ML19257B639
| ML19257B639 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 01/10/1980 |
| From: | Woodhead C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Doherty J DOHERTY, J.F. |
| References | |
| NUDOCS 8001180025 | |
| Download: ML19257B639 (6) | |
Text
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lATORY COMMISSION BEFORE THE ATu,'uC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING & POWER COMPANY
{
Docket No. 50-466
/
(Allens Creek Nuclear Generating
)
Station, Unit 1)
)
NRC STAFF INTERROGATORIES TO INTERVEN0R JOHN DOHERTY The NRC Staff hereby requests the Intervenor John Doherty, pursuant to 10 CFR 52.740b to answer separately and fully in writing and under oath or affirmation the following interrogatories.
Intervenor's response should be set forth in a manner such that each response is identified with the particular contention to which it pertains.
The interrogatories deal with the stipulated contentions of Intervenor Doherty admitted to this proceeding by Board Order November 19, 1979.
Question 1 (a) State the names, addresses and professional qualifications of the persons upon whose views the Intervenor relies to substantiate each contention. State the 1768 016 h
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name of each person who will testify for Intervenor as an expert witness for each contention.
(b) State by author, title, date of publication and publisher all books, texts and papers upon which each person named in the response to interrogatory 1(a) relies to substantiate his or her views.
(c)
Describe all independent calculations, physical and mathematical models upon which each person named in 1(a) or the Intervenor relies to substantiate that person's views.
Contention 10 Question 2 Will your concerns be satisfied after Staff review of NUREG-0660 and requirements for improved diesel generator reliability are completed?
Question 3 Explain the basis for your belief that the procedural errors you reference as basis for this contention will occur at Allens Creek.
Question 4 Explain the reason that you believe diesel generator reliability will not be satisfactorily improved by the time HL&P applies for an operating license.
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- Contention 25 Question 5 Will the resolution of fuel failure detection concerns raised in NUREG-0401 remove the basis of this contention?
Contention 26 Question 6 To what " adequate minimum stand;rds for yield strength" do you refer in 26(a)?
Question 7 Please clarify your meaning in 26(b) by explaining " maximum primary tensile component."
Question 8 What " consideration" of the tensile component do you believe necessary?
Question 9 Please quantify the stresses on each stud bolt that you believe will occur.
State the basis for this belief.
Question 10 Explain why you believe all stud bolts will fail following one failure as stated in26(c).
State the basis for your belief.
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4_
Question 11 Quantify the strain energy that you believe would occur in the reactor head flange during ATWS. State the basis for this belief.
Contention 31 Question 12 What evidence do you have to show that coolant flow vibration will degrade the LPRMs?
Contention 41 Question 13 Do the commitments by Applicant to improve reactor water level indicators in response to the " Lessons Learned" recommendations satisfy your concerns in this contention?
Intervenor's attention is directed to 10 CFR 52.740(e)(1)-(3) which states a duty to supplement certain responses to interrogatories when new or changed infomation is obtained.
Resp ctfully sub d,
Y Colleen P. Woodnead Counsel for NRC Staff Dated at Bethesda, Maryland, this 10th day of January,1980.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t'EFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING & POWER COMPANY Docket No. 50-466 (Allens Creek Nuclear Generating Station, Unit 1)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERR0GATORIES TO INTERVENOR JOHN DOHERTY" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal mail system, this 10th day of January,1980:
. Sheldon J. Wolfe, Esq., Chairman
- Richard Lowerre, Esq.
Atomic Safety and Licensing Board Panel Asst. Attorney General for the U.S. Nuclear Regulatory Commission State of Texas Washington, DC 20555 P.O. Box 12548 Capitol Station Dr. E. Leonard Cheatum Austin, Texas 78711 Route 3, Box 350A Watkinsville, Georgia 30677 Hon. Jerry Sliva, Mayor City of Wallis, Texas 77485 Mr. Gustave A. Linenberger
- Atomic Safety and Licensing Board Panel Hon. John R. Mikeska U.S. Nuclear Regulatory Commission Austin County Judge Washington, DC 20555 P.O. Box 310 Bellville, Texas 77418 R. Gordon Gooch, Esq.
Baker & Botts Mr. John F. Doherty 1701 Pennsylvania Avenue, N.W.
4327 Alconbury Street Washington, DC 20006 Houston, Texas 77021 J. Gregory Copeland, Esq.
Mr. and Mrs. Robert S. Framson Baker & Botts 4822 Waynesboro Drive One Shell Plaza Houston, Texas 77035 Houston, Texas 77002 Mr. F. H. Pottheff, III Jack Newman, Esq.
1814 Pine Village Lowenstein, Reis, Newman & Axelrad Houston, Texas 77080 1025 Connecticut Avenue, N.W.
Washington, DC 20037 D. Marrack 420 Mulberry Lane Carro Hinderstein Bellaire, Texas 77401 8739 Link Terrace Houston, Texas 77025 17~68 020
Texas Public Interest Margaret Bishop Research Group, Inc.
11418 Oak Spring c/o James Scott, Jr., Esq.
Houston, Texas 77043 8302 Albacore Houston, Texas 77074 Glen Van Slyke 1739 Marshall Brenda A. McCorkle Houston, Texas 77098 6140 Darnell Houston, Texas 770/4 J,. Morgan Bishop 11418 Oak Spring Mr. Wayne Rentfro Houston, Texas 77043 P.O. Box 1335 Rosenberg, Texas 77471 Stephen A. Doggett, Esq.
Pollan, Nicholson & Doggett Rosemary N. Lemmer P.O. Box 592 11423 Oak Spring Rosenberg, Texas 77471 Houston, Texas 77043 Bryan L. Baker Charles Andrew Perez
,1118 Montrose 1014 Montrose Blvd.
Houston, Texas 77019 Houston, Texas 77019 Robin Griffith Leotis Johnston 1034 Sally Ann 1407 Scenic Ridge Rosenberg, Texas 77471 Houston, Texas 77043 Elinore P. Cummings Atomic Safety and Licensing
- 926 Horace Mann Appeal Board Rosenberg, Texas 77471 U.S. Nuclear Regulatory Connission Washington, DC 20555 Mrs. Connie Wilson 11427 Oak Spring Atomic Safety and Licensing
- Houston, Texas 77043 Board Panel U.S. Nuclear Regulatory Comission Patricia L. Streilen Washington, DC 20555 Route 2, Box 398-C Richmon, Texas 77469 Docketing and Service Section
- Office of the Secretary Carolina Conn U.S. Nuclear Regulatory Comission 1414 Scenic Ridge Washington, DC 20555 Houston, Texas 77043 Mr. William J. Schuessler Mr. Robert Alexander 5810 Darnell 10925 Briar Forest #1056 Houston, Texas 77074 Houston, TX 77042 7
~-
~ Colleen P. Woodhead Counsel for NRC Staff,
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