ML20042C548

Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl

ML20042C548
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	03/23/1982
From:	Doherty J DOHERTY, J.F.
To:	HOUSTON LIGHTING & POWER CO.
References
ISSUANCES-CP, NUDOCS 8203310508
Download: ML20042C548 (16)

Text

UNITES STATES OF AMERICA March.23 ', 1932 NUCLEAR REGULATORY COMMISSION

'O BEFORE THE ATOMIC SAFETT & LICENSING BOARD

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_.I 9 In the Matter of:

HOUSTON LIGHTING & POWER CO.

Docket No. 50-466 CP (Allens Creek Nuclear Generating i

Station, Unit 1)

INTERVENOR DOHERTY'S FOURTH SET OF REQUESTS FOR ADMISSIONS TO APPLICANT (QUADREX REPORT MATTERS'AND TEXPIRG CONTENTION 31)

Pursuant to 10 CFR 2 742 of the Commission's rules of practice, John F. Doherty, Intervenor in the above procee N

now files the below requests for admissions.

RECEIvga It 1

Admit or deny: that at least six computer pro 6 rams w e

MAR 3019825 listed in the Program Status Summary as having

'8 gmu usage at the STNP with no Computer Program Verificat Report (CPVR) in place.

(C/M-3)*

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2. Admit or deny that procedure STP-DC-017 does not require verification of non-safety related programs. (C/M-3)

3. Admit or deny thc.t the B&R CPVR did not indicate which options of a particular code had been verified. (C/M-3)

4. Admit or deny B&R did not consider any streaming analysis l

to be safety-related. (R-7) l

5. Admit or deny that there were computer codes used at STNP which were classified as non-safety-related and hence not verified because radiation streaming analysis was considered non-safety related by B&R.

6. Admit or deny that prior to the Quadrex Report, Applicant did not know there were at least six computer programs listed in the Program Status Summary as having usage at the STNP with no Computer Program Verification (CPVR) in l

place. (C/M-3)

7. Admit or deny that the CPVR procedure did not prohibit use -

3 I

of a wh ng verification pr',blem to be subsequently si6ned 30 off as verified (Sec. 4.L 2.1(e))

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8 The figures in parentheticals at the end of each item refer to Quadrex Questions, or sections.

l 8203310508 820323 PDR ADOCK 05000466 G

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~t 8. Admit or deny that the CPVR proedures did not include any way to determine if a wrong verification problem had been subsequently si ned off as verified.

6

9. Admit or deny Applicant did not know thet the CPVR pro-cedures did not prohibit use of a wrong verification problem to be subsequently signed off as verified. (See item 141 infra)"

10. Admit or deny that Aplicant' did n6t know' that' the Bir.R CPTR did not indicate which options of a particular code had been verified when the Quadrex Report finding of this was given them. (C/M-3) 1% Admit or deny STP-DC-017-0 allows any ne or a. combination of five options to be used for compute.' code verification.

(Sec. 4.2.2.1 (f))

12. Admit or deny that Applicant did not know that STP-DC-017-C f.

allows any one or a combination of five options to be used for computer code verification. (Sec. 4.2.2.1(f))

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13. Admit or deny nationally recognized procrams were used at E

the STNP site without further verification relative to their intended application. (Sec.'4.2.2.4(i))

14. Ad=it or deny that Apolicant did not know that nationally fff N

recognized programs were used at the STNP site without verification relative to their intended application. (See : item' 142)"

15. Admit or deny no Technical Reference Document exists that specifies the STNP plant-wide separation requirement for the electrical discipline. (Sec. '4 3.2.1(b))

16. Admit or deny that Apolicant did not know that no Technical ff Reference Document existed that specified the STNP plant-Eg wide separation requirement for the electrical discipline.

[f (Sec. 4 3.2.1(b)),

(See: item 143, infra.)

EP 17 Admit or deny that prior to the date of the Quadrex report

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there was no Technical Reference Document-(TRD) for

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choice of coincidence logic in the electrical systems for

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the STNP plant. (Sec. 4.3.2.1(c))

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18. Admit or den / that at the STNP site there had never been I

MJ formalmethodologyordocumentationtoverifya[quate separation within the electrical systems beforethe'Quadrex h

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Report.

_(Sec. 4 3.2.1(d))

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Refers to a closely related, butlater added item.

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. 19.

