ML19305D333

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Answers to Intervenor Jf Doherty Second Request for Admissions.Includes Questions Re Authenticity of Certain Documents & Info Concerning GE Diesel Generators.Certificate of Svc Encl
ML19305D333
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 03/07/1980
From: Biddle C
BAKER & BOTTS, HOUSTON LIGHTING & POWER CO.
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8004140415
Download: ML19305D333 (9)
v • d • e


Text

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1

In the Matter of S S

HOUSTON LIGHTING & POWER S COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear S Generating Station, Unit S No. 1)

HOUSTON LIGHTING & POWER COMPANY'S RESPONSE TO JOHN F. DOHERTY'S SECOND REQUEST FOR ADMISSIONS Houston Lighting & Power Company (Applicant)  !

provides herewith its answers to John F. Doherty's Second Request for Admissions. These answers are provided without waiver of objections to the relevance of these requests for admission under Rule 26 of the Federal Rules of Civil Pro .

cedure and 10 C.F.R. S 2.740. ,

Contention No. 8:

1. Applicant cannot attest to either the genuineness or authenticity of the attached document excerpt since the base document was not prepared in whole or in part by Applicant. Therefore, Applicant neither admits nor denies that the enclosed document is as repre-sented. ,

8004140 jfy]f

Contention No. 10:

1. Applicant denies that a warmup time is required before the HPCS diesel generator unit designed for ACNGS is capable of powering the requisite parts of the HPCS system.
2. Applicant cannot attest to either the genuineness or authenticity of the attached document excerpt since the base document was not prepared in whole or in part by Applicant. Therefore, Applicant neither admits or denies that the enclosed document is as repre-sented.
3. Applicant cannot attest to either the genuineness or authenticity of the attached document excerpt since the base document was not prepared in whole or in part by Applicant. Therefore, Applicant neither ,

admits nor denies that the enclosed document is as repre-sented.

4. Applicant denies that General Electric diesel generators have the lowest percent of test failures of all commercially-available generators of a size usable in the HPCS application. ,
5. Applicant denies that the ACNGS HPCS diesel ,

l generators will be subject to the problem referenced.

6. Applicant cannot attest to either the genuineness or authenticity of the attached document excerpt since the base document was not prepared in whole I

or in part by Applicant. Therefore, Applicant neither admits nor denies that the enclosed document is as repre-sented.

7. Applicant denies that its use of "relatively" in the referenced interrogatory answer means any of the listed choices.

Contention No. 13: ,

8. Applicant has not examined each and every study of the type referenced, and therefore cannot admit or deny that insulation is not predicted in any study to remain entirely on a pipe that severs during a large pipe LOCA.
9. - 15. These statements are all vague references to hypothetical possibilies calling for abstract speculation.

None calls for the admission of the truth of a particular

" relevant matter of fact." 10 C.F.R. S 2.742. Since -

these statements address conclusory hypotheticals and not F

relevant facts, Applicant is not required to, and cannot admit or deny that the general possibilities recited are true and correct.

Contention No. 14:

16. Applicant denies that the ACNGS MSLRM system '

cannot detect gross fuel failure in less than a minute.

17. Applicant is not knowledgeable of every 4

conclusion reached by the NRC and therefore can neither admit nor deny that the NRC has never concluded 'that the MSLRM systems by General Electric will reliably detect gross fuel failure in less than one minute.

18. Applicant denies that " gross" in its answer to the referenced interrogatory means any of the listed choices.
19. Applicant cannot attest to either the genuineness or authenticity of the attached document excerpt since the base document was not prepared in whole l or in part by Applicant. Therefore, Applicant neither admits nor denies that the enclosed document is as repre-sented.

Contention No. 17:

20. Applicant denies that the current planned safety relief valve logic for ACNGS has been identified by the NRC as a hazard for any reason.
21. Applicant cannot attest to either the genuineness or authenticity or the attached document .

excerpt since the base document was not prepared in whole r or in part by Applicant. Therefore, Applicant neither i

admits nor denies that the enclosed document is as repre-sented.

