ML19209B864

First Set of Interrogatories & Requests for Production of Documents,Directed to Jf Doherty.Certificate of Svc Encl

ML19209B864
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	08/03/1979
From:	Biddle J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Doherty J DOHERTY, J.F.
References
NUDOCS 7910110067
Download: ML19209B864 (20)

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UNITED STATES OF AMERICA '

NUCLEAR REGULATGRY COMMISSION 's BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 5 5

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

(Allens Creek Nuclear 5 Generating Station, Unit 1) 5 FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM HOUSTON LIGHTING & POWER COMPANY TO JOHN F. DOHERTY Pursuant to Section 2.740b and 2.741 of the Commission's Rules of Practice, Houston Lighting & Power Company (Applicant) propounds the following Interrogatories and Requests for Production of Documents to John F. Doherty (Intervenor) .

I.

Instructions

1. Each interrogatory must be answered separately and fully in writing under oath or affirmation by the person or persons making them within 14 days from the date of service, and each document requested must be produced no later than 30 days after service of these Interrogatories and Requests for Eroduction.

2. As used herein the singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun so used, and vice l'~0 196 O L,1 7910110 g G

versa; in similar fashion, the use of the masculine form of a pronoun shall be considered to also include within its meaning the feminine form of the pronoun so used, and vice versa; and in a similar fashion, the use of tense of any verb shall be considered to also include within its meaning all other tenses of the verb so used.

3. These Interrogatories shall be deemed continuing, so as to require additional an1wers if after answering such Interrogatories Intervenor obtains information upon the basis of which he knows a response was incorrect when made, or he knows that the response though correct when made is no longer true and the circumstances are such that a failure to amend the response is in substance a knowing concealment.

4. In your answer, recea3 each Interrogatory set forth herein and then set forth the answer thereto separately and fully. As to any Interrogatory, section or sub-section of said Interrogatory that you refuse to answer for any reason, separately state the grounds for any such refusal.

Where a complete answer to a particular Interrogatory, section or sub-section of said Interrogatory is not pos-sible, such Interrogatory, section or sub-section of said Interrogatory should be answered to the extent possible and a statement made indicating the reason for the partial answer.

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5. If any response is withheld, in whole or in part, for any reason, including but not limited to any claim of privilege, confidentiality or trade secret, set forth the basis upon which such response is withheld, and include in such explanation a statement of what is being withheld, the whereabouts of all documents referring expressly to whatever response is being withheld, and the identify of all persons who have seen any documents being withheld or have knowledge of the matters being withheld.

II.

Definitions The following definitions and instructions shall apply to these Interrogatories:

1. The words " identify," " identity" or " identification" when used in reference to a natural person means to state his full name and present or last known address, his present or last known position in business affiliation, and each of his positions during the relevant period; when used in reference to a business entity, means to state the name, address and any account or computer number to which such entity is referred to in your records; when used in reference to a document, means to state the type of document (i.e.,

i1 'O 198 letter, memorandum, chart, sound production, report, computer input or output, etc.), the location where it is maintained, all identifying marks and codes, the addressee, the document date, author, and persons to whom copies were sent or persons initiating or reading or approving the document and the name of each of the present custodians of the document. If any such document was, but is no longer in your possession or subject to your control, or in existence, state whethe'; it is (1) missing or lost, (2) has been destroyed, (3) has been transferred, voluntarily or involuntarily, to others, or (4) otherwise disposed of, and in each instance, explain the circumstances surrounding an authorization for disposition thereof and state the date or approximate date thereof.

2. The terms " document" or " documentation" mean and include every writing or record of any type and description .

that is in your possession, control or custody of your attorney's possession, control or custody as of the date of filing your answers to these Interrogatories, including, but not limited to, correspondence, memoranda, stenographic or handwritten notes, drafts, studies, publications, invoices, ledgers, journals, books, records, accounts, pamphlets, voice recordings, reports, surveys, statistical compilations, work papers, data processing cards, computer tapes or print outs, or any other writing or recording of any kind. The 1' 0 199 term " document" also includes every copy of a writing or record where such copy contains any commentary or notation of any kind that does not appear on the original or on any other copy. Without limitation of the term " control," a document is deemed to be within your control if you have ownership, possession, or custody or the document or a copy thereof, or the right to secure the document or copy thereof from any person or public or private entity having physical possession thereof.

