ML19341A093
| ML19341A093 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/19/1981 |
| From: | Rothschild M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | ASSOCIATION OF COMMUNITY ORGANIZATIONS FOR REFORM |
| References | |
| NUDOCS 8101220078 | |
| Download: ML19341A093 (41) | |
Text
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01/19/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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TEXAS UTILITIES GENERATING COMPANY, ET AL.
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Docket Nos. 50-445
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446 (Comanche Peak Steam Electric Station,
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Units 1 and 2)
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NRC STAFF'S FIRST SET nF INTERROGATORIEL u,,g',s,@lh' 8/g /Ce/
~i AND REQUEST FOR T ~ PRODUCTION OF DOCUMENTS FROM, INTERVENOR ACORN J
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The Nuclear Regulatory Commission (NRC) Staff hereby r
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Intervenor ACORN, pursuant to 10 CFR 6 2.740(b) and in accordance with the Atomic Safety and Licensing Board's (hereafter "the Board") " Order Subse-quent To The Prehearing Conference of April 30, 1980", dated June 16, 1980, and the Board's Memorandum and Order of December 31, 1980,1/ answer separately and fully, in writing under oath or affirmation, the following interrog-atories within fourteen (14) days after service hereof.S/
1/ The Board's Memorandum and Order of December 31, 1980, contains the Board's rulings on 1) consolidation of the intervenors,
- 2) appoint-ment of lead intervenors and 3) miscellaneous motions and other matters.
The Board consolidated the intervenors for certain contentions, with ACORN being appointed lead intervenor for consolidated contentions 5 and 23, and as sole sponsor cf contentions 10, 12, 13, 14, 15, 16, 17, 18,19, 20, and 21, for those contentions as well. The Board provided that the lead party-intervenor for a particular contention is lead for all purposes, which would include discovery. Accordingly, the Staff has directed interrogatories for consolidated contentions 5 and 23 to ACORN only, as lead intervenor for those contentions.
It is the Staff's expectation that in responding to those interrogatories, ACORN will consult with the other intervenors. ACORN's responses should be the joint responses of the intervenors consolidated for these contentions and should reflect the views and positions of all the consolidated intervenors.
1 The Staff has attempted to avoid duplication of any of Applicants' previously filed interrogaotries to ACORN and has not included inter-rogatories which, in its view, seek precisely the same information ACORN has provided in response to Applicants' interrogatories to ACORN.
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-2 For each response to the interrogatories set forth below, identify the person or persons who prepared or substantially contributed to the prepa-ration of the response.
The NRC Staff further requests that Intervenor ACORN, pursuant to 10 CFR 5 2.741, provide copies of, or make available for Staff inspection and copying, the documents designated by Intervenor in response to certain of the accompanying interrogatories.
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I.
GENERAL INTERROGATORIES G-1.
State whether or not you intend to call any person or persons as witnesses in this proceeding in support of h) Centention 5
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Contention 15 (k)
Contention 20 (o) Contention 10 (g) Contention 16 (1)
Contention 21 (c) Contention 12 (h) Contention 17
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Contention 23 (d) Contention 13 (i) Contention 18 (e) Contention 14 (j) Contention 19 i
ard provide the names, addresses, educational backgrounds and professional qualifications of those persons you intend to call.
G-2.
Indicate which of those persons identified in response to Inter-rogatory G-1 will appear voluntarily and which persons you i1 tend to subpoena.
I Interrogatories in this section should be answered with respect to each contention. The contentions referred to are those contentions
' raised by Intervenor as modified, renumbered and admitted by the Licensing Board in its 1) Order Subsequent to The Prehearing Con-ference of April 30, 1980, dated June 16, 1980 and 2) Rulings on i
Objections to Board's Order of June 16, 1980 and on Miscellaneous Motions, dated October 31, 1980.
In the Board's October 31, 1980 order, the Board deleted Contention 11 and construed Contention 5 to cover the Inspection and Enforcement Report subjects which ACORN specifically identified at Appendix A of its offer of proof served August 29, 1980.
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. G-3.
Provide
.maries of the views, positions, or proposed testimony on (a) Conte ' ion 5 (f) Contention 15 (k) Contention 20 (b) Contention 10 (g)
Contention 16 (1) Contention 21 (c) Contention 11 (h) Contention 17 (m) Contention 23 e
(d) Contention 13 (i) Contention 18 (e) Contention 14 (j) Contention 19 of all persons named in response to Interrogatory G-1 that you intend to present during this proceeding.
G-4.
Identify by author, title, date of publication and publisher, all books, documents and papers that you intend to employ or rely t,pon in pre-senting your direct case on (a) Contention 5 (f) Contention 15 (k) Contention 20 (b) Contention 10 (g) Contention 16 (1) Contention 21 (c)
Contention 12 (h) Contention 17 (m) Contention 23 (d) Contention 13 (i) Contention 18 (e) Contention 14 (j) Contention 19 and provide copies of, or make available for Staff inspection and copying, those items.
If the hipresentations made in G-5.
(a) Contention 5 (f) Contention 15 (k) Contention 20 (b) Contention 10 (g) Contention 16 (1) Contention 21 (c) Contention 12 (h) Contention 17 (m) Contention 23 (d) Contentior. 13 (i)
Contention 18 (e)
Contention 14 (j) Contention 19
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4 are based in whole or in part on any documents prepared by the Applicants or NRC Staff which you contend are deficient, identify the documents and specify the particular portions thereof you regard as deficient and explain why they are deficient.
G-6.
