ML20050C479
| ML20050C479 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 03/29/1982 |
| From: | Rozzell S BAKER & BOTTS, HOUSTON LIGHTING & POWER CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8204080540 | |
| Download: ML20050C479 (40) | |
Text
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March 29, 1982 00f.1'rTED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD In the Matter of S HOUSTON LIGHTING & POWER COMPANY $ Docket No. 50-465 5 0 (Allens Creek Nuclear Generating &
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HOUSTON LIGHTING & POWER COMPANY'S 95 % 'n6l #-19 ANSWERS AND OBJECTIONS TO 3 hff4 d82 DOHERTY'S FOURTH SET OF INTERROGATORIES g '[jk@jlt[s y ;
In response to a document entitled "Intervenor 4 Doherty's Fourth Set of Interrogatories to Applicant With Regard to TexPirg Contention 31 and Quadrex Matters", Applicant answers and objects as set forth below. As stated in response to Mr. Doherty's First Set of Interrogatories, Mr. J. H.
Goldberg, Vice President - Nuclear Engineering and Construction will testify regarding the pertinence of Quadrex Corporation's review of engineering work at the South Texas Nuclear Project to the Allens Creek Nuclear Generating Station. Mr. Louis J.
Sas, Vice President - Engineering with Ebasco, will testify regarding Ebasco's engineering organization for the Allens Creek Nuclear Generating Station.
Initially Applicant notes that it has objected to a number of the interrogatories in this Fourth Set because they are irrelevant to the limited 1seue to be neard in the f
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t reopened proceeding pursuant to the Board's Order of January 28, 1982. For example, many of Mr. Doherty's interrogatories are directed at exploring either the details of design of the STP or the Quadrex evaluation of specific Brown & Root engineering practices -- matters which are beyond the scope of the Board's Order. Questions concerning whether the STP is being safely designed and constructed are before the STP Board, which has deferred consideration of all Quadrex related issues until ongoing reviews of the Quadrex Report by the Applicant and the NRC Staff are completed late this year. The Board's Order did not admit these STP-specific matters for litigation in this proceeding. Rather, the limited issue to be explored in this reopened proceeding is how the Quadrex Report, and specifically the matters labelled (A) through (O) in Doherty's December 7, 1981 motion, reflect t
-upon the technical qualifications of HL&P to oversee the design and construction of the ACNGS. While Applicant has objected to a number of such interrogatories, it has also answered some interrogatories of questionable relevance.
Applicant's decision to answer such interrogatories should not be taken as conceding their relevance to this reopened proceeding. On the contrary, ,\pplicant maintains that the
, vast majority of the hundreds'of obscure and pointless interrogatories contained in the six sets of interrogatories j - -.
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thus far received from Mr. Doherty are not relevant to.the reopened Allens Creek proceeding. Moreover, in answering any questions hereinafter, Applicant does not admit the accuracy or relevance of any assumptions made by Mr. Doherty in posing such questions.
INTERROGATORY NO. 1 What are the personal qualifications of R. Koppe, Q. Hossain, J. Nardello, Gene Esswein, H. R. Booth, and R.
Uffer of the Quadrex Corporation?
ANSWER
- 1. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 2 What examples did Quadrex provide to support its statement in Sec. 4.6.2.l(c) of the Report, that: " Nuclear Analysis has failed to scope, perform or have analysis per-formed that should have been completed (including correction of reports containing obsolete or erroneous analysis) given the present state of STP design and construction?
e (a) Does Applicant agree with the finding in 4.6.2.l(c)?
(b) Does the finding apply to NUS and B&R?
(c) What part of its organization will Applicant rely upon to prevent a similar problem or situation at ACNGS?
ANSWER
- 2. The Quadrex Report contains the entirety of the information provided HL&P on this subject.
2(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on-TexPirg Additional Contention 31).
2(b). Same objection as 2(a).
2(c). As described in PSAR Section 17.l.3A, HL&P-Project Engineering provides programmatic direction and overview of Ebasco engineering activities to ensure that such activities are conducted in accordance with approved engineering procedures. HL&P Engineering performs reviews of selected elements of the completed design, design docu-ments and specifications to ensure that contractual require-ments are met. As stated in PSAR Section 17.1.18A HL&P QA
audits Ebasco activities to verify compliance with the QA Program. In addition, the HL&P Engineering Assurance Depart-ment will review selected elements of the design for technical t
adequacy.
