ML19343D360

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Third Set of Interrogatories & Requests to Produce Directed to Util Re Inconsistencies Between Util Accident Series Computer Codes & Semiscale Large Break Test Series. Certificate of Svc Encl.Related Correspondence
ML19343D360
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/14/1981
From: Mccoll A
CITIZENS FOR FAIR UTILITY REGULATION, MCCOLL, A.C.
To:
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8105040340
Download: ML19343D360 (8)
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N March 14,1981 i'

pp C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD )

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.- In the Matter of 4 M .C ggo I stGG 3 TEXAS UTILITIES GENERATING Q Docket Nos. 50-445 Ot- -

COMPANY, et at i 50-446  ; $g <37

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CFUR'S THIRD SET OF INTERROGATORIES TO APPLICANT AND REQUESTS TO PRODUCE Pursuant to 10 C.F.R. 002.740b and 2.741, Citizens for Fair Utility Regulation

("CFUR"), hereby serves CFUR's Third Set of Interrogatories and Requests to Produce upon Texas Utilities Generating Company, et al ' (" Applicants"). Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent information known to Applicant, its officers, directors or members as well as any pertinent 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 Applicant, its officers, directors or members as well as its employees, advisors or counsel. In answering each interrogatory and in responding to each request, please recite the interrogatory or request preceding each answer or response.

These interrogatories and requests shall be continuing in nature. Thus, any time Applicant obtains information which renders any previous response incorrect or

_ indicates that a response was incorrect when made, Applicant should supplement its previous. response to the app.ropriate interrogatory or request to produce. Applicant should alsq syp ent its responses as necessary with respect to identification of

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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. Tha term

" documents" shall include any writings, drawings, graphs, charts, photographs, .and

,- other data compilations from which information can be obtained. We request that at a date or dates to be agreed upon, Applicant make available for inspection and copying all documents subject to the requests set forth below.

I.

CFUR'S INTERROGATORIES AND REQUESTS TO PRODUCE

1. Are there any inconsistencies, regardless of how small, between the predicted results of any of the Applicants' accident series computer codes used in connection with CPSES and the actual results obtained in the Semiscale Large Break Test Series?
2. If your response to the preceding interrogatory is anything but "No," please answer the following:
a. Describe in detail each result inconsistency between the Semiscale Large Break Test Series and the computer code involved;
b. Describe with particularity all documents which reflect any inconsistency described in your response to the preceding sub-part of this interrogatory;
c. State the name, business address, business telephone number," employer and business position of each person who has knowledge of any inconsistency described;
d. For each of the Applicants' computer codes not described in your response to the preceding sub-parts of this interrogatory, describe with particularity all documents which reflect the consistency between such computer codes and the Semiscale Large Break Test Series.
3. If your response to Interrogatory One is "No," please answer the following:
a. Describe with particularity all documents which reflect the consistency between the results of Semiscale Large Break Test Series and each computer code involved;
b. State the name, business address, business telephone number, employer and business position of each person who has firsthand knowledge of the

. consistency- between the Semiscale Large Break Test Series and each ec 7puter code involved. .

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4. Are there any inconsistencies,- regardless of how small, between the predicted 1

results of any of the Applicants' accident series computer codes used in connection _ with CPSES and the actual results obtained in the LOFT Large Break Experiments?

5. If your response the preceding interrogatory is anything but "No," please

. ~ answer the followmg: .

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a. Describe V detail each result inconsistency between the LOFT Large Brea' ,,.ariments and the computer code involved;
b. Describe with particularity all documents which reflect any inconsistency described in your response to the preceding sub-part of this interrogato y;
c. State the name, business address, business telephone number, employer and business . position of each person who has knowledge of any inconsistency described;
d. For each of the Applicants' computer codes not described in your response to the preceding sub-parts of this interrogatory, describe-with particularity all documents which reflect the consistency between such computer. codes and the LOFT Large Break Experiments.
6. If your response to Interrogatory Four is "No," please answer the following:
a. Describe with particularity all documents which reflect the consistency between the results of LOFT Large Break Experiments and each computer code involved;
b. State the name, business address, business telephone number,. employer and business position of each preson who has firsthand knowledge of the

, consistency between the LOFT Large Break Experiments and each

computer code involved. ,

! 7. Are ther'e any inconsistencies, regardless of how small, between the predicted

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results of any of the Applicants' accident series computer codes used in connection with CPSES and the actual results obtained in the Semiscale Small Break Test Series?