Admit or deny that at the STNP site there had never been formal methodology or documentation to verify the single failure criterion for the electrical systems prior to the Quadrex Report. (Sec. 4 3 2.1(d))

20.

Admit or deny that prior to Quadrex Report, the Appli-cant did not know there was no formal methodology or documentation to verify adequate separation within elec-trical systems at the STNP.

(See: item 144, infra. ) *

• 21.

Admit or deny that the Applicant did not know there had never been formal methodology or documentation to verify the single failure criterion for.the elec-trical systems prior to the Quadrex eview.and report.

r 22.

Admit or deny there was no existins document that provides guidance to the designers on the circuit application of the various types of isolation devices used or to be used in the electrical systems of the STNP up to^the time the Quadrex Report was written. (Sec. 4.3 2.1(n))

i 23.

Admit or deny that Applicant was unaware there was no existing document that provides guidance to the designers on the circuit application of the various types of iso-lation devices used or to be used in the electrical systems of the STNP up to the time the Quadrex Report was written.

24 Admit or deny the specifications at STNP allowed use of plastic, aluminum and 75% fill for the'special' raceways.

(Sec. 4 3.2.1(n))

l 25 Admit or deny Applicant did not know the specifications at STNP allowed use of plastic, aluminum and 75% fill for the "special" raceways up to the time the Quadrex Report was written.

26.

Admit or deny that none of the HVAC heat load calculations considered the off-normal system condition called partial power, at STNP. (E-3) t 27 Admit or deny that none of the HVAC heat load calculations considered the off-normal system condition of startup, at STNP. (E-3) e m

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28. Admit or deny that aone of the HVAC heat load calculations at STNP considered the off-normal system condition, shutdown. (E-3)

29. Admit or deny that none of the HVAC heat load calcu-lations consider the off-normal system condition of loss i

of off-site power at STNP? (E-3)

30. Admit or deny that none of the HVAC heat load calet:laticns j

considered the off-normal system condition of refueling at STNP. (E-3) (See: item 146, infra.)**

31. Admit or deny that Applicant was unaware that the HVAC heat load calculations did not consider off-normal system conditions up to the time the Quadrex Report was written.

32. Admit or deny the safety classification of HVAC systems is not traceable to " user" systems. (4.4.2.1(b))

33. Admit or deny that accident condition duty cycles or dur-ations of operation in the safety-related HVAC system snecifications had. not been considered up to the date of the writing of the Quadrex Report. (H-30)

34. Adait or deny that Applicant was unaware that accident condition duty cycles or durations of operation in the safety-related HVAC system specifications had not been considered up to the date of the writing of the Quadrex Report.

35 Admit or deny that there was no consistent method for keeping track of margins in the HVAC design at the time the Quadrex Report was written. (4.a.2.4(n))

36.

Admit or deny a planned mar-in for the final HVAC system capacity did not exist at STNP prior to the date of the writing of the Quadrex Report. (H-8) 37 Admit or deny Applicant did not know no planned margin existed for the final HVAC system capacity at STNP up to the date the Quadrex report was written. (See: item 147)*

• 38.

Admit or deny there is not yet a procedure to assure that volume damper pressure drops are accounted for in HVAC fan selection calculations. (Sec. 4.4.2.4(o))

. 39 Admit or deny a review of the impact of non-safety-related component failures in the Equipnent and Floor Drain system had not been performed up to the date of the writing of the Quadrez Report. (Sec.4.a.2.4(y))

EO. Admit or deny the Applicant did not know the review described in item 39 (suura.)

had not been performed until the Quadrez reviewer pointed it out.

41. Admit or deny the HVAC design criteria were not documented in a single criteria document at STNP up to the time of writing of the Quadrex Report on STNP.

42. Admit or deny that no review of the essential cooling water (ECW) system to assure that a single rupture in an ECW line will not result in a loss of the source of the ECV had not f

been accomplished prior to the Quadrex review. (Sec 4.4.2.4 (x)).

