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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042B2381982-03-15015 March 1982 Sixth Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20041F0761982-03-10010 March 1982 Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence ML20049J6571982-03-0808 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl ML20041E1181982-03-0505 March 1982 Third Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept Matters.Related Correspondence ML20041E1071982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl ML20041E1001982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20041E0711982-03-0404 March 1982 Second Set of Interrogatories Re Tx Pirg Contention 21 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20041B5421982-02-17017 February 1982 First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl.Related Correspondence ML20010G0731981-08-24024 August 1981 First Set of Interrogatories Directed to NRC Re Contention 21.Certificate of Svc Encl.Related Correspondence ML19343B7071980-12-0505 December 1980 Response to First Set of Interrogatories & Request for Production of Documents from Util on Health Effects of Low Level Radiation.Certificate of Svc Encl.Related Correspondence ML19340C3141980-11-10010 November 1980 Response to W Schuessler Request for Addl Answers to First Set of Interrogatories.Applicant Is Not in Possession of Data Analyzing Hypothetical Significant Offsite Radiological Releases.Certificate of Svc Encl ML19339C0471980-11-0606 November 1980 Response to W Schuessler Second Set of Interrogatories & Requests for Production of Documents.Describes Discussions W/Austin County,Tx Sheriff Dept Re Evacuation Analysis. W/Affidavit,Prof Qualifications & Certificate of Svc ML20008E3971980-10-22022 October 1980 First Set of Interrogatories & Requests for Production of Documents Directed to E Cumings,R Griffith,L Johnston & R Lemmer Re Consolidated Contention on Effects of low-level Radiation.W/Certificate of Svc.Related Correspondence ML20062J4311980-10-20020 October 1980 Informal Request for Addl Responses to First Set of Interrogatories & Requests for Production of Documents,In Lieu of Motion to Compel.Includes Second Set of Interrogatories Directed to Util.Related Correspondence ML19347C1851980-10-14014 October 1980 Amended Response to First Set of Interrogatories.Info Includes Identity of Individuals Directing Site Selection. Certificate of Svc Encl.Related Correspondence ML19332B1801980-09-24024 September 1980 Response to Intervenor Schuessler First Set of Interrogatories & Requests for Production of Documents. Requested Documents & Certificate of Svc Encl ML19347A6951980-09-22022 September 1980 Response to Fh Potthoff Third Set of Interrogatories.Objects to All Questions Due to Irrelevancy.Affidavits & Certificate of Svc Encl.Related Correspondence ML19332A8501980-09-0909 September 1980 Further Response to Tx Pirg 16th Interrogatories.Discusses Future Prices of Gas,Nuclear & Coal Energy,Personnel Qualifications,Control Room Design,Safety Relief Valve Setpoints & Hydrogen Explosion.Certificate of Svc Encl ML19351D1451980-09-0505 September 1980 First Set of Interrogatories & Request for Production of Documents Soliciting Info Re Results of Accident at Site, Emergency Plan & Demographics.Certificate of Svc Encl. Related Correspondence ML19344D8731980-08-18018 August 1980 Response to Potthoff Second Set of Interrogatories. Percentage of Electric Generation by Natural Gas Will Be 68% & 21% by 1985 & 1990,respectively.Objects to Remaining Interrogatories.Certificate of Svc Encl ML19327A5091980-08-0101 August 1980 Second Set of Interrogatories Directed to Applicant. Questions Feasibility of Marine Biomass Farm as Alternative to Facility.Certificate of Svc Encl ML19327A5021980-08-0101 August 1980 Response to Applicant First Set of Interrogatories. Intervenor Has No Intention to Call Expert Witnesses at Present Time ML19327A2261980-07-28028 July 1980 Response to Financial Qualifications Intervenors Fourth Set of Interrogatories.Discusses Program Improvements Made as Result of South Tx Project Incidents,Prefiling Package & H Dean Testimony.Affidavit & Certificate of Svc Encl ML19330B2061980-07-25025 July 1980 Response to Jm & M Bishop 800705 Interrogatories & Requests for Production of Documents.Identifies Witnesses & Summarizes Substance of Testimony.Certificate of Svc & Prof Qualifications Encl.Related Correspondence ML19321B2591980-07-25025 July 1980 Response to 800709 Interrogatories & Request for Production of Documents.Includes Info Re Natural Gas Alternative, Conservation & Interconnect,Error in Computer Program & Technical Qualifications.Certificate of Svc Encl