Identify by author, title, date of publication and publisher all books, document; or papers that you intend to employ or rely upon in conduct-ing your cross-examination of prospective NRC St ff witnesses testifying in connection witt (a) Contention 5 (f) Contention 14 (j)
Contention 18 (b) Contention 10 (g) Contention 15 (k) Contention 19 (c) Contention 12 (h) Contention 16 (1)
Contention 20 (d) Contention 13 (i) Contention 17 (m) Contention 21 (e) Board Questions 1, 2 and 3 as set (n) Contention 23 forth in the Order Subsequent To The Prehearing Conference, dated June 16,1980.
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, II.
INTERROGATORIES RELATED TO SPECIFIC CONTENTIONSSI Contention 5 Statement of Contention The Applicants' f ailure to adhere to the quality assurance /
quality control provisions required by the construction cer-mits for Comanche Peak, Units 1 and 2, and the requirements of Appendix B of 10 CFR Part 50, and the construction practices employed, specifically in regard to concrete work, mortar blocks, steel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, weloing, inspection and testing, materials used, craf t labor qualifi-cations and working conditions (as they may affect QA/QC, and training and organization of QA/Qr personnel, have raised sub-stantial questions as to the adequacy of the construction of the facility. As a resuit, the Commssion cannot make the findings required by 10 CFR 6 50.57(a) reces(ary for iscusnce of an op?roting licente for Comanche Peak.
(CFUR 4A-ACORN 14-CASE 19 Joint Contentions)S_/
SI Interrogatories in this section should be answered with respect to each contention. The contentions referred to are those contentions raised by Intervenor as modified, renumbered and admitted by the Licensing Board in its 1) Order Subsequent to The Prehearing Con-ference of April 30, 1980, dated June 16,1980 and 2) Rulings on Objections to Board's Order of June 16, 1980 and on Miscellaneous Motions, dated October 31, 1980.
In the Board's October 31, 1980 order, the Board deleted Contention 11 and construed Contention 5 to cover the Inspection and Enforcement Report subjects which ACORN specifically identified at Appendix A of its offer of proof served August 29, 1980.
As stated in fn. 3, the Board has construed Contention 5 to cover the Inspectica and Enforcement Report subjects which ACORN specifically identified at Appendix A of its Offer of Proof served August 29, 1980.
ACORN's Offer of Proof " documents fundamental problems in the QA/QC program with regard to lack of compliance, subcontractors
- failure to report items of noncompliance, lack of methods of identification and control of nonconformance, program surveillance, procedural deficiencies, storage of electrical components, failure to follow pipe fabrication procedures, failure to follow equipment mainterance instructions, and potential construction deficiency regarding the Unit 1 pressurizer".
S/ The numbers in parentheses indicate +he contertions in Intervenors' filings from which the admitted contention is derived.
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- C5-1.
Identify the quality assurance / quality control provisions re-quired by the construction permits for Comanche Peak which you assert Appl'-
cants have failed to adhere to and st-te the basis for your position in this regard.
C5-2.
Identify the requirements of Appendix B of 10 CFR Part 50 which you assert Applicants have failed to adhere to and state the basis for your position in this regard.
C5-3.
Define what is meant by " construction practices employed' es that phrase is used in the contention.
C5-4 Describe the " concrete work" referred to in the contention and state the basis for your assertion that Applicants construction practices with regard to " concrete work" have raised " substantial questions as to the adequacy of the construction of the facility."
C5-5.
Identify the " mortar blocks" referred to in the contention and state the basis for your assertion that Applicants' construction practices with respect to " mortar biccks" have " raised substantial questions as to the adequacy of the construction of the facility."
C5-6.
Describe specifically and in detail the " steel" referred to in the contention and state the basis for your assertion that Applicants con-struction practices with respect to steel have " raised substantial questions as to the adeqJacy of the construction of the facility."
. C5-7.
Define what is meant by " fracture toughness testing" as that phrase is used in the contention and state the basis for your assertion that Applicants' construction practices with respect to " fracture toughness testing" have " raised substantial questions as to the adequacy of the con-struction of the facility."
C5-8.
Identify the " expansion joints" referred to in the contention and state the basis for your assertion that Applicants' construction 4
practices with respect to " expansion joints" have " raised suistantial questions as to the adequacy cf the construction of the facility."
C5-9.
Describe what is meant by " placement of the reactor vessel for Unit 2" and state the basis for your assertion that Applicants' construction practices with respect to " placement of the reactor vessel for Unit 2" have
" raised substantial questi' ns as to the adequacy of the construction of the fa cil i ty. "
C5-10.
Describe specifically and in detail the " welding" referred to in the contention and state the basis for your assertion that Applicants' construction practices with respect to " welding" have " raised substantial questions as to the adequacy of the construction of the facility."
C5-ll.
Describe specifically and in detail the " inspection and testing" i
referred to in the contention and state the basis for your assertion that Applicants' construction practices with respect to " inspection and testing"
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. have raised substantial questions as to the adecuacy of the construction of the facility.
C5-12.
Identify the " materials used" and state the basis for your assertion that Applicants' construction practices with respect to " materials used" have " raised substantial questions as to the adequacy of the construc-tion of the facility."
C5-13.
Describe specifically and in detail the " craft labor qualifi-cations and working conditions (as they may affect QA/QC)" referred to in the contention and state the basis for your assertion that Applicants' con-struction practices with respect to " craft labor qualifications and working conditions (as they may affect QA/QC)" have " raised substantial questions as to the adequacy of the construction of the facility."
