ML19350D430

Answers to Citizens for Fair Util Regulation 810324 First Set of Interrogatories Re Contention 1.Objects to Interrogatories 1,2,3,9,11,12,13 & 17 & Objects in Part to 5 & 7.Certificate of Svc Encl.Related Correspondence

ML19350D430
Person / Time
Site:	Comanche Peak
Issue date:	04/13/1981
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	CITIZENS FOR FAIR UTILITY REGULATION
References
NUDOCS 8104150476
Download: ML19350D430 (11)

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L RELATED CORRESPONDENCB April 13, 1981 9'

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OOI A UNITED STATES OF AMERICA 9

=D'ter i NUCLEAR REGULATORY COMMISSION cocx:!TLD uesne , g FORE THE ATOMIC SAFETY AND LICENSING BOA g g4$81*

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In the Matter of ) . . ,J

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TEXAS 'JTILITIES GENERATING ) Docket Nos. 50-445 e ;c COMPANY, _et _al. ) 50-446

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(Cemanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)

APPLICANTS' ANSWERS TO CFUR'S FIRST SET OF INTERROGATORIES Pursuant to 10 C.F.R. $2.740(b), Texas Utilities Generat-ing Company, et al. (" Applicants") hereby submit answers to "CFUR's First Set of Interrogatories to Applicants," served March 24, 1981.*/ Applicants will respond to CFUR's Requests to Produce included in its First Set of Interrogatories pursuant to and on the schedule set forth in 10 C.F.R. 2.741(d).

I. General Comments CFUR does not identify in its interrogatories the conten-tion at which each interrogatory is directed. It appears to l

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CFUR's interrogatories were mailed to Applicants on March 24, 1981. Applicants were informed by CFUR in a telephone call on that date that Applicants had been l left off the service list when CFUR originally mailed I the interrogatories to the other parties on February 26, l 1981 (which is the date on the first page of the inter-l rogatories). Accordingly, Applicants have provided l timely responses based on the date the interrogatories

! were served on Applicants.

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t the Applicants that the interrogatories are directed solely at issues raised in Contention 1. Accordingly, Applicants have interpreted CFUR's interrogatories as relating to Contention 1, which reads as follows:

Contention 1: Applicants have not demonstrated technical qualifications to operate CPSES in accordance with 10 CFR

$50.57(a)(4) in that they have relied upon Westinghouse to prepare a portion of the Final Safety Analysis Report (FSAR).

Applicants' responses to CFUR's interrogatories are predicated on that interpretation.

II. Answers to CFUR's Interrogatories Each answer is identified by the number of the corres-ponding interrogatory as set forth in CFUR's First Set of Interrogatories.

1. Applicants object to this interrogatory as seeking, in part, information which is irrelevant to Contention 1. That contention is concerned solely with the contribution by the Westinghouse Electric Corporation (" Westinghouse") to the preparation of

! the Final Safety Analysis Report ("FSAR") for the Comanche Peak facility and the Applicants ' technical qualifications to operate the facility in view of those contributions. To the extent this interroga-tory seeks information regarding (1) activities by entities other than Westinghouse and (2) activities other than preparation of the FSAR, the interrogatory seeks information which is irrelevant to Contention 1.

To the extent Applicants deem the interrogatory

to seek relevant information, Applicants respond

as follows:

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( Applicants have relied on Westinghouse to perform l certain analyses, as documented in the FSAR.

l Also, see response to Interrogatory 17.

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2. Applicarits object to this interrogatory to the same extera and on the same grounds as specified in Applicants' answer to Interrogatory 1. To the exte-: the interrogatory seeks information relevant to contention 1, Applicants Jaspond, as follows:

a. Westinghouse

b. Applicants relied upon the " documents, representations and other information" provided by Westinghouse which are either senmarized or referenced in the FSAR.

Also, see response to Interrogatory 17.

c, Approximately 1977 to the present.

d. See response to 2b.

3. Applicants object to this interrogatory to the extent it seeks information concerning "other topical reports" which were not provided by Westinghouse. Such informa-tion is irrelevant to Contention 1. Accordingly, Applicants respond as follows:

Applicants have made no contributions to Westinghouse topical reports. However, Applicants or their repre-sentatives review the applicability of Westinghouse topical reports to the Comanche Peak facility prior to their use in the FSAR.