43. Admit or deny that loads associated with pipe; rupture were used as a basis for plant design although EDS performed neither a design review or design verification of preliminary loads which were transmitted to B&R for use in design of STNP. (Sec. 4 5.2.1(b))

44. Admit or deny that Applicant was unaware that loads associated

-with pipe rupture were used as a basis for plant design although EDS performed neither a design review or design verification of preliminary loads which weratransmitted to B&R for use in de-sign of the STNP. (See: item 148, infra.)**

45. Admit or deny that damage to pipe supports due to pipe impact and det impingement was not investigated up to the date of the Quadrex Report writing. (Sec. 4 5.2.1(c))

46. Admit or deny that EDS company did not apply controlled cri-teria for ISI in the design for STNP up to the time of the Quadrex Report. (M-26A)

46. Admit or deny that the stability criteria for pipe rupture inside containment does not include a rpecific criterion for

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ensuring that maximum response has been determined, at STNP i

up to the time of the Quadrex Report. (M-23, EDS)

47. Admit or deny the Quadrex Report Question M-9 (B&R), shows that criteria for the "no break zone" (superpipe) was in-correct for STNP as shown by Report LO10RR064A, up to the date of writing the Quadrer Report.

(M-9 (B&R))

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. 48.

Admit or deny no acceptance criteria were formed at the STNP site up to the date of the writing of the Quad-rex Report for determining acceptability of pipe whip onto another pipe. (M-26 (B&R))

49.

Admit or deny B&R had no controlled criteria for main-tainance access, at STP. (M-26A)

50. Admit or deny B&R had no controlled criteria for ISI at STNP. (M-26A)

51. Admit or deny B&R had no controled' criteria for ALARA at STNP. (M-26A)

52. Admit or deny there was no THD for analysis procedures for pipe rupture evaluation outside containment at the STNP up to the time of the Quadrex Report. (Sec. 4 5.3.3(p))

53. Admit or deny that lack of consideration of pipe rupture effects in the component purchase specifications presents problems for equipment already installed at the STNP.

(M-25(B&R)).

54. Admit or deny that Applicant did not know that pipe rupture effects in the component purchase specificationswere not being included in equipment already instal 3ed at the STNP, until Quadrex made such a finding. (See: item 149, infra.i'*

55. Admit or deny that B&R assumed that pipe whip response in-side containment did not produce pipe stresses outside con-tainment (Sec. 4 5.3.4(u))

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56. Admit or deny that Applicant did not know that its ardlitect-engineer, B&R assumed that pipe whip response inside contain-ment did not produce pipe stresses outside containment.

57. Admit or deny that no evaluation for secondary effects of unrestrained pipe whip in the Turbine Generator Building was done prior to the Quadrex Corp. finding. (Sec. 4.5.3 4(z))

58. Admit or deny B&R used the Westinghouse definitions of tr,an-sients and plant design events. (Sec. 4 5 5.1 (b))

59. Admit or deny B&R utilized a 1 to 1 correlation of plant design events to ASME service level stress allowables. (Ibid.)

60. Admit or deny that at STNP all normal plant design events were ecuated to ASME Service Level A stress allowables. (Ibid.)

61. Admit or deny that at STNP plant upset events were equated to ASME Service Level B stess allowables. (Ibid.)

62, Admit or deny that the pipe rupture event is typically iden-tified as a Service Level B load for the ECCS systems. (M-29) l I

63. Admit or deny that B&R had no procedure providing guide-lines for the consistent review and approval of vendor reports. (M-50)

64. Admit or deny that Applicant did not know that B&R had no procedure providing guidelines for the consistent re-view and approval of vendor reports.

65. Admit or deny that Applicant knew that B&R had no pro-cedure providing Suidelines for the consistent review and approval of vendor reports, yet took no steps to change this prior to the Quadrex Report findings.

66. Admit or deny that B&R did not know whether passive valves and pumps are required to operate following an earthquake while employed as architect-engineers at STNP. (M-49)

67. Admit or deny that Applicant did not know whether Dassive valves and pumps are required to operate following an earthquake during the term from start of construction at STNP until the Quadrex finding M-49.

68. Admit or deny that Applicant did not know of any of the deficiencies reported by Quadrex Corp in M-49,'"Quadrex Assessment",- item 3, with regard to Hills-McCanna butter-fly valves, until brought to their attention by Quadrez Corp.

69. Admit or deny that Applicant has never inquired of the NRC with regard to approval of ANSI 278.2.4 as a licensing document. (M-50, and Sec.4 5.5.1(f))

70. Admit or deny that B&R specified containment penetrations a

with a primary plus secondary membrancplus bending stress j

allowable for upset load of 3.3 S,, which violated,ASME Section III and Section VII stress allowables. (Sec. 4 5.5.1(g),

1 M-30 and M-39) 6

71. Admit or deny that Applicant was unaware of the specifica-g tion deficiency in Sec. 4 5 5.1(g) of the Renort, until

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its attention was bought to it by Quadr?x Corp.

