ML20010E392

First Set of Interrogatories Directed to J Doherty Re Doherty Amended Contention 21.Certificate of Svc Encl

ML20010E392
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/02/1981
From:	Black R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Doherty J AFFILIATION NOT ASSIGNED
References
NUDOCS 8109040062
Download: ML20010E392 (5)

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9/2/81 UllITED STATES OF A!! ERICA NOCLEAR REGULATORY COMlilSSION g3.\\

s BEFORE THE AT0 HIC SAFETY AND LICEt1 SING BOARD qs '

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HOUSTON LIGHTIliG AllD POWER COMPANY OocketNo.50-46h-6/

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(Allens Creek lluclear Generating

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Station, Unit 1) dfisil4. j f4RC STAFF FIRST SET OF It4TERROGATORIES RELATING TO DOHERTY AMEf1DED CONTEllTI0ft 21 TO JOHN DOHERTY Pursuent to 10 C.F.R. s2.740b, the following interrogatories are directed to John Doherty relating to his Amended Contention 21.

Each interrogatory is to be answered separately and fully in writing under oath or affirmation.

The answers should be supplemented as required by 92.740(e).

Please do not hesitate to supplement your responses to questions as aure complete answers become available to you. Section 2.740b requires interrogatories to be answered within 14 oays of service.

Five days are added to this time under 52.710 when l

service is by mail.

I With regard to your Amended Contention 21 provide the following information:

1.

Identify the individual (s), if any, that you intend to present as witnesses. The identification should include the individual's name, affiliation, and a summary of educational I

and professional background of each individual.

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Provide a reasonable description of the tuostance of the testimony of any witness (es) that you intend to have, including an identification of all documents that will be relied upon by them in that testimony.

3.

Following the substantive response to each interrogatory, identify all documents and studies relied upon by you in providing your answers to that interrogatory.

Identification should be specific to the portion of the document or study relied upon.

Studies shall be deemed to include observations, calculations, literature and other types of work, whether recorded in writing or not, which consist of an examination or analysis of a phenomenon.

4.

Following the substantive response to each of the subsequent interrogatories identify by name and affiliation each individual who has knowledge which served as a basis for the answer to that interrogatory.

5.

Amended Contention 21 has been admitted by the Board, at your suggestion, to a consideration of power core density and the adequacy of the ODYN coae to demonstrate the reactor scram i

i curve. State in what way the power core density is an important parameter to consider in assessing BWR core behavior during overpressure transients.

In addition, state how the power core density is an important parameter in an analysis i

using the ODYH code.

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State the facts upon which you rely in :upporting the allegation that the ODYN coae cannot be relied upon to accurately predict BWR core behavior and reference all docuuents relied upon in your answer.

7.

State the facts upon which you rely in supporting your allegatien that plant deratirg will result if the reactor scram curve cannot be accurately predicted by use of the ODYN code.

8.

What is the amount of plant derating that might result if the reactor scram curve cannot be accurately predicted?

9.

If plant derating should occur, what is the basis for your belief that this will intensify the requirement for new generating facilities?

10. What is your understanding about the alleged derating that occurred at Browns Ferry 1 and 2, Quad Cities 1 and 2, and Pilgrim Station?

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'l VilITED STATES OF AMERICA tiUCLEAR REGULATORY COMillSSION BEFORE THE ATOMIC SAFETY AliD LICENSIflG BOARD In the Matter of

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HOUSTON LIGHTIf1G A140 POWER COMPANY )

Docket No. 50-466 (Allens Creek fluclear Generating Station, Unit 1)

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CERTIFICATE OF SERVICE I hereby certify that copies of flRC STAFF FIRST SET OF INTERROGATORIES RELATING TO 00iERTY AMEl40ED CONTENTI0fl 21 TO JOHil DOHERTY in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the fluclear Regulatory Commission's internal mail system, this 2nd day of September,1981.

Sheldon J. Wolfe, Esq., Chairm&n*

Administrative Judge Susan Plettman, Esq.

Atomic Safety and Licensing David Preister, Esq.

Board Panel Texas Attorney General's Office U.S. Nuclear Regulatory Commission P.O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711 Dr. E. Leonard Cheatum Administrative Judge Hon. Jerry Sliva, Mayor Route 3, Box 350A City of Wallis, TX 77485 Watkinsville, Georgia 30677 Hon. John R. Mikeska Mr. Gustave A. Linenberger*

Austin County Judge Administrative Judge P.O. Box 310 l

Atomic Safety and Licensing Bellville, TX 77418 l

Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. John F. Doherty 4327 Alconbury Street The Honorable Ron Waters Houston, TX 77021 State Representative, District 79 3620 Washington Avenue, No. 362 Mr. William J. Schuessler Houston, TX 77007 5810 Darnell Houston, TX 77074 i

J. Gregory Copeland, Esq.

Baker & Botts One Shell Plaza Houston, TX 77002

Jack Newman, Esq.

D. Harrack Lowensteir, Reis, flewman &

420 Mulberry Lane Axelrad Bellaire, TX 77401 1025 Connecticut Avenue, N.W.

Washington, UC 20037 Texas Public Interest Research Group, Inc.

Brenda A. McCorkle c/o James Scott, Jr., Esq.

6140 Darnell 13935 Ivymount Houston, TX 77074 Sugarland, TX 77478 Mr. Wayne Rentfro Rosemary N. Lemmer P.O. Box 1335 11423 Dak Spring Rosenberg, TX 77471 Houston, TX 77043 Leotis Johnston Carro Hinderstein 1407 Scenic Ridge Houston Bar Center Houston, TX 77043 723 Main Suite 500 Houston, TX 77002 Margaret Bishop U.S. Nuclear Regulatory Commission J. Morgan Bishop Region IV, I&E 11418 Oak Spring 611 Ryan Plaza Drive, Suite 1000 Houston, TX 77043 Arlington, TX 76011 Stephen A. Doggett, Esq.

Bryan L. Baker Pollan, Nicholson & Doggett 1923 Hawthorne P.O. Box 592 Houston, TX 77098 Rosenberg, TX 77471 Robin Griffith Carolina Conn 1034 Sally Ann 1414 Scenic Ridge Rosenberg, TX 77471 Houston, TX 77043 Mr. William Perrenod Atomic Safety and Licensing 4070 Merrick Board Panel

• Houston, TX 77025 U.S. Nuclear Regulatory Commission Washington, DC 20555 Docketing and Service Section*

Office of the Secretary atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Panel

• Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 q.

L Wat Ricbar'd L.'B14ck Counsel for'6RC Staff l

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