INTERROGATORY NO. 3 What are the personal qualifications of Earl Willey of Quadrex Corp.?
ANSWER 4
- 3. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's~ January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 4 What basis did Quadrex provide for the statement:
"The technical' assumptions used for design ar.J analysis are not reasonable for STP?" (See Sec. 4.6.2., p. 4-57, Report)
(a) Prior to Quadrex, did Applicant protest that any technical assumptions were not reasonable for STNP?
(b) Make available any documents that question technical assumptions in the above, but identify same in your reply, please.
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ANSWER
- 4. Quadrex provided no explanation'beyond_that which is contained in its report.
4(a). Applicant objects to this interrogatory on the ground th&t the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg-Additional Contention 31). Moreover, Applicant objects to this interrogatory on the ground that it-is unduly vague and Applicant cannot determine what information is sought.
4(b). Same objection as Interrogatory 4(a).
INTERROGATORY NO. 5 In Sec. 4.6.2., p. 4-57, has Quadrex indicated-what it means when it states, "...no evidence has been seen that the B&R Nuclear Analysis Group has produced a signi-ficant' contribution to the STP design?"
(a) Prior to Quadrex has Applicant been dis-satisfied with-the production of.this group?
l (b) Make available any documents that show Appli-i cant's dissatisfaction expressed, but identify same in your reply, please.
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(c) What does Applicant intend to do supervising ACNGS construction with regard to the analogoua Ebasco Services Nuclear Analysis Group that will prevent the problem cited here by Quadrex?
(d) With regard to Question N-15, what equipment had been purchased without backup analysis?
ANSWER
- 5. See discussion following the quoted statement on p. 4-57 of the Quadrex Report.
5(a). Applicant objects to this inte.rrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in.the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31). Moreover, Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what information is sought.
5(b). See response to Interrogatory 5(a).
5(c). As described in PSAR Section 17.1.3A, HL&P Project Engineering provides programmatic direction and overview of Ebasco engineering activities to ensure that such activities are conducted in accordance with approved engineering procedures. HL&P Engineering pertorms reviews 4
. of selected elements of the completed design, design docu-ments and specifications to. ensure that contractual require-ments are' met. As stated in PSAR Section 17.1.18A HL&P QA audits Ebasco activities to verify compliance with the QA Program. In addition, the HL&P Engineering Assurance Depart-4 ment will review selected elements of the design-for technical adequacy.
5(d). Applicant objects to this interrogatory on-i the ground. that the information cought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's' January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
d INTERROGATORY NO. 6 Had Applicant prior to Quadrex detected the inap--
propriate use of RELAP3 code mentioned in Question N-13?
(a) If so, make available any document showing this, and identify-the document by name and date in your response, please.
ANSWER
- 6. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified
- in the Licensing Board's January 28, 1982 Memorandum and
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Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
6(a). Same objection as Interrogatory 6.
INTERROGATORY NO. 7 Did~ Applicant obtain any reasons from B&R for not identifying any high energy lines in the' Mechanical Auxil-liary Building (MAB) to be analyzed for environment? (See Question N-3)
(a) Was Applicant aware that B&R had no breaks 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 aware sooner of thia type of problem if it should occur at ACNGS?
(.c) Would it be one of Applicant's responsi-bilities to make B&R certain of any need to perform analyses for high energy line breaks in the MABI ANSWER
- 7. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order-(Granting The Doherty Renewed Motion For Additional F.vidence on TexPirg Additional Contention O'.).
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7(a). Same objection as Interrogatory 7.
7(b). As described in PSAR Section 17.1.3A, HL&P Project Engineering "- " ides programmatic direction and overview of Ebasco engineering activities to ensure that such activities are conducted in accordance with approved engineering procedures. HL&P Engineering performs reviews of selected elements of the completed design, design docu-ments and specifications to ensure that contractual require-ments are met. As stated in PSAR Section 17.1.18A HI GP QA audits Ebasco activities to verify compliance with the QA Program. In addition, the HL&P Engineering Assurance Depart-ment will review selected elements of the design for technical adequacy.
7(c). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified
- in the Licensing Board's January 28, 1982 Memorandum and l Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 8 Did Applicant know that NUS Company was using an i
obsolete code in its annulus pressurication analysis?
i (Question N-2, Reoort)
(a) inuit 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 calcu-
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3 lated for ACNGS?