4. Not applicable.

S. Applicants object to the portions of this inter-rogatory which seek information concerning topical reports not prepared by Westinghouse on the grounds that these portions are irrelevant to Contention 1.

Accordingly, Applicants respond, as follows:

Applicants have not conducted an independent investi-gation or verifiestion of Westinghouse topical reports, other than as described in Applicants' answer to Interrogatory 3.

6. Not applicable.

7. Applicants object to the portions of this interroga-tory which seek information concerning topical reports not prepared by Westinghouse on the grounds that these reports are irrelevant to Contention 1.

Accordingly, Applicants respond, as follows:

Applicants accept the~.sestinghouse topical reports referenced in the FSAR as applicable to and appro-priate for use in the FSAR for the Comanche peak facility.

8. Not applicable.

9 Applicants object to this interrogatory as seeking information which is irrelevant to Contention 1.

This interrogatory is concerned with activities unrelated to Westinghouse's contributions to the preparation of the FSAR and Applicants' technical qualifications to operate the facility in view of those contributions. In addition, the interrogatory is vague in that the meaning and relevancy of the term "to review" are not apparent in the context of the issues raised in Contention 1.

10. Not applicable.

11. Applicants object to this interrogatory as seeking, in part, information which is irrelevant to conten-tion 1. This interrogatory seeks information not related to Westinghouse's contribution to the prepa-ration of the FSAR and Applicants' technical qualifi-cationc to operate the facility in view of those contributions. Accordingly, Applicants respond, as follows:

Applicants have reviewed for applicability to Comanche Peak all analyses provided by Westinghouse which are either included in or referenced in the FSAR.

12. Applicants object to this interrogatory as seeking information not relevant to Contention 1 in that it seeks information not related to Westinghouse's contribution to the preparation of the FSAR and Applicants' technical qualifications to operate the Cccanche Peak facility in view of that contribution.

In addition, Applicants obfect to the interregatory as being vague, in dnat the meaning of the term " safety review or investigation" is not apparent from the

5-context of the interrogatory. Accordingly, Applicants respond, as follows:

Applicants have reviewed for applicability to Comanche peak the information provided by Westinghouse with respect to those sections of the FSAR identified in Applicants' answer to Interrogatory 17, below.

13. Applicants object to this interrogatory as seeking information which is irrelevant to Contention 1.

This interrogatory is concerned with matters other than Westinghouse's contribution to the preparation of the FSAR and the Applicants ' technical qualifications to operate the Comanche peak facility in view of that contribution. In addition, Applicants object to the interrogatory as being vague, in that the meaning of the term "to review ... to insure that safety function will be accomplished" is not apparent from the context of the interrogatory.

14. Not applicable.

15. See response to Interrogatory 13. To the extent the interrogatory seeks relevant information, see response to Interrogatory 5.

16. Not applicable.

17. Applicants object to this interrogatory as seeking, in part, information which is not relevant to Con-tention 1 in that it is not related to Westing-house's contribution to the preparation of the FSAR and Applicants' technical qualifications to

' operate the Comanche Peak facility in view of that contribution. Accordingly, Applicants respond, as follows:

The Applicants relied en Westinghouse to prepare the following sections of the FSAR:

FSAR Section Title l 1.5 Requirements for Further i

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Technical Information l N ._

1.6 Material Incorporated by Reference w'

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FSAR Section Title 3.6N Protection Against Dynamic Effects Associated with the Postulated Rupture of Piping 3.7N Seismic Design 3.9N.1 Special Topics for Mechanical Components 3.9N.2 Dynamic Testing and Analysis 3.9N.3 ASME Code Class 1, 2, and 3 Components, Component Supports, and Core Suport Structures 3.9N.4 Control Rod Drive System 3.9N.5 Reactor Vessel Internals 3.10N Seismic Qualification of Seismic Category I Instrumentation and Electrical Equipment 3.llN Environmental Design of Mechanical and Electrical Equipment l

Chapter 4 Reactor l

5.1 Reactor Coolant System and Control Piping -

Summary Description 5.2 Integrity of Reactor Coolant Pressure Boundary 5.2.1 ' Compliance with Codes and Code Cases 5.2.2 Overpressure Protection l

