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Responses to Second Set of Interrogatories on Contention Ivc.Certificate of Svc Encl
ML20071N946
Person / Time
Site: Harris Duke energy icon.png
Issue date: 06/02/1983
From: Oneill J
CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To: Wilson R
WILSON, R.
References
Download: ML20071N946 (12)


Text

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'83 Jbn -5 p; ;33 UNITED' STATES OF AMERICA NUCLEAR REGULA2'7Y COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN MUNCIPAL ) Docket Nos. 50-400 OL POWER AGENCY ) 50-401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 & 2) )

APPLICANTS' RESPONSES TO RICHARD WILSON'S INTERROGATORIES ON CONTENTION IVC (SECOND SET)

Applicants Carolina Power & Light Company and North Carolina Eastern Muncipal Power Agency, pursuant to 10 C.F.R.

Section 2.740b, hereby submit the following responses to

" Richard Wilson Interrogatories To Applicant (Second Set)."

The provision of answers to these interrogatories is not to be deemed a representation that Applicants' consider the informa-tion sought to be relevant to the issues to be heard in this proceeding.

ANSWER TO GENERAL INTERROGATORY AND RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS GENERAL INTERROGATORY. For each of the answers you provide to the following interrogatories please give in footnote form each document (including all relevant page citations) you used in formulating the answers and you would use in refuting the contention during this proceeding. Please use the definition of document which you offered on page 3 of your January 31 interrogatories to me. Please produce all B306070291 830602 PDR ADOCK 05000400 0 PDR

  • l documents mentioned and permit copying'and inspection by me or my agent. Please state the name, title, and employer of each person who contributes to the answers. Please identify explicitly any models or assumptions used in your answers.

Please include all calculations in their entirety. Please 1 footnote every fact in every answer. '

RESPONSE: All such facts, documents, models and assump-tions relied upon are indicated within each response to the specific interrogatories on Contention IVC. Ronald L. Shes.rin; Project Specialist - Environmental; Carolina Power & Light Company, prepared Applicants' responses to the specific interrogatories on Contention IVC. Other persons who contribu-ted to each response are also identified within each response to the specific interrogatories on Contention IVC.

The requested documents will be made available at the Harris Energy & Environmental Center, Route 1, New Hill, North Carolina 27562. The documents will be made available during Carolina Power & Light Company business hours (or such other mutually agreeable time). Appointments to inspect the docu-ments 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.

Wilson, for a reasonable time (i.e., through July 1, 1983),

after which they will be returned to their place of origin.

Inspected documents which Mr. Wilson wishes to have copied will be reproduced by Carolina Power & Light Company on a schedule compatible with other demands for duplicating

l equipment. A Carolina Power & Light Company employee will be available during the inspection in order to receive any requests for copying. Copies of such selected documents will then be furnished to Mr. Wilson upon payment of 7 cents per page, to meet Carolina Power & Light Company's cost of repro-duction.

ANSWERS TO INTERROGATORIES ON CONTENTION IVC INTERROGATORY NO. IVC-1. With respect to the L.L.D.

equation given in table 4.12-1 of NUREG 0472 please answer the following questions.

(1). Why are 95% and 5% selected as the error levels?

ANSWER NO. IVC-1(1). 95% and 5% are the normally accepted standards used in sampling procedures. Any errors that may be introduced into the total dose assessment program using these confidence levels are insignificant when compared to the variance introduced by natural background and other sources of public radiation exposure.

(2). This form of the equation suggests that 6 sample =6 blank =6. Is this reasonable to assume at this preliminary stage?

ANSWER NO. IVC-1(2). Yes. The Lower Limit of Detection is a determination of that point at which the analytical system can distinguish sample activity from background activity. At this interface CT sample = d- blank (background).

