ML20037D334
| ML20037D334 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/30/1981 |
| From: | Hart J CITIZENS FOR FAIR UTILITY REGULATION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8107100018 | |
| Download: ML20037D334 (10) | |
Text
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In the Matter of S
0#" cf be seh g TEXAS UTILITIES GENER ATING S
Docket Nos. 50-445
S 50-446 6
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(Application for Cb e
N Station, Units 1 and 2)
S Operating License)
CFUR'S FIFTH SET OF INTERROGATORIES TO APPLICANTS AND REQUESTS TO PRODUCE Pursuant to 10 CFF. SS 2.740b and 2.741, Citizens for Fair Utility Regulation
("CFUR"), hereby serves CFUR's Fifth Set of Interrogatories and Requests to Produce-upon Texas Utilities Generating Company, et al. ("Ipplicants"). Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent in'ormation known to Applicants, its officers, directors or members as well as any pertinent information known to its employees, advisors or counsel. Each request to produce applies to pertinent documents which are in the possession, custody or control of Applicants, its officers, directors or members as well as its employees, advisors er counsel. In answering each interrogatory and in responding to each request, please recite the interrogatory or request preceding each answer or response.
These interrogatories and requests shall be continuing in nature. Thus, any time Applicants obtain information which renders any previous response incorrect or indicates that a response was incorrect when made, Applicants should supple-ment its previous response to the appropriate interrogatory or request to produce.
Applicants should also supplement its responses as necessary with respect to 8107100018 810630 PDR ADOCK 05000445 pgp$
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identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony and the substance of that The term " documents" shall include any writings, drawings, graphs, testimeny.
charts, photographs and other data compilations from which information can be obtained. We request that at a date or dates to be agreed upon, Applicants make available for inspection and copying all documents subject to the requests set forth below.
Interrogatories State the maximum distance from CPSES which must be analyzed to 1.
determine the effect of radioactive releases on the general public?
What are your bases (legal and/or other) for your response to the 2.
preceding interrogatory?
- 3. -Where in the FSAR is it described how the requirements of 10 CFR S 20.l(c) will be met?
4.
Section 11.1 of the FSAR states:
The source terms for the effluent release analysis are based on the realistic model for reactor coolant activity as formulated as a draft standard for the American Nuclear Society. (emphasis added)
What are your legal bases for the use of a " realistic model" verus the use of a
" conservative model" for source terms for shi-iding design and for component failure?
What are your bases (legal and/or other) for the use of the " draft 5.
standard" as stated in Section 11.1 of the FSAR?
6.
Section 11.1.2 of the FSAR states:
The Gaseous Waste Processing System is assumed to strip fission gases from the volume control tank. The overall y parameter, as given in Reference [2] is interpreted as being equivalent to the stripping fractions. (emphasis added)
. 3
Why was it " assumed" that the Gaseous Waste Processing System would a.
strip fission gases from the volume control tank?
What is the reliability of the Gaseous Waste Processing System?
b.
What are your technical bases for your response to the preceeding c.
subpart of this interrogatory?
Why is it necessary to use the word " interpreted" in the above-quoted d.
passage?
Provide your technical bases for the interpretation referenced above.
e.
Provide your 1cgal bases for the above interpretations.
f.
additional radioactive gases (that is, racioactive gases 7.
How much generated in addition to the amount normally generated) by each of the acciden listed in FSAR Section 15.0.1.2, Condition II-Faults of Moderate Frequency?
Ease provide I]I Please list the quantity of gas separately for each listed accident.
source term data (isotope and quantity) separately for each listed accident.
J Ji much additional radioactive gases (that is, radioactive gases 8.
How generated in addition to the amount normally generated) by each of the acciden Please list the listed in FSAR Section 15.0.1.3, Condition III-Infrequent Faults?
Please provide source term quantity of gas separately for each listed accident.
data (isotope and quantity) separately for each listed accident.
much additional radioactive gases (that is, radioactive gases 9.
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generated in addition to the amount normally generated) by each of the acc Please list the listed in FSAR Section 15.0.1.4, Condition IV - Limiting Faults?
Please provide source term quantity of gas separately for each listed accident.
data (isotope and quantity) sepa ately for each listed accident.
With respect to the accidents listed in FSAR Section 15.0.1.2, Condition 10.
II-Faults of Moderate Frequency, please answer the following separately for ea accident:
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What is the probability of occurrence for each fault?
a.
b.
What is the variance for each probability of occurrence?
