ML19341D478
| ML19341D478 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/02/1981 |
| From: | Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | CITIZENS FOR FAIR UTILITY REGULATION |
| References | |
| NUDOCS 8103050656 | |
| Download: ML19341D478 (16) | |
Text
-. - -- -. - __ . -- - -
t ,
.ggD coluusruNDESCE March 2, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION S ,, fx
. s* 'v s BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g 9- g7 ,
A
[&, .gf.,. /?: 9 N In the Ma'tter of ) \ / t#b"#
TEXAS UTILITIES GENERATING Docket Nos. 50-445 COMPANY, et al.
) 50-446
)
(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License ,qh no a
(
C d
&4, 7 pY Eg APPLICANTS' SECOND SET OF INTERROGATORIES TO --j 4 0j k CFUR AND REQUESTS TO PRODUCE g Ug7 }/
D /
Pursuant to 10 C.F.R. $$2.740b and 2.741, Texas U i f Generating Company, et al. (" Applicants") hereby serve App 11-cants' Second Set of Interrogatories and Requ'ests to Produce upon Citizens for Fair Utility Regulation ("CFUR"). Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent information known to CFUR, its officers, directors or menbers as well as any perti-
, nent information known to its employees, advisors or counsel.
Each request to produce applies to pertinent documents which are
)
in the possession, custody or control of CFUR, its officers, directors or members as well as its employees, advisors or counsel. In answering each interrogatory and in responding D
s l8 s 1 o 30 50 fo5fp G- 1
. _ . - - _ = - .
r 1
to each request, please recite the interrogatory or request proceeding each answer or response.1/
These interrogatories and requests shall be continuing in nature. Thus, any time CFUR obtains information which renders any previous response incorrect or indicates that a response was incorrect when made, CFUR should supplement its previous response to the appropriate interrogatory or request to produce. CFUR should also supplement its responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony.
The term " documents" shall include any writings, drawings, graphs, charts, photographs, and other data ccmpilations frcm which information can be obtained. We request that at a date or
- dates to be agreed upon, CASE make available for inspection and copying all documents subject to the requests set forth below.
APPLICANTS' INTERROGATORIES AND REQUESTS TO PRODUCE Contention 1: Applicants he*re not demonstrated technical qualifications to operate CPSES in accordance with 10 C.F.R.
-1/ The instant interrogatories directed to CFUR concern Contentions 1 and 6, for which CFUR has been designated lead-party Intervenor. If, however, any other Intervenor possesses information or documents requested herein which CFUR intends to use in support of its position on these contentions, such information or documents should be provided in response to these interrogatories and requests to produce.
c
$50.57(a)(4) in that they have relied upon Westinghouse to prepare a portion of the Final Safety Analysis Report (FSAR).
1-2.2/please state in your own words the meaning of Contention 1.
2-2. What is your basis for Contention 17 Please list all documents not elsewhere identified upon which you rely with respect to Contentica 1. Please provide copies of all such documents for inspection and copying.
3-2. Have you prepared any report, study or analysis with respect to Contention l? If so, please identify each such report, study or analysis by subject and author, including the author's professional and educational background. Please provide each such report, study or analysis for inspection and copying.
4-2. Have you caused others to prepare any report, study or analysis with respect to contention 17 If so, please identify each such report, study or analysis by subject and author, including the professional and educational background of the author. Please provide for inspection and copying each such repcrt, study or analysis on which you intend to rely.
5-2. What are the dates of the meetings or contacts you have had with the other intervening parties with respect to contention 17 Please apecify the purpose of such meetings or contacts anel the results of such meetings or contacts.
6-2. What are the dates of the meetings or contacts you l
have had with persons other than the intervening parties with respect to contention 17 Please identify the purpose and dates of those meetings or contacts, the other persons involved, and the results of such meetings or Contacts.
7-2. Do you plan to participate in the upcoming hearing with respect to contention 17 If so, what will be the 1 extent of your participation?