5.2.3 Reactor Coolant Pressure Boundary Materials

FSAR Section Title 5.2.4 Inservice Inspection and Testing of Reactor Coolant Pressure Boundary 5.3 Reactor Vessel 5.4.1 Reactor Coolant Pumps 5.4.2 Steam Generators 5.4.3 Reactor Coolant Piping 5.4.4 Main Steam Line Flow Restrictions 5.4.6 Reactor Core Isolation Cooling System 5.4.7 Residual Heat Removal System 5.4.10 Pressurizer 5.4.11 Pressurizer Relief Discharge Systems 5.4.12 Valves 5.4.13 Safety and Relief Valves 5.4.14 Component Supports 6.lN Engineered Safety Feature Materials 6.3 Emergency Core Cooling System 6.6 Inservice Inspection .

of Class 2 and 3 Components 9.1.1 New Fuel Storage 9.1.2 Spent Fuel Storage

. FSAR Section Title 9.1.4 Fuel Handling System 9.3.4 Chemical and Volume Control Systim 11.1 Source Terms 11.3 Gaseous Waste Management Chapter 15 Accident Analysis

18. Portions of the following documents contain provisions which relate to agreements be, tween the Applicants and -

Westinghouse with regard to the preparation of the Comanche Peak FSAR:

(1) Contract between the Applicants and Westinghouse for purchase of the Nuclear Steam Supply System, Contract CP-1000, dated October 6, 1972.

(2) Contract between the Applicants and Westinghouse regarding nuclear fuel, Contract CP-5000, dated May 11, 1973.

(3) Agreement of Settlement between the Applicants and Westinghouse, dated December 16, 1977.

19. Applicants will respond to this request for production of documents pursuant to and on the schedule provided in 10 C.F.R. $2.741(d).

20. Not applicable.

o Respectfully submitted, 7 ^ 4/ Mil Nic olas S. Rdfnolds William A. Horin Debevoise & Liberman 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 i (202) 857-9817 Counsel for Applicants April 13, 1981

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STATE OF TEXAS )

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COUf4TY OF DALLAS )

Homer C. Schmidt, being duly sworn, deposes and says:

That he is Manager, Nuclear Services, Texas Utilities Services, Inc., and knows the contents of the foregoing Applicants' Answers to CFUR's First Set of Interrogatories; that the same is true of his own knowledge except.as to matters therein stated on information and belief, and as ,

to that, he believes them to be true.

SWORN to and subscribed

before me on this 9th day of April,1981.

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l ' Notary Publif My Commission Expires:

PAT SLAY, Motary Puoiu:

in and for Dettas county, Texas My comrresnian empires Octomer 29, ((f l

UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

In the Matter of )

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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, e* al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Li. cense)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing' Applicants' Answers to CFUR's First Set of Interrogatories, in the above captioned matter, were served upon the following persons by deposit in the United States mail, first class postage prepaid this 13th day of April, 1981:

Valentine B. Deale, Esq. Chairman, Atomic Safety and Chairman, .itemic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear F# iatory 1001 Connecticut Avenue, N.W. Commissior.

Washington, D.C. 20036 Washington, _.c. 20555 Dr. Forrest J. Remick, Member Marjorie Ulman Rothschild, Esq.

Atomic Safety and Licensing Office of the Executive l Board Legal Director 305 E. Hr. milton Avenue U.S. Nuclear Regulatory State College, Pennsylvania 16901 Commission Washington, D.C. 20555

, Dr. Richard Cole, Member 1 Atcmic Safety and Licensing David J. Preister, Esq.

Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Protection

, Commission Division Wasnington, D.C. 20555 P.O. Box 12548 Capitol Station Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel i

U.S. Nuclear Regulatory Mr. Richard L. Fouke l Commission CFUR l Washington, D.C. 20555 1668B Carter Drive l

Arlington, Texas 76010 i

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i Arch C. McColl, III, Esq. Mr. Geoffrey M. Gay 701 Commerce Street West Texas Legal Services Suite 302 100 Main Street (Lawyers Bldg.)

Dallas, Texas 75202 Fort Worth, Texas 76102 I

Jeffery L. Hart, Esq. Mr. Chase R. Stephens  ;

4021 Prescott Avenue Docketing & Service Branch Dallas, Texas 75219 U.S. Nuclear Regulatory Commission Mrs. Juanita Ellis Washington, D.C. 20555 President, CASE 1426 South Polk Street Dallas, Texas 75224

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k William A. Horin cc: Homer C. Schmidt Spencer C. Relyea, Esq.

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