ML20041F076

Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence

ML20041F076
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	03/10/1982
From:	Doherty J DOHERTY, J.F.
To:	HOUSTON LIGHTING & POWER CO.
References
ISSUANCES-CP, NUDOCS 8203160166
Download: ML20041F076 (9)

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azuTED CORRESPONDENN m .--

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION March to,1982 BEFORE THE ATOMIC SAFETY & LICENSING a0AM f.ll 25 In the Matter of: ,_ ._ .

HOUSTON LIGHTING & POWER CO. >

(Allens Creek Nuclear Generating ) Docket"Noi 50-466 CP Station, Unit 1)

INTERVENOR DOHERTY'S FOURTH SET OF INTERROGATORIES TO APPLICANT WITH REGARD TO TEXPIRG CONTENTION 31 AND QUADREI REPORT MATTERS John F. Doherty, Intervenor in the above construction license proceeding, and acting under the Board Order of Jan- ,

uary 28, 1982, now files the below Interrogatories pursuant to 10 CFR 2 740(b) and 10 CFR 2 741. Please answer each question fully. Please identify all~ documents, memoranda, reports, studies,or other.similar items relied upon by Appli-can which support the answer, and make available such docu-ments to this Intervenor. Identify expert witnesses who answer the questions and give their relationship to Applican 9 A Identify any expert witnesses who Applicant intends 9 ave  %

testify on the subject matter questioned and state NECEyED Z 4 expert's qualifications. Thank you. -

5a %/jg7 'O1985 : O THE INTERROGATORIES-

1. What are the personalqualifications of R. Koppe,- Q. \

J. Nardello, Gene Esswein, H. R. Booth, and R. Uffer o

'. the Quadrex Corporation?

2. What examples did Quadrex provids.to support its statement in Sec. 4.6.2.1(c) of the Reoort, that: " Nuclear Analysis has failed to scope, perform or have analysis performed that should have been completed (including corredtion of reports containing obsolete,or erroneous analysis) given the present state of STP design and construction?

(a) Does Applicant agree with the finding in 4.6.2.1(c)?

(b) Does the finding apply to NUS and B&R?

(c) What part of its organization will..Applicaat rely upon to prevent a similar problem or situation at ACNGS?

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3. What are the personal qualifications of Earl Willey of Quadrex Corp.?

4 What basis did Quadrex provide for the statenent:

"The technical assumptions used for design and analysis are not reasonable for STP?" (See Sec. 4.6.2, p. 4-57, Reoort)

(a) Prior to Quadrex, did Applicant protest that any technical asaumptions were not reasonable for STNP7 (b) Make available any documents that question technical assumptions in the above, but identify same in your reply please.

5. In Sec. 4.6.2, p. 4-57, has Quadrer indicated what it means when it states, "...no evid.ence has been seen that the B&R Nuclear Analysis Group has produced a signifi-cant contribution to tho STP' design?"

(a) Prior to Quadrex has Applicant been dissatisfied with the oroduction of this group?

.(b) Make available any documents that show Applicant's dissatisfaction expressed, but identify same in your reply please.

(c) What,does Applicant intend to do supervising ACNGS

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construction with regard to the analogous Ebasco Services Nuclear Analysis Group that will prevent the problem cited here by Quadrex?

~(d)~With regard to Question N-15, what equiptment had-been purchased without backup analysis?

6 . Had Applicant prior to Quadrex detected the inappropriate use of RELAP3 code mentioned in Question N-13?

(a) If so, make available any document sho~ wing:this, and identify 'che document by name and date in.your response please.

7 . Did Applicant obtain any reasons from B&R for not identifying any high energy lines in the Mechanical .

Auxilliary Building (MAB) to be analyzed for environ-ment? (See Question N-3)

(a) Was applicant aware that B&R had no plans or scoping mass releases for breaks in the MAB of high energy lines, prior to Quadrex?

(b) How will Applicant be organized differently to become

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aware sooner of this type of problem if it should occur at ACNGS?

(C) Would it be one of Applicant's responsibilities to make B&R certain of any need to perform analyses for high energy line breaks in the MAB7 8.. Did Applicant know that NUS Company was using an obsolate code in its annulus pressurization analysis? (Question N-2, Report)

(a) What group in Applicant would consider codes used by NUS in this work?

(b) Did anyone from Applicant urge NUS to use the COMPARE code instead of RELAP3 code?

