ML20050E296

Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence

ML20050E296
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	04/05/1982
From:	Rozzell S BAKER & BOTTS, HOUSTON LIGHTING & POWER CO.
To:	DOHERTY, J.F.
Shared Package
ML20050E286	List: ML20050E285 ML20050E289 ML20050E296
References
NUDOCS 8204130210
Download: ML20050E296 (34)

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April 5,19879'EUU MQgg, , - , e,

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD In the Matter of 5 5

HOUSTON LIGHTING & POWER COMPANY 5 Docket No. 50-466 5

(Allens Creek Nuclear Generating 5 Station, Unit 1 5 HOUSTON LIGHTING & POWER COMPANY'S ANSWERS AND OBJECTIONS TO-DOHERTY'S SEVENTH SET OF INTERROGATORIES In response to a document entitled "Intervenor Doherty's Seventh 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 Seventh Set because they are irrelevant to the limited issue to be heard in the dOhhjg5

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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 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, Applicant maintains that the vast majority of the hundreds of obscure and pointless interrogatories contained in the seven sets of interrogatories

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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 Referring to Attachment A, did B&R or Applicant perform the large break ECCS analysis for the South Texas Project (STP)?

(a) If B&R, when was Applicant first aware of the error?

(b) Please make available any reports or letters, etc., that show this, and identify them in your reply.

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 identifie1 in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence I on TexPirg Additional Contention 31).

1(a). Same objection as Interrogatory 1.

1(b). Same objection as Interrogatory 1(a).

I INTERROGATORY NO. 2 With regard to the Quadrex Report on Allens Creek work by EBASCO Services, (a) Approximately what % (percent) of the EBASCO engineering response was sampled in each of the four areas (Civil / Structural; Mechanical; Nuclear; Pipe Support? (See: Sec. 1.0 of the Report).

(b) What is meant by " insight regarding the current status of the technical work performed by each discipline? (Sec. 1.0, Report).

(c) Did Quadrex use any kind of guide for making ,

comparisons with " normal industry practice", or was this concept merely experience-based and without written criteria?

(d) Why was ISI (in-service inspection) not  ;

included in this design review, in view of the difficulties with this for ACNGS design work? (See this Intervenor's '

Sixth Set of Interrogatories, Question #9, and Attachment B).

(e) Why did Applicant cause the Quadrex Report on [

I EBASCO to be done? '

(f) Were there any signs to Applicant that l EBASCO Services was not working properly on the project at the time the report was started? If "yes", please indicate what these were, and indicate the date and

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identify the first Applicant report on each sign that EBASCO Services was not working properly, and make them available.

(g) What investigations of battery room hydrogen concentration, and heating and ventilation were done by Quadrex? (See: p. 3-8, Report).

(h) Has EBASCO Services reviewed any vendor submitted reports in any area or discipline other than civil / structural? If so, which disciplines have done this for ACNGS?

(i) Was any conscious effort made to choose items for the Quadrex Report on EBASCO which were similar to items in which the Quadrex Report on Brown & Root (B&R) revealed deficiencies or other difficulties?

(j) Prior to the Quadrex-EBASCO Services Report, had Applicant questioned EBASCO if its civil / structural department maintained a guide to computer programs? If "yes", when? Identify any report showing this in your reply, please, and make it available.

(k) What did EBASCO engineers state that gives Quadrex confidence computer programs have been used properly? (Report, Question C-104) How many programs are included in this statement?

(1) How many hours total were spent in reviewing:

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4 (1) Civil / Structural (2) Mechanical (3) Nuclear (4) Pipe Support; for the Quadrex-EBASCO Report by Quadrex?

(m) Referring to Question C-111 of the Report, what is non-participating mass? Is the effect on safety negative when this is too great a magnitude when used in the PIPESTRESS 20'.O Program?

(n) Is the Corporate MNE Pipe Rupture Analysis

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Manual noted in Question M-lO2, being done by EBASCO?

