ML19347D889
| ML19347D889 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/10/1981 |
| From: | Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | ASSOCIATION OF COMMUNITY ORGANIZATIONS FOR REFORM |
| References | |
| NUDOCS 8104140402 | |
| Download: ML19347D889 (25) | |
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HELATED CORRESPONDENCE April 10, 1981
- e. D UNITED STATES OF AMERICA g 9 NUCLEAR REGULATORY COMMISSION s y DX:XEm3 -;
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD C-f t:SNSC i 2: APR 131961 * ;
In the Matter of ) [ Ctfice of Se !!eetary U/
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L'cekeng '. mi:e buca g
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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 ' ' ' '
COMPANY, _et _al. ) 50-446 N 1 '
(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)
APPLICANTS' THIRD SET OF INTERROGATORIES TO ACORN AND REQUESTS TO PRODUCE Pursuant to 10 C.F.R. $$2.740b and 2.741, Texas Utilities Generating Company, et al. (" Applicants") hereby serve Applicants' Third Set of Interrogatories and Requests to Produce upon Texas Association of Community Organizations for Reform Now (" ACORN"). Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent information known to ACORN, its offi-cers, directors or members as well as any pertinent informa-tion known to its employees, advisors or counsel. Each .
request to produce applies to pertinent documents which are in the possession, custody or control of ACORN, its officers, directors or members as well as its employees, advisors or counsel. In answering each interrogatory and in responding to each request, please recite the interrogatory or request
, preceeding each answer or response. Also, please identify o'h
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the person providing each answer or response. 1/
These interrogatories and requests shall be continuing in nature. Thus, any time ACORN obtains information which renders any previous response incorrect or indicates that a response was incorrect when made, ACORN should supplement
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its previous response to the appropriate interrogatory or request to produce. ACORN should also supplement its responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony. The term " documents" shall include any writings, drawings, graphs, charts, photo-graphs, and other data compilations from which information can be obtained. We request that at a date or dates to be agreed upon, ACORN make available for inspection and copying, all documents subject to the requests set forth below.
APPLICANTS' INTERROGATORIES AND REQUESTS TO PRODUCE
. Contention 15: The CPSES design does not provide -
adequate, reliable instrumentation to monitor variables and systems affecting the integrity of the reactor core, the pressure boundary of the containment after an accident, in violation of General Design Criterion 13 of Appendix A of 10 CFR Part 50.
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-1/ The instant discovery requests directed to ACORN concern i Contentions 15, 17, 18, 19 and 21 for which ACORN is lead party-intervenor. If, however, any other Inter-venor possesses information or documents requested herein which ACORN intends to use in support of its position on these contentions, such information or documents should be provided in response to these interrogatories and requests to produce.
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_3-1-3.2/ What is your basis for Contention 157 Please list all documents not elsewhere identified in your responses to these interrogatories on which you rely with respect to Contention 15.
Please provide copies of all such documents for inspection and copying.
- 2-3. Have you prepared any report, study or analysis with respect to Contention 15? If so, please identify each such repo.rt, study or analysis by subject and author, including the author's professional and educational background. Please provide each such repor~t, study or analysis for inspection and copying.
3-3. Have you caused others to prepare any report, study or analysis with respect to Contention 157
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If so, please identify each such report, study or analysis by subject and author, including the professional and educational background of the author. Please provide for inspection and '
copying each such report, study or analysis on which you intend to rely.
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4-3. Have you had any meetings or contacts with the other intervening parties with respect to
. Contention 157 If so, please specify the purpose of such meetings or contacts and the results of such meetings or contacts.
5-3. What are the dates of the meetings or contacts you have had with persons other than the inter-vening parties with respect to Contention 15?
Please identify the purpose of those meetings or contacts, the other persons involved, and the results of such meetings or contacts.
6-3. Do you plan to participate in the upcoming hearing with respect to Contention 157 If -
so, what will be the extent of your partici-pation?