(c) Have any mass and energy releases been calculatedfor ACNGS? g (d) What has Applicant donefbe sure obsolete codes are not used there, if the answer to (c) is affirmative?

9 With regard to Question N-8 of the Renort, was Applicant aware that B&R did not know the proper methodology for .

. handling potential flow paths during environmental analysis?

10 With regard to Question N-10 of the Renort, was Applicant aware B&R did not know of the need to model makeup supplies of water for long term environmental analysis, prior to Quadrex? If so, make available any documents which show this, but provide here please the names and dates of them.

11 Was Applicant aware B&R was not giving consideration to valve performance qualification requirements near break locations, prior to Quadrex? (Question N-12)

(a) If so, make available any memoranda or. documents showing this, but in reply, please give dates and names of these documents.

12 Was Applicant aware prior to Quadrer that B&R had sot con-sidered local hydrogen concentrations in the battery room?

(Question N-25, Renort)

(a) If yes, indicate what memos, documents etc. indicate this and give dates in your reply, and please make them available for inspection and copying.

(b) Is hydrogen generation in the battery room of the ACNGS a consideration it that plants design?

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13. With reference to Question N-11, (and see also p. 4-61 of the Renort) , what part of the reactor protection system does the MSIV trip or valve ramp characteristics play?

(a) Prior to Quadrex, was Applicant aware of any " weakness" in B&R's understanding of the MSIY trip logic?

(b) How will Applicant be able to assess this weakness sooner should it occur at the ACNGS site?

14. Referring to Question N-18, does Applicant agree with Quadrex that acceptance criteria for the containment Spray Analysis should have been performed by B&R?

(a) Was Applicant aware this was not done, prior to the Reoort?

(b) Was Applicant aware that B&R considered this analysis a Westinghouse resposibility?

(c) What steps has Applicant taken to be certain there is no recurrence of this at ACNGS7

- 15. In Quadrex's discussion of the B&R response to Question C-4,

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they mention a reportable deficiency on the structural steel inside containment caused by the lack of consideration of cc-::ider2ti- rf thermal loadings and two other factors.

(a) Was this due to lack of knowledge of "much higher localized temperatures than expected?"(See: Question N-13, last sen-teges of "Quadrex Assessment")

(b) Was the structural steel constructed prior to the deficien-cy report?

! 16. In Sec. 4.6.2.4(u) of the Report, did Quadrez calculate how much higher the localized temperature.for the outside con-tainment concrete would be?

(a) Prior to Quadrex, was Applicart aware a higher temperature l- was required, and if so, when was A' pplicant first aware?

17. Referring to item 4.6.2.4(v) of the Reoort, has Applicant

! the' option of enlarging the ECP to accomodate concurrent trip of the STNP units?

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18. Question N-23 of the Reoort, which consists of several cuestions on ECCS pump room floading, states in the"Quadrex assessment": "Quadrex review of hand-out calculations showed a 44% non-conservative error.

(Break area of .432 in 2 should be,.622 in 2, pyp, ,,11 thickness was inadvertently used."

(a) Does this mean B&R substituted the pipe wall thick-ness for the break area?

(b) Was Applicant aware of these two errors prior to Quadrex review?

(c) If Applicant was aware, please give the date of first awareness, and make available any documents, etc. on the discovery of these errors.

19 Does Applicant agree with the Quadrex finding in Sec.

4.8.2, " Sufficient evidence to verify that appropriate design inputs (based on the criteria documents) were utilized, was not provided? If not, for what reasons?

20. Relevant to Question R-9 of the Renort, was Applicant aware that access to a steam generator manway was in-terfered with by structures, prior to Quadrex?

(a) If "yes" to the above, when did Applicant first

.become aware? (Please make available any documents, etc. showing Applicant was aware as stated)

(b) How did Applicant first , find out?

(c) If 'Recort.was Applicants first notice, what l

changes has Applicant made at ACNGS to prevent l structures from impeding access to frequently l maintained equiptmedt in containment?

21. Relevant to Question R-9 of the report, was Applicant aware that access to Valves RH060B and XRH-019B were located such that maintainability would be very diffi-cult or almost impossible, prior to the Recort? If so, at what date was ADplicant aware, and indicate in your reply which documents,etc. show this,.plus make I the docuements,etc. available.

(a) What is the function of these valves, and what systems utilize their function?