8. If your response to the preceding interrogatory is anything but "No," please answer the following:
a. Describe in detail each result inconsistency between the Semiscale Small ~

Break Test Series and the computer code involved;

__ b. Describe with particularity all documents which reflect any inconsistency described in your response to the preceding sub-part of this interrogatory;

c. State the name, business address, business telephone number, employer and business position of each person who has knowledge of any inconsistency described; h

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d. For each of the Applicants' computer codes not described in your response to the preceding sub-parts of this interrogatory, describe with particularity all documents which reflect the consistency between such computer codes and the Semiscale Small Break Test Series.
9. 'If your response to Interrogatory Seven is "No," please answer the following:
a. Describe with particularity all documents which reflect the consistency between the results of Semiscale Small Break Test Series and each computer code involved;
b. State the name, business address, business telephone number, employer and business position of each person who has firsthand knowledge of the consistency between the Semiscale Small Break Test Series and each computer code involved.
10. Are there any inconsistencies, regardless of how small, between the predicted results of any of the Applicants' accident series computer codes used in connection with CPSES and the actual results obtained in the LOFT Small Break Experiments?
11. If your response to the preceding interrogatory is anything but "No," please answer the following:
a. Describe in deteil each result inconsistency between the LOFT Small Break Experiments 6nd the computer code involved;
b. Describe with particularity all documents which reflect any inconsistency described in your response to the preceding sub-part of this interrogatory;
c. State the name, business address,-business telephone number, employer and business position of each person who has knowledge of any inconsistency described;
d. For each of the Applicants' computer codes not described in your response to the preceding sub-parts of this interrogatory, describe with particularity all documents which reflect the consistency between such computer codes and the LOFT Small Break Experiments.
12. If your response to Interrogatory Ten is "No," please answer the following:
a. Describe with particularity all documents which reflect the consistency between the results of LOFT Small Break Experiments and each computer code involved.
b. State the name, business address, business telephone number, employer and business position of each person who has firsthand knowledge of the consistency, between the LOFT Small Break Experiments and ea^h computer code involved.

- 13. Are there any inconsistencies, regardless of how small, between the predicted results of any of the Applicants' accident series computer codes used in connection with CPSES and the predicted results of any of the NRC Staff's computer codes used in connection with CPSES for large break accidents?

14. If your response to the preceding interrogatory is anything but "No," please answer the following:
a. Describe in detail each result inconsistency between the Applicants' computer codes and the NRC Staff's computer codes used in connection with CPSES for large break accidents;
b. Describe with pareticularity all documents which reflect any inconsis-tency described in your response to the. preceding sub-part of this interrogatory;
c. State the name, business address, business telephone number, employer and business position of each person who has knowledge of any inconsistency described;
d. For each of the Applicants' computer codes not described in your response to the preceding sub-parts of this interrogatory, describe with particularity all documents which reflect the consistency between such computer codes and the NRC Staff's computer codes used in connection with CPSES for large break accidents.
15. If your response to Interrogatory Thirteen is "No," please answer the following:
a. Describe with particularity all documents which reflect the consistency between the predicted results of the NRC Staff's computer codes used in connection with CPSES for for large break accidents and each of the Applicants' computer codes;
b. State the name, business address, businesphone number, employer, and business position of each person who has firsthand knowledge of the consistency between the predicted results of the NRC Staff's computer codes used in connection with CPSES for large break accidents and each of the Applicants' computer codes.
16. Are there any inconsistencies, regardles of how small, between the predicted results of any of the Applicants' accident scies co.nputer codes used in connection with CPSES and the predicted results of any of the NRC Staff's computer codes used in connection with CPSES for small break accidents?
17. If your response to the preceding interrogatory is anything but "No," please answer the following: ,
a. - Describe in detail- each result inconsistency between the Applicants' -

computer codes and the NRC Staff's computcr codes used in connection with CPSES for s:nall break accidents; L