3. " Studies" means all analyses of every typ'e, including but not limited to evaluations, reports, research, examinations, abstracts, criticisms, calculations, tabulations, compilations, compendiums, surveys, books, essays, monographs, and all other investigations, published or unpublished.

4. " Relating to" means relating to in any way and includes the documents which are the subject of the request (e.g. " relating to a study" includes the study itself). Re-quests concerning a study or basis should be understood to include all input considered and all possible outcomes with respect to such study or basis. For example, requests for documents relating to engineering studies would include all data compiled but not used and all results considered but rejected.

1' 0 200 II.

A. Doherty Contention 5

1. Produce all documents you rely upon to show that the fuel rods referenced in this contention failed by any means other than by clad perforation.

2. Define the " design safety limit of thermal energy for each fu'le rod" and describe how this value is calculated for ACNGS. Produce all supporting calculations and documents.

3. Describe "a cluster such as that proposed for ACNGS" and explain how this " cluster" arrangement affects "the design safety limit of thermal energy for each fuel rod." Produce all documents supporting your answer.

4. Define " Reactivity Initiated Accident" and identify each such accident which has the potential of exceeding the

" design safety limit of thermal energy for each fuel rod."

Produce all supporting calculations and documents.

5. What length of time will a fuel rod in the ACNGS typically be irradiated? Identify the source of your answer.

6. Produce all documents you rely upon to show that the censequences listed in subcontentions 3.a. thru 3.d.

will necessarily follow a " cladding rupture" of the variety described in this contention.

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7. What causes pressure pulses when fuel is "in contact with the water after it escapes from the fuel rod"? What is the peak pressure experienced during these pulses? Provide the calculation showing this peak pressure pulse and all supporting documents.

8. What quantity or percentage of the fuel will escape "into the coolant from the rods due to the pressure of gases escaping through the rupture"? Identify the source of your answer and provide all supporting calculations and documents.

9. What are the " disturbances due to the power excursion (RIA) itself"? Explain the phenomena generating " disturbances",

including a description of the initiating events and probable consequences. Identify the source of your answer and provide all supporting documents.

10. Define " excess fissioning" and explain how rod misalignment causes " excess fissioning." What is the magnitude of the " excess fissioning"? Identify the source of your answer and provide all supporting calculations and documents.

11. Define " excess reactivity" and explain how " excess fissioning" causes " excess reactivity." What is the magnitude of the " excess reactivity". Identify the source of your answer and provide all supporting calculations and documents.

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12. How much fuel will accumulate in the " interstices between the control rods and the reactor bottom"? Identify the source of your answer and provide all supporting calculations and documents.

13. Define " compact [ ness]" in rods and " power core density" and explain how these parameters affect. the design safety limit of the fuel rods for ACNGS. Produce all supporting calculations and documents relating to your answer.

14. How should the "various parameters in the reactivity control system be altered" to account for a lowered " design safety limit of the fuel rods"? Produce all supporting calculations and documents relating to your answer.

~

15. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(e) Identify and produce all documents prepared by, for, or under the supervision of each such expert witness, or reviewed or relied upon in formulating the expert's 11 0 ^03 opinions and conclusions, including work papers, preliminary outlines and memoranda, and communications between such experts and Intervenor.

B. Doherty Centention 5

1. Produce all documents you rely upon to show that the Hydraulic Control Units (HCUs) or the Traversing'Incore Probes (TIPS) can be damaged by suppression pool uplift.

2. What is the magnitude of the loadings on the HCUs or TIPS as a result of the worst case suppression pool uplift? What damage will result if the HCUs or TIPS are subjected to this loading? Provide all supporting calculations and documents relating to your answer.

3. State every reason, with every fact supporting triauc 7easons, why the Mark-III containment system can not be licensed until full scale tests on suppression pool uplift loadings are performed. Produce all supporting calculations and documents relating to your answer.

4. What consequences will occur if the TIPS system is damaged by any means? Produce all documents supporting your answer.

5. List all accidents that can result in suppression pool uplift before a SCRAM occurs. Describe the intiating events and the subsequent events creating a suppression pool uplift for these accidents and explain the reasons why a 11~0 204

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SCRAM would not be initiated before the suppression pool uplift occurs. Provide all supporting calculations and documents relating to your answer.

6. What consequences will occur if the HDUs are damged by any means after a SCRAM? Produce all documents supporting your answer.

7. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness. -

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expcrt's testimony.

