ML20003G635

Answers to Citizens for Fair Util Requlation 810409 Second Set of Interrogatories Directed to Applicant.Affidavit & Certificate of Svc Encl.Related Correspondence

ML20003G635
Person / Time
Site:	Comanche Peak
Issue date:	04/28/1981
From:	Horin W, Reynolds N, Reynolds W DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	CITIZENS FOR FAIR UTILITY REGULATION
References
NUDOCS 8104300321
Download: ML20003G635 (8)

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In the, Matter of )

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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, -et_al. ) 50-446

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

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APPLICANTS' ANSWERS TO CFUR's SECOND SET OF INTERROGATORIES Pursuant to 10 C.F.R. $ 2.740(b), Texas Utilities Gener-ating Company, et al. (" Applicants") hereby submit answers to "CFUR's Second Set of Interrogatories to Applicant [ sic]"

served April 9, 1981. Applicants will respond to CFUR's requests to produce included in its second set of interrogatories pursuant to and on the schedule set forth in 10 C. F. R. I 2.741(d).

I. General Comments As with CFUR's first set of interrogatories, CFUR does not identify in this second set the contention at which each of the interrogatories is directed. It appears to the Applicants that the interrogatories are directed solely at Contention 7.

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Accordingly, Applicants' responses are predicated on the assump-tion that the interrogatories are concerned solely with conten-tion 7, which reads, as follows:

Contention 7: Applicants have failed to-adequately evaluate whether the rock "overbreak" and subsequent fissure repair using concrete grout have impaired .the ability of category I structures to withstand seismic disturbances.

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

1. Unit 1 - Yes.

Unit 2 - Yes.

2. a. Unit 1: Rock overbreak resulted from blasting activities on the Unit 1 Category I Power Block Structures from late January to early Feb rua ry, 1975.

Unit 2: Rock overbreak resulted from blasting activities on the Unit 2 Category I Power Block Structures from late January to early February, 1975.

The fissure repair activities necessitated by the above occurrences of rock overbreak were performed as described in FSAR Section 2.5.4.12 and were completed in May, 1980.

b. The following documentation contains information pertinent to the above instances of rock over-break and fissure repair:

FSAR Section 2.5.4.5 and response to NRC Question 362.15, FSAR p. 362-16.

Geologic sections.

Fracture maps.

Photographs.

Correspondence.

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c. Applicants will respond to this request for production of documents pursuant to and on the schedule provided for in 10 C.F.R.

I 2.741(d).

d. The following entities were involved in the excavation for Units 1 and 2 during the period l when rock overbraak occurred and fissure repair was effected. The dates of their involvement -

in the excavations of category I structures are listed below Mason-Johnston & Associates (January 1975 to October 1975)

' Brown & Root, Inc. (January 1975 to October 1975)

Texas Utilities Services, Inc. (January 1975 to October 1975)

Gibbs & Hill, Inc. (January 1975 to October 1975) i j 3-6. See response to Interrogatory 2.d.

7. FSAR Figure 2.5.4-27.

l The documentation listed in response to Interrogatory 2.b.

Appropriate field survey notes.

8 See response to Interrogatory 7.

9. See response to Interrogatory 7, and FSAR Figure 2.5.4-28.

10. See response to Interrogatory 9.

11. Applicants will respond to this request for pro-duction of documents pursuant to and on the schedule provided for in 10 C.F.R. I 2.741(d).

12-17. Applicants object to these interrogatories as seeking information which is irrelevant to Contention 7. That contention is concerned solely with whether Applicants have adequately evaluated the effect of rock overbreak and fis-sure repair on the ability of category I struc-tures to withstand seismic disturbances. These interrogatories seek information concerning the separate and unrelated activity of pouring con-crete for the foundations of Units 1 and 2.

Thus, the information sought is irrelevant to contention 7.

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18. Sea response to Interrogatory 7, FSAR Figures

3 8-1 to 3.8-4 and applicable structural drawings.

19. See response to Interrogatory 18.

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

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21. See response to Interrogatory 18.

22. See response to Interrogatory 18.

l 23. Applicants object to this interrgatory as seeking

! information which is irrelevant to Contention 7.

That contention is concerned solely with whether Applicants have adequately evaluated 4

the effect of rock overbreak and fissure repair on the ability of category I structures to withstand seismic disturbances. These interroga-

tories seek information concerning the construc-tion of the foundation or material "placed above unexcavated bedrock" before or during the l pouring of concrete for the foundation of Unit 1.

Such information is irrelevant to the contention.

24. Not applicable.

25. See response to Interrogatory 23.

26. See response to Interrogatory 24.

27-30. Applicants object to these interrogatories as seeking information which is irrelevant to contention 7. That contention is concerned solely with whether Applicants have adequately evaluated the effect of rock overbreak and fis-sure repair on the ability of category I struc-tures to withstand seismic disturbances. These interrogatories seek information concerning the separate and unrelated activity of pouring con-crate for the foundations of Units 1 and 2.

Thus, the information sought is irrelevant to contention 7.

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31. Not applicable.

Respectfully submitted, i

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$/WM Nicho as S. Reynol s

, GdL aL William A. Horin DEBEVOISE & LIBERMAN 1200 Seventeenth Street N.W.

Washington, D.C. 20036 (202) 857-9817 Counsel for Applicants April 28, 1981 i

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STATE OF TEXAS )

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CGb5TY 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 Second 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.

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SWORN to and subscribed before me on this 27th day of April,1981.

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l Notary Public l

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

In the Matter of I l I TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, et al.i

) 50-446

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(Comanche Peak St'eam Electric ) (Application for Station, Units 1 and 2) ) Operating License)

, CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' Answers to CFUR's Second Set of Interrogatories" in the above captioned m'atter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 28th day of April, 1981:

Valentine B. Deale, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board. U.S. Nuclear Regulatory 1001 Connecticut Avenue, N.W. Commission Washington, D.C. 20036 Washington, D.C. 20555 l Dr. Forrest J. Remick, Member Marjorie Ulman Rothschild, Esq-l Atomic Safety and Licensing Office of the Executive Board Legal Director 305 E. Hamilton Avenue U.S. Nuclear Regulatory State College, Pe'nnsylvania 16801 Commission Washington, D.C. 20555 Dr. Richard Cole, Member Atomic Safety and Licensing David J. Preister, Esq.

l Board Assistant Attorney General U.S. Nuclear Regulltory Environmental Protection Commission Division Washington, D.C. 20555 P.O. Box 12548 Capitol Station Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S. Nuclear Regulatory Mr. Richard L. Fouke Commission CFUR Washington, D.C. 20555 1668B Carter Drive Arlington, Texas 76010 i

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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 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 William A. Horin

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Homer C. Schmidt l Spencer C. Relyea, Esq.

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