Therefore, the magnitude of background activity is a major factor governing the system's ability to detect non-background activity. It must be remembered that, because the L.L.D. is a

given requirement, if background is high, Applicants will be required to compensate by taking larger samples, increasing efficiency or improving chemical yield in order to meet the sensitivity specified in table 4.12-1 of NUREG-0472.

(3). Since the L.L.D. is an a priori limit, how are observed. concentrations estimated, i.e. by confidence intervals or determination limits?

ANSWER IVC-1(3) . By confidence intervals. ,

CONTENTION IVC-2. With respect to the Sb form in the L.L.D. equation given in table 4.12-1 of NUREG-0472 please answer the following questions.

(1). Since Sb is an estimated quantity, what are the details of estimation procedure'?

ANSWER IVC-2 (1) . Sb is not an " estimated quantity." Sb is measured prior to the analysis of each environmental sample.

It is calculated by making a count without an active sample in the counter.

Sb is the square root of the total count divided by the time over which the background is counted.

(2). Is the theoretical variance that you refer to usually of smaller or larger magnitude than the Sb terms?

ANSWER IVC-2(2). Since an Sb calculation is made at the time of each analysis, theoretical variability plays no part in the calculation for the analysis. Performing a background count prior to each sample count neutralizes the effect of weather, seasonable or temporal variability.

(3). Is there any documentation describing how the mean and variance of Sb vary with weather, season or time of day?

ANSWER NO. IVC-2(3). No. The raw data have not been summarized in-this format.

(4). Please. illustrate a particular sampling pathway in detail, examining the precise method of control measurement, the systematic nature of sampling times, and the effects of inclement weather, etc. on the collection process.

ANSWER NO. IVC-2(4). See attached chart.

This chart was prepared by Don H. Edwards, Jr.; Senior Specialist - Environmental; Carolina Power & Light.

INTERROGATORY IVC-3. With respect to the cross-check validation analysis of 6.1.5.5 of the Environmental Report please answer the following questions.

(1). Select a particular example and describe the cross-check process in enough detail to identify how the "mean result of a cross-check analysis" is calculated.

ANSWER IVC-3(1). Example: Environmental Radioactivity Laboratory Intercomparison Study.

Applicants participate in the EPA Environmental Radioactivity Laboratory Intercomparison St'udy and plan to continue to rely predominately on this study in the future.

This program is described in EPA-600/4-81-OO4. (February 1981).

1. A special sample (i.e. liquid for drinking water, filters for air, etc.) is received from EPA.
2. EPA supplies instructions for any special pretreatment required to split the sample into three aliquots.

I

3. Analyses are performed on each aliquot separately.
4. These analyses are returned to the EPA within the specified date for this study.
5. The laboratory supervisor receives the textbook answers from EPA. He compares his results at that time.
6. If he is not satisfied with the comparison, he initiates an investigation to determine the possible cause of the discrepancy.
7. EPA will provide a report showing where Applicants' laboratory stands relative to other participating laboratories.

Notc: The "mean" result of the cross check analysis is calculated-by EPA by averaging the three analyses provided them.

This analysis was prepared, in part, by Dr. Daniel F.

Cahill; Senior Specialist - Environmental Laboratory; Carolina Power & Light Company.

(2). What is the expected delay between error discovery i and correction action?

ANSWER IVC-3(2). The length of delay is totally dependent 4

on the type of error that is determined to have occurred. The delay is minimized as much as possible.

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-- - ~ _ -

Discrepancies occur infrequently. .One possible cause of those discrepancies that do occur is defective counting standards. These counting standards are re-ordered immediately and replaced as soon as possible.

(3). Does this expected delay depend upon the size and type of error?

ANSWER IVC-3(3). No. The extent of delay is dependent only upon the time required to take the necessary corrective action.

J John H. O'Neill, Jr.

Pamela H. Anderson Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1400 Richard E. Jones Samantha Fran'cis Flynn Carolina Power & Light Company P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Counsel for Applicants Dated: June 2, 1983

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

                                       )

CAROLINA POWER a LIGHT COMPANY ) Occket Hos. 50-400 OL AND NORTH CAROLINA EASTERN ) 60-401 OL MUNICIPAL POWER AGENCY .)