C5-14 Describe specifically and in detail the " training and organi-zation of QA/QC personnel" referred to in the contention and state the basis l
for your assertion that the Applicants' practices with respect to " training and organization of QA/QC personnel" have " raised substantial questions as to the adequacy of the construction of the facility."
C5-15.
Define what is meant by the phrase " substantial questions as to the adequacy of the construction of the facility."
Exactly what " questions" do you contend are raised by Applicants' " failure,to adhere to the quality assurance / quality control provisions required by the construction permits for Comanche Peak, Units 1 and 2
..."?
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9 C5-16. State specifically and in detail what is meant by the phrase
" lack of compliance" and state the basis for your assertion that Applicants'
" lack of compliance" has " raised substantial questions as to the adequacy of the construction of the facility."
C5-17. State specifically what is meant by the phrase " subcontractors' failure to report items of noncompliance"; spsify the " items of noncom-pliance" and state the basis for your assertion that " subcontractors' failure to report items of noncompliance" has " raised substantial questit ns as to the adequacy of the construction of the facility."
C5-18.
State specifically what is meant by the phrase " lack of methods of identification and control of nonconformance" and state the basis for your assertion that Applicants' " lack of methods of identification and control of nonconformance" has " raised substantial questions as to the adequacy of the construction of the facility."
1 C5-19. S ta tt. specifically what is meant by the phrase " program sur-veillance" and state the basis for your assertion that Applicants' " program surveillance" has " raised so stantial questions as to the adequacy of the construction of the facility."
C5-20.
State specifically what is meant by the phrase " procedural deficiencies"; specify the " procedural deficiencies" and state the basis for your assertion that Applicants' " procedural deficiencies" have " raised 4
substantial questions as to the adequacy of the construction of the facility."
C5-21. State specifically what is meant by the phrase " storage of electrical components"; identify the " electrical components" and state the basis for your assertion that Applicants' " storage of electrical components" has " raised substantial questic' as to the adequacy of the construction of the facility."
C5-22. State specifically what is meant by the phrase " failure to follow pipe fabrication procedures"; identify the " pipe fabricat,an pro-cedures" and the " pipe" and state the basis for your assertion that Applicants'
" failure to follow pipe fabrication procedures" has " raised substantial questions as to the adequacy of the construction of the facility."
1 C5-23. State specifically what is meant by the phrase " failure to follow equipment ir.cintenance instructions"; identify the " equipment" and state the basis for your assertion that Applicants' " failure to follow equip-ment maintenance instructions" has " raised substantial questions as to the adequacy of the construction of the facility."
C5-24 State specifically what is meant by the phrase " potential con-struction deficiency regarding the Unit 1 pressurizer"; describe the " potential construction deficiency" and state the basis for your assertion that the
" potential construction deficiency regarding the Unit 1 pressurizer" has
" raised substantial questions as to the adequacy of the construction of the facility."
C5-25.
Identify the findint
' qui-i by 10 CFR 6 50.57(a) which you assert the Commission cannot make v:1
.c to Comanche Peak.
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Contention 10 Statenent of Contention The CPSES design fails to adequately account for the effect of asymmetric loading resulting from a pipe break in the areas between the reactor vessel and the shield wall.
(ACORN 1)
C10-1. Describe specifically the "CPSES design" referred to in the contention. Does the "CPSES design" include the facility as built?
C10-2. State specifically the meanf 99 of the term " adequately account" in the contention.
C10-3.
State specifically your understanding of the term "effect of asymmetric loading" in Contention 10.
C10-4.
Identify the " pipe break" referred to in the contention.
C10-5.
Identify specifically the " areas between the reactor vessel and the shield wall".
1 C10-6.
Identify the " shield wall" referred to in the contention.
C10-7.
State specifically the basis for Contention 10.
C10-8.
State specifically the NRC requirements which you contend mandate that the CPSES design " account for the effect of asymmetric loading resulting from a pipe break in the areas between the reactor vessel and the shield wall."
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r C10-9. What do you contend Applicants must do to demonstrate that the CPSES design " adequately accounts for the effect of asymmetric loading rasulting from a pipe break in the areas between the reactor vessel and the shieli wall"? State the basis for your position in this regard.
l C10-10. What do you contend the NRC Staff must do to demonstrate that the CPSES design " adequately accounts for the effect of asymmetric loading resulting from a pipe break in the areas between the reactor vessel and the shield wall"? State the basis for your position in this regard.
C10-ll. Have you reviewed the Applicants' Final Safety Analysis Report
("FSAR")? If so, please answer the following questions.
a.
Do you object to any of the information, data or analysis contained or referenced therein with respect to measures "to account for the effect of asymmetric loading resulthg from a pipe break in the areas between the reactor vessel and the shield wall"?
b.
If your response to a. is in the affirmative, please specify your objections by identifying the sections of the FSAR to which you object and the substance of your objections.
c.
What are your bases for your responses to a. and b.?
C10-12. State the manner in which you believe the CPSES design should
" adequately account for the effect of asymmetric loading resulting from a pipe break in the areas between the reactor vessel and the shield wall."
State the basis for your position in this regard.
. Contention 12 Statement of Contention Neither the Applicants nor the Staff has reliable methods for evaluating and insuring that structures, systems and compo-nents important to safety are designed to withstand the affects
[ sic] of the safe shutdown earthquake without losing the capability to safely shutdown the plant; thus, General Design Criterion 2 has not been satisfied.
(ACORN 4)
Cl2-1.
Define what is meant by the term " reliable methods" as that term is used in Contention 12. Who do you contend should determine whether
" methods" are " reliable"?
Cl2-2.