ML19321B2641980-07-25025 July 1980 Response to 800706 Interrogatories & Requests for Production of Documents.Includes Info Re Movement of Brazos River Toward Proposed Pipeline Route & Max Peak Overpressure for Each Critical Structure.Certificate of Svc Encl ML19330A7151980-07-23023 July 1980 Response to Potthoff First Set of Interrogatories.Objects to Majority of Interrogatories on Basis of Irrelevancy. Applicant Has Not Commissioned Study on Marine Bio Farm Feasibility to Provide Synthetic Gas.W/Certificate of Svc ML19330C5521980-07-0909 July 1980 Response to First Set of Interrogatories.Lists Documents Relied Upon in Study of Effect of Power Transmission Lines on Migratory Waterfowl & Identifies Experts.Affidavit, Resume & Certificate of Svc Encl.Related Correspondence ML19320C3151980-07-0909 July 1980 Response to Intervenor D Marrack 800508 Interrogatories. Identifies Expert Witnesses Expected to Be Called in Support of Consolidated Rentfro Contention 2.Affidavit & Certificate of Svc Encl ML19320C5611980-07-0909 July 1980 Interrogatories & Request for Production of Documents Directed to Nrc.Requests Factual Basis of Anticipated Testimony Re Natural Gas Use as Fuel & Subsequent Costs of Electricity.W/Certification of Svc.Related Correspondence ML19320C9271980-07-0909 July 1980 First Set of Interrogatories Directed to Houston Lighting & Power.Requests Factual Info Re U Fuel Sources,Costs,Method of Mining & Stripping,Site & Extent of Mining & Feasibility of Marine Biofarm for Synthetic Natural Gas Supply ML19320C2691980-07-0808 July 1980 Response to Applicant Second Set of Interrogatories & Request for Production of Documents Re Intervenor Pleadings Before ASLB & Aslab.Certificate of Svc Encl ML19330A3501980-07-0808 July 1980 First Set of Interrogatories Directed to NRC Re Financial Qualifications,Hearing Expectation & Witnesses Intended to Be Called ML19330A3421980-07-0808 July 1980 Fourth Set of Interrogatories Directed to Util Re Financial Qualifications.Includes Questions on Disciplinary Actions & Role of Houston Industries.Related Correspondence ML19320C2651980-07-0808 July 1980 Response to Applicant First Set of Interrogatories & Request for Production of Documents Re Impact of Transmission Lines & Fes ML19320C2701980-07-0808 July 1980 Response to D Marrack First Set of Interrogatories.Includes Statements Re Transmission Lines & Alternative Transmission Sites & Routes.Prospective Witness Fj Schlight Prof Qualifications,Affidavit & Certificate of Svc Encl ML19330B2091980-07-0606 July 1980 Interrogatories & Request for Documents Directed to Util. Requests Most Recent Population Projection Data & Methodology Used for Updating Projection.Related Correspondence 1982-06-15
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20063N7591982-10-0606 October 1982 Withdrawal of Application for CP ML20055A7221982-07-15015 July 1982 Memorandum & Order Denying Jf Doherty 820615 Submittals, Treated as Motion to Reconsider ASLB 820602 Order.Motion Untimely Filed & Failed to Show Significance or Gravity of Issues ML20055A3551982-07-12012 July 1982 Amended Contention 59.Certificate of Svc Encl ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20052D1221982-04-29029 April 1982 Findings of Fact on Supplemental Issues to Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20052A4541982-04-22022 April 1982 Submittal of Contention 58 Re Applicant Conduct on Reporting Violations at Plant.Certificate of Svc Encl ML20054E0561982-04-21021 April 1982 Supplemental Findings of Fact on Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20049K0671982-03-25025 March 1982 Reply to Tx Pirg 820315 Addl Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20042B2451982-03-15015 March 1982 Motion for Subpoena of Quadrex Corp Employees.Testimony Necessary for Clear Understanding of Brown & Root Deficiencies Despite Util Supervision & Specific Steps Needed to Correct & Prevent Problems.W/Certificate of Svc ML20042B2381982-03-15015 March 1982 Sixth Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20041F0761982-03-10010 March 1982 Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence ML20041F0871982-03-10010 March 1982 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Addl Time Needed to Complete Discovery.Certificate of Svc Encl ML20049J6571982-03-0808 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl ML20041E1741982-03-0505 March 1982 Brief Opposing R Alexander Appeal from ASLB 820112 Order Denying Petition to Intervene.Aslb Did Not Abuse Discretion in Denying Petition.Certificate of Svc Encl ML20041E1201982-03-0505 March 1982 Motion for Order Directing Applicant to Provide Forthcoming Bechtel Quadrex Rept Review.Rept Pertinent to Remaining