If "yes" why is this necessary since they have built other plants?

(o) Referring to Question M-lO3 of the Report, did EBASCO state it would evaluate all potential targets?

If not, what does the last sentence of "Quadrex Assess-ment" for M-lO3 mean? (That is, isn't Quadrex in error?)

(p) In Question N-lOl of the caport, what does

" Appropriate" mean in the "Quadrex Assessment"?

l (q) Referring to Question N-lOl of the Report, what is Applicant's understanding of the meaning Quadrex applied to the "EBASCO Response" with regard to flow models and acceptance on Waterford (PWR) and St. Lucie (PWR) plants?

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(1) Flow of what is involved?

(2) What was the concern addressed about NRC requiring 0.6 times model flow? .

(3) What is the flow from and to?

(4) Is the NRC requiring a 0.6 times model flow, placing a greater requirement than the Homogeneous Equilibrium Critical Flow Model with a multiplier 1.O?

ANSWER 2(a). HL&P does not have the information requested in this interrogatory.

2(b). As requested by HL&P, Quadrex was expected to examine the current status of the technical work done by each Ebasco discipline and provide an assessment of that status.

2(c). HL&P believes that comparisons with " normal industry practices" made by Quadrex were based on the experience of the individuals conducting the review.

2(d). ISI was included in the Quadrex review of Ebasco. See Question P-111.

2(e). The Quadrex review of Ebasco was performed in order to provide HL&P with an independent assessment of 1

Ebasco's performance as architect / engineer at ACNGS. 1 2(f). No.

2(g). See Question N-112 of the Quadrex Report /Ebasco.

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i 2(h). Yes. Mechanical / Nuclear, Electrical, Instru-mentation and Control, Radwaste, Nu-lear Engi.saering and -;

Applied Physics.

2(1). No.

2(j). HL&P is not aware of any such inquiry.

2(k). HL&P did not writa the Quadrex Report /Ebasco and cannot speak for Quadrex.

2(1). (1)(1) Civil Structural - 56 h'ours '

(1)(2) Mechanical - 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> , t (1)(3) Nuclear - 77 hours8.912037e-4 days <br />0.0214 hours <br />1.273148e-4 weeks <br />2.92985e-5 months <br /> (1)(4) Pipe Support.- 112 hours0.0013 days <br />0.0311 hours <br />1.851852e-4 weeks <br />4.2616e-5 months <br /> 2(m). Applicant objects to this interrogatory on ,

i the ground that the information sougNt 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(n). Same objection as 2(m).

2(o). Same objection as 2(m).

2(p). HL&P believes that the term " appropriate" means that the codes are correct and acceptable and that proper assumptions and input data are'used in analyses.

2(q). Applicant objects to this interrogatory'on the ground that the information sought is not relevan,t to the limited issues in this reopened proceeding as identified

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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. 3

, Did Mr. Sas of EBASCO Services, (Identified as an Expert Witness who will testify) attend any of the formal review meetings in September, 1981 with Quadrex Corp.?

ANSWER

3. No.

INTERROGATORY NO. 4 Why- did Applicant's witnesses Mr. Oprea and Mr.

Goldberg not mention the Quadrex Report on EBASCO in their testimony on TexPIRG Additional Contention 31, Technical Qualifications, in the October 1981 hearings, or at least allude to the Quadrex work if it was in progress?

ANSWER

4. The answer to this interrogatory is set forth 3 in Mr. Goldberg's Supplemental Testimony dated March 26, 1982 at pp. 3-4.

INTERROGATORY NO. 5 Did Mr. Oprea direct that Mr. Goldberg would not mention the Quadrex Report on EBASCO Services in the October hearings on ACNGS on TexPIRG Additional Contention 31?

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5. No.

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l INTERROGATORY NO. 6 Did Mr. Oprea direct that Mr. Goldberg would not mention the Quadrex Report on Brown & Root design work at STNP in the October 1981 hearings on ACNGS on TexPIRG Addi-tional Contention 31?