I l
1
8-2. Do you plan to file testimony in the upcoming hearing with respect to Contention 17 If so, who will be the sponsor (i.e., witness) of that testimony? Please set forth the nature of such testimony and the professional and educational background of the witness. Please provide copies of that tes timony. Also, please identify by titia, subject matter and author, and provide for inspection and copying, any documents relied upon in such testimony.
9-2. Do you plan to call any witness in the upcoming hearing with respect to Contention I? If so, please provide a summary of his or her professional and educational background. Also, set forth any information which has a bearing on his or her qualifications to testify in this proceeding on Contention 1.
10-2. If you plan to call any witness in the upcoming hearing with respect to contention 1, please specify the nature and scope of that person's testimony.
Please provide copies of such testimony. Please state whether that witness has conducted any research or made any studies on which the witness intends to rely.
Also, identify by title, subject matter, and author, and provide for inspection and copying. any document on which such witness will rely in their testimony
- with regard to Contention 1.
11-2. Please identify with particularity those portions of the Applicants' Final Safety Analysis Report ("FSAR") which you contend Applicants have relied upon Westinghouse to prepare.
12-2. With respect to each portion of the FSAR identified in your response to Interrogatory 11-2, please specify the information which you contend Westinghouse provided with respect to those sections.
13-2. What are your baces for your responses to Interroga-tories 11-2 and 12-27 14-2. Precisely what role do you contend Westinghouse played in preparing those protions of the FSAR iden-tified in your response to Interrogatory 11-27 15-2. What is your basis for your response to Interrogatory 14-2?
m
1 1
i 4
16-2. With respect to each portion of the FSAR identified in your response to Interrogatory 11-2, please specify the particular NRC licensing requirements which you contend require the Applicants to provide all the information or analysis which you contend was provided by Westinghouse.
17-2. With respect to each portion of the FSAR identified in your response to Interrogatory 11-2, please set forth with particularity the associated technical capabilities which you contend Applicants do not have which are required fcr operation of Comanche Peak.
18-2. What are your bases (legal and/or other) for your responses to Interrogatories 16-2 and 17-27 19-2. With respect to each of the sections of the FSAR identified in your response tc Interrogatory 11-2, please set forth with particularity the reasons for your allegation that Applicants do not have technical qualifications in the areas dealt with in those FSAR sections.
20-2. What is your basis (legal and/or other) for your response to Interrogatory 19-27 21-2. What do you contend the Applicants must do to demon-strate that they have the technical qualifications or capabilities identified in your response to Interrogatory 17-27 22-2. What is your basis (legal and/or other) for your response to Interrogatory 21-27 23-2. Do you contend that the Applicants must prepare or supply all data, information or analyses used in the FSAR7
, 24-2. If your response to Interrogatory 23-2 is in the l affirmative, please specify the particualr NRC licensing requirements which you contend require the Applicants to prepare or supply all data, information or analysis in the FSAR? l 25-2. If your response to Interrogatory 23-2 is in the negative, what data, information and analysis do you contend the Applicants are required to supply in the i FSAR?
f t
26-2. What are your bases (legal and/or other) for your responses to Interrogatories 23-2 to 25-27 27-2. Do you contend that the NRC Staff review of the FSAR is unable to determine whether the Applicants are technically qualified to operate Comanche Peak?
28-2. If your answer to Interrogatory 27-2 is in the affirmative, please specify the aspects of that review which you contend are inadequate.
29-2. If your response to Interrogatory 27-2 is in the affirmative, what do you contend Applicants must do to assure that the NRC Staff review of the FSAR will determine whether Applicants are technically qualified to operate Comanche Peak?
30-2. What are your bases (legal and/or other) for your responses to Interrogatories 27-2 through 29-27 31-2. Do you contend that Applicants must supply additional information to demonstrate that they are technically qualified to operate Comanche Peak?