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.22. Referring to Question R-9 of the Report, was Applicant aware prior to Quadrex that Valve XRC-0740 had been installed upside down? If so, please identify and make available any document, report, etc., which shows this.

(a) What is the function of Valve IRC-0740, and of -

which plant system is it a part?

23 What is the radiation streaming referred to in Question R-13 of the Report?

(a) Does Applicant agree with the Quadrer assessment that for the most part, the criteria of TRD A509NQ005-B dealing with (radiation) streasing through shield pene-trations had not been implemented?'

(b) Prior to Quadrex Report, had Applicant noticed that-the document mentioned in part 23(a) criteria had not been implemented with regard to shield penetrations?

If so, please identify and make available any document, report, etc., which shows this.

24. Refsring to Question R-10 of the Reoort, what is a " gap release" accident?

25. In what ways does Quadrex Corp maintain shielding design did not adequately consider ISI requirements or poten-tial locations for temporary shielding? (Recort, Question R-10)

26. Does Applicant agree that, "The radiation zones...have not taken into account accident situations or other ab-normal conditions?'(Report, , Question R-10)

(a) Prior to Quadrer Reoort, had Applicant noticed this alleged deficiency? If so, please identify and make available any document, report, etc., which shows this.

27. Report, Question R-6, states, "A failure mode and effects analysis has not beenl performed from a radiological safety standpoint on the systems referred to in the B& R response". Are each of the systems below included '

in that statement to the best of your knowledge?

(a) Spent Fuel Pool Ventilation, (b) Fuel Handling Buil-ding Ventilation, (c) Control Room Ventilation, (d)

Reactor Containment Building Stack Monitor.

28. Were any reviews of plant design from an ALARA stand-point, ever given to Applicant in result form?

29. Did Applicant ever as for the results of such reviews as mentioned in item 28, above?

30. Referring to the Reoort, Question R-1, does Applicant accept the statement that B&R reviews of plant. design from an ALARA standpoint were inadequate? If so, indicate the date and names of any report, document, or memo indicatin6 this, and make it available to this Intervenor, please.

31. At any time urior to the Recort, had any of Apolicant's personnel reviewed models and codes used for shielding analysis by B&R? Has Applicant any reports, memos, etc.

showing their ouinion of B&R's understanding of these analyses? If so, please indicate the date of, and iden-tify these reports or memos, etc. as well as make them

. availab'le to Intervenor. (See: Report, Question R-11)

32. What.is.the identity .and. data'.of any memo, report,etc., where Apolicant requested that B&R make a listing of radio-active niping outside containment? Please make this request available to Intervenor. (See Report, Question R-12)

33. Did A,pplicant concur in B&R's conduct in not reviewing the documents NUS-TM-261, " Pressure Vessel Activiation Product Radiation Analysis and Shield Design," 1976; and NUS' TM-232h " Radiation St' reaming Through Reactor Vessel Primary Shield Gap and Inspection Torus," 19767 (See:

Reoort, Question R-14)

34. Did Applicant, prior to Feb. 1981, request that B&R create radiation zone drawings based on accident con-ditions? (See: Report, Question R-30)' If so, please give the date of the reqcas,t, identify any memo, report, letter, etc., showing this, and make such item avail-able to this Intervenor, please.

33. Had Aoplicant, prior to Quadrex Report, ever notified B&R or other contractor at STNP of the need for a de .

sign basis governing removable concrete block walls?

(See: Reoort, Sec.4.8.2.1( g))

(a) If so, identify and please make available a copy of any means used by Applicant to notify them, but give the date and identify the doc-ument or means used, in your reply to this Inter-rogatory.

36. Has; Applicant concluded B&R performed a thorough

review of system design features relative to crud buildup? (Report, R-15) If so, identify and make available memos, documents, etc. from which Appli-cant concluded this. Identify them in your reply, please.

, 37. Referring to a letter from G. W. Oprea signed by J. H. (?) Goldberg ("for") of 6/5/81 identified

! as ST-BL-AE-678; SPN: Y-0530, did the. assessment of conputer codes mentioned there refer to work by Quadrex?

(See Attacliment "A")

38. Referring to Question Ch!-3 of the Report, what are the names of the following computer pro 6 rams and what do they compute or provide for the user?

a) ES-425; b)CP-231; c)EP-2OO;. d) EI.-303; e)CW-522.