(e) Identify and produce all documents prep'ared by, for, or under the supervision of each such expert witness, or reviewed or relied upon in formulating the expert's opinions and conclusions, including work papers, preliminary outlines and memoranda, and communications between such experts and Intervenor.

C. Doherty Contention 6

1. State every reason, with every fact supporting these reasons, why the r.ecirculation pump case thickness, 11'O 205 pipe supports and restraints will be ineffective in preventing impeller missiles. Produce all supporting calculations and documents relating to ycur answer.

2. Identify the equipment and/or strucutres which will be disabled or damaged by recirculation pumps impeller missiles and the maximum damage that can occur including the worst case consequences. State every reason, with every fact supporting these reasons, why this maximum damage and worst case consequences can be expected. Produce all supporting calculations and documents relating to your answer.'

3. Define "an adequate bases...to assure that [ impeller missile prevention] measures will be effective." Identify each criteria to be used in assaying the effectiveness of such prevention measures and the ultimate, comprehensive standard for measuring acceptability of design for such prevention measures.

4. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provida a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

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(e) Identify and produce all documents prepared by, for, or under the supervision of each such expert witness, or reviewed or relied upon in formulating the expert's opinions and conclusions, including work papers, preliminary outlines and memoranda, and communications between such experts and Intervenor.

D. Doherty Contention 7

1. What is the maximum reactivity increase that can be caused by " Low Pressure Coolant Injection (LPCI) core spray water"? Provide the calculation showing this value and produce all supporting documents.

2. What is the maximum core temperature which can result from LPCI " core spray"? Provide the calculation showing this value and produce all supporting documents.

3. Define " fuel melt" and identify the threshold fuel temperature for initiating this phenomena. Provide the calculation showing this threshold value or identify the source of your answer and produce all supporting documents.

4. State every reason, with every fact. supporting these reasons, why the ACNGS core will reach criticality after SCRAM due to cold water addition from the LPCI system.

5. What temperature water will cause post-SRAM criti-cality? Provide the calculation showing this value and produce all supporting documents. (

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6. Define " Reactivity Insertion Accident." List every such accient and every event which would have to occur to cause m .h such an accident.

7. Define " Transient Without Scram." List every such transient and every event which would have to occur to cause such a transient.

8. List all events which would have to occur to cause an LPCI " core spray" reactivity insertion during each " Reactivity Insertion Accident" listed in 6 above. Produce all supporting documents. '

9. List all events which would have to occur to cause an LPCI " core spray" reactivity insertion during each " Transient Without Scram" listed in 7 above. Produce all supporting documents.

10. List all events which would have to occur to prevent a SCRAM at the inception or during the accidents listed in 8 above or at the inception or during a LOCA.

Produce all supporting documents.

11. Stato every reason, with every fact supporting these rc:sonF, why LPCI " core spray" inserts more reactivity than inadvertent ECCS operation. Provide the calculation chowing the magnitude of LPCI reactivity insertion over the amount inserted due to inadvertent ECCS operation and produce all supporting documents. '

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12. What is the magnitude of the " increased possibility ...

of full melt and formation of a critical mass"? Provide the calculation showing the probability and produce all supporting documents.

13. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony .

(e) Identify and produce all documents prepared by, for, or under the supervision of each such expert witness, or reviewed or relied upon in formulating the expert's opinions and conclusions, including work papers, preliminary outlines and memoranda, and communications between such experts and Intervenor.

E. Doherty Contention 8.

1. The Board's Order dated April 11, 1979, consoli-dated TexPirg and Intervenor with regard to this contention.

Who is the designated single representative-spokesman with regard to this contention?

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2. Describe in detail the automatic redundant scram system that should be incorporated into the ACNGS design to adequately protect against ATWS. Produce all documents relating to the description of the proposed system.

3. State every reason, with every fact supporting these reasons, why the system described in 2 above is superior to the design alternatives 2, 3, and 4 described in NUREG-0460, volume 3. Produce all supporting documents relating to your answer.

4. Explain the basis for the statement that' Applicant has only a manually operated SCRAM system as its redundant system. In so doing, specify the exact changes that need to be made in the Applicant's SCRAM system in order to provide a sufficiently redundant SCRAM system.

5. Produce the "[n]ew information [which] shows that 20 transients per annum are typical for new reactors with about 6 transients per annum typical after several years."