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72. Admit or deny the selection of 3 "g" horizontal and 2 "g" h

vertical seismic design loads for pumps will result in E

oversuoport of the piping system. (M-51, and Sec. 4.5 5 3(k) )

1

. 73.

Admit or deny that environnetal conditions for other than main steamline brea'k in the isolation valve cubicle (IVC) we re NOT provide 4for the equipment qualification document, SDD 4E010EQOO4-A. (N-15) (See: item 151) * *

74. Admit or deny that Applicant did not know that environ-mental conditions for other than main steamline break in the isolation valve cubicle were not provided for the equipment qualification document, SDD 4E010EQOO4-A.

75. Admit or deny there are differences between the assumptions used for Emergency Cooling Pond (ECP) initial temperatire for the Nuclear Analysis group and the Heavy Civil group at STNP. (Sec. 4.6.2.1(m).

76. Admit or deny Aoplicant was unaware of these differences prior to the Quadrez Corp. finding. (See: item 150, infra.)**

77. Admit or deny analysis for a double ended break rather than a crack break disagrees with an FSAR commitment for IVC studies. (N-13, Sec. 4.6.2.1(d))

78. Admit or deny the use of the computer program, RELAP3, for annulus pressurization analysis was inappropriate.

(Sec. 4.6.2.1(e))

79. Admit or deny that B&R planned to analyze all high energy lines in the IVC and MAB. (Sec. 4.6.2.2(p))

80. Admit or deny that B&R planned to seismically support all non-safety-related lines in the IVC and MA3 (Sec. 4.6.2.2(p))

81. Admit or deny that Applicant knew that B&R planned to seismically suoport all non-safety-related lines in the IVC and MAB, prior to Quadrer 6orporation's findings. (See: item 152, infra.)**

82. Admit or deny that Applicant knew B&R planned to analyze j

all high energy lines in the IVC and MAB.

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83. Admit or deny that Applicant knew that B&R had no acceptance criteria for containment spray analysis until the Quadrex l

finding in Question N-18. (See: item 153, infra.)**

84. Admit or deny that no analysis was performed of the most severe ECP load. (Sec. 4.6.2.4(v))

85. Admit or deny that the most severe load on the ECP is simultaneous normal shutdown of both units.

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86. Admit or deny that Applicant knew the most severe load on the ECP is simultaneous normal shutdown of both units l

prior to the Quadrex Corp. finding.

87. Admit or deny that Applicant knew no analysis had been performed for the most severe ECP load at STNP. (See: item 154)**

88. Admit or deny that B&R used a 7 level calculation for I

analysis of flooding of the ECCS pump room. (Sec.4.6.4.1(b))

89. Admit or deny that no investigation of the effects of elevated ECP temperatures occuring during a shutdown was made on operation of the Essential C'ooling Water l

(ECW) system.'

(Sec. 4.6.4.4(g))

)

90. Admit or deny that Apolicant knew that no investigation l

of the effects of elevated ECP temperature occuring during a shutdown was made on operation of the Essential Coolin6 Water system.

91. Admit or deny that SSE SAM loads as a primary load on pipe supports were ignored. (4.7.3.1(h))

92. Admit or deny that no consideration of feedwater hammer had been done for the STNP prior to 3/25/81. (Sec. 4.7.3.1(i))

93. Admit or deny that B&R was basing their definition of loads on anchors used to separate seismic from non-seismic cortions of oiping syste=s on engineering judgement by sel&cted engineers. (Sec. 4.7.3.1, and Question P-29) (See: item 155)"

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95. Admit or deny that the FSAR stated modal analysis is i

done in the piping analysis inside containment. (Sec.

7 7.2.1(a), and. "EDS Response, 3-31(a), questionP-7)

96. Admit or deny EDS's use of high stiffness (default values) for pine supports gives unconservative results compared to actual stiffness values. (Sec. 4 7.2.1(d)

97. Admit or deny that approximately (plus or minus 10%) 50%

of the system design documents for piping did not contain I

system operating temperatures at STHP prior to the Quadrex i.2 findings on this. (Sec. 4 7 3.1(b))

"* # elete item 94.

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. 98.