ANSWER

6. No.

INTERROGATORY NO. 7 Had Quadrex Corp. performed a review of BWR design engineering prior to its report on EBASCO Services at ACNGS?

ANSWER

7. The review of ACNGS was the first comprehensive review of a BWR undertaken by Quadrex.

INTERROGATORY NO. 8 Had Quadrex Corp. performed a review of nuclear power plant design work, at as early a stage as that of ACNGS, at any previous time?

ANSWER

8. Yes.

INTERROGATORY NO. 9 In Section 4.1.2 of the Quadrex Report on STNP (hereinafter: Report) what are the " number of studies mentioned in the first sentence? Who is doing them other than Applicant?

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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 Referring to Sec. 4.1.2 of the Report and specifi-cally on the statement, " Based solely on the current findings of this review, a determination of current adequacy cannot be made.":

(a) Did Quadrex indicate to Applicant the statement meant B&R Civil / Structural Work was technically inade-quate?

(b) If "no", what did the statement mean?

ANSWER lO(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).

lO(b). See response to 10(a).

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l INTERROGATORY NO. 11 Referring to Sec. 4.1.2 of the Report, what generally i

did Quadrex indicate was " evident", as a result in the design process caused by lack of experience and consistency in implementing appropriate Code interpretations and industry practice?

ANSWER

11. Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what information is sought. Moreover, Applicant objects to this interrogatory on the ground that the informa-tion 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. 12 Referring to Question C-1, "Quadrex Assessment" item (e), did Applicant prior to Quadrex have any doubts that the B&R structural (group) checked the reasonableness of that input data or that the group acknowledged its receipt?

(a) If "yes", please give the date of any memo, report, etc. where doubt is shown, identify it, and make it available to this Intervenor.

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(b) Does Applicant believe B&R did check for reasonableness of input data? For what reasons?

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 response to Interrogatory 12.

12(b). Same objection as Interrogatory 12.

INTERROGATORY NO. 13 Referring to Question C-1, "Quadrex Assessment" item (f), was Applicant aware B&R did not require that receipt of the "really important" data transmitted to a discipline be acknowledged back to the originating discipline?

(a) If "yes", please give the date of any memo, report, etc. where this is shown, identify it, and make it available to this Intervenor.

(b) Did Quadrex (perhaps through Reviewer Hossain) explain what "really important" meant? If so, please given the explanation.

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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 objection as Interrogatory 13.

13(b). Same Objection as Interrogatory 13.

INTERROGATORY NO. 14 Referring to Question C-1, "Quadrex Assessment" item (g), it states B&R procedures called for a final design verification at a time when final data became available and probably (emphasis added) when the structures had been erected.

(a) Was Applicant aware of these procedures prior to the Quadrex Report?

(b) If "yes", please give the date of any memo, report, etc. where this awareness is shown, identify l it, and make it available to this Intervenor.

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l (c) Did Applicant attempt to change B&R's procedure?

ANSWER l

14(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to l

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1 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).

14(b). Same objection as Interrogatory 14.

14(c). Same objection as Interrogatory 14.

INTERROGATORY NO. 15 Referring to Question C-4 of the Report, "Quadrex Assessment", what is the secondary shield wall in a PWR?

(a) Is it in containment building?

(b) What is the NRC margin mentioned in this part of C-47 i

l (c) Which factor, 1.2 or 1.4 was, actually employed?

(d) Was this secondary shield wall actually -

constructed in STNP-I, or STNP-II?

ANSWER

15. 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 l Evidence on TexPirg Additional Contention 31).

15(a). Same objection as Interrogatory 15.

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15(b). Same objection as Interrogatory 15.

15(c). Same objection as Interrogatory 15.

15(d). Same objection as Interrogatory 15.

INTERROGATORY NO. 16 Referring to Question H-12 of the Report, has the pressurizer support skirt been constructed?