6. (a) Identify each expert witness you intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

11'O 210 (d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(e) Identify and produce all documents prepared by, for, or under the supervision of each such expert witness, or reviewed or relied upon in formulating the expert's opinions and conclusions, including work papers, preliminary outlines and memoranda, and communications between such experts and Intervenor.

F. Doherty Contention 9

1. List every " dynamic and static load which may plausibly occur in the lifetime of the atomic plant."

Produce the documents supporting your answer.

2. List the magnitude of each load identified in 1.

above. Provide the calculation showing these values and produce all supporting documents.

3. List every failure mode the containment is subject to under the loads identified in Fl. above. Identify each failure made with the load or combination of loads listed in Fl. above which cause such failure. Produce all supporting documents.

4. State every reason, with every fact supporting those reasons, why " adequate experimental data for determining design criteria for buckling of steel containments does not 1'~0 211 exist." Produce all supporting documents relating to your answer.

5. Identify and produce the " consultant's report" discussed in this contention.

6. Produce all other documents you rely upon to support the conclusions attributed to the " consultant's report" and numbered (1) through (4) in this contention.

7. Define each of the following items, identify the source (s) of your definition and explain how each item will affect " buckling of steel containments":

(a) imperfections (b) assymetric loading (c) load interaction (d) dynamic and nonlinear effects

8. Identify each item of design that demonstrates a similarity between the containment structure of Three Mile Island, Unit 2 (TMI-2) and the containment design for ACNGS.

9. Identify each fact or occurrence that demonstrates a similarity between the "large dynamic loads" applied to the TMI-2 containment and any dynamic loads that can be anticipated for the ACNGS containment. In so doing, identify every event which must occur at ACNGS to create a dynamic loading similar to the loads allegedly experienced at TMI-2.

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10. (a) Identify each expert witness you. intend to call in this proceeding to testify concerning this contention.

(b) State the qualifications and credentials of each such expert witness.

(c) Provide a summary of the testimony which each such witness is expected to offer.

(d) State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(e) Identify and produce all documents prepared by, for, or under the supervision of each such expert witness, or reviewed or relied upon in formulating the expert's opinions and conclusions, including work papers, preliminary outlines and memoranda, and communications between such experts and Intervenor.

Resfectfully submitted, OF COUNSEL:

O h J. Gregory Copeland h

f' C. Thomas Biddle, Jr.

BAKER & BOTT Charles G. Thrash, Jr.

3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W. 1025 Connecticut Ave., N.W.

Washington, D.C. 20036 W:shington, D.C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY TB:2:F

]1 ~0 213 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING E';ARD In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that capies of the foregoing First Set of Interrogatories and Requests for Production of Documents From Houston Lighting & Power Company to John F. Doherty in the above captioned proceeding were served on the following by deposit in the United Stdtes mail, postage prepaid, or by hand delivery this $L4J) day of b d , 1979. N Q

Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq.

Atomic. Safety and Licensing Assistant Attorney General Board Panel -

for the State of Texas U.S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D. C. 20555 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Ho%. Charles J. Dusek Watkinsville, Georgia 30677 %ayor, City of Wallis P. O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 Atomic Safety and Licensing Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission County Judge, Austin County Washington, D. C. 20555 P. O. Box 99 Bellville, Texas 77418 Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of the Appeal Board Commission U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 R. Gordon Gooch, Esq. Atomic Safety and Licensing Baker & Botts Board Panel 1701 Pennsylvania Avenue, N. W. U.S. Nuclear Regulatory Washington, D. C. 20006 Commission Washington, D. C. 20555 1O 214

Steve Schinki, Esq.

Staff Counsel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 John F. Doherty 4438 1/2 Leeland Houston, Texas 77023 Madeline Bass Framson 4822 Waynesboro Drive Houston, Texas 77035 Robert S. Framson 4822 Waynesboro Drive Houston, Texas 77035

• Carro Hinderstein -

8739 Link Terrace Ecuston, Texas 77025 .

D. Marrack 420 Mulberry Lane Bellaire, Texas 77401 Brenda McCorkle 6140 Darnell Houston, Texas 77074 F. H. Potthoff, III 1814 Pine Village ,

Houston, Texas 77080 Wayne E. Rentfro P. O. Box 1335 Rosenberg, Texas 77471 James M. Scott, Jr.

8302 Albacore Houston, Texas 77074 C . Amu %dL V C. Thomas Biddle, Jr.

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