Issue.Certificate of Svc Encl.Related Correspondence ML20041E1181982-03-0505 March 1982 Third Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept Matters.Related Correspondence ML20041E1071982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl ML20041E1001982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20041E0711982-03-0404 March 1982 Second Set of Interrogatories Re Tx Pirg Contention 21 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20049H8881982-03-0101 March 1982 Response Opposing D Marrack 820213 Motion for Review of Dates for Reopening Hearings & Continuance.No Commission Regulations or Atomic Energy Act Provisions Require Applicant Irrevocable Commitment.Certificate of Svc Encl ML20041B5381982-02-22022 February 1982 Reply to Intervenors Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20041C0671982-02-22022 February 1982 Response Opposing Tx Pirg 820209 Motion for Addl Time to File Proposed Findings of Fact & Conclusion of Law.Motion Mooted by Tx Pirg Filing Proposed Findings on 820212. Certificate of Svc Encl ML20041B5421982-02-17017 February 1982 First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl.Related Correspondence 1982-07-02
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of S S # 4 HOUSTON LIGHTING & POWER S COMPANY S DOCKET NO. 50-466 M yS S 2 %(fc. ,
(Allens Creek Nuclear S OF '
,Ds q
Generating Station, Unit S ~. -
No. 1) S e APPLICANT' S RESPONSE TO JOHN F. DOHE RTY ' S 6
Rh(' $) S.
d 7
EIGHTH SET OF INTERROGATORIES y In response to the interrogatories propounded by John F. Doherty, Houston Lighting & Power Company
( Applicant) answers as follows:
INTERROGATORY NO. 8-2:
Will Applicant's control room be equipped with a data recorder such as the one described in the Kemeny Commission report in its findings on pg. 30 as finding #9, and called a reactimeter?
(a) Has applicant considered such a device as part of its control room?
(b) What objections would there be to a permanently installed reactimeter?
RESPONSE : (a) No (b) The ACNGS control room design includes the use of recorders which not only record important para-meters for post accident analysis but give the operator useful real-time information as well.
Additional duplication of this recording capa-bility with a reactimeter device is unnecessary.
1701 327 8 *108o 0 1
INTERROGATORY NO. 8-3:
Cite the three most recent documents which show that irradiation increases cladding strength as stated on pg. 4.2-14a, and make these documents available to this Intervenor, please.
(That is, documents in your possession) .
RESPONSE: This data is discussed in Licensing Topical Report NEDE 24011, "GE BWR Generic Reload Fuel Applications" dated July, 1979.
INTERROGATORY NO. 8-4:
Cite the three most recent documents in your possession which show the design fission gas release model employed in the determination of fuel rod plenum size and clad wall thickness has been shown to over predict available data on fission gas release when applied with a pellet-clad thermal conductance value of 1,000 btu /hr-f t2 and make these documents available to this Intervenor. (Note: see pg. 4.2-14b of PSAR on this item).
RESPONSE: NEDE 20944 - BWR 4, 5 Fuel Design, October, 1976 (Applicant only has Amendment 1)
NEDE 20948-lP - BWR 6 Fuel Design, December, 1975*
(Proprietary document)
NEDO 10505 - Experience with BWR Fuel Through 1971, May, 1972.
INTERROGATORY NO. 8-5:
When does Applicant expect to have fuel rods operating at linear heat generation rate of approximately 21 kw/ft, other than abnormal occurences? (Sec 4.2-14b PSAR) .
RESPONSE: Applicant does not expect to operate with a linear heat generation rate of 21 kw/ft.
INTERROGATORY NO. 8-6:
Has applicant any data other than NEDO 10329 for giving the distributien of fuel rod internal pressures used in LOCA rod perforction calculations during LOCA? (See PSAR 4. 2-14 f) .
- / This docunent is now available for inspection under previously agreed uptn procedures for proprietary documents, Note that this rer,ponse changes the response given to Doherty's seventh requesj. for documents, item number 14.
1701 328
RESPONSE : Yes, a discussion on fuel rod internal pressure during a LOCA can be found in NEDO 20566 "GE Analytical Model for LOCA in Accordance with 10 CFR Appendix K,"
January, 1976.
INTERROGATORY NO. 8-7:
What is accomplished having the LPCS initiated by drywell high pressure of reactor vessel low water signal for a LOCA? (See PSAR 6. 3-21)
RESPONSE: Reactor vessel low water level and drywell high pressure signals indicate that there is a possible break in the Reactor Coolant Pressure Boundary (a LOCA) ; hence, the LPCS is initiated to provide cooling water. (There is no page 6.3-21 in the ACNGS PSAR.)
