ML20024E402

First Set of Interrogatories on Contention 4.Certificate of Svc Encl.Related Correspondence

ML20024E402
Person / Time
Site:	South Texas
Issue date:	08/08/1983
From:	Berwick B TEXAS, STATE OF
To:	JOINT APPLICANTS - SOUTH TEXAS PROJECT
Shared Package
ML20024E401	List: ML20024E400 ML20024E402
References
NUDOCS 8308100358
Download: ML20024E402 (5)

Text

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8 RECEIVE 3 CA UNITED STATES OF AMERICA --

,j NUCLEAR REGULATORY COMMISSION D AUG 81993 > -lij I

BEFORE THE ATOMIC SAFETY AND LICENSING BOA Q [Sc5 M;CX.Nac ca

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In the Matter of S CC S

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HOUSTON LIGHTING AND POWER S Docket Nos. 50-498 COMPANY, ET AL. S 50-499 S

(South Texas Projects, Units 1 S

& 2) g agtxrED ColGgpogugsck STATE OF TEXAS'S FIRST SET OF INTERROGATORIES TO APPLICANTS ON CONTENTION 4

1. Do the Applicants contend that there are no recorded hurricanes

a. in the Gulf of Mexico

b. in the North Atlantic Ocean in which the fastest mile wind speed, 30 ft. above ground has been higher than 125 mph?

2. Please define " fastest mile wind speed" as used by the Applicants in answering interrogatory 1.

3. If the answer to interrogatory 1 is "no,"

l a. please identify hurricanes whose fastest mile wind speed, 30 ft. above ground exceeded 125 mph and provide the speed for each hurricane.

b. please explain the selection of 125 mph as the design wind velocity for the fastest mile wind speed at STNP.

{ c. Please identify all studies or documents relied upon in answering 3a and 3b.

4. If the answer to interrogatory 1 is "yes," please provide i

Applicants' position on the fastest mile wind speed for each of the 8308100358 830808 PDR ADOCK 05000498 PDR g

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. o following:

a. The hurricane on September 27 through October 6, 1949 making landfall near Freeport, Texas

b. Hurricane'Carla (1961)

c. Hurricane Hilda (1964)

d. Hurricane Betsy (1965)

e. Hurricane Celia (1970)

f. Hurricane Allen (1980)

g. Hurricane Anita

5. Please identify all studies or documents relied upon in answering interrogatory 4.

6. a. What is the peak hurricane wind gust value used by Applicants in designing STNP?

b. Where- is this value documented in Applicant's filings with the NRC? Please provide a copy of said filing.

c. Please identify all studies or documents relied upon in answering interrogatory 6. -

7. Do the Applicants contend that there are no recorded hurricanes

a. in the Gulf of Mexico

b. In the North Atlantic Ocean in which the peak wind gust has been higher than the value given in response to interrogatory 6a?

8. If the answer to interrogatory 7 is "no,"

a. please identify the hurricanes whose gusts exceeded the value given in answer to interrogatory 6

b. the highest gust for each hurricane identified l

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c. please explain Applicants' selection of the value given in answer to interrogatory 6a.

d. please identify all studies or dccuments relied upon-in answering 8a and 8b.

9. Please produce a copy of the non-published private correspondence dated Jun 1974 referenced in the October 15, 1982 Memorandum and Order of the ASLB in this proceeding (and appar-ently also referenced in FSAR Section 2.3.1.2.6., at p. 2.3-6a).

10. What is the. Applicants' position on the extent of the

" surrounding area" required to be considered by 10 CFR Part 50, Appendix A, Criterionn2? .Please explain the basis for Applicants' position.

.11. Would the design of:STNP differ if the Applicants had selected a fastest-mile speed of 185 mph rather than 125 mph? r If.

so, please describe generally how the design would have differed.

If not, please explain why not.

12. Wo uld the design of STNP differ if the Applicants had selected a peak gust value of 200 mph rather than the value given in response to interrogatory 6a? If so, please describe generally how the design would have differed. If not, please explain why not.

13. Please identify each witness Applicants intend to call on Contention 4 and summarize the testimony of each.

14. Is it Applicants' position that having designed parts of STNP to withstand missiles carried by tornado winds of 360 mph, these same parts of STNP are therefore designed to withstand a fastest mile wind speed of 360 mph? Please explain.

15. a.

What is the heaviest rainfall Applicants have considered in the design of STNP?

b.

Please identify studies or documents Applicants relied upon for their answer to interrogatory 15.

16. a.

What is the highest flood crest on the Colorado River Applicants have considered in the design of STNP?

b.

Please identify all studies or documents Applicants relied upon in answering interrogatory 16.

17. a.

What is the highest hurricane storm surge Applicants have considered in the design of STNP?

b.

Please identify all studies and documents Applicants relied upon in answering interrogatory 17.

18. Please identify the witnesses Applicants intend to call on Contention 4 and' summarize their testimony.

JIM MATTOX Attorney General of Texas DAVID R. RICHARDS Executive Assistant Attorney General JIM MATHEWS Assistant Attorney General Chief, Environmental Protection ,fs Division s ii M hL BRIAN E. BERWICK (SBN 02258500)

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Assistant Attorney General Environmental Protection Division -

P.O. Box 12548 Austin, Texas 5 78711 (512) 475-4143 $:

u ATTORMEY FOR THE State of Texas h.

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r JK UNITED STATES OF AMERICA S REGD'ED (; \(

NUCLEAR REGULATORY COMMISSION 1 .

BEFORE THE ATOMIC SAFETY AND LICENSING BOARI 3 AUC i.' ~ ~ iY CERTIFICATE OF SERVICE V E$[n 4.[cp /

secr sac I hereby certify that copies of State of Texas's ,et of Interrogatories to Applicants on Quadrex and Interoggato ~ hto Applicants on Contention 4, were served by deposit in the United States Mail, first class postage paid to the following individuals and entities on the 6'fk. day of August, 1983, except that service on the singlo-asterisked people was by federal express and on the double asterisked people was by hand.

• Charles Bechhoefer, Esq. William S. Jordan, Esq..

Chief Administrative Judge Harmon and Weiss Atomic Safety and Licensing 1725 I Street, NE Board Panel E' lite 506 U.S. Nuclear Regulatory Commission WaThington D.C. 20006 Washington D.C. 20555

• • Jack R. Newman, Esq.

• Dr. James C. Lamb, III Lowenstein, Newman, Reis &

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Adminstrative Judge Axelrad 313 Woodhaven Road 1025 Connecticut Avenue, NS Chapel Hill, NC 27514 Washington D.C. 20036

• Ernest E. Hill

• Robert G. Perlis Administrative Judge ~~~

Office of the Executive Lawrence Livermore Laboratory ' Legal Director University of California U.S. Nuclear Regulatory Commission P.O. Box 808, L-123 Washington D.C. 20555 Livermore, CA 94550 Atomic Safety and Licensing Board Mr. Peggy Buchorn U.S. Nuclear Regulatory Comm.

Executive Director Washington D.C. 20555 Citizens for Equitable Utilities Atomic Safety and Licensing Route 1, Box 1684 Appeal Board Brazoria, Texas 77411 U.S. Nuclear Regulatory Comm.

Washington D.C. 20555

• • Tom Hudson, Esq.

Graves, Dougherty, Hearon & Moody Docketing and Service Section InterFirst Bank Tower Office of the Secretary Austin, Texas 78701 U.S. Nuclear Regulatory Comm.

Washinton D.C. 20555 Lanny Sinkin 2207 D Nueces Austin, Texas 78705 g b d% P* b/El Brian E. Berwick

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