39 Relevant to Question C/M-8 of the Report, had Appli-i cant ever examined o( approved of the document f STP-DC-017-07 (a) Did Quadrez ever give Applicant an idea of how many times the " loop hole" had been used? How many?

! (b) Was Applicant aware B&R was not verifying nationally recognized programs? If so, please give th's date l

and identifying name or number of any document or report showing this and make said item available.

1 If not, how will Applicant at the ACNGS site pre-

! vent this with Ebasco Services?

(c) Was Applicant aware, prior to Quadrex, that B&R was permitted to verify codes in five ways accor-ding to document STP-DC-017-C, without guidance for preference? If so, please give the date it determined this, and identify anjdocument or other

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item showing this and make it available.

...- 40. Prior to Quadrex Reoort, was Applicant aware that

- document STP-DC-017 permitted that, "If any part er portion of the conputer code is verified, the whole is considered verified."? If so, indicate date Appli-cant became aware of it, anything it did as a result of this awareness, and identify and make available any memo, etc. that shows this. (Refer to C/M-13, Report)

41. Is Applicant aware at this time if there is a control document identifying all computer codes used on STP?

(a) Prior to Quadrex, was Applicant aware that a control document of the type described in the first paragraph of the Quadrex Assessment of Question C/M-1' did or did not exist?

(b) Prior to Quadrex, was Applicant aware of the differ-ences in the listings between the PSAR and the PSS mention by Quadrex in Question C/M-1 of the Report?

If co, when was Apolicant first aware, and what memo or document, etc. shows this awareness?

(c) What will Applicant do in the case of its ACNGS organ-ization to keep these two documents correctly. updated, that it did not do in the case of STNP7

42. Was Applicant aware program name and version numbe, date of execution, and sequential page numbering did not appear on every page of all output prior to Quadrex Assessment C /M-27 If so, please indicate the date of first awareness and identify any letters, memos,etc., that show diis. -

Did Applicant attempt to have B&R revise this practice?

SERVICE OF PROCESS I. certify that copies of-the above:INTERVENOR DOHERTT'S FOURTH.

SET OF INTERROGATORIES TO APPLICANT WITH REGARD TO TEIPIRG CON-TENTION 31, AND QUADREX REPORT MATTERS were served on the below via First Class U. S. Postal Service, this <i,. $_

_ af March, 1982.

Sheldon J. Wolfe, Esq., Dr. E. Leonard Cheatum, Gustave A.

Linenberger, Administrative Judges; Richard A. Black, Esq. Staff; J. Gregory Copeland, Esq. & Jack R. Newman, Esq.,.Appli-cant; The Several Intervening Parties; USNRC Docketing &

Service; Atomic Safety Licensing & Appeal Board.

Respectfully,

{}f ohn F. Doherty

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('. n ATTACHMENT (Intbrog 37)

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,_ MON nq Company sou, ion ughiing a r..., mo.aoxivoo nou. ion.re rvooi .c i332 s.92ir '

June 5, 1981

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ST-HL-AE'678 SFN: V-0520 o ^

Mr. Karl Seyfrit g P ,_ '

g Director, Region IV d[. h, Nuclear Regulatory Comission y *

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611 Ryan Plaza Drive Suite 1000 --

JUN 111981 >

Arlington, Texas 76012

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Dear Mr. Seyfrit:

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South Texas Project Units 1 & 2 -

Docket Nos. STN 50-498, STN 50-499 A First Interim Report Concerning Comouter Procram Verificatioa On May 8,1981. Houston Lighting & Power Comca'ny, cursuant to 10CFR50.55(e), notified your office of an item concerning comouter program (code) verification. The verification methods lack adequate visibility to the user as to whether or not the program versions in use have been verified..

An assessment of computer codes ustd on the South Texas Project is in progress. This assessment includes 'a review of the comouter program verification reports (CPVR) to evaluate the qualificatYon of the computer codes used on the South Texas Project and.a review of calculations for aooropriate application of computer code <- Ta rfate. there has been no technical inadequacy identified in the use of comouter niagrame which umuld ereclude the sW nn=rn 4mt nf the Dlant. The nort interim report concerning this item will be submitted to your office by August 28, 1981.

If you have any questions concerning this item, please contact Mr. Michael E. Po.tll at (713) 676-8592.

Yery truly yours, ,

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5 G. W. Oprea, Jr g

V ." . , . ' Executive Vice President MEP/amj s noewers7 5f