(a) When constructed was HL&P aware the conse-quences of loss of off-site power were yet to be assessed with regard to pressurizer cooling requirements?

(b) If "yes" to (a) please give the date of any memo, report, etc. which shows this, identify it, and make it available.

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. Moreover,

! 1 Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what information is sought.

16(b). See response to Interrogatory 16(a).

l INTERROGATORY NO. 17 Referring to Question C-4 of the Report, in the "B&R Response" at che *, is Quadrex saying here B&R was designing prematurely such that it had to make changes due to new input information?

(a) Is Applicant aware of any instances where a structure had been constructed, then had to be redesigned because of new environmental loadings?

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 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).

17(a). Same objection as Interrogatory 17.

INTERROGATORY NO 18 Referring to Question H-3 of the Report, was Applicant aware that heat load calculations for the HVAC did not consider off-normal system conditions, prior to Quadrex?

(a) If "yes", give the date of any papers, reports, memos, etc. that reveal this, identify them, and make them available please.

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ANSWER

18. 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).

18(a). See response to Interrogatory 18.

INTERROGATORY NO 19 Referring to Question H-3 of the Report, was Applicant aware no criteria existed at the STNP for the HVAC design of air flows in radioactive areas?

(a) Had Applicant suggested to B&R that they get this?

(b) Referring to (a) above, when was this first suggested, and what is the identity of any memo, letter, etc. doing this?

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).

19(a). Same objection as Interrogatory 19.

19(b). Same objection as Interrogatory 19.

INTERROGATORY NO. 20 Which came first? The release to the NRC of a copy of the Quadrex Report, or the termination of B&R as architect engineer at the STNP site?

ANSWER

20. The answer to this interrogatory is set forth in the answers to interrogatories 6 and 17 to Mr. Doherty's first set of interrogatories re Quadrex.

INTERROGATORY NO. 21 Referring to H-3, did Applicant understand the "Quadrex Assessment" statement: "...(a]n evaluation of the effect of some of these openings being in the expected plant operating open position was not performed", meant that in normal operation some of the openings would be open.

(a) Is it correct to say that B&R had not estab-lished the normal operating air flow conditions at STPN?

(b) If so, please identify and give the date of any memo, report, etc. of Applicant, which shows Appli-cant noticed this prior to Quadrex.

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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 Contention 31).

21(a). Same objection as Interrogatory 21.

21(b). Same objection as Interrogatory 21.

INTERROGATORY NO 22 Referring to H-3, was Applicant aware if B&R had the proper information it needed on NRC rules with regard to hydrogen in the containment building to perform " calculations for hydrogen mixing and the potential for pocket accumulations in the containment after a LOCA"?

(a) Did B&R ever request any such information of Applicant?

(b) Does Applicant know if these calculations are deficient at this time?

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 i 1

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in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).

22(a). Same objection as Interrogatory 22.

22(b). Same objection as Interrogatory 22.

INTERROGATORY NO. 23 Does Applicant believe any heat loads from pipes would be great enough to affect the HVAC design basis?

(Question H-3) If so, give a single example of a normal operating load and an accident condition load, please.

ANSWER

23. 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. 24 Referring to Sec. 4.4.2, was Applicant aware B&R had no procedure for an engineering discipline to be sure its requirements (outputs) were properly used by HVAC, other than "the usual document cycle"?

(a) If "yes" did HL&P think that satisfactory?

(b) If not did Applicant ever try to get B&R to do something to change this?

ANSWER

24. 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).

24(a). See response to Interrogatory 24.

i 24(b). See response to Interrogatory 24.

INTERROGATORY NO 25 Referring to H-5 of the Reoort, "Quadrex Assessment",

when did Applicant first become aware B&R was determining the safety classification of the HVAC systems using their engineering experience, knowledge, ANSI N18.2, and Reg.

Guide 1.26, instead of, " documented requirements of interfacing systems"?