Provide your technical bases for your responses to the preceding c.
subparts of this interrogatory.
With respect to the accidents listed in FSAR Section 15.0.1.3, Condition 11.
III-Infrequent Faults, please answer the fonowing separately for each accident:
What is the probability of occurrence for each fault?
a.
What is the variance for each probability of occurrence?
b.
Provide your technical bases for your responses to the preceding c.
subparts of this interrogatory.
With respect to the accidents listed in FSAR Section 15.0.1.4, Condition 12.
IV - Limiting Faults, please answer the follcwing serrately for each accident:
What is the probability of occurrence for each fault'.
a.
What is the variance for each probability of occurrence?
b.
Provide your technical bases for your responses to the preceding c.
subparts of this interrogatory.
What effect woulc a single occurrence of " loss of normal feedwater
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13.
fic w" (Fault No.10 - FSAR Section 15.0.1.2) have on Figure 11.3-4 if this accident l
cecurred at the end of the first year of operation?
What effect would the " loss of normal feedwater flow" (Fault No.10 -
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14.
FSAR Section 15.0.1.2), which occurs with the frequency of once per year, each l
year, from the first year through the fortieth year of operation, have on Figure 11.3 - 4 ?
f Please provide a table listing the data responsive to the two preceding l
15.
interrogatories.
What effect would a single occurrence of each of the other accidents 16.
listed in FSAR Section 15.0.1.2 have on Figure 11.3-4 if each such accident occuis n
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Please answer separately for each alone at the end of the first year of operation?
listed accident.
What effect would the occurrence of each of the other acc 17.
in FSAR Section 15.0.1.2, if each occurred with the frequency of once per year each year, from the first through the fortieth year of operation, have on F 11.3-4? Please answer separately for eachlisted accident.
Please provide a table listing the data responsive to the two precedin 18.
interrogatories. Please provide separate tables for each accident inq both interrogetories.
How much unused capacity of the GWPS is necessary in order to 19.
preclude the release of radioactive effluents during unfavorable e conditions during the occurrence of each of the accidents listed in FSA 15.0.1.2, Condition II-Faults c,f Moderate Frequency? P12ase answe iPk 1!;
xd eachlisted accident.
How much unused capacity of the GWPS is necessary in order to 20.
preclude the release of radioactive effluents during unfavorable conditions during the occurrence of each of the accidents listed in FSA 15.0.1.3, Condition III-Infrequent Faults? Please answer separately accident.
How much unused capacity of the GWPS is necessary in order to 21.
preclude the release of radioactive effluents during unfavorable conditions during the occurrence of eacn of the accidents listed in FS Please answer separately for each listed 15.0.1.4, Condition IV - Limiting Faults?
accident.
What are your technical bases for your responses to the preceding t 22.
interrogatories? *
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- 23. How much unused capacity of the GWPS is necessary in order to preclude the release of radioactive effluents during unfavorable environmental conditions during the occurrence of accidents more serious than Condition IV?
Please identify the accident sequence determined to be the limiting accident.
- 24. What are your bases (legal and/or other) for your response to the preceding interrogatory?
- 25. Have you prepared uy report, study c,--
alysis with respect to the following Contentions:
a.
Contention 1; b.
Contention 2; c.
Contention 3; d.
Contention 4; e.
Contention 7; f.
Contention 9; g.
Board Question No.1; h.
Board Question No. 2;
- i. Board Question No. 3.
If so, please identify each such report, study or analysis by subject and author, including the employer, place of employment, title, business address and business telephone number of the author. Please provide for inspection and coyping each 1
such report, s' ady or analysis.
- 26. Describe in detail-the provisions made and the steps taken to assure that CPSES 1 and 2 reactor operators have been adequately trained prior to power operation of CPSES 1 and 2.
- 27. Describe in detail the provisions made and the steps taken to assure that conditions are safe to commence power operation of CPSES 1 and 2.
. ~
- 28. Describe in detail all manuals, instructions, procedures and other i
documents which support your responses to the two preceding interrogatories.
Please make all such manuals, instructions, procedures and documents available for inspection and copying.
- 29. What is the volume of the containment for CPSES 1 and 2?
- 30. What quantity of hydrogen gas would be produced at CPSES 1 and 2 if the same relative quantity as was produced at TMI-2 is produced at CPSES 1 and 2?
- 31. What pressure would be produced if instantaneous combustion of the quantity of hydrogen gas listed in your response to the preceding interrogatory were to occur?