Define what is meant by the terms " evaluating and insuring" as those terms are used in Contention 12.
1 Cl2-3.
Identify specifically the " structures, systems and components important to safety" referred to in Contention 12.
Cl2-4 Define what is meant by the terms " withstand the affects" [ sic]
as those terms are used in the contention.
C12-5. State specifically and in detail your understanding of the term
" safe shutdown earthquake" as that term is used in the contention.
C12-6.
State what is meant by the terms "the capability to safely shutdown the plant" ar. those terms are used in the contention.
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Cl2 7.
Precisely what do you contend Applicants must do to demon-strate that " structures, systems and components important to safety are j
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. designed to withstand the affects [ sic] of the safe shutdown earthquake with-out losing the capability to safely shutdown the plant"? State the basis for your position in this regard.
Cl2-8.
Precisely what do you contend the Staff must do to insure that " structures, systems and components important to safety are designed to withstand the affects [ sic] of the safe shutdown earthquake without losing the capability to safely shutdown the plant"? State the basis for your position in this regard.
C12-9.
Have you reviewed the Applicants' Final Safety Analysis Report
(" FS AR") ? If so, please answer the following questions, a.
Do you object to any of the information, data or analysis contained or referenced therein with respect to " methods for evaluating and insuring that structures, systems and components important to safety are designed to withstand the affects [ sic] of the safe shutdown earthquake with-out losing the capability to safely shutdown the plant"?
b.
If your response to a. is in the affirmative, please specify your objections by identifying the sections of
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the FSAR to which you object and the substance of your objections?
c.
What are your bas,es for your responses to a. and b.?
Cl2-10.
State the basis for Contention 12.
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. Contention 13 Statement of Contention Present fire protection measures proposed by Applicants are not adequate to minimize the probability and effects of a fire from disabling the electric cables for all redundant safety systems; thus, General Design Criterion 3 has not been satisfied.
(ACORN 5).
Cl3-1.
Describe specifically and in detail the " fire protection measures" referred to in the contention.
Cl3-2.
State what is meant by the term " adequate" as that term is used in Contention 12.
i Cl3-3.
State what is meant by the term " minimize" as that term is used in Contention 13.
C13-4 Describe specifically the " fire" referred to and state the basis for your assertion that such a fire could occur.
Cl3-5. ptate specifically what is meant by the term " disabling" as it is used in Contention 13.
Cl3-6.
Identify specifically the " electric cables" and " redundant safety systems" referred to in the contention.
Cl3-7.
Precisely what do you contend Applicants cust do to demon-strate that "present fire protection measures proposed by Applicants are adequate to minimize the probability and effect of a fire from disabling
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the electric cables for all redundant safety systems"? State the basis for your position in this regard, i
Cl3-8.
Precisely what do you contend the NRC Staff must do to demon-strate that "present fire protection maasures proposed by Applicants are adequate to minimize the probability and effect of a fire from disabling the elec+.ric cables for all redundant safety systems"? State the basis for your position in this regard.
Cl3-9. Describe the fire protection measures "to minimize the probability and effect of a fire from disabling the electric cables for all redundant i
safety systems" which you would consider to be adequate and state the basis for your position in this regard.
Cl3-10. State specifically and in detail the basis for Contention 13.
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Contention 14 Statement of Contention j
The D.C. Power System for the CPSES plant fails to meet the single failure criterion as defined in 10 CFR Part 50, Apperdix A.
(ACORN 6) i C14-1. State your understanding of the term "D.C.
Power Syste'm".
Cl4-2.
State specifically and in detail the meaning of the phrase
" fails to meet".
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. C14-3.
State your understanding of the term " single failure criterion".
C14-4.
Precisely what do you contend Applicants must do to demon-strate that the "D.C. Power System for the CPSES plant... [ meets] the single failure crti.arion as defined in 10 CFR Part 50, Appendix A"? State the basis for your position in this regard.
Cl4-5.
Precisely what do you contend the NRC Staff must do to demon-strate that the "D.C.
Power System for the CPSES plant... [ meets] the single failure criterion as defined in 10 CFR Part 50, Appendix A"? State the basis for your position in this regard.
Cl4-6.
Have you reviewed the Applicants' final Safety Analysis Report
("FSAR")? If so, please answer the following questions.
a.
Do you object to any of the information, data or analysis contained or referenced therein with respect to compliance of the D.C. Power System wit.h the " single failure criterion" as defined in 10 CFR Pa-t 50, Appendix A?
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If your response to a. is in the affirmative, please specify your objections by identifying the sections of the FSAR to which you object and the substance of your objections?
c.
What are your bases for your responses to a. and b.?
C14-7.
State the basis for your assertion in Contention 14 that the "D.C. Power System for the CPSES plant fails to meet the single failure criterion as defined in 10 CFR Part 50, Appendix A".
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, Contention 15 Statement of Contention The CPSES design does not provide adequate, reliable instru-mentation to monitor variables and systems affecting the integrity of the reactor core [and] the pressure boundary of the containment after an accident, in violation of General Design Criterion 13 of Appendix A of 10 CFR Part 50.
(ACORN 7)
C15-1.
Does the term "CPSES design" include the facility as built?
C15-2.
Describe specifically the " adequate, reliable instrumentation" referred to in the contention.
Precisely where do you contend such instru-mentation must be located?
C15-3.
State the bases for your response to Interrogatory C15-2.
C15-4.
Describe specifically the " variables and systems" referred to.
C15-5.
State specifically what is meant by the term " integrity of the reactor core.
C15-6.
State specifically what is meant by the phrase "the pressure boundary of the containment".