(a) Please give the identify of any letter, memo, etc. that shows Applicant was aware of this, and make it available.

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25. Applicant objects to this interrogatory on i

the ground that the information sought is not relevant to

t 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).

25(a). Same objection as Interrogatory 25.

INTERROGATORY NO. 26 Referring to Question M-3 (B&R).of the Report, had B&R in its pipe rupture studies up to its termination, analyzed whether identified targets of pipe whip or water spray were necessary for safe shutdown for that break?

(a) Had Applicant asked them to do make [ sic]

such an identification in any study?

(b) Please provide the date of any such request, and identify the letter, memo, etc. where the request is made, as well as make it available.

ANSWER

26. Applica.nt oF1ects to this interrogatory on the ground that the informatiot. 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).

26(a). Same objection as Interrogatory 26.

26(b). Same objection as Interrogatory 26.

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INTERROGATORY NO. 27 Referring to Question M-10 (B&R) was Applicant aware the problem of pipe support failures caused by impact from a whipping pipe had not been considered?

(a) Please give the date and identity of any memo, report, etc. which shows applicant was aware of this prior to the "Quadrex Assessment" finding?

ANSWER

27. 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).

27(a). Same objection as Interrogatory 27.

INTERROGATORY NO 28 Referring again to M-10 (B&R), was Applicant aware that a group identified as "B&R Stress" had not prepared a TRD for identifying essential components for consideration in the unrestrained pipe whip analysis?

(a) Please give the date and identity of any memo, report, etc. which shows Applicant aware of this prior to the "Quadrex Assessment" finding?

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ANSWER

28. 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).

28(a). Same objection as Interrogatory 28.

INTERROGATORY NO. 29 Referring to Question M-50, "Quadrex Assessment" item 2, and Sec. 4.5.5.1(a)(1) of the Report, has the finding that, "All active pumps were demonstrated operable by analysis.",

raised concern because the active pumps were not demonstrated operable by testing?

(a) Was Applicant aware of this deficiency prior to Quadrex mentioning it?

(b) If Applicant was, please give the date, identity and make available any memo, report or other paper that shows this awareness.

ANSWER

29. Applicant objects to this interrogatory on the ground that the information sought is not relevant to j the limited issues in this reopened proceeding as identified l

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in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional l Evidence on TexPirg Additional Contention 31).

29(a). Same objection as Interrogatory 29.

29(b). Same objection as Interrogatory 29.

INTERROGATORY NO. 30 Referring to Question M-51 of the Report, when had Applicant first noticed B&R was uncertain as to the definition of passive pumps and valves, versus active pumps and valves?

(a) Give the date, identify and make available any report, memo, etc. showing when Applicant first took notice of this, please.

ANSWER

30. 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).

30(a). Same objection as Interrogatory 30.

INTERROGATORY NO. 31 Referring to Question P-20 of the Report, prior to Quadrex, was Applicant aware B&R had not developed criteria for jet impingement protection on unbroken piping systems?

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(a) Does Applicant agree with Quadrex that this finding could be expected to seriously impact plant licensability?

(b) If Applicant was aware, when did it expect B&R to develop the criteria?

(c) When did Applicant first become aware of this?

(d) Identify and make available any memo, etc.

that shows (c), please.

ANSWER

31. 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).

31(a). Same objection as Interrogatory 31.

31(b). Same objection as Interrogatory 31.

31(c). Same objection as Interrogatory 31.

31(d). Same objection as Interrogatory 31.

INTERROGATORY NO. 32 If the Quadrex Report on B&R had never got out of Applicant's possession, and hence remained secret, does Applicant believe it would have terminated B&R as architect-engineer when it did?

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i ANSWER

32. The reason for the termination of Brown & Root is explained in Mr. Goldberg's Supplemental Testimony dated March 26, 1982 at p. 3.