Admit or deny that environmental conditions used by West-inghouse to cualify its ' equipment WELE not identical to those used by B&R. (Sec. 4.7.3.1(e))

99.

Admit or deny, that at the STNP site, there was no auto-matic required review of Westinghouse Project Information Packages (PIP) changes to assure that they are identified.

(P-3) 100.

Admit or deny, that at the STHP site, there was no auto-matic required review of PIPS changes to assure they are acted upon. (P-3) 101.

Admit or deny that documented guidance on ISI was not formally used in the design process of STNP. (Sec. 4 7.3.2(n))

102.

Admit or deny that support self weighting was not con-sidered in seismic self wei6ht excitation analysis at STNP. (Sec. 4 7.3.4(x))

103.

Admit or deny that B&R did not document their bases for selecting valve end loads. (Sec. 4 7.3.4(s))

104.

Admit or deny that B&R did not document how relative dis-placements will be analysed for piping supports (Sec. 4 7.3.h(t) 105.

Admit or deny that B&R did not define any tollerances for restraint orientation. (Sec. 4.7.3.3(q) 106.

Admit or deny that Applicant took no steps toward an ALARA re-review program as recommended by Quadrex in March 1981.

(Sec. 4.8.2) 107 Admit or deny that B&R had no criteria for locating radiation probes in the ductwork of the STNP plants at least.until7the Quadrez review. (R-22) 108.

Admit or deny that B&R had no document criteria governing where concrete block walls may be located in the STUP design at.least 'uatil. the Quadrez review. (R-11) 109 Admit or deny there was no listing to' identify radioactive piping outside containment at the STNP plant prior to Quadrex identifying this lack. (R-12) 110.

Admit or deny thatApplicant did not know there was no listing to identify radioactive piping outside containment at the STNP plant prior to the Quadrex finding. (See item 157, infra.)**

111.

Admit or deny that the criteria of TRD, A509NQOO5-B,(the document identified by B&R "as the basis for design-for streamingzthrough-shield penetrations *was not,incorp. orated p f.. f-. c-s m

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. (Continuing item #111) in the design of the STNP. (R-13) 112.

Admit or deny that B&R told Applicant it would use the TRD, A509NQ005-B for the purpose identified in item #111 113.

Admit or deny that Applicant did not know at the time of the Quadrez review that B&R had not used TRD A509NQ005-B.

114 Admit or deny that the instrument air pipin5, between the valves actuated by redundant radiation.,moziitors -and.

the. valves that divert air flow through safety-related filter trains in the fuel handling building HVAC ex-haust system, does not meet the single failure criterion of IEE 279-1971 in the design of STNP. (Sec. 4.8.2.1(a),

and R-6) 115.

Admit or deny that until the Quadrex w view Applicant did not know of the item with regard to instrument air piping stated in item #114 (See: item 158, infra.)"

116.

Admit or deny that in the design of the STNP, B&R did not consider any radiation steaming analysis caelulations to be safety-related. (Sec. 4.8.2.1(d), and R-7) 117 Admit or deny that B&R told Applicant that in the design of the STNP, B&R did not consider any radiation streaming analysis safety-related.

118.

Admit or deny that prior to the Quadrex Review, Applicant did not know that in the design of the STNP, B&R did not consider any radiation streaming analysis safety-related.

a 119.

Admit or deny that Applicant did not know that no analysis y

of radiation streaming through reach rod penetrations had i-been performed for the STNP design prior to the Qtladrex Review. (Sec. 4.8.2.4(dd))

120.

Admit or deny that at the time of the Quadrex review, spe-cific criteria had not been developed which addressed mini'-

p mum area air change requirements.~(R-5)

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121.

Admit or deny that at the time of the Quadrex reviewi spe-

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cific-criteria had not been developed which addressed mini-

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mum area air change requirements.

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122.

Admit or deny that at the time of the Quadrex review,.spe-f f

cific. criteria had-not been developed which addressed 2.,.k,2 X_ m u.

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. (Continuing item 122) 4 minimum fan capacities to ensure that appropriate negative pressures would be maintained in areas where there was potential air-borne contamination. (R-5) 123.

Admit or deny that Applicant did not know the criteria mentioned in item #122 had not been developed prior to the Quadrer finding and its communication to Auplicant.

124.

Admit or deny that in the STNP design, B&R did not evaluate filter units for ease of access at any time prior to the Quadrex review. (Sec. 4.8.2.4(w))

125.