(d) What has Applicant done to be sure obsolete codes are not used there, if the answer to (c) is affirmative?
ANSWER
- 8. Applicant objects to this interrogatory on the ground that the information sought is.not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and 1
Order (Granting The Doherty Renewed Motion For Additional i Evidence on TexPirg Additional Contention 31).
8(a). Same objection as Interrogatory 8.
8(b). Same objection as Interrogatory 8.
8(c). Yes.
8(d). HL&P's contracts with Ebasco and General
) Electric require the use of appropriate design and engineering
{ practices. Moreover the use of adequate codes is. assured by the NRC review of SAR analyses. Finally, HL&P Engineering performs reviews of selected elements of.the completed i
a design, design documents.and specifications to ensure that contractual requirements are met.
INTERROGATORY NO. 9 With regard to Question N-8 of the Report, was Applicant aware that B&R did not know the proper methodology for handling potential flow paths during environmental analysis?
l ANSWER
- 9. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 10 With regard to-Question N-lO of the Report, 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 l them.
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ANSWER
- 10. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in'the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 11 Was Applicant aware B&R was not giving considera-tion 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.
ANSWER
- 11. Applicant objects to this interrogatory on the ground that the information sought is not relevant to l
the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
'r ll(a). See objection to Interrogatory 11.
I 1
. INTERROGATORY NO. 12'
-Was Applicant aware prior to Quadrex that B&R had not considered local hydrogen concentrations in the battery-room? (Question N-25, Report)
(a) If yes, indicate'what memos, documents, etc.
indicate this and give names in your reply, and please
. make them available for inspection and copying.
(b) Is hydrogen generation in the battery room of t
the ACNGS a consideration in that plant's design?-
ANSWER
- 12. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and
- Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
12(a). See objection to Interrogatory 12.
12(b). Yes.
1 INTERROGATORY NO. 13 4
With reference to Question M-11 (and see also p.
4-61 of the Report), what part of the reactor protection system does the MSIV trip or valve ramp characteristics play?
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3 (a) Prior to Quadrex, was Applicant aware of any
" weakness"'in B&R's understanding of the MSIV trip logic?
(b) How will Applicant be able to assess this a weakness sooner should it occur at the ACNGS site?
ANSWER
- 13. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
13(a). Same cbjection as Interrogatory 13.
13(b). As described in PSAR Section 17.1.3A, HL&P Project Engineering provides programmatic direction and overview of Ebasco engineering activities to ensure that 1
such activities are conducted in accordance with approved i engineering procedures.
i HL&P Engineering performs reviews of selected elements of the completed design, design documents and specifications to ensure that contractual requirements are met.
As stated in PSAR Section 17.1.18A HL&P QA audits Ebasco activities to verify compliance with the QA Program.
In addition, the HL&P Engineering Assurance Department will review selected elements of the design for technical adequacy.
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INTERROGATORY NO. 14 Referring to Question N-18, .does Applicant agree I
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 a to the Report?
- (b) Was Applicant aware that-B&R considered this analysis a Westinghouse responsibility?
(c) What steps has Applicant taken to be certain a
there is no recurrence of this at ACNGS?
ANSWER
- 14. Applicant objects to this interrogatory on the ground that the information sought is not relevant to i
the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and i Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31). Moreover, Applicant objects to this interrogatory on the ground that i
it is unduly vague and Applicant cannot determine what information is sought.
I 14(a). Same objection as Interrogatory 14.
- 14(b). Same objection as Interrogatory 14.
14(c). Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what information is sought.
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INTERROGATORY NO. 15.
In Quadrex's discussion of the B&R-response to
~ Question C-4, they mention a reportable deficiency on the structural steel inside containment caused by the lack of i consideration-of 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 sentence of "Quadrex Assessment")
(b) Was the structural steel constructed prior to the deficiency report?
I ANSWER 15(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding aus identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
15(b). Same objection as Interrogatory 15(a).
INTERROGATORY NO.
- In Sec. 4.6.2.4(u) of the Reoort, did Quadrex calculate how much higher the localized temperature for the outside containment concrete would be?
o (a) Prior to Quadrex, was Applicant aware a higher temperature was required, and if so, when was Applicant first aware?
I -
ANSWER
- 16. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
16(a). Same objection as Interrogatory 16.