INTERROGATORY NO. 8-8:
Which valves in ACNGS will be provided by Anchor-Darling Valve Co.?
RESPONSE: BOP NSSS Non ASME Section III 2 1/2" and larger
- 1) 900/1500 Class Gate Valves 1) 900 class 22" gate
- 2) 900 and 1500 Class Swing Check 2) 900 class 24" gate Valves 3) 150 class 16" gate
- 3) 150, 300, and 400 Class non-slam 4) 900 class 12" gate Check Valves 5) 900 class 10" globe
- 4) 600 Class non-slam Check Valves 6) 900 class 4" gate
- 7) 150 class 24" gate
- 8) 900 class 12" globe ASME Section III 2 1/2" and larger
- 1) 600 Class Gate Valves
- 2) 900 Class Gate Valves
- 3) 150 and 300 Class Globe Valves
- 4) 600 Class Globe Valves
- 5) 900 Class Globe Valves
- 6) 900 Class Swing Check Valves
- 7) Non-slam Check Valves
- 8) Testable Check Valves INTERROGATORY NO. 8-9 (a) :
What is the name of the manufacturer of the recircula-tion pumps of ACNGS?
RESPONSE: Byron Jackson Pump Division Borg Warner Corporation INTERROGATORY NO. 8-9 (b) :
2 What is moment of inertia in lbs/ft of applicant's recirculation pumps?
RESPONSE: 800 lb/ft2 1701.329 INTERROGATORY NO. 8-10:
Is one of Applicant's suppliers of componenes or supplies the Target-Rock Corporation or a corporation, company, etc., that uses " Target Rock" as a tradename, symbol or mark?
(a) If so, indicate what this supplier makes, and where these devides components or supplies will be used in ACNGS, please.
RESPONSE : Target Rock valves have not been purchased or specified to date.
(a) N/A INTERROGATORY NO. 8-11:
Are any check valves to be supplied by Velan Engineer-ing Corp.?
RESPONSE : Velan Engineering valves have not been purchased or specified to date.
INTERROGATORY NO. 8-12:
Is there any piping section in the reactor coolant system where the length of the pipe is 100 times larger than the pipe radius and the pipe is of stainless steel? .
RESPONSE : No INTERROGATORY NO. 8-13:
Is there any piping section in the reactor coolant system where the length of the pipe is 50 times larger than the pipe radius and the pipe is of stainless steel?
RESPONSE : No INTERROGATORY NO. 8-14:
Is there any stainless steel piping in ACNGS where the length of the pipe is 100 times greater than the pipe radius?
(a) Same wording as 8-14, but 200 times greater?
(b) Same wording as 8-14, but 50 times greater?
RESPONSE : Yes 1701 330
s -
(a) Yes (b) Yes INTERROGATORY NO. 8-15:
In the analysis of axial (longitudinal) of the ACNGS steel containment standing shell, is the stress presumed to not vary greatly over a distance equal to about half a buckle wave length? If so, why?
RESPONSE: Yes, the stress is presumed to not vary greatly over a distance equal to half a buckle wave length. For the ACNGS buckling evaluation the caximum stress in a panel (portions of the steel containment shell usually between stif feners) is assumed uniform over the area. This assumption is more conservative than using a varying stress distribution.
INTERROGATORY NO. 8-16:
How has applicant determined loads on its steel con-tainment shell?
(a) Has it used any of the following codes: NASTRAN, Marc, SAP 6, or ANSYS?
(b) If it uses any other code, please name it here.
(c) Regardless cf code use, please indicate'if a
" linear" bifurcation analysis has been used or is planned it. the future.
RESPONSE: The loads on the containment are discussed in Containment Structures Design Report , Rev. 2, provided to Intervenor previously.
(a) ANSYS is used to determine the overall steel containment responses to dynamic loadings.
NASTRAN is used to compute the behavior of elastic structures under a wide range of loading conditions.
(b) The programs used for the detailed analysis of the containment shell arc labeled E1374, E1779, E1775, E781, and E775. They are Chicago Bridge and Iron programs.
1701 33l
s -
(c) A linear bifurcation analysis has not been performed for ACNGS Steel containment nor is one planned.
INTERROGATORY NO. 8-17:
On page 5.5-4 of the PSAR, it states that the pump impeller is designed for as long a " life" as is practical.
Applicant has stated in a previous interrogatory, "there is no regular inspection planned for the recirculation pump im-pellers", (pg. 2 of Applicant's answer to J. D. Interog. 7-2) .