Admit or deny that in the STNP design, B&R did not evaluate i

filter units for minimizing exposures to plant employees until at least after the Quadrex review. (Sec.4.8.2.4(w))

126.

Admit or deny that Applicant did not know that B&R did not evaluate filter units for minimizing exposures to plant employees untfl at least after the Quadrex review.

127 Admit or deny that Applicant did not know that B&R did evaluate filter units for ease of access.

128.

Admit or deny that 3&R did not have radiation zone drawings based on accident conditions up to the time of the Quadrex finding in "Quadrex Assessment", Question R-30.

,29. Admit or deny no documented basis exists for the shield design of the counting room. ((Sec. 4.8.2.4(kk))

130.

Admit or deny that no documented basis existed _for selection of the range for a specific Area Range Monitor ( ARM), prior to the date of Quadrax finding Sec. 4.8.2.4(cc) at STNP.

131.

Admit or deny that Applicant did not know that no documented basis existed for selection of the range for a specific ARM prior to the date of the relevant Quadrex finding for STNP.

132.

Admit or deny that B&R had not reviewed the criticality monitors to assure that all of the design requirements specified in 10 CFR 70.24 hado been met at STHP up to the date of Quadrex findings in Sec. 4.8.2.4 (cc).

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133.

Admit or deny that 3&R had not deveDped any guidelines as a basis for~ making ALARA decisions, prior to the Quadrex findings in Sec.4.8.2.4(r) and R-3 134.

Admit or dany thatARM humidity conditions were not addressed in' specifications for them by S&R. (Sec. 4.8.2 3(p))

135.

Admit or deny that Applicant did not know ARM humidity conditions were not addressed in specifications for them by B&R.

136.

Admit or deny that the Radiation Shielding TRD, A509NQOO3B did, not address the use of removable shielding at STNP.

(Sec. 4.8.2.2(1))

137.

Admit or deny no TRD at STNP addresed the use of removable shielding.

138.

Admit or deny that B&R did not correlate radiation zones I

to the shielding design for the STNP plant. (Sec. 4.8.2.1(e))

139.

Admit or deny an HVAC duct is located under radweste

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piping in the Mechanical Auxilliary Building (MEAB) area on elevation 29 ft. (Sec. 4.9.2(o))

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140.

Admit or deny that EBASCO's methodolgy for a calculation h

of main steamline tunnel pressurization.< analysis does not f

take into account water level rise in the RPV which re-sults in an increase in mass-energy flow from the break.

(Quadrex EE1SCO Report, N-103) 141.

Admit or deny Applicant knew that the CPVR procedures did not prohibit use of a wrong verification problem to be sub-sequently signed off as verified, but was unsuccessful in having this changed. (See: items;. 8 and 9, suora.) *

• E 142.

Admit or deny Applicant knew that nationally rec-ognized pro-grams were used at the STNP site without verification rela-1 I

tive to.their intended application, but took no action to b

change this.

(See :.

items 13 and 14, supra.)**

143.

Admit or deny that Applicant knew. that no Technical Refer-

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l ence Document existed that specified the STNP plant-wide

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l separation recuirement for the electrical discipline, but 3

took no action. (See: items.

'15'and 16, suora.)**

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'144.

Admit or deny that Applicant knew there had never been formal methodology to verify the single failure criterion for the electrical systems at STNP, but took no action. (See:: Items-20 and 21, suora.)**

145 Admit or deny that Applicant knew ther, had never been formal documentation to verify adequate separ-ation of electrical systems at STNP, but took no action. (See:fitems 20 and 21, suora.)..

^146.

Admit or deny that Applicant was aware that the HVA0 heat load calculations did not consider off-normal i

system conditions at STNP, but took no action. (See:

Items.30 and 31, suora)..

147.

Admit or deny that Applicant knew a planned margin for the final HVAC system capacity did not exist at STNF, but took no action. (See: items 36 and 37,, suora. )

148.

Admit or deny that Applicant w&s aware that loads asso-ciated with pipe rupture were used as a basis for plant design although tt$ performed neither a design review 9:

or design verification of preliminary loads which were to be transmitted to B&R for use in the desi6n of STNP, but took no action. (See: items 43 and 44, suora.)..

149 Admit or deny that Applicant was aware that pipe rup-ture effects in the component purchase specifications were not being included in equipment already installed at STNP, but no action was taken. (See: items 53 and 54, suora.)..

