ML20072L512

Seventh Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20072L512
Person / Time
Site:	South Texas
Issue date:	03/28/1983
From:	Gutterman A JOINT APPLICANTS - SOUTH TEXAS PROJECT, LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Citizens Concerned About Nuclear Power, INC.
References
ISSUANCES-OL, NUDOCS 8303310335
Download: ML20072L512 (8)

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6 ME4TED 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY CO!H4ISSION BEFORE THE ATOMIC StJETY AND LICENSING BOARD A D

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'In the Matter of

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HOUSTON LIGHTING & POWER ) Docket Nos. S Ek4 T-COMPANY, ET A_L. 50 j4 Uk?@ 3 4

(South Texas Project, Units 1 ) ,

and 2) ) 0

%. A Applicants' Seventh Set of Interrogatories and Requests for Production of Documents to CCANP t Pursuant to the Licensing Board's June 24, 1982 Memorandum (Memorializing Certain Rulings Announced During Evidentiary Hearing Sessions of June 15-17, 1982), the Licensing Board's

October 15, 1982 Memorandum and Order (Ruling Upon CCANP's Motion to Adopt Contentions of CEU), and Sections 2.740b and 2.741 of the Nuclear Regulatory Commission's Rules of Practice, l

Applicants propound the following Interrdgatories and Requests for Production of Documents to Citizens Concerned About Nuclear Power, Inc. (hereinafter "CCANP"). Applicants incorporate herein the instructions and definitions set-  ;

forth in their First Set of Interrogatories and Requests for Production of Documents.

Interrogatories and Requests for Production of Documents

1. Section 3.3.1.1 of the STP FSAR states that As required by Reg. Guide 1.70, a design wind velocity based on the fastest mile -

wind speed, 30 ft above ground, 100-year mean recurrence interval has been selected.

The design wind velocity for STP is 125 l mph at 30 ft above ground level. . . .

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Does CCANP contend that for the South Texas Project site the fastest mile wind speed, 30 ft. above ground, 100-year mean recurrence interval is greater than 125 mph? If so, state the bases for such contention with every fact supporting such bases (including a statement of the wind speed CCANP contends to be the fastest mile wind speed, 30 ft. above ground, 100-year mean recurrence interval), identify and produce all studies or other documents upon which CCA' relies, and identify each expert witness that CCANP to testify on its behalf with respect to such content:

2. Section 3.3.2.1 of the STP FSAR states that i

1 Category I structures are designed to with-stand effects of a tornado having the following characteristics . . .

Translational Velocity 70 mph (maxi.7um) 5 mph (minimum)

Tangential Velocity 290 mph Atmospheric Pressure Drop 3 psi Rate of Pressure Drop 2 psi /sec Radius of Maximum Wind 150 ft Speed Does CCANP contend that such statement ~is incomplete or inaccurate? If so, state the bases for such contention with every fact supporting such bases, identify and produce all studies or other documentation upon which CCANP relies, and identify each expert witness that CCANP expects to testify on its behalf with respect to such contention.

• 3. Section 3.3.2.3 of the STP FSAR states that To ensure the ability of Category I struc-tures to. perform despite failure of struc-tures not designed for tornado loads, the following criteria are met:

1. The plant arrangement provides for sufficient separation between Category'I structures and non-Category I structures so that failure of the latter cannot affect the ability of Category I structures to perform their safety functions.

2. Where the above criteria are not met, the affected non-Category I structure has been designed either to withstand tornado loads or not to collapse against Category I structures under tornado loadings."

Does CCANP contend that such statement is incomplete or inaccurate? If so, state the bases for such contention, s

with every fact supporting such bases, identify and produce all studies or other documentation upon which CCANP relies, and identify each expert witness that CCANP expects to testify on its behalf with respect to such contention.

4. Section 3.3.2.3 of the STP FSAR provides thau To ensure the ability of Category I struc-tures to perform despite failure of struc-tures not designed for tornado loads, the following criteria are met . . .

3. The tornado missile parameters considered in the design of Category I structures . . .

encompass the spectrum of miss les which could be generated as a result of failure of structures or equipment not designed to withstand tornado loading.

Does CCANP contend that this statement is incomplete or inaccurate? If so, state the bases for such contention, with every fact support,ing such bases, identify and produce

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all studies or other documentation upon which CCANP relies, and identify each expert witness which CCANP expects to testify on its behalf with respect to such contention.