INTERROGATORY NO. 17 Referring to item 4.6.2.4(v) of the Report, has Applicant the option of. enlarging the ECP to accommodate concurrent trip of the STNP units?
ANSWER
- 17. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 23, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 18 Question N-23 of the Report, which consists of several questions on ECCS pump room flooding, states'in the "Quadrex assessment": "Quadrex review of handout calcula-tions showed a 44% non-conservative error. (Break area of
.432 in2 should be .622 in2. Pipe wall thickness was in-advertently used."
(a) Does this mean B&R substituted the pipe wall thickness 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.
ANSWER 18(a). Applicant objects to this interrogatory on i the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and
' Order (Granting The Doherty Renewed-Motion For Additional Evidence on TexPirg Additional Contention 31).
18(b). Same objection as Interrogatory 18(a).
18(c). Same objection as Interrogatory 18(a).
INTERROGATORY NO. 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, j was not provided? If not, for what reasons?
ANSWER
- 19. Applicant objects to this interrogatory on the ground that the information sought is not relevant'to '
the-limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order-(Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
a INTERROGATORY NO. 20 .
Relevant to Question R-9 of the Report, was=Ap-plicant aware that access to a steam generator manway was interfered with by structures, prior to Quadrex?
(a) If "yes" to the above, when did Applicant first become aware? (Please make available any docu-ments, etc. showing Applicant was aware as stated)
, (b) How did Applicant first find out?
(c) If Report was Applicant's first notice, what changes has Applicant made at ACNGS to prevent structures
- from impeding access to frequently maintained equipment.
, in containment?
ANSWER j 20. Applicant objects to this interrogatory on the ground that-the information sought is not relevant to the limited issues in this reopened proceeding as identified
-in the Licensing Board's January 28, 1982 Memorandum and
Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
20(a). See response to Interrogatory 20.
20(b). See response to Interrogatory 20, 20(c). Without conceding that any such situation existed at STP, Applicant states as follows with respect to ACNGS:
As described in PSAR Section 17.1.3A, HL&P Project Engineering provides programmatic direction and overview of ,
Ebasco engineering activities to ensure that such activities are conducted in accordance with approved engineering procedures.
HL&P Engineering performs reviews of selected elements of the completed design, design documents and specifications to ensure that contractual requirements are met. As stated in PSAR Section-17.1.18A HL&P QA audits Ebasco activities to verify compliance with the QA Program. In addition, the HL&P Engineering Assurance Department will review selected elements of the design for technical adequacy.
INTERROGATORY NO. 21 Relevant to Question R-9 of the Report, was Ap-plicant aware that access to Valves RHO 60B and XBH-Ol9B were located such that maintainability would be very difficult or almost impossible, prior to the Report? If so, at what date was Applicant aware, and indicate in your reply which documents, etc. show this, plus make the documents, etc. available.
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(a) What is the function of these valves, and what systems utilize their function?
ANSWER
-21. Applicant objects-to this interrogatory on the ground that.the information sought is not relevant to the limited. issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Centention~31).
21(a). See objection to Interrogatory 21.
. INTERROGATORY NO. 22 ,
Referring to Question R-9 of the Report, was Applicant aware prior to Quadrex that Valve XRC-074C 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 XRC-074C, and I
of which plant system is it a part?
ANSWER
- 22. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional U
Evidence on TexPirg Additional Contention 31).
22(a). Same objection as Interrogatory 22.
INTERROGATORY NO. 23 What is the radiation streaming referred to in Question R-13 of the Report?
(a) Does Applicant agree with the Quadrex assess-ment that for the most part, the criteria of TRD A509NQOO5-B dealing with (radiation) streaming through shield penetrations had not been implemented?
(b) Prior to Quadrex Reoort, had Applicant noticed that.the document mentioned in part 23(a) criteria had not been implemented with regard to shield penetra-tions? If so, please identify and make available any document, report, etc. which shows this.
ANSWER
- 23. Radiation streaming normally refers to an increase in dose rate of radiation (usually neutron or gamma) with respect to the shielded dose rate. This relative increase in dose rate is due to the lower amount of attenuation i
caused by random irregularities of the shield and by necessary l
l discontinuities in the shield.
23(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified I
in the Licensing Board's January 28, 1982 Memorandum and l Order (Granting The Doherty Renewed Motion For Additional i
Evidence on TexPirg Adaitional Contention 31).
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23(b). Same objection as Interrogatory 23(a).