32-2. If your response to Interrogatory 31-2 is in the affirmative, please identify with 1pecificity the information which you contend Applicants must supply and in what manner that information is to be supplied?
33-2. If your response Interrogatory 31-2 is in the affir-mative please specify how you contend the information identified in your response to Interrogatory 32-2 demonstrates the Applicants ' technical qualifications to operate Comanche Peak.
34-2. What are your bases (legal and/or other) for your responses to Interrogatories 31-2 through 33-27 35-2. Do you contend that the FSAR is the only source of information for determining whether the Applicants are technically qualified to operate Comanche Peak?
36-2. If your response to Interrogatory 35-2 is in the affirmative, what is your basis (legal and/or other) for that response?
37-2. If your response to Interrogatory 35-2 is in the negative, what other means do you contend Applicants 3 have available to demonstrate their technical quali-fications to operate Comanche Peak?
i 38-2. Please set forth with specificity the particular NRC licansing requirements which you contend require that the Applicants use those other means identified in your response to Interrogatory 37-2 to demonstrate the technical capabilities which you contend Applicants do not have with respect to the operation of Comanche
. peak.
39-2. What are your bases (legal and/or other) for your responses to Interrogatories 37-2 and 38-27 Contention 6: There is no assurance that the Spent Fuel Fool area can withstand the effects of tornadoes, as required by 10 C.F.R. Part 50, Appendix A, Criterion 2 because:
- a. The analyses upon which the Design Basis Tornado (DBT) is [ sic] based on [ sic] perfunctory, outdated and unreliable;
- b. The loading analyses based on the Design Basis Tornado (DBT) are inappropriate because they fail to consider the potential loading combination of the DBT and a tornado-generated missile.
~.
- c. The assignment of a loading factor of 1.0 for load combination equations incorporating tornado loadings in combination with " normal and accident conditions" is unacceptable.
- d. The DBT parameters used in FSAR Section 3.3.2.1 are less conservative that the parameters found in NRC Regulatory Guide 1.76.c.2.
40-2. Please state in your own words the meaning of Conten-tion 6.
41-2. What is your basis for Contention 6? Please list all documents not elsewhere identified upon which you rely with respect to Contention 6. Please provide copies of all such documents for inspection and copying.
42-2. Have you prepared any report, study or analysis with respect to Contention 67 If so, please identify each such report, study or analysis by subject and author, including the author's professional and educational
~
t background. Please provide each such report, study or analysis for inspection and copying.
43-2. Have you caused others to prepare any report, study or analysis with respect to Contention 6? If so, please identify each such report, study or analysis by subject and author, including the professional and educational backgr6und of the author. Please provide for inspection and copying each such report, study or analysis on tich you intend to rely.
44-2. What are the dates of the meetings or contacts you have had with the other intervening parties with respect to Contentio- 67 Please specify the purpose of such meetings or contacts and the results of such meetings or contacts.
45-2. What are the dates of the meetings or contacts you have had with persons other than the intervening parties with respect to Contention 6? Please identify the purpose and dates of those meetings or contacts, the other persons involved, and the results of such meetings or contacts.
46-2. Do you plan to participate in the upcoming hearing with respect to Contention 6? If so, what will be the extent of your participation?
! 47-2. Do you plan to file testimony in the upcoming hearing with respect to Contention 6? If so, who will be the sponsor (i.e., witness) of that testimony? Please set forth the nature of such testimony and the l
professional and educational background of the witness. Please provide copies of that testimony.
Also, please identify by title, subject matter and author, and provide for inspection and copying, any documents which any such testimony will rely upon.
i 48-2. Do you plan to call any witness in the upcoming hearing with respect to Contention 6? If so, please provide a summary of his or her professional and educational background. Also, set forth any informa-tion which has a bearing on his or her qualifications to testify in this proceeding on Contention 6.
i j 49-2. If you plan to call any witness in the upcoming l hearing with respect to contention 6, please specify i the nature and scope of that person's testimony.
l Please provide copies of such testimony. Please
~ - . _- . _ . . - _ . . . . -
~9-state whether that witness has conducted any research or made any studies on which the witness intends to rely. Also, identify by title, subject matter, and author, and provide for inspection and copying, any document on which such witness will rely in their testimony with regard to Contention 6.