7

22. Applicant denies that all 900 class valves in the ACNGS will be provided by Anchor Darling Valve Co.
23. Applicant admits that all 900 class valves in the ACNGS NSSE will be provided by Anchor Darling Valve Co.
24. Applicant admits that all gate valves in the NSSS will be provided by Anchor Darling Valve Co.
25. Applicant denies that the scram reliability for ACNGS as currently planned is less than 2 X 10-1/4 l per reactor year. t Respectfully submitted, OF COUNSEL:

C A u s bri & h.

J. Gregory Copeland C. Thomas Biddle, Jr.

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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

Washington, D.C. 20036 Washington, D.C.  ;

ATTORNEYS FOR APPLICANT.

HOUSTON LIGHTING & POWER COMPANY

i f

STATE OF TEXAS S  ;

5 ,

COUNTY OF HARRIS S ,

BEFORE ME, the undersigned authority, on this day personally appeared L. R. Jacobi, who upon his oath stated [

J that he has answered the foregoing Houston Lighting & Power Company's Response to John F. Doherty's Second Request for  :

Admissions in his capacity as Supervising Engineer.  !

J 9 . .

L. R. J bi i

SUBSCRIBED AND SWORN TO BEFORE ME on this the day of March, 1980.

i Y  ! -

  • NOTAKY PUBLIC IN AND FOR

' HARRIS COUNTY, TEXAS I b L

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6-1 f

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 S

(Allens Creek Nuclear Generating S Station, Unit No. 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Houston Lighting & Power Company's Response to John F. ,

Doherty's Second Request for Admissions in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 7fts day of March, 1980.

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 12548 Washington, D. C. 20555 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. Charles J. Dusek Watkinsville, Georgia 30677 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 Washingcon, D. C. 20555 1

4 Steve Schinki, Esq. Carolina Conn Staff Counsel 1414 Scenic Ridge U.S. Nuclear Regulatory Commission Houston, Texas 77043 Washington, D. C. 20555 Elinore P. Cumings John F. Doherty Route 1, Box 138V  ;

4327 Alconbury Street Rosenberg, Texas 77471  ;

Houston, Texas 77021 Stephen A. Doggett, Esq.

Robert S. Framson P. O. Box 592 i Madeline Bass Framson Rosenberg, Texas 77471 ,

4822 Waynesboro Drive Houston, Texas 77035 Robin Griffith 1034 Sally Ann Carro Hinderstein Rosenberg, Texas 77471 8739 Link Terrace Houston, Texas 77025 Leotis Johnston 1407 Scenic Ridge ,

D. Marrack Houston, Texas 77043 420 Mulberry Lane Bellaire, Texas 77401 Rosemary N. Lemmer 11423 Oak Spring Brenda McCorkle Houston, Texas 77043 i 6140 Darnell l Houston, Texas 77074 Kathryn Otto Route 2, Box 62L F. H. Potthoff, III Richmond, Texas 77469 7200 Shady Villa, #110 Houston, Texas 77055 Frances Pavlovic 111 Datonia Wayne E. Rentfro Bellaire, Texas 77401 P. O. Box 1335

  • Rosenberg, Texas 77471 Charles Perez 1014 Montrose L James M. Scott, Jr. Houston, Texas 77019 '

8302 Albacore .

Houston, Texas 77074 William Schuessler -

5810 Darnell Bryan L. Baker Houston, Texas 77074 1118 Montrose Houston, Texas 77019 Patricia L. Strelein Route 2, Box 395C Dorothy F. Carrick Richmond, Texas Box 40.9, Wagon Rd. Rfd. #1 Wallis, Texas 77485 t l

Glenn Van Slyke Donald D. Weaver 1739 Marshall P. O. Drawer V Houston, Texas 77098 Simonton, Texas 77476 Connie Wilson J. Morgan Bishop 11427 Oak Spring 11418 Oak Spring Houston, Texas 77043 Houston, Texas 77043 i

C % meIkhk C. Thomas Biddle, Jr. p

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