INTERROGATORY NO. 24 Referring to Question R-lO of.the Report, what is a " gap release" accident?
ANSWER
- 24. HL&P believes that a " gap release accident" as stated in Question R-lO refers to an event in which the gaseous activity initially residing within the-fuel pin is released from the fuel pin to the reactor environment.
INTERROGATORY NO. 25 t In what ways does Quadrex Corp. maintain' shielding design did not adequately consider ISI requirements or
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potential locations for temporary shielding? (Report, Question R-lO)
ANSWER .
- 25. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and
' Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 26 Does Applicant agree that, "The radiation zones
...have not taken into account accident situations or other abnormal conditions?" (Recort, Question R-lO) 24-
__m.
~(a) Prior to Quadrex Recort, had Applicant noticed this alleged deficiency? If so, please identify and make available any document, report, etc. which shows this.
ANSWER
- 26. Applicant objects to this in.terrogatory on the ground that the information sought is not relevant'to 'l the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional ,
Evidence on TexPirg Additional Contention 31). ,
26(a). Same objection as Interrogatory 26. x INTERROGATORY NO. 27 Reoort, Question R-6, states, "A failure mode and effects analysis has not been performed from a radiological-safety standpoint on the systems referred to in the B&R 7_
response". Are each of the systems below included in that statement to the best of your knowledge? (a) Spent Fuel Fool Ventilation, (b) Fuel Handling Building Ventilation, (c) Control Room Ventilation, (d) Reactor Containment Building Stack Monitor. .
ANSWER
- 27. Applicant objects to this interrogatory on
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the ground that the information sought is not relevant to
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tihe l'i,mited isstfes in this reopened proceeding 'as identified in the, Licensing Board's Janu&ry 28, 1981 Memorandum and , .
Order (Grant,ing The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contentiion 3b .
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INTERROGATORY NO. 28
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Were any] reviews of plant-design from an ALARA ,.
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standpoint, ever given:~to Applicant in result form?
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ANSWER
- 28. Applicant objects to this inter ogatory on the ground that the information sought.'is no't' relevant to s v-i% _{ .
tiie'~limitedissuesinthisreopenedproceedinh.asi_dentified in the Licensing Board's January 28, 1992 Memorandum and
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Order (Granting The Doherty Renesed Motion ~For Additional Evidence en TexPirg Additional Contentibn,31).,,
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INTERR GATORY No. 29
'Did Applicant ever ask for the resul'ts of,such reviews asl mentioned in item 28, above? -
~ ; -ANSWER .
Applicant objects to this int'errogatory on
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the ground that the,information sought is not relevant to
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' sthe limite$-issues in this reopened proceeding as identified c' !in the Licens ng Board's January 28, 1982 Memorandum and i
Order (Gr nting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31). Moreover, e
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information is sought.
jNTERROGATORY NO. 30
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Referring to the Report, Question R-1, does Ap-s plicant accept the statement that BAR reviews of plant " '
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.s design from an ALARA standpoint were inadequate? If so, indicate the date.and names of any report, document or memo.
indicating this, and make it available to this Intervenor, ^
please.
ANSWER !
- 30. Applicant objects to this interrogatory on
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th'e, ground thai the information sought is not relevant to ,
the s limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum an'd
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Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 31 .
At any time prior to the Reoort, had any of Appli-cant's personnel reviewed models and codes used for shielding analysis by B&R? Has Applicant any reports, memos, etc.
showing ~their opinion of B&R's understanding of these analyses?
If so, please indicate the date of, and identify these reports or memos, etc. as well as make them available to Intervenor. (See: Report, Question R-ll)
ANSWER -
- 31. Applicant objects to this interrogatory on the ground that the information sought is not relevant to 4
the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, (982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 32 What is the identity and date of any memo, report, etc. where Applicant requested that B&R make a listing of radioactive piping outside containment? Please make this request available to Intervenor. (See Report, Question R-12)
ANSWER
- 32. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 33 Did Applicant concur in B&R's conduct in not reviewing the documents NUS-TM-261, " Pressure Vessel Activa-tion Product Radiation Analysis and Shield Design," 1976; I
- . . . .- ~ _ .__ __ . ._
and NUS-TM-232, " Radiation Streaming Through Reactor Vessel Primary Shield Gap and Inspection Tot.rs," 1976? (See:
Report, Question R-14)
. ANSWER
- 33. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 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 request, identify any memo, report, letter, etc. showing this, and make such item available to this Intervenor, please.