50-2. Have you reviewed the Applicants' FSAR? If not, please explain. If so, please answer the following:
- a. Do you object to any of the information, data or analysis contained or referenced therein with respect to the effects of tornadoes on the spent fuel pool area?
D. 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 objection.
- c. What are your bases (legal and/or other) for your responses to a. and b.?
51-2. Please specify the analyses of the Design Basis Tornado (DBT) which you contend are inadequate.
52-2. With respect to the analyses identified in your response to Interrogatory 51-2 please set forth with particularity the data, assumptions or computations which you contend are inadequate.
53-2. What are your bases (legal and/or other) for your responses to Interrogatories 51-2 and 52-27 54-2. With respect to the data, assumptions, computations identified in your response to Interrogatory 52-2, please specify the precise manner in which those items are inadequate and set forth with particularity the data, assumptions or computations and any other information which you contend should be utilized in their place.
55-2. What is your basis (legal and/or other) for your response to Interrogatory 54-2?
56-2. Please set forth with specificity the structures, equipment and any other componants that you consider to be included in the'" spent fuel pool area",
i I
i N
k 57-2. What is your basis (legal and/or other) for your response to Interrogatory 56-27 58-2. What loading analyses do you contend are inappropri-ate because they fall to consider the loading combination of a DBT and a tornado-generated missile?
59-2. Please specify the loads or loading combinations which you contend have not been adequately considered.
60-2. What are the sources of the loads or loading ccm-binations identified in your response to Inter-rogatory 59-27 61-2. What are the correct magnitudes of the loads or loading combinations identified in your response to Interrogatory 59-27 62-2. What are your bases (legal and/or other) for your responses to Interrogatories 58-2 through 61-27 63-2. What are the consequences which you contend would occur if the loads or load combinations identified in Interrogatory 59-2 are not considered for the spent fuel pool area?
64-2. What are the maximum loads or loading combinations which you contend the spent fuel pool building can withstand?
65-2. With respect to your response to Interrogatory 64-2 please provide all assumptions, data and computations on which you base your response.
66-2. What are your bases (legal and/or other) for your responses to Interrogatories 63-2 through 65-27 67-2. What do you contend the Applicants must demonstrate in order to show that the loading combination of the DBT and a tornado-generated missile have been adequately considered?
68-2. What is your basis (legal and/or other) for your response to Interrogatory 67-27 69-2. What kind of tornado-generated misailes do you contend should be considered in loading analyses?
~
70-2. For your response to Interrogatory 69-2 please specify the mass, dimensions, velocity and kinetic energy of each such missile.
71-2. What are your bases (legal and/or other) for your responses to Interrogatories 69-2 and 70-2 ?
72-2. What loading factor do you contend should be used in load combination equations incorporating tornado loadings in combination with " normal and accident condi tions "?
73-2. What do you consider to be the purpose of the loading factor used in loading combination equations with respect to tornado loads?
74-2. Do you contend that use of the loading factor for tornado loadings identified in your response to Interrogatory 72-2 vould result in a finding that the structures, equipment or other compenents in the spent fuel pool area are unable to withstand the effects of a tornado and perform their safety functions?
75-2. What considerations do you contend should be utilized in determining the loading factor to be used in load combination equations for any particular load?
76-2. With respect to the loading factor for tornado loadings and load combination equations, do you contend that it is improper to consider the probability of a tornado load occuring at any specific point?
77-2. If your response to Interrogatory 76-2 is in the negative, please explain how you believe such probability should be factored into the determination of the loading factor for load combination equations incorporating tornado loadings?