                                       )

(Shearon Harris Nuclear Power ) Plant, Units 1 and 2) ) AFFIDAVIT OF 5. H. WEBSTEP. 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 IVC contained in " Applicants' Responses to Richard Wilson's Interrogatories on Contention IVC (Second Set)" are trud 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.

b. $ B.~H. [ Webster Sworn to and subscribed before me this a.d day of h ,,1983.

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

                                                  )

CAROLINA POWER & LIGHT COMPANY ) AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL

                                                  )

(Shearon Harris Nuclear Power ) Plant, Units 1 and 2) ) CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Responses To Richard Wilson's Interrogatories On Contention IVC (Second Set)" and." Affidavit Of B. H. Webster" were served this 2nd day of June, 1983, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List. i r Aux Pamela H. Anderson

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

                                                                           )                                                                                  ~i CAROLINA POWER & LIGHT COMPANY                               )        Docket Nos. 50-400_OL                                                   "

i AND NORTH CAROLINA EASTERN ) 50-401 OL l MUNICIPAL POWER AGENCY ) .,

                                                                           )                                             .

(Shearon Harris Nuclear Power ) Plant, Units 1 and 2) ) - SERVICE LIST JaTes L. Felley, Esglire John D. Runkle, Esquire Atmic Safety and Licensing Board Conservation Council of Nm3 Carolina U.S. Nuclear Regulatory Cr -iasian 307 Granville Road Washington, D.C. 20555 @=% Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Lice.nsing Board Edaletein arxi Payne U.S. Nuclear. Regulatory Ccmnissi'1n P.O. Box 12643 Washington, D.C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter ' Dr. ' Richard D. Wilson Atcznic Safety and Licensing Bcard 729 Hunter Street U.S. Nw'laar Regulatory remi=sion Apex, North Carolina 27502 Washington, D.C. 20555 Mr. Wells Sidlenan Chailes A. Barth, Esquire 718-A Ir M a11 S' m Durhan, North Carolina 27705

 .              Myron Ka: man, Esqui.re Office of Executive legal Director U.S. Nuclear Regulatory rer,m4 =sica                        Ms. Patricia T. Neman Washington, D.C. 20555                                      Mr. Sla*ar E. Newan Citizens Against Nuclear Pc7aer                                                    ,

Docketing and Service Section 2309 Weynouth Court Office of the Secretary Raleigh, North Carolina 27612 U.S. Nuclear Regulatory Ccmnission Richard E. Jones, Esquire Washington, D.C. 20555 Vice President & Senior Counsel Mr. Daniel F. Read, President Carolina Power & Light Canpany Chapel Hill Anti-Nuclear Group Effort P.O. Box 1551 Raleigh, North Carolina 27602 P.O. Box 524 Chapel Hill, North Carclina 27514 Dr. Phyllis Ictchin 108 Bridle Run' Chapel Hill, North Carolina 27514

         , - . , -                ,   ,---.,n   ..,-.--,---,-n-.              , - .  . - - , - - . - - - - - - - - - _ ,               .~,-. - --. .- , ..-

Deborah Greenblatt, Esquire 1634 Crest Road Paleigh, North Carolina 27606 1 Bradley W. Jones, Esquire U.S. Nuclear Regulatory Ccmnission Region II , , 101 Marrietta Street Atla:Pa, Georgia 30303 Rutbalnne G.. Miller, Esquira

  • Atcznic Safety and I? wing Board Panel .

U.S. Nuclear Regulatory.Cmm4=sicn - Wa=hirsten, D.C. 20555 , Karen E. Long, Esq.

  • Staff Atto 'ney Public Staff - NCUC -

P.O. Box 991 Raleigh, North Ca'rolina 27dO2. O O h ee g, e# 9 4

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