150.

Admit or deny that Applicant knew the assumtions for calculating the ECP initial temperature by the Nuclear Analysis Group and the Heavy Civil Group were different, but took no action. (See: items 75 and 76, suora.)

• 151.

Admit or deny that even though Applicant knew' that environmental conditions for other than main steam-line break in the isolation valv.e cubicle were not provided in the equipment qualification document, SDD 4E010EQOO4-A, it took no action. (See: items 73 and 74, suers. ).*

l

~

+

. 152.

Admit or deny that even though Applicant knew that B&R planned to seistically support all non-safety-related lines in the IVC and MAB, it took no action. (See: items 80 and 81, suora. ) *

• 153.

Admit or deny that Applicant knew that B&R had no accep-tance criteria for containment spray analysis, but took no action.

(See: items 82 and 83, suora. ) *

• 154 Admit or deny that Applicant knew no analysis had been performed for the most severe ECP load at STNP, but took no action. (See: item 87, suora. ) *

• d 155.

Admit or deny that Applicant knew B&R was basing their g

definition of loads on anchors used to separate seismic from non-seismic portions of piping systems on engineering judgement.by selected engineers. (See: item 93, suora. ) * *

(

156.

Admit or deny that Applicant knew B&R was basing their definition of loads on anchors used to separate seismic l

from non-seismic portions of piping systems on enSineeering g

judgement by~ selected engineers, but took no action. (See:

[

items 93 and 155, suora. ) *

• Y 157.

Admit or deny that Applicant tock no action even though i

it knew there was no listing to identify radioactive piping f

outside containment at the STNP site. (See: items 109 and l

110, suora.)**

158.

Admit or deny that Applicant knew that the instrument air piping, between the valves actuated by redundant f

radiation monitors and the valves that divert air flow l

through safety-related filter trains in the fuel handling buildin5 HVAC exhaust system. did. not meet the single E

failure criterion of IEE 279-1971 in the desi5n'of the STNP, but took no action to correct the problem.

(See: items 114 and 115, suora.) **

159 Admit or deny that Applicant knew that B&R had not 5

used TRD A509NQ005-B.as a basis for design for radi-

}

l ation streaming through shield penetrntions, but took 5

l no action to correct the situation.

(See: items 111, i

112, and 113, suora.') * *

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4 4

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. 160.

Admit or Deny that Attachment A to this Intervenor's sixth set.of Interogatories, was an authentic and gen-uine copy of a memo from T. D. Stanley (HL&P) to A. J.

Granger (HL&P) of.Feb. 22,'1980.

161 Admit or Deny that Attachment B to this Intervenor's sixth set of Interogatories, was an authentic and gen-uine copy of an? office memorandum from S. Viaclovsky (HL&P) to A. Granger (HL&P) of lan. 15, 1981.

162.

Admit or deny that Attachment B to this Intervenor's fifth set of interogatroies, was an authentic and gen-uine copy of an Applicant " Audit Deficiency Report",

numbered BR 25-D2.

j k

163.

Admit or deny that Attachmeid-C to this Intervenor's fifth set of interogatories, was an authentic and gen-uine couy of an audit deficiency report by HL&P, numbered BR 25-D3.

s Respectfully,

~

1. 1. r'u

?

John F. Doberry

=!

CERTIFICATE OF SERVICE I certify that copies of INTERVENOR DOH2RTY'S FOURTH SET OF REQUESTS FOR ADMISSIONS TO APPLICANT (QUADREX REPORT MAT B

'd Al'D TEXPIRG CONTENTION 31) were served on the parties below b

i this 2.3 of March, 1982, in Houston, Texas via First Class U. S. Postal Service.

I Sheldon J. Wolfe, Esq.

Administrative Judge Gustave A. Linenberger Jr.

Dr. E. Leonard Cheatum Administrative Judge Administrative Judge 551 Jack R. Newman, Esq.

Applicant J. Gregory Copeland, Es Richard A Black, Esq. q.

Applicant 3

~ ~d Staff U.S.H.R.C. Docketing & Service

~

Atomic Safety Licensing & Appeal Board

?

Ths Several Intervenin6 Parties

?

pg 4

Q

!b G

d!/

h&

John F. Doherty

• Hand delivered to Baker & Botts, S-3000; One Shell Plaza,

}f Houston, Texas, 77002, March 23, 1982.

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