78-2. If your response to Interrogatory 76-2 is in the affirmative, please explain in detail why you contend that probability should not be considered in deter-mining the loading factor?
79-2. Do you contend that it is improper to consider the duration of tornado loadings in determining the leading factor for load combination equations usi.1g the tornado loadings? l
I 80-2. If your response to Interrogatory 79-2 is in the negative, please specify the manner in which you contend the loading duration should be considered in determining the loading factor for tornado loadings to be used in load combination equations.
81-2. If your response to Interrogatory 79-2 is in the affirmative, please explain in detail why you believe the duration of the load should not be considered in determining the loading factor for tornado loadings used in load ccmbination equations?
82-2. What are your bases (legal and/or other) for your responses to Interrogatories 72-2 through 81-27 83-2. Which DBT parameters used in FSAR 53.3.2.1 do you contend are less conservative than tha parameters found in NRC Regulator *z Guide 1.76.c.27 84-2. With respect to each of the parameters identified by you in your response to Interrogatory 83-2, l please set forth what you mean by the term "less cons e rva tive . "
85-2. Do you contend that the Applicants are required to utilize the DBT parameters found in Reg. Guide
, 1.767 86-2. What are your bases (legal and/or other) for your responses to Interrogatories 83-2 through 85-27 87-2. With respect to each of the parameters identified in your response to Interrogatory 83-2, please specify precisely how use of those parameters affects the design of structures, systems and components important to safety in the spent fuel pool area with respect to their ability to withstand the effects of the DBT without loss of their capability to perform safety functions. What is your basis (legal and/or other) for your response?
88-2. If your response to Interrogatory 85-2 is in the affirmative, do you contend that the structures, systems and components important .o safety in the spent fuel pool area would be unable to withstand the effects of a tornado with the parameters in Reg.
Guide 1.76?
- 89-2. .If your response to Interrogatory 88-2 is in the affirmative, please set forth with particularity the assumptions, data, computations or any other informa-tion you have used in making an analysis to support your response.
90-2. If your response to Interrogatory 88-2 is - La the affirmative and you have not conducted any analysis to support that conclusion please set forth with particularity your basis for that conclusion. I 91-2. Do you contend that the loads induced by the DBT in the spent fuel pool area are the maximum loads which i would be induced by any natural phenomenon?
92-2. If your response to Interrogatory 91-2 is in the 8
affirmative, please set forth in detail your analysis to reach that conclusion.
93-2. If you have not performed an analysis requested in Interrogatory 92-2, please set forth your basis (legal
, and/or other) for your response to Interrogatory 91-2.
94-2. If your response to Interrogatory 91-2 is in the negative, what natural phenomenon that would occur at Comamche Peak do you contend would cause the greatest
, loads on the spent fuel pool area 7 i 95-2. Please set forth with particularity the loadings caused by the natural phenomenon identified in your response to Interrogatory 94-2.
96-2. What are your bases (legal and/or other) for your
- responses to Interrogatories 94-2 and 95-27 97-2. Do you contend that the DBT parameters used in the FSAR do not permit a design basis for structures, systems and components in the spent fuel pool area
^
that reflects an appropriate consideration of the ,
most severe tornado historically reported for the l area surrounding Comanche Peak including a suf- '
! ficient margin to account for the limited accuracy, quantity, and period of time in which the historical
- data on tornadcas have been accumulated?
98-2. If your response to Interrogatory 97-2 is in the affirmative, what are the DBT parameters which you contend should be used in the design basis for i
i
i l
l structures, systems and components important to safety in the spent fuel pool area?
99-2. What are your bases (legal and/or other) for your responses to Interrogatories 97-2 and 98-27 Respec f ly submitted, .
I- <b NicholsS . Reynolds
" 0 William A. Horin DEBEVOISE & LIBERMAN 1200 - 17th Street, N.W.
Washington, D.C. 20036 . .
(202) 857-9817 Counsel for Applicants t-i March 2, 1981 i
i