ANSWER
- 34. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified [
- in the Licensing Board's January 28, 1982 Memorandum and 4
Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
. _ . _ _ _ _ . _ _ _ _ ~_ - - _ _ . - . _
INTERROGATORY NO. 35 Had Applicant, prior to Quadrex Report, ever notified B&R or other contractor at STNP of the need for a 1
design basis governing removable concrete block walls?
(See: Report,'Sec. 4.8.2.l(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. document or means used,-
in your reply to this Interrogatory.
ANSWER
- 35. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982. Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
35(a). See response to Interrogatory 35.
INTERRGATORY NO. 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 Applicant concluded this. Identify them in your reply, please.
ANSWER
- 36. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 37 Referring to a letter from G. W. Oprea signed by J. H. (?)_Goldberg ("for") of 6/5/81 identified as ST-HL-AE-678; SEN: V-0530, did the assessment of computer. codes mentioned there refer to work by Quadrex? (See Attachment A")
ANSWER
- 37. No.
INTERROGATORY NO. 38 Referring to Question C/M-3 of the Report. what are the names of the following computer programs and what do they compute or provide for the user? a) ES-425; b) CP-231; c) EP-200; d) EL-303; e) CW-522.
- ANSWER 1
- 38. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and
, -+ - - , . . , _ - - - - - , . , , , - r . ,-- .-- -,e..,
. . - . . - = . . .. . _ . _
l Order (Granting The Doherty Renewed Motion For Additional '
Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 39 Relevant to Question C/M-8 of the Report, had Applicant ever examined or approved of the document STP-DC-017-C? ~
(a) Did Quadrex 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 the date and identifying name or number of any document or i
report showing this and make said item available. If not, how will Applicant at the ACNGS site prevent this-with Ebasco Services?
(c) Was Applicant aware, prior to Quadrex, that i
j B&R was permitted to verify codes in five ways according to document STP-DC-017-C, without guidance for preference?
] If so, please give the date it determined this, and identify any document or other item showing this and make it available.
m - - - - - ,v,- .- a -, - - ,--.-,.-.w -
,~..r,. . , . - - - , -
r-,-,--,a e -
i ANSWER
- 39. Applicant objects to this interrogatory on the ground tha. the information sought is not relevant to-the limited issues in this reopened proceeding as identified i
i in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contcati n 31).
39(a). Same objection as Interrogatory 39.
39(b). Applicant objects to the first two parts j of this interrogatory on the ground that the information 4
sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed
- Motion For Additional Evidence on TexPirg Additional Conten-tion 31).
As to the third part of this interrogatory, with respect to ACNGS, as described in PSAR Section 17.1.3A, HL&P Project Engineering provides programmatic direction and overview of Ebasco engineering activities to ensure that such activities are conducted in accordance with approved :
engineering procedures. HL&P Engineering performs reviews l of selected elements of the completed design, design documents and specifications to ensure that contractual requirements are mot. As stated in PSAR Section 17.1.18A 4
j' i I
i .
- HL&P QA audits Ebasco activities to verify compliance with the QA Program. In addition, the HL&P Engineering Assurance
] Department will review selected elements of the design for
! technical adequacy.
39(c). Applicant objects to this interrogatory on ,
the ground that the information sought is not relevant to
, the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty P.enewed Motion For Additional
- l. . .
Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 40 Prior to Quadrex Report, wk.1 Applicant aware that document STP-DC-017 permitted that, "If any part or portion
.; of the computer code is verified, the whole is considered .
verified."? If so, indicate date Applicant became aware of l.
[ it, anything it did as a result of this awareness, and i
identify and make available any memo, etc. that shows this.
l (Refer to C/M-13, Report)
ANSWER
- 40. Applicant objects to this interrogatory on the ground that the information sought is not. relevant to
, the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
, , , - - - , , -,-n .,-..-,-.,-..-n ,..-.,..n_-, , - - - , , . , - - - , . - - ,,n ~ , , . - , . . , - - - - , , , - c n ,-.
. A INTERROGATORY NO. 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 differences in the listings between the FSAR and the PSS mentioned by Quadrex in Question C/M-1 of the Recort? If so, when was Applicant first aware, and what memo or document, etc. shows this awareness?-
(c) What will Applicant do in the case of its ACNGS organization to keep these two documents correctly updated, that it did not do in the case of STNP?