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b. Describe with particularity all documents which reflect any inconsistency described in your response to the preceding sub-part of this interrogatory;
c. State the name, business address, business telephone n'imber, employer and business positlen of each person who has knowledge of any inconsistency described;
d. For each of the Applicants' computer codes not described in your response to the preceding sub-parts of this interrogatory, describe with particularity all doeurnents which reflect the consistency between such 4

computer codes and the NRC Staff's computer codes used in connection i with CPSEs for small break accidents.

18. If your response to Interrogatory Fifteen is "No," please answer the following: .
a. Describe with particularity all documents which reflect the consistency.

between the predicted results of the NRC Staff's computer codes used in' connection with CPSES for small break accidents and each of the Applicants' computer codes; l

b. State the name, business address, business telephone number, employer, and business position of each person who has firsthand knowledge of the consistency between the predicted results of the NRC Staff's computer-codes used in connection with CPSES for small break accidents and each of the Applicants' computer codes.
19. Other tha.1 what is contained in your responses to the preceding eighteen interrogatories, is there ' any other documentation or information which demonstrates the consistency or inconsistency between the Applicants' acci-dent series computer codes used in connection with CPSEs and the. inquired--

about Test Series, Experiments and NRC Staff's computer codes?

20. If your response to the preceding interrogatory is anything other than "No,"

please answer the following:

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a. Describe in reasonable detail all documents and information to which you have reference which demonstrate consistency;
b. Describe in reasonable detail all documents and information to which you have reference which demonstrate inconsistency.
Res ectfully submitted,

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. _ A H C. McCOLL, III -

The Katy Building, Suite 302 701 Commerce Street' Dallas, Texas 75202 (214)744-5044 s

JEFFERY L. HART 4021 Prescott Avenue Dallas, Texas 75219 (214)521-4852 we rw y m -

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '

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In the Matter of i g TEXAS UTILITIES GENERATING Docket Nos. 50-445 $' y COMPANY, et al i 50-446 --

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(Comanche Peak Steam Electric (Application for Y Station, Units 1 and 2) i Operating License) C#

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'u 10 0 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "CFUR's Third Set of Interrcgatories to Applicant and Requests to Produce," in the captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 15th day of April,1981:

Valentine B. Deale, Esq. Chairman, Atomic Safety Chairman, Atomic Safety and and Licensing Board Panel

. Licensing Board U.S. Nuclear Regulatory 1001 Connecticut Avenue, N.W. Commission Washington, D.C. 20036 Washington, D.C. 20555 Nicholas S. Reynolds, Esq. Chairman, Atomic Safety and Debevoise & Literman Licensing Appeal Panel 1200 - 17th Street, N.W. U.S. Nuclear Regulatory Commission Washington, D.C. 20036 Washington, D.C. 20555 Dr. Forrest J. Remick, Member Marjorie Ulman Rothschild, Esq.

Atomic Safety and Licensing Office of the Executive Legal Director Board U.S. Nuclear Regulatory Commission 305 E. Hamilton Avenue Washington, D.C. 20555 State College, Pennsylvania 16801 Dr. Richard Cole, Member David J. Preister, Esq.

Atomic Safety and Licensing Assistant Attorney General Board Environmental Protection Division U.S. Nuclear Regulatory P. O. Box 12548

- Commissior- Capitol Station .

Washington, D.1 20555 Austin, Texas 78711 l

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Mr. Richard L. Fouke Mrs. Juanita Ellis CFUR President, CASE 1668B Carter Drive 1426 South Polk Street-Arlington, Texas - 76010 Dallas, Texas 75224 Jeffery L. Hart, Esq. Mr. Geoffrey M. Gay

.' 4021. Prescott Avenue West Texas Legal Services Dallas, Texas 75219 100 Main Street (Lawyers Building)

Fort Worth, Texas _76102 ~

Mr. _ Chase R. Stephens Docketing & Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 jle Lb [LdtT'3 ARCH C. McCOLL, Ill i

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