C15-7.
Describe specifically the " accident" referred to in the contention.
How do you believe any such accident could occur?
C15-8.
State specifically the bases for your response to Inte"r.cg=-
tory C15-6 and Interrogatory C15-7.
- C15-9. Have you reviewed the Applicants' Final Safety Analysis Report
(" FSAR" ) ? If so, please answer the following questions.
a.
Do you object to any of the information, data or analysis contained or referenced therein with respect to "instru-mentation to monitor variables ar.a systems affecting the integrity of the reactor core [and] and the pressure boundary of the containment after an accident"?
b.
If your response to a. is in the affirmative, please specify your objections by identifying the sections of the FSAR to which you object and the substance of your objections.
c.
What are the bases for your responses to a. and b.?
C15-10.
Precisely what do you contend Applicants must do with respect to the design features identified in your response to Interrogatory C;5-2 to bring the CPSES design into compliance with General Design Criterior 13?
What is the basis for your position in this regard?
C15-11.
Precisely what do you contend the NRC Staff must do to demon-strate that the CPSES design provides " adequate, reliable instrumentation to monitor variables and systems affecting the integrity of the reactor core
[and] the pressure boundary of the containment after an accident"? State the basis for your position in this regard.
C15-12.
Describe the " instrumentation to monitor variables and systems affecting the integrity of the reactor core [and] the pressure boundary of the containment after an accident" which you would consider to be ': adequate" and " reliable". State the basis for your position in this regard.
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. C15-13.
State the basis for Contention 15.
Contention 16 Statement of Contention The CPSES design does not provide adequate equipment outside of tne control room to promptly put the reactor in hot shut-down and so maintain it until attaining cold shutdown (also from outside the control room) as required by General Design Criterion 19 of Appendix A to 10 CFR Part 50.
C16-1.
Have you reviewed the Applicants' Final Safety Analysis Report
(" FSAR" ) ? If so, please answer the following.
a.
Do you ooject to any of the information, data or analysis contained or referenced therein with respect to the designation of equipment and procedures for obtaining prompt hot shutdown of tha reactor from outside the control room?
b.
Do you object to any of the information, data or analyses contained or referenced therein with respect to providing for the potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures?
c.
If your answer to either a. or b. is in the affirmative, please specify your objections by identifying the sections of the FSAR to which you object and the substance of your objections.
d.
What are the bases for your responses to a., b. and c.
above?
C16-2.
Describe the " equipment" not provided at Comanche Peak which you contend must be provided to put the reactor in hot shutdown from outside the main control room.
. C16-3.
Describe the equipment not provided at Comanche Peak which you contend must be provided to have a potential capability to attain colt' shut-down from outside the main control room.
C16-4. Where do you contend the equipment which you identified in your response to Interrogatories C16-2 and C16-3 must be located?
C16-5.
Describe the equipment not provided at Comanche Peak which you contend must be provided to maintain hot shutdown until attaining cold shutdown from outside the main control room.
C16-6. Where do you contend the equipment identified in your response to Interrogatory C16-5 must be located?
C16-7. What are the bases for your responses to Interrogatories C16-2 through C16-6?
C16-8. What instrumentation and controls not provided at Comanche Peak do you contend must be provided to maintain the reactor in a safe con-dition during hot shutdown?
C16-9.
Do you contend that any instruments and controls besides those identified in your response to Interrogatory C16-8 which are not provided at Comanche Peak, must be provided to satisfy your concerns as set forth in Contention 16?
, C16-10. What are your bases for your responses to Interrogatories C16-8 and C16-9?
C16-11. What suitable procedures not provided for at Comanche Peak do you contend are necessary to attain cold shutdown of the reactor from outside the control room?
C16-12. What is the basis for your response to Interrogatory C16-ll?
C16-13. Where do you contend that the instruments and controls identi-J fied in your response to Interrogatory C16-8 need be located?
C16-14. What is the basis for your response to Interrogatory C16-13?
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C16-15.
Do you contend that any equipment required for safe shutdown j
cannot be operated from controls remote from the main control room? If so, please specify.
C16-16. What are the bases for your responses to Interrogatory C16-15?
i C16-17.
Do you contend that any of the equipment used to attain safe i
shutdown remote from the main control room is not designed to the requisite standards or criteria? If so, please specify.
C16-18. What is the basis for your response to Interrogatory C16-17?
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. C16-19. Do you contend that adequate indicators to alert persons in the main control room of actuation of remote controls are not provided?
C16-20. What is the basis for your response to Interrogatory C16-19?
C16-21. What do you contend Applicants must do to demonstrate that the CPSES design provides " adequate equipment outside of the control room to promptly put the reactor in hot shutdown and so maintain it until attaining cold shutdown (also from outside the control room) as required by Ge.neral Design Criterion 19 of Appendix A to 10 CFR Part 50"? State the basis for your position in this regard.
C16-22. What do you contend the NRC Staff must do to demonstrate that the CPSES design provides " adequate equipment outside of the control room to promptly put the reactor in hot shutdown and so maintain it until obtaining cold shutdown (also from outside the control room) as required by General Design Criterion 19 of Appendix A to 10 CFR Part 50"? State the basis for your position in this regard.
Contention 17 Statement of Contention Neither the Applicants nor the Staff has adequately considered the effects of aging and cumulative radiation on safety-related equipment which must be seismically and environmentally qualified, thus, General Design Criterion 4 has not been satis-fied.
(ACORN 10)
C17-1.
State what is meant by the phrase " adequately considered".
, C17-2.