INTERROGATORY NO. 33 Did Quadrex Corp's representatives indicate to Applicant that current construction work done at the STNP plants suffered from inadequate separation of HVAC? (Referring to Question H-6, Report).

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 When did Applicant first become aware there were no written criteria for physical separation of HVAC components at STNP, to protect against postulated fires and high energy line breaks? (Referring to Question H-6, Report)

(a) Please give the date and identify of any memo, report, etc. that shows this, and make it available.

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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 Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).

34(a). Same objection as Interrogatory 34.

INTERROGATORY NO. 35 Referring to Question H-6 of the Report, who was the contractor for the fire hazards analysis for STNP?

(a) Was Applicant aware there was no control document governing plant design on the topic of fire hazards?

(b) If "yes", please indicate the date, identity, and make available any document, memo, etc. showing this.

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).

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l 35(a). Same objection as Interrogatory 35. I 35(b). Same objection as Interrogatory 35.

INTERROGATORY NO 36 Referring to Question H-23, "Quadrex Assessment",

was Applicant aware that the B&R design used the floor drainage system for leak detection, and would have to meet the requirements of Standard Review Plan 9.3.3 of the NRC?

(a) Did Applicant approve of this detection plan?

(b) If "yes" to (a), when was the approval?

(c) To what grade would the system have to be upv.=ded, if the final design uses floor drainage as the only means for leakage protection?

. 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).

36(a). Same objection as Interrogatory 36.

36(b). Same objection as Interrogatory 36.

36(c). Same objection as Interrogatory 36.

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INTERDOGATORY NO. 37 Referring to Question H-11 of the Report, did Quadrex indicate to Applicant at post-meetings, that any of the differences in " Exhibit-II" of Question H-11, represented a serious difference between the FSAR statement and the Reactor Containment Fan Cooler (RCFC) specifications?

(a) If "yes", which one or ones are significantly different?

ANSWER

37. 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).

37(a). Same objection as Interrogatory 37.

INTERROGATORY NO. 38 Referring to Question H-17 of the Report, was Applicant aware prior to Quadrex there was no criteria for selection of the person to verify the HVAC design?

(a) Did HL&P Q/A take note of the selection of design verifiers by no criteria?

(b) If the answer to (a) is "yes" what did Applicant  !

do?

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(c) Did HL&P Q/A approve the choice of a design verifier outside of HVAC for HVAC design?

ANSWER

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 Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).

38(a). Same objection as Interrogatory 38.

38(b). Same objection as Interrogatory 38.

38(c). Same objection as Interrogatory 38.

Respectfully submitted, OF COUNSEL: O[Copelando '

( J. Uregory BAKER & BOTTS Scott E. Rossell 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 l

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1 STATE OF TEXAS l COUNTY OF HARRIS l BEFORE ME, the undersigned authority, on this day personally appeared C.G. Robertson, Manager - Nuclear Licensing, for Houston Lighting & Power Company, who upon his oath stated that the foregoing answers to "Intervenor Doherty's Seventh Set of Interrogatories 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.

' )

C. G. Rolfertson SUBSCRIBED AND SWORN TO BEFORE ME by the said C.G. Robertson, on this SB day of April,1982.

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'82 APR -9 D0 21 UNITED STATESJOF, AMERICA NUCLEAR REGULATORY; COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of Applicant's Answers and Objections to Doherty Interrogatory Sets Six and Seven in the above-captioned proceeding were served on the following by deposit in the United States mail, prepaid, or by hand-delivery this did" day of April, 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 l 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 I 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 l Washington, D. C. 20555 Washington, D. C. 20555 l I

Susan Plettman Richard Black David Preister Staff Counsel '

Texas Attorney General's Office U.S. Nuclear Regulatory )

P. O. Box 12548, Capitol Station Commission i Austin, Texas 78711 Washington, D. C. 20555 i

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 1000 Austin Street, Suite C P. O. Box 1335 Richmond, Texas 77469 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 *

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t E. Rozzell **

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