Does Applicant have any data on the longevity of pump impellers in these pumps with the particular requirements planned for them?
(a) If so, please identify and make available such information?
(b) How frequently will the recirculation pumps be inspected?
RESPONSE : (a) The type of recirculation pump to be utilized at ACNGS has been in use for approximately 10 years and no impeller replacement has been needed.
(b) There is no required or planned inspection of the pump impellers. Pump casings are subjected to In-service Inspection every 10 years.
All documents requested which are in Applicant's possession will be made available at the Engineering Development Complex. No expert witnesses have been identified to date.
Respectfully submitted, 7S OF COUNSEL: J. Gregory Copeland V C. Thomas Biddle, Jr.
BAKER & BOTTS Charles G. Thrash, Jr.
3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W. 1025 Connecticut Ave., N.W.
Washington, D. C. 20036 Washington, D. C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY 1701 332
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S
HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 5
(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Applicant's Response to John F. Doherty's Eighth Set of Interrogatories to Houston Lighting & Power Company in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 27th day of December, 1979.
Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel for the State of Texas U.S. Nuclear Regulatory Commission P. O. Box 1254F Washington, D. C. 20555 . Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. Charles J. Dusek Watkinsville, Georgia 30577 Mayor, City of Wallis P. O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 Atomic Safety and Licensing Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission County Judge, Austin County Washington, D. C. 20555 P. O. Box 99 Bellville, Texas 77418 Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of the Appeal Board Commission U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 R. Gordon Gooch, Esq. Atomic Safety and Licensing Baker & Botts Board Panel 1701 Pennsylvania Avenue, N. W. U.S. Nuclear Regulatory Washington, D. C. 20006 Commission Washington, D. C. 20555 1701 333
Steve Schinki, Esq. Dorothy F. Carrick Staff Counsel Box 409, Wagon Rd. Rfd. #1 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D. C. 20555 Carolina Conn John F. Doherty 1414 Scenic Ridge 4327 Alconbury Street Houston, Texas 77043 Houston, Texas 77021 Elinore P. Cumings Robert S. Framson Route 1, Box 138V Madeline Bass Framson Rosenberg, Texas 77471 4822 Waynesboro Houston, Texas 77035 Stephen A. Doggett, Esq.
P. O. Box 592 Carro Hinderstein Rosenberg, Texas 77471 8739 Link Terrace Houston, Texas 77025 Robin Griffith 1034 Sally Ann D. Marrack Rosenberg, Texas 77471 420 Mulberry Lane Bellaire, Texas 77401 Leotis Johnston 1407 Scenic Ridge Brenda McCorkle Houston, Texas 77043 6140 Darnell Houston, Texas 77074 Rosemary N. Lemmer 11423 Oak Spring F. H. Potthoff, III Houston, Texas' 7704 3 7200 Shady Villa, #110 Houston, Texas 77055 Kathryn Otto Route 2, Box 61L Wayne E. Rentfro Richmond, Texas 77469 P. O. Box 1335 Rosenberg, Texas 77471 Frances Pavlovic 111 Datonia James M. Scott Bellaire, Texas 77401 8302 Albacore Houston, Texas 77074 Charles Perez 1014 Montrose Bryan L. Baker Houston, Texas 77019 1118 Montrose Houston, Texas 77019 William Schuessler 5810 Darnell J. Morgan Bishop Houston, Texas 77074 11418 Oak Spring Houston, Texas 77043 Patricia L. Strelein Route 2, Box 395C Richmond, Texas 1701 334
Glen Van Slyke 1739 Marshall Houston, Texas 77098 Donald D. Weaver P.O. Drawer V Simonton, Texas 77476 Connie Wilson 11427 Oak Spring Houston, Texas 77043 0 1 k m n (hn d w %
C. Thomas Biddle, Jr. y' 170) 335 STATE OF TEXAS COUNTY OF HARRIS BEFORE ME, the undersigned authority, on this day personally appeared, who upon his oath stated that he answered the foregoing Houston Lighting & Power Company's Response to John F. Doherty's Eighth Set of Interrogatories to Houston Lighting & Power Company in his capacity as Supervising Engineer for Houston Lighting & Powc- Company, ard all state-ments contained therein are true and correct to the best of his knowledge and belief.
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, .u , L ,i.a-Jon G. White SUBSCRIBED AND SWORil TO BEFORE ME by the said Jon G. White, on this 27th day of December,1979. .
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tiotary Public in and for Harris County, Texas My commission expires:
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1701.336