Describe specifically and in detail the " effects" referred to.
C17-3.
State your understanding of the phrase " aging and cumulative radiation".
C17-4 Identify specific lly the ' safety-related equipment" referred to.
C17-5.
State your understanding of the phrase " seismically and environ-mentally qualified".
C17-6.
State in what ways the Applicants have not " adequately con-sidered the effects of aging and cumulative radiation on safety related equipment which must be seismically and environmentally qualified".
C17-7.
Precisely what do you contend Applicants must do to demon-strate that they have " adequately considered the effects of aging and cumu-lative radiation on safety related equipment which must be seismically and environmentally qualified"? State the basis for your position in this regard.
C17-8.
State in what ways the Staff has not " adequately considered the effects of aging and cumulative radiation on safety related equipment which must be seismically and environmentally qualified".
C17-9.
Precisely what do you contend the Staff must do in order to demonstrate that it has " adequately considered the effects of aging and cumulative radiation on safety related equipment which must be seismically
, and environmentally qualified"? State the basis for your position in this regard.
C17-10.
Have you reviewed the Applicants' Final Safety Analysis Report
(" FSAR") ? If so, please answer the following questions.
a.
Do you object to any of the information, data or analysis contained or referenced therein with respect to consideration of the effects of " aging and cumulative radiation on safety-related equipment which must be seismically and environmentally qualified"?
b.
If your response to a. is in the affirmative, please specify your objections by identifying the sections of the FSAR to which you object and the substance of your objections.
c.
What are the bases for your responses to a. and b.?
C17-ll.
State the basis for Contention 17.
Contention 18 Statement of Contention The CPSES design fails to present a means for dealing with pressure transients produced by component failure, personnel error, or spurious valve actuation which exceed the pressure /
..emperature limits of the reactor vessel.
(ACORN 13)
C18-1.
Does the phrase "the CPSES design" include the facility as constructed?
C18-2.
State specifically what is meant by the phrase "a means for dealing with".
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. C18-3. State specifically what is meant by the phrase " pressure 4
transients... which exceed the pressure / temperature limits of the reactor vessel" and describe the " pressure transients" which you contend would be produced by:
a) "componed failure" b)
" personnel errer" c) " spurious valve actuation" State the basis for your responses to a), b) and c).
C18-4 State specifically what is meant by the phrase " component failure".
Identify the component (s) referred to.
C18-5.
State specifically what is meant by the phrase " personnel error" and identify the " personnel" referred to. Also, what kind of " error" do you contend the " personnel" would commit and what is the basis for your belief i
that such " errors" would be committef' C18-6.
State specifically what is meant by the phrase " spurious valve actuation"? Identify the valve (s) referred to.
C18-7.
Have you reviewed the Applicants' Final Safety Analysis Report
(" FSAR" ) ? If so, please answer the following questions:
a.
_Do you object to any of the information, data, or analyses contained or referenced therein with respect to "a means for dealing with pressure transients reo-duced by component failure, personnel error, or 3
spurious valve actuation which exceed the pressure /
temperature limits for the reactor vessel"?
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. b.
If your response to a. is in the affirmative, specify your objections by identifying the sections of the FSAR to which you object and the substance of your objections.
c.
What are the bases for your responses to a. and b.?
C18-8.
State specifically the NRC requirements which you contend mandate that the CPSES design present "a means for dealing with pressure transients produced by component failure, personnel error, or spurious valve actuation which exceed the pressure / temperature limits of the reactor vessel".
C18-9.
What do you contend Applicants must do to demonstrate that the CPSES design presents "a means for dealing with pressure transients produced by component failure, personnel error, or spurious valve actuation which exceed the pressure / temperature limits of the reactor vessel"? State the basis for your position in this regard.
C18-10. What do you contend the NRC Staff must do to demonstrate that the CPSES design presents "a means for dealin with pressure transients produced by component failure, persornc error, or spurious valve actuation which exceed the pressure /tsnperature limits of the reactor vessel"? State the basis for your position in this regard.
C18-11. What is the basis for Contention 18?
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Contention 19 Statement of Contention The CPSES design fails to protect against corrosion within the steam generators which causes cracking of pipes and leakage of radioactive water.
(ACORN 15)
C19-1.
Does the meaning of the phrase "the CPSES design" include the facility as constructed?
C19-2.
State what is meant by the phrase " protect against".
Do you contend that the CPSES design must insure that corrosion within the steam generators will not occur?
C19-3.
State your und(estanding of the term " corrosion within the steam generators".
How do you contend such " corrosion" could occur?
C19-4 Identify "the steam generators" referred to.
C19-5.
Identify the " pipes" referred to in the contention.
C19-6. State the basis for your assertion that " corrosion within the steam generators causes cracking of pipes and leakage of radioactive water".
C19-7.
Set forth specifically the NRC requirements which you contend mandate that the CPSES design protect "against corrosion within the steam generators which causes cracking of pipes and leakage of radioactive water."
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. C19-8.
Precisely what do you contend Applicants must do to demonstrate that the CPSES design protects "against. corrosion within the steam generators which causes cracking of pipes and leakage of radioactive water"? State the basis for your position in this regard.
C19-9.
Precisely what do you contend the NRC Staff must do to demon-strate that the CPSES design protects "against corrosion within the steam generators which causes cracking of pipes and leakage of radioactive water"?
State the basis for your position in this regard.
C19-20. Have you read the portion of Applicants' FSAR relating to pro-tection against corrosion within the steam generators? If so, please answer the following questions:
a.