5. Section 3.5.1.4 of the STP FSAR states that Structures, systems, and components whose failure could prevent safe shutdown of the reactor or result in significant uncontrolled release of radioactivity . . .

are protected from such failure due to design tornado and wind loading missiles by the following methods:

1. Structure or component is designed to withstand tornado loading or tornado missile.

2. Component is housed within a struc-ture which is designed to withstand the tornado loading and tornado missile.

. Does CCANP contend that this statement is incomplete or inaccurate? If so, state the bases for such contention, with every fact supporting such bases, identify and produce all studies or other documentation upon which CCANP relies, and identify each expert witness which CCANP expects to testify on its behalf with respect to such contention.

6. Section 3.5.1.4 of the STP FSAR states that Missiles resulting from hurricane winds could be postulated to be similar to

. the types of missiles generated by tor-nadoes; due to the lower hurricane wind speeds, the effects would be less severe than the effects of tornado-generated missiles, however. Tornado generated l

missiles are used as design basis missiles j for STP. A maximum tornado wind speed of 360 mph . . . is used to calculate the missile velocities. .

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E Does CCANP contend that this statement is incomplete or inaccurate? If so, state the bases for such contention, .~

with every fact supporting such bases, identify and produce.

all studies or other documentation upon which CCANP relies, and identify each expert witness that CCANP expects to testify on its behalf with respect to such contention.

7. In addition to the information provided in response to interrogatories 1-6, supra, are there any other facts or reasons which CCANP contends support its contention that the South Texas Project is not adequately designed to provide reasonable protection to the public health and safety from the direct or indirect effects on safety related structures and equipment of hurricane winds or missiles propelled by hurricane winds (Contention 4)? If so, identify all such facts and reasons, identify and produce all studies or other

! documentation upon which CCANP relies for such facts or

! reasons, and identify each expert witness that CCANP expects to testify on its behalf with respect to such contention.

8. Identify each person CCANP intends to call as an expert witness regarding Contention 4, for whom CCANP has l

not provided an identification and summary of testimony in response to interrogatories 1-7, and state the substance of the testimony of such witness.

9. Identify each person not identified in response to the interrogatories 1-8 whom CCANP intends to call as a .

witness regarding Contention 4 and state the substance of the testimony of such witness. .

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-I 10. For each interrogatory herein, identify each

. person who participated in the preparation of CCANP's response.

Respectfully submitted, AL MK Jack R. Newman 11aurice Axelrad Alvin H. Gutterman Donald J. Silverman 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 Finis E. Cowan Thomas B. Hudson, Jr.

3000 One Shell Plaza Houston, Texas 77002 Dated: March 28, 1983 ATTORNEYS FOR HOUSTON LIGHTING

& POWER COliPANY, Project lianager LOWENSTEIN, NEWMAN, REIS of the South Texas Project acting

& AXELRAD, P.C. herein on behalf of itself and 1025 Connecticut Avenue, the other Applicants, THE CITY OF N.W. SAN ANTONIO, TEXAS, acting by and Washington, D.C. 20036 through the City Public Service Board of the City of San Antonio, BAKER & BOTTS CENTRAL POWER AND LIGHT COIIPANY, 3000 One Shell Plaza and CITY OF AUSTIN, TEXAS Houston, Texas 77002 l

UNITED STATES OF AMERICA 1 HUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

HOUSTON LIGHTING & POWER ) Docket Nos. 50-498 OL' COMPANY, ET AL.

) 50-499 OL (South Texas Project, Units 1 )

and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of Applicants' Seventh Set of Interrogatories and Requests for Production of Documents to CCANP dated March 28, 1983, have been served on the following individuals and entities by deposit in the U.S.

Mail, first class, postage prepaid on this 28th day of March, 1983.

Charles Bechhoefer, Esq. Brian Berwick, Esq.

Chairman, Administrative Judge Assistant Attorney General Atomic Safety and Licensing for the State of Texas Board Panel Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548, Capitol Station Washington, D.C. 20555 Austin, TX 78711 Dr. James C. Lamb, III William S. Jordan, III, Esq.

Administrative Judge Harmon & Weiss 313 Woodhaven Road 1725 I Street, H.W.

Chapel Hill, NC 27514 Washington, D.C. 20006 l

l Ernest E. Hill Kim Eastman, Co-coordinator Administrative Judge Barbara A. Ililler l Lawrence Livermore Laboratory Pat Coy University of California Citizens Concerned About P.O. Box 808, L-46 Nuclear Power Livermore, CA 94550 5106 Casa Oro San Antonio, TX 78233 Mrs. Peggy Buchorn Executive Director Lanny Sinkin

Citizens for Equitable 2207-D Nueces l Utilities, Inc. Austin, TX 78705 l Route 1, Box 1684 i Brazoria, TX 774.22 Robert G. Perlis, Esq. -

r Office of the Executive Legal i Director

! U.S. Nuclear Regulatcry Commission Washington, D.C. 20555 l

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-e 3 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary

-U.S. Nuclear Regulatory Commission Washington, D.C. 20555 4

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