ANSWER
- 41. Applicant objects to this interrogatory on-the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
41(a). Same objection as Interrogatory 41.
i _ ._
.- = - -
41(b). Same objection as Interrogatory'41.
Order (Granting The Doherty Renewed Motion'For Additional Evidence on TexPirg Additional Contention 31).
41(c). Ebasco and General Electric provides HL&P with the pertinent SAR provisions and the updates thereto.
HL&P Engineering performs reviews of selected elements of the completed design, design documents and specifications as well as SAR changes. As stated in PSAR Section 17.1.lSA HL&P QA audits Ebasco and General Electric activities to verify compliance with the QA Program.
INTERROGATORY NO. 42 Was Applicant aware program name and version number, date of execution and sequential page numbering did not appear on every page of all output prior to Quadrex Assessment C/M-2? If so, please indicate the date of first awareness and identify any letters, memos, etc. that show this. Did Applicant attempt to have B&R revise this practice?
ANSWER
- 42. Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
e 9
Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
- Respectfully submitted, OF COUNSEL: ON M' 4 regory Copeland * '
BAKER & BOTTS Scott E. Ro ell 3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, Jack R. Newman
. REIS & AXELRAD - Alvin H. Gutterman 1025 Connecticut Ave., N.W. David B. Raskin Washington, D.C. 20036 1025 Connecticut Ave., N.W.
Washington, D.C. 20036 ATTORNEYS FOR APPLICANT -
HOUSTON LIGHTING & POWER COMPANY
- , - - , - - -----,y- - -
-, ,,,,,mw, -
STATE-OF TEXAS S S
COUNTY OF HARRIS S BEFORE ME, the undersigned authority, on this day personally appeared George W. Oprea, Jr., Executive Vice President of-Ho'iston Lighting & Power Company, who upon his oath stated that the. foregoing answers to "Intervenor Doherty's Fourth Set of Interrogatorie,s Re Quadrex" were prepared under his supervision and direction, and that all statements contained therein are true and correct to the best of his knowledge and belief.
surrL " i / s\
- rew
~ dorgpV. OpregJr.,
SUBSCRIBED AND SWORN TO BEFORE ME by the said George W. Oprea, Jr., on this g hday of March, 1982.
G dkW Notary Public, State of My Commission Expires /,.f.exasJ e - {&
4
, - .- - - , - , ~ -
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S
HOUSTON LIGHTIWG & POWER COMPANY S Docket No. 50-466 S
(Allens Creek Nuclear Generating S Station, Unit 1) 5 CERTIFICATE OF SERVICE I hereby certify that copies of Houston Lighting &
Power Company's Answers and Objections to Doherty's Fourth Set of Interrogatories in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by. hand-delivery this 14Tkday of March, 1982.
Sheldon J. Wolfe, Esq., Chairman Hon. Charles J. Dusek Atomic Safety and Licensing Mayor, City of Wallis Board Panel P. O. Box 312 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D. C. 20555 Hon. Leroy H. Grebe Dr. E. Leonard Cheatum County Judge, Austin County Route 3, Box 350A P. O. Box 99 Watkinsville, Georgia 30677 Bellville, Texas 77418 Mr. Gustave A. Linenberger Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 Susan Plettman Richard Black David Preister Staff Counsel Texas Attorney General's Office U.S. Nuclear Regulatory P. O. Box 12548, Capitol Station Commission Austin, Texas 78711 Washington, D. C. 20555
Bryan L. Baker Brenda McCorkle 1118 Montrose 6140 Darnell Houston, Texas 77019 Houston, Texas 77074 J. Morgan Bishop W. Matthew Perrenod 11418 Oak Spring 4070 Merrick Houston, Texas 77043 Houston, Texas 77025 Stephen A. Doggett Wayne E. Rentfro P. O. Box 592 P. O. Box 1335 Rosenberg, Texas 77471 Rosenberg, Texas 77471 John F. Doherty William Schuessler 4327 Alconbury 5810 Darnell Houston, Texas 77021 Houston, Texas 77074 Carro Hinderstein James M. Scott 723 Main, Suite 500 13935 Ivy Mount Houston, Texas 77002 Sugar Land, Texas 77478 D. Marrack 420 Mulberry Lane Bellaire, Texas 77401 b \
. Rozzell
.