Do you object to any of the information, data or analyses contained or referenced therein with respect to protec-tion "against corrosion within the steam generators which causes cracking of pipes and leakage of radioactive water?"
b.
If your answer to a. is in the affirmative, specify your objections by identifying the sections of the FSAR to which you object and the substance of your objections.
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What are the bases for your responses to a. and b.?
c.
C19-ll. What is the basis for Contention 19?
, Conter. tion 20 Statement of Contention The CPSES design does not adequately insure that safety-related water supplies will be available for plant operation in the event of ice bulldup at the service water intake structure.
C20-1. Have you reviewed the Applicants' Final Safety Analysis Report
(" FSAR") ? If so, please answer the following questions:
a.
Do you object to any of the information, data or analysis contained or referenced therein with respect to consideration of freeze protection at the service water intake structure?
b.
If your answer to a. is in the affirmative, please specify those objections by identifying the sections of the FSAR to which you object and the substance of your objections.
c.
What are the bases for your responses to a. and b.?
C20-2.
Please specify precisely where and in what manner you contend ice would cause the service water intake structure to be unable to perform any function necessary for safe operation.
C20-3.
Please specify the conditions (e_.3., water level, flow rates, meteorological conditions, etc.) which you contend would cause ice to prevent operations of the service water intake structure necessary for safe operation.
C20-4.
Do you contend that ice would form within the service water intake building as opposed 's ice formed outside of the building being drawn into the service water intake building?
C20-5. What are the bases for your responses to Interrogatories C20-2 through C20-4?
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How thick do you contend ice could become on the safe shutdown impoundment?
C20-7. Do you contend that ice formed on the surface of the safe shut-down impoundment could break up and flow into the service water intake structure and thus prevent uptake of adequate safety-related water supplies?
C20-8. What is the minimum water temperature you contend might occur in the safe shutdown impoundment?
C20-9. What are the bases for your responses to Interrogatories C20-6 through C20-8*.
C20-10.
Please specify precistly how you contend ice buildup at service water intake structures at other plants is related to possible ice buildup in the Comanche Peak service water intake structure.
C20-ll.
Do you contend that the ice could block the water intake openings of the service water intake structures?
C20-12.
Do you contend that the ice could block and prevent the operation of the screens?
C20-13.
Do you contend that the ice could block and prevent the operation of the stop gates?
a C20-14 Do you contend that the ice would prevent operation of the service water pump?
C20-15. What are the bases for your responses to Interrogatories C20-10 through C20-14?
C20-16. Do you contend that Applicants would not be able to properly respond in the esent that ice buildup at the service water intake structure prevented safety-related water supplits from being available for plant operation?
C20-17.
If your response to Interrogatory C20-16 is in the affirmative, please set forth with particularity the sequence of events which you contend could prevent safe operation of Comanche Peak.
C20-18. What is the basis to your response to Interrogatory C20-17?
C20-19.
Do vou contend that an ice storm could be the cause of the ice buildup at the service water intake structure?
4 C20-20.
If your answer to Interrogatory C20-19 is in the affirmative, please specify what you mean by " ice storm"?
C20-21. What is the sequence of events which you contend would occur in an ice storm to prevent safety-related water from being supplied through the service water intake structure?
. C20-22. What are the bases for your responses to Interrogatories C20-19 through C20-21 ?
C20-23.
How often do you contend conditions could exist for ice buildup at the service water intake structure to prevent necessary operation thereof?
C20-24 Specify the measures which you contend Applicants must take to prevent ice buildup at the service water intake structure from causing any danger to the safe operation of Comanche Peak.
l C20-25.
In your response to Interrogatory C20-24, olease identify the specific structures, equipment and procedures which you contend must be changed to prevent ice buildup at the service water intake structure from posing any danger to the safe operation of Comanche Peak.
1 C20-26. How do you contend Applicants should incorporate the specific structures, equipment or procedures identified in your responses to Inter-rogatory C20-25 in the service water intake structure?
C20-27. What are the bases for your responses to Interrogatories C20-23 through C20-26?
C20-28.
Do you contend that ice buildup at the service water intake structure could totally prevent uptake of safety-related water supplies?
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C20-29.
If your response to Interrogatory C20-28 is in the negative, please specify the extent to which you contend ice buildup could prevent uptake of safety-related water supplies.
C20-30.
For what period of time do you contend ice buildup could prevent uptake of safety-related water supplies?
C20-31. What rate of water uptake from the safe shutdown impoundment do you contend is necessary for " safety-related water supplies"?
C20-32. What are the bases for your responses to Interrogatories C20-28 through C20-31 ?
C20-33. Specify the NRC requirements which you contend are not satisfied because "the CPSES design does not adequately insure that safety-related water supplies will be available for plant operation in the event of ice buildup at the service water intake structure".
C20-34. What do you contend the NRC Staff must do to demonstrate that
" safety-related water supplies will be available for plant operation in the event of ice buildup at the service water intake structure"? State the basis for your position in this regard.
C20-35. What do you contend the Applicants must do to demonstrate that
" safety-related water supplies will be available for plant operation in the l
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. event of ice buildup at the service water intake structure"? State the basis for your position in this regard.
Contention 21
_ Statement of Contention The CPSES design fails to protect against accidents involving the movement and handling of heavy loads in the vicinity of spent fuel at the facility.
(ACORN 22)
C21-1.
Does the phrase "CPSES design" include the facility as con-structed?
C21-2.
State specifically and in detail the meaning of " heavy loads" l
as that phrase is used in the contention.
4 C21-3.
Describe specifically the area of the facility which is in the " vicinity of spent fuel".
C21-4.