7-3. Do you plan to file testimony in the upcoming hearing with respect to contention 15? If so, who will be the sponsor (i.e., witness) of that testimony? Please set forth the nature of such testimony and the professional and educational background of the witness. Please provide
- 2/ Applicants have identified these interrogatories as the ,
third set to ACORN by the hyphen 3 following each number.
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copies of that testimony. Also, please identify by title, subject matter and author, and provide for inspection and copying, any documents Which any such testimony will rely upon.
8-3. Do you plan to call any witness in the upcoming hearing with respect to contention 15? If so, please provide a summary of his or her pro-fessional and educational background. Also, set forth any information which has a bearing on his or her qualifications to testify in this proceeding on Contention 15.
9-3. If you plan to call any witness in the upcoming hearing with respect to Contention 15, please ,
specify the nature and scope of that person's testimony. Please provide copies of such testimony. Please state Whether that witness has conducted any research or made any studies on Which the witness intends to rely. Also, identify by title, subject matter, and author, and provide for inspection and copying, any document on which such witness will rely in their testimony with regard to Contention 157 10-3. Have you reviewed the Applicants' Final Safety Analysis Report ("FSAR")? If not, please explain. If so, please answer the following:
- a. Do you object to any of the information, data or analyses contained or referenced therein with respect to the instrumentation to monitor variables and systems affecting the integrity of the reactor core and the pressure boundary of the containment after an accident?
- b. If your answer to a. is in the affirmative, please identify those objections by the -
section of the FSAR to Which you object and the substance of your objection.
- c. If your answer to a. is in the affirmative, please specify in what way the information concerning instrumentation to monitor variables in systems affecting the integrity of the reactor core and the pressure boundary of the containment after an accident do not satisfy the concerns raised in Contention 15.
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- d. What are your bases (legal and/or other) for your responses to a. through c.?
11-3. Describe the specific structures, systems, and components which constitute the "CPSES design" as that term is used in Contention 15. 1 12-3. Describe the characteristics which you contend the instrumentation with Which Contention 15 is concerned must have in order to be considered
" adequate".
13-3. Describe precisely the functional and operational i capabilities which you contend the " instrumentation" with which Contention 15 is concerned must have.
14-3. Describe the characteristics which you contend the instrumentation with which Contention 15 is concerned must have in order to be considered
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" reliable".
15-3. Describe in detail the monitoring which you contend must be provided by the instrumentation with Which Contention 15 is concerned.
16-3. Identify each variable which you contend the instrumentation which is the subject of Contention 15 should be capable of monitoring and the location in the facility at which you contend the variable should be monitored.
17-3. Specify for each of those variables the range of measurement over which the instrumentation 1
should be capable of monitoring. Provide specific answers to this interrogatory, e.g.
temperature range between x degrees and y degrees (identify temperature scale).
I 18-3. Explain what is meant by the term " integrity of the reactor core" as that term is used in Contenti'on 15. -
In what way do you contend each of the variables identified in your response to Interrogatory 16-3 affect the " integrity of the reactor core"?
i 19-3. Identify each and every " system" as that term is used Contention 15 which you contend affects "the integrity of the reactor core."
20-3. Specify the way in which you contend the systems identified in your response to Interrogatory 19-3 will affect "the integrity of the reactor core."
21-3. Explain what is meant by the term " pressure boundary l of the containment" as that term is used in -
l Contention 15.
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- l 22-3. Describe the precise location of the "presssure boundary of the containment".
23-4. In what way do you contend each of the variables identified in your response to Interrogatory 16-3 affect the " pressure boundary of the containment?"
24-3. What are y)ur bases (legal and/or other) for your response to Interrogatories 11-3 through 24-37 25-3. Specify the type of " accident" which you contend the instrumentation which is the subject of Contention 15 is supposed to " monitor".
26-3. Identify the particular characteristics of the
" accident", including the effect of the " accident" on each of the variables identified in your response to Interrogatory 16-3.
27-3. Specify the consequences of the " accident" identified in your response to Interrogatory 25-3.
