ML20008G153

Answers to Citizens for Fair Util Regulation 810415 Third Set of Interrogatories Directed to Applicant & Requests to Produce Documents.Responses Assume Interrogatories Re Contention 3.Certificate of Svc Encl.Related Correspondence

ML20008G153
Person / Time
Site:	Comanche Peak
Issue date:	05/04/1981
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8107020365
Download: ML20008G153 (7)

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Ig BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, _e t _al . ) 50-446 (Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)

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APPLICANTS' ANSWERS TO CFUR'S THIRD 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 Third Set of Interrogatories to Applicant [ sic]

and Requests to Produce," served April 15, 1981. 1/ CFUR does not request production of any documents, contrary to the indication given in the heading of its pleading. Thus, Appli-cants need not provide any further response with regard to requests for production of documents in that document.

I. General Comments As with CFUR's first and second sets of interrogatories, CFUR does not identify in this third set the contention at

$P 1 1/ The date on the first page of CFUR's interroga to ries is O March 14, 1981. However, the attached certificate of service indicates the interrogatories were served April 15, 1981. Applicants have responded based on the date -

service was made.

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which each of the interrogatories is directed. It appears to the Applicants that the interrogatories are directed solely at Contention 3. Accordingly, Applicants responses f

are predicated on the assumption that the interrogatories are concerned with Contention 3, which reads, as follows:

Contention 3: The computer codes used in [the]

CPSES/FSAR must be tested and, if necessary, modified to accept the parameters reflecting the sequence of events at Three Mile Island and then to realistically predict plant behavior.

II. Answers to CTUR's Interrogatories Each answer is identified by the number of the corresponding interrogatory as set forth in CFUR's Third Set of Interrogatories.

1. Applicants object to this interrogatory as seeking informa-tion which is irrelevant to Contention 3. That contention is concerned solely with the ability of the Applicants' computer codes to model the sequence of events at TMI and to predict resulting plant behavior. The interrogatory seeks information concerning a research program which r consists of generic tests of reactor response to hypothetical large break loss-of-coolant accidents ("LOCA's"), while the l

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! " parameters relecting the sequence of events at Three Mile Island" are unrelated to a large break LOCA event sequence.

Accordingly, the ability of the Applicants' computer I

codes to predict the " actual results" of that research program is irrelevant to the issue raised in Contention 3.

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2. Not applicable.

3. Not applicable.

4. - Applicants object to this interrogatory on the same grounds as set forth in the response to Interrogatory 1.

5. Not applicable.

6. Not applicable.

7. Applicants' computer codes conservatively predict the results of the Semiscale and LOFT small break test series. An evaluation of this matter is being conduct-ed by the Applicants in concert with the Westinghouse Owners Group (WOG) pursuant to NRC Action Plan Items I.C.1, II.K.3.5, II.K.3.30. The WOG reports on this matter were transmitted to the NRC on the following dates; October 26 and December 15, 1979, and March 3, 1981. As a result of an April 24, 1981 meeting between WOG and NRC, the WOG will transmit to the NRC in the near future a report documenting differences between the predicted results and the actual results of the l

I appropriate LOFT and Semiscale small break tests.

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8. See response to Interrogatory 7.

[ 9. Not applicable.

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10. See response to Interrogatory 7.

11. See response to Interrogatory 7.

12. Not applicable.

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13. This information is not known to Applicants.

14. Not applicable.

15. Not applicable.

16. This information is not known to Applicants.

17. Not applicable.

18. Not applicable.

19. To the extent this interrogatory concerns "the inquired-about Test Series [and] Experiments" in Interrogatories 1 and 4, Applicants object on the c ounds set forth in their responses to those interrogatories. To the extent this interrogatory concerns "the inquired-about Test Series [and] Experiments" in Interrogatories 7 and 10, Applicants respond as follows: None of which the Applicants are aware. To the extent the interrogatory concerns the "NRC Staff's computer codes," see responses to Interrogatories 13 and 16.

20. Not applicable.

I,0, r Nichol s . Reynolds William A. Horin DESEVOISE & LIBERMM 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 202-857-9817 May 4, 1981 Counsel for Applicants i

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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 ) 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)

CERTIFICATE OF SERVICE I hereby certify tha copies of the foregoing "Appli-cants' Answers to CFUR's Third 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 4th day of May, 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 Dr. Forrect J. Remick, Member Marjorie Ulman Rothschild, Esq.

Atomic Safety and Licensing Office of the Executive Board Legal Director 305 E. Hamilton Avenue U.S. Nuclear Regulatory State College, Pennsylvania 16801 Commission Ja s% ington , D.C. 20555 Dr. Richard Cole, Member Atomic Safety and Licensing

• L. .. J. Preister, Esq.

I Board Ass.stant Attorney General i

U.S. Nuclear Regulatory Environmental Protection Commission Division

" Washington, D.C. 20555 P.O. Box 12548 i

Capitol Station Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S. Nuclear Regulatory Mr. Richard L. Fouke l Ccmmission CFUR Washington, D.C. 20555 1668B Carter Drive Arlington, Texas 76010 l

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2-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 Pegulatory Commission Mrs. Juanita Ellis Washington, D.C. 20555 President, CASE 1426 South Polk Street Dallas, Texas 75224

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

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