Do you assert in Contention 21 that accidents could occur involving "the movement and handlin,g of heavy loads in the vicinity of spent fuel at the facility"? If so, state specifically the basis for such assertion and describe how such accidents could occur.
C21-5.
State specifically the NRC requirements which you contend mandate that the CPSES design protect against " accidents involving the move-ment and handling of heavy loads in the vicinity of spent fuel at the facility".
. C21-6. What do you contend Applicants must do to demonstrate that the CPSES design protects against " accidents involving the movement and handling of heavy loads in the vicinity of spent fuel at the facility"?
C21-7.
Have you reviewed the Applicants' Final Safety Analysis report
(" FSAR" ) ? If so, please answer the following questions.
a.
Do you object to any of the information, data or analysis contained or referenced therein with respect to protection against " accidents involving the movement and handling of heavy loads in the vicinity of spent fuel at the facility"?
b.
If your response to a. is in the affirmative, please specify your objections by identifying the sections of the FSAR to which you object and the substance of your objections?
c.
What are your bases for your responses to a. and b.?
C21-8. What is the basis for Contention 21?
Contention 23 Statement of Contention Neither the Applicants nor the Staff has adequately considered the health effects of low-level radiation on the population surrounding CPSES in as much that the CPSES design does not assure that radioactive emissions will be as low as is reasonably achievable.
(ACORN 25 and CASE 9)
C23-1. State specifically what is meant by the phrase "not adequately considered" as it is used in the contention.
C23-2.
Describe the " health effects" referred to in Contention 23.
If Applicants comply with the as low as is reasonably achievable (ALARA)
. standard, what " health effects" do you contend will occur and what is the basis for your assertion in this regard? What is the basis for your assertion that such " health effects" must be consiot m
C23-3.
Define specifically your understanding of the term " low-level radiation."
C23-4 Define what is meant by the phrase "the population surrounding CPSES" as that phrase is used in Contention 23. What geographical area corresponds to the area containing "the population surrounding CPSES"?
Specify the distance of this area from the CPSES site.
State the basis for your position in this gard.
C23-5.
Does the phrase "CPSES design" include the facility as con-structed?
C23-6. State specifically your understanding of the phrase " radioactive emissions".
C23-7.
Describe the manner in which " radioactive emissions" can affect the health of "the population surrounding CPSES" and provide the basis for your response in this regard.
C23-8.
Describe specifically your objections to the NRC Staff's con-sideration of "the health effects of low-level radiation on the population 1
. surrounding CPSES" with respect to the ALARA standard.
State the basis for your position in this regard.
C23-9 Describe specifically your objections to the Applicants' con-sideration of "the health effects of low-level radiation on the population surrounding CPSES" with respect to the ALARA standard. State the basis for your position in this regard.
C23-10. What do you believe the NRC Staff must do to bring the Comanche Peak design into compliance with the ALARA standard? State the basis for your position in this regard.
C23-11. What do you believe the Applicants must do to bring the Comanche Peak design into compliance with the ALARA standard.
State the basis far your position in this regard.
C23-12. What kinds of radiation do you believe the Staff has not ade-quately considered with respect to the health effects thereof?
C23-13. What kinds of radiation do you believe the Applicants have not adequately considered with respect to the health affects thereof?
C23-14.
Describe the type of consideration by the Applicants and the NRC Staff of "the health effects of low-level radiation on the population
j
. surrounding CPSES" and the ALARA standard which you_ believe would be adequate o
and state the basis for your response.
C23-15.
State the basis for Contention 23.
Respectfully submitted, W Ch {d Marjorie Ulman Rothschild Counsel for NRC Staff Dated at Bethesda, Maryland this 19th day of January,1981 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
TEXAS UTILITIES GENERATING COMPANY, ET AL.
)
Docket Nos. 50-445
)
50 446 (Comanche Peak Steam Electric Station,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S FIRST SET OF INTERR0GATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, INTERVENOR ACORN" 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, through deposit in the Nuclear Regulatory Commission's internal mail system, this 19th day of January,1981:
Valentine B. Deale, Esq., Chairman Mr. Geoffrey M. Gay Administrative Judge West Texas Legal Services Atomic Safety and Licensing Board 100 Main Street (Lawyers Bldg.)
1001 Connecticut Avenue, N.W.
Fort Worth, TX 76102 Washington, DC 20036 David J. Preister, Esq.
Forest J. Remick, Administrative Assistant Attorney General Judge Environmental Protection Division Atomic Safety and Licensing Board P.O. Box 12548, Capital Station 305 E. Hamilton Avenue Austin, TX 78711 State College, PA 16801 Mr. Richard Fouke Richard Cole, Administrative Judge
- 1668-B Carter Drive Atomic Safety and Licensing Board Arlington, TX 76010 U.S. Nuclear Regulatory Commission Washington, DC 20555 Arch C. McColl III, Esq.
701 Commerce Street Nichclas S. Reynolds, Esq.
Suite 302 Debevoise & Liberman Dallas, TX 75202 1200 17th Street, N.W.
Washington, DC 20036 Jeffery L. Hart, Esq.
4021 Prescott Avenue Mrs. Juanita Ellis Dallas, TX 75219
)
President, CASE 1426 South Polk Street Dallas, TX 75224 1
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. Atomic Safety and Licensing Board Docketing and Service Section (7)*
Panel
- Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Appeal Panel (5)*
U.S. Nuclear Regulatory Commission Washington, DC 20555 4
F*t,1? W '4 w h b bNldi Marjofie Ulman Rothschild Counsel for f.RC Staff i
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