28-3. Please specify how you contend the Applicants should demonstrate that the " instrumentation" with which Contention 15 is concerned has been provided.
29-3. Identify the actions which you believe Applicants must be able to take following the accident identified in your response to Interrogatory 25-3. Specify which of the instruments which are subject of Contention 15 would assist the Applicants in taking each of those actions.
30-3. For each of the actions identified in your response to Interrogatory 28-3, identify the particular variables you believe the Applicants should be able
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to monitor in order to take each of those actions.
31-3. Identify the NRC licensing requirements which require that the Applicants must provide each of the instruments which are the subject of Contention 15.
32-3. What are your bases (legal and/or other) for your responses to Interrogatories 26-3 through 31-37
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- Contention 17: Neither the Applicants nor the Staff has adequately considered the effects of aging and cumulative radiation on safety-related equipment which must be seismically and environmentally qualified, thus, General Design Criterion 4 has not been satisfied.
33-3.. What is your basis for Contention 17? Please list all documents not elsewhere identified in your responses to these interrogatories on which you rely with respect to Contention 17.
Please provide copies of all such documents for inspection and copying.
34-3. Have you prepared any report, study or analysis with respect to Contention 17? If so, please identify each such report, study or analsysis by subject and author, including the author's professional and educational background. Please provide each such report, study or analysis for inspection and copying.
35-3. Have you caused others to prepare any report, study or analysis with respect to Contention 17?
If so, please identify each such report, study or analysis by subject and author, including the professional and educational background of the author. Please provide for inspection and copying each such report, study or analysis on which you intend to rely.
36-3. Have you had any meetings or contacts with the other intervening parties with respect to Contention 177 If so, please specify the purpose of such meetings or contacts and the results of such meetings or contacts.
37-3. What are the dates of the meetings or contacts you have had with persons other than the inter-vening parties with respect to Contention 177 -
Please identify the purpose of those meetings or contacts, the other persons involved, and the results of such meetings or contacts.
38-3 Do you plan to participate in the upcoming hearing with respect to Contention 17? If so, what will be the extent of your partici-pation?
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-g-39-3. Do you plan to file testimony in the upcoming hearing with respect to Contention 177 If so, who will be the sponsor (i.e., witness) of that testimony? Please set forth the nature of such testimony and the professional and educational background of the witness. Please provide copies of that testimony. Also, please identify by title, subject matter and author, and provide for inspection and copying, any documents which any such testimony will rely upon.
40-3. Do you plan to call any witness in the upcoming hearing with respect to contention 177 If so, please provide a summary of his or her pro-fessional and educational background. Also, set forth any information which has a bearing on his or her qualifications to testify in this proceeding on Contention 17.
41-3. If you plan to call any witness in the upcoming hearing with respect to Contention 17, please specify the nature and scope of that person's testimony. Please provide copies of such testimony. Please state whether that witness has conducted any research or made any studies on which the witness intends to rely. Also, identify by title, subject matter, and author, and provide for inspection and copying, any document on which such witness will rely in their testimony with regard to Contention 17?
42-3. Have you reviewed the Applicants' Final Safety Analysis Report ("FSAR")? If not, please explain.
If so, please answer the following:
- a. Do you object to any of the information, data or analysis contained or referenced therein with respect to consideration of the effects of aging and cumulative radiation on safety- -
related equipment as postulated in Contention 177
- b. If your answer to a. is in the affirmative, please identify those objections by the section of the FSAR to which you object and the substance of your objections.
- c. If your answer to a. is in the affirmative, please explain how the information, data, or analysis contained in the FSAR with respect to the effectu of aging and cumulative radiation on safety-related equipment fails to address the specific concern raised in Contention 17.
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- d. What are your bases (legal and/or other) for l your responses to a. through c.? !
43-3. Please specify each "effect" of aging on safety-related equipment Which you contend in Contention 17 should be " considered."
44-3. Please describe the particular " effects" in terms of the period of time in which you contend those effects would occur on'the safety-related equipment which is the subject of Contention 17.