- 32. Have any special or additional measures been incorporated to handle hydrogen gas in the CPSES containment structure since the TMI-2 accident?
Answer separately for Unit 1 and Unit 2.
- 33. If your response to the preceding interrogatory is anything but "No,"
answer the following, separately for Unit 1 and Unit 2:
a.
Describe in detail the special or additional measures incor-porated.
b.
Describe in detail all documer.ts reflecting the special or addi-tional measures incorporated.
Provide for inspection and copying of all documents listed in your c.
response to the preceding subpart of this interrogatory.
l
- 34. If your response to interrogatory 32 is not affirmative, provide your bases (legal and/or other) for that response.
- 35. Have any special additional measures been incorporated to handle hydrogen gas in the CPSES primary coolani loops since the TMI-2 accident?
Answer separately for Unit I and Unit 2.
l -
I If your response to the preceding interrogatory is cnything but "No,"
36.
please answer the following, separately for Unit 1 ar.d Unit 2:
Describe in detail the special or additional measures incor-a.
porated.
Describe in detail all documents reflecting the special or addi-b.
tional measures incorporated.
Provide for inspection and copying of all documents listed in your c.
response to the preceding subpart of this interrogatory.
If your response to interrogatory 35 is not affirmative, provide your 37.
bases (legal and/or other) for that response.
Describe in detail what management and administrative actions have 38.
been initiated by the Applicants prior to the request for issuance of an operating license in order to resolve Safety Issue TAP A-9 (ATWS) as it relates to CPSES 1 f
and 2?
Describe in detail what management and administrative actions have 39.
been initiated by the Applicants subsequent to the request for issuance of an i
operating license in order to resolve Safety Issue TAP A-9 (ATWS) as it relates to CPSES l and 2?
Describe in detail what financial actions have been initiated by the 40.
Applicants prior to the request for issuance of an operating license in ords.' to resolve Safety Issue TAP A-9 (ATWS) as it relates to CPSES 1 and 2.
Describe in detail what financial actions have been initiated by the 41.
Applicants subsequent to the request for issuance of an operating license in order to resolve Safety Issue TAP A-9 (ATWS? as it relates to CPSES 1 and 2.
Describe in detail what technical actions have been initiated by the 42.
Applicants prior to the request for issuance of an operating license in order to resolve Safety Issue TAP A-9 '.ATWS) as it relates to CPSES 1 and 2.
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- 43. Describe in detail wnat technical actions have been initiated by the 1
Applicants subsequent to the request for issuance of an operating license in order to resolve Safety Issue TAP A-9 (ATWS) as it relates to CPSES 1 and 2.
- 44. Describe in detail all documents which support responses to the preceding six Interrogatories.
Please make all such documents available for inspection and copying.
Respectfully submitted, By
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re Li Hart 1
escott Avenue s, Texas 75219 I
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ELHED ConnEsposonycn CERTIFICATE OF SERVICE I certify that a copy of the foregoing CFUR's Fifth Set of Interrogatories to Applicant and Requests to Produce has been forwarded to all parties and counsel of record this M day of.he
,1981 by first class mail.
Administrative Judge Marshall E. Miller Mrs. Juanita Ellis U.S. Nuclear Regulatory Commission President, C ASE Atomic Safety and Licensing Board 1426 South Polk Street 1001 Connecticut Avenue, N.W.
Dallas, Texas 75224 Washington, D. C. 20036 Mr. Dwight H. Moore, Esq.
Dr. Forrest J. Remick, Member West Texas Legal Services Atomic Safety and Licensing Board 100 West Main Street 305 E. Hamilton Avenue Lawyers Puilding State College, PA 16801 Fort Worth, Texas 76102 Dr. Richard Cole, Member David J. Preister, Esq.
Atomic Safety and Licensing Board Assistant Attorney General U.S. Nuclear Regulatory Commission Environmental Protection Division Washington, D. C. 20555 P. O. Box 12548 Capitol Station Marjorie Ulman Rothschild, Esq.
Austin, Texas 78711 Office of Executive Legal Director U.S. Nuclear Regulatory Commission Richard L. Fouke Washington, D. C. 20555 1668B Carter Drive Arlington, Texas 76010 Nicholas S. Reynolds, Esq.
Debevotse & Liberman Arch C. McColl, III, Esq.
120017th Street, N.W.
701 Commerce Street Washington, D. C. 20036 Suite 302 Dallas, Texas 75202 Chase R. Stephens Docketing and Service Section Chairman Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, D. C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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