Has NRC Staff given any consideration to any of the reasons (i) thru (iv) of contention 8F2 in preparing for the FES on Harrist 87 If answer to 86 is affirmative, for each such reason (i)(ii)II (iii) or (iv) please state what consideration you have given.

88. Does the Staff nake a separate analyds of the health effects of the effluents listed in Table S-? for radiological enissions (effluents) in the IES? If so where7 89 If not in the DES, does the Staff plan to include an analysis of health effects of effluents listed in Table 3-3 (radiological effluents) in the FEST

90. Ehat consideration to contanination of water supplies as a result of the uranium fuel cycle in the X Uestern US (where water is scarcer) is igiven in the DES for effluents p ological) in Table S-37

91. If answer to 90 is, none, does Staff think such consideration is appropriate in (i) the DES (ii) the FES

92. Did the Staff take into account the arid environ .ents and windier conditions near uranium r:inin: nd milling operations (compared to the Eastern US or US average) in figuring health effects of the Table S-3 radiological effluents?

92 If answer to 92 is not affi:::ative, why not?

94 If no such consideration as incuired about in 92 g above has been given, does Staff believe it is appropriate for FES?

95 Please fully explain all reasons for your answer to 94.

96. Please identify all docu-ents in which .the.13C Staff assesses the health effects of the radiological e .issions in"*' fable S-s3 Please describe or cite fully the methods, models and calculations, if any, used in c.aking such asses pent.

97 Are the nodels used by NP.C St,aff in assessing health effects of radiological enissions given in Table S-s3 the same as used for assessing health effects of nucl e r power plants' radiological enissions?

98. If answer to 97 is other than affirnative, please explain and fully give the reasons for each difference or use of a different nodel.

99. Please state whether Staff has actually nonitored enissions of radio-nuclides fron the nuclear fuel cycle other than at nuclear power plants.

100. Please state what .onitoring data Staff has on e-issions of radio-nuclides fron the nuclear fuel cycle other than from nuclear powcr plants operating.

oeg en faife$$ Yor"a raYo [iksh[ Nicguaa y Enater than

P?.0IXJCTION OF DOC':2NTS Wells Eddlenan requests that all documents containing infornation inquired about above, including those containing monitoring data on nuclear fuel cycle kissions, be identified and produced for inspection and copying by n?.c staff.

This 31 day of August 1983 8 J N<v

' dells Eddlenan

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