45-3. Do you contend that the effects identified in your responses to Interrogatories 43-3 and 44-3 are such that the safety-related equipment would not be able to perform safety-related functions?
46-3. Please identify each piece of equipment which is described in Contention 17 as " safety-related equipment which must be seisimically and environ-mentally qualified".
47-3. If your response to Interrogatory 45-3 is in the affirmative, please set forth for each piece of equipment identified in your response to Inter-rogatory 46-3 the specific safety-related function Which you contend that piece of equipment will not be able to perform because of the " effects of aging."
48-3. Please identify each and every "effect" of " cumulative radiation" on safety-related equipment which you contend in Contention 17 should be considered.
49-3. Please describe the particular effects of cumulative radiation which you contend would occur on each piece of equipment which was identified in your response to Interrogatory 46-3.
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50-3. Do you contend that the effects identified in your response to Interrogatory 48-3 are such that the safety-related equipment would be unable to perform its safety-related functions?
51-3. If your response to Interrogatory 50-3 is in the affirmative, please identify the particular safety-related functions which you contend would not be able to be performed by each piece of safety-related equipment identified in your response to Interrogatory 46-3.
52-3 If your responses to Interrogatories 45-3 and 50-3 are in the negative, please explain the purpose of '
Contention 17.
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53-3. What are your bases (legal and/or other) for '
your responses to Interrogatories 43-3 through 52-3?
54-3. What do you mean by the term " seismically and environmentally qualified"?
55-3. What do you contend the Applicants must do to
" adequately consider" the effects of aging and cumulative radiation on the equipment Which is the subject of Contention 17?
56-3. What do you contend the NRC staff must do to " adequately consider" the effects of aging and cumulative radiation on the equipment which is the subject of Contention 177 57-3. What are the specific licensing requirements which you believe require the Applicants and the NRC Staff to consider the effects of aging and cumulative radiation on safety-related equipment in the manner you contend in Contention 17?
58-3. What do you contend the Applicants must do in order to " adequately" demonstrate that they have considered the effects of aging and cumu-lative radiation on safety-related equipment?
59-3. What are your bases (legal and/or other) for your responses to Interrogatories 54-3 through 58-37 60-3. What do you contend the NRC Staff must do to demonstrate that the effects of aging and cumulative radiation on the equipment which is the subject of Contention 17 has been " adequately considered."
61-3. Do you contend that any of the safety-related
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could not be replaced if the effects of aging and cumulative radiation adversely affected the
- ability of the equipment to perform its safety-
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related functions?
62-3. Do you contend that Applicants would be unable to determine that the equipment Which is the subject of Contention 17 had suffered or was suffering from adverse effects of aging and cumulative radiation so that the equipment could be replaced, if necessary?
63-3. Do you contend that any studies must be ,
performed on the safety-related equipment which is - the subject of Contention 17 in order to determine the effects of aging and cumulative radiation ?
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64-3. If your response to Interrogatory 63-3 is in the affirmative please specify the nature and scope of those studies, and the NRC rules and regulations i
which require that the study be performed.
Contention 18: The CPSES design fails to present a means for dealing with pressure transients produced by component failure, personnel error, or spurious valve actuation which exceed the pressure / temperature limits of the reactor vessel.
65-3. What is your basis for Contention 18? Please list all documents not elsewhere identified in your responses to these interrogatories on which you rely with respect to Contention 18.
Please provide copies of all such documents for inspection and copying.
66-3. Have you prepared any report, study or analysis with respect to Contention 187 If so, please identify each such report, study or analysis by subject and author, including the author's professional and educational background. Please provide each such report, study or analysis for inspection and copying.
67-3. Have you caused others to prepare any report, study or analysis with respect to Contention 187 If so, please identify each such report, study or analysis by subject and author, including the professional and educational background of the author. Please provide for inspection and copying each such report, study or analysis on which you intend to rely.
68-3. Have you had any meetings or contacts with the other intervening parties with respect to Contention 18? If so, please specify the -
purpose of such meetings or contacts and the results of such meetings or contacts.
69-3. What are the dates of the meetings or contacts you have had with persons other than the inter-vening parties with respect to Contention 18?
Please identify the purpose of those meetings or contacts, the other persons involved, and the results of such meetings or contacts.
70-3. Do you plan to participate in the upcoming hearing with respect to Contention 18? If so, what will be the extent of your partici-pation? -
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71-3. Do you plan to file testimony in the upcoming hearing with respect to contention 187 If so, who will be the sponsor (i.e., witness) of that testimony? Please set forth the nature of such testimony and the professional and educational background of the witness. Please provide copies of that testimony. Also, please identify by title, subject matter and author, and provide for inspection and copying, any documents which any such testimony will rely upon.
72-3. Do you plan to call any witness in the upcoming .
hearing with respect to Contention 187 If so, please provide a summary of his or her pro-fessional and educational background. Also, set forth any information which has a bearing on his or her qualifications to testify in this proceeding on Contention 18?
73-3. If you plan to call any witness in the upcoming hearing with respect to Contention 18, please specify the nature and scope of that person's testimony. Please provide copies of such testimony. Please state whether that witness has conducted any research or made any studies on which the witness intends to rely. Also, identify by title, subject matter, and author, and provide for inspection and copying, any document on which such witness will rely in their testimony with regard to Contention 18?
74-3. Have you reviewed the Applicants' Final Safety Analysis Report ("FSAR")? If not, please explain.
If so, please answer the following:
- a. Do you object to any of the information, data, or analysis contained or referenced
- therein with respect to pressure transients produced by component failure, personnel error, or spurious valve actuation which -
exceed the pressure / temperature limits of the reactor vessel as postulated in Contention 18?
- b. If your answer to a. is in the affirmative, p'.. ease identify those objections by the section of the FSAR to which you object and the substance of your objections.
- c. If your answer to a. is in the af firmative, please explain how the information, data or analysis contained in the FSAR with respect to pressure transients which are the subject of Contention 18 fails to address the ~
specific concern raised in Contention 18.
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. d. What are your bases (legal and/or other) for your responses to a. through c.?
75-3. Please specify the structures, systems or components Which you contend are included in the "CPSES design" as that term is used in Contention 18.
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76-3. What do you mean by the term " fails to present"?
Please specify exactly what you contend must be presented, by who and in what manner.
77-3. What is the "means for dealing with" pressure -
transients which you contend must be presented?
78-3. Precisely what type of event do you consider to be a " pressure transient"?
. 79-3. Please specify the conditions which you consider to " exceed the pressure / temperature limits of the reactor vessel."
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80-3. With respect to the conditions identified in your response to Interrogatory 79-3, please specify the precise measurements which you 4
contend " exceed the pressure / temperature limits of the reactor vessel."
81-3. Please specify each and every " component failure" which you contend would cause a " pressure transient" as that term is used in Contention 18.
82-3. Please specify the nature of the " component failure" which you contend might occur.
83-3. Please specify the precise cause of such failure for each component which you identified in your response to Interrogatory 81-3.
84-3. With respect to each component failure which you contend _
might occur, please specify the probability of such failure. I
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85-3. Please identify each " personnel error" which you l
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contend would cause a " pressure transient" as that term is used in Contention 18.
86-3. Please identify the " personnel" which you contend would commit such errors.
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. 87-3. Please identify the consequences of each
" personnel error" which you identified in your response to Interrogatory 85-3.
88-3. Please set forth the probability of each " personnel error" which you identified in your response to Interrogatory 85-3.
89-3. Please identify each of the valves which you contend are subject to the " spurious valve actuation" with which Contention 18 is concerned. Specify the location and type of valve involved.
90-3. Describe in detail the mechanism which you contend constitutes " spurious valve accuation" that would cause the pressure transients which you are concerned with in contention 18.
91-3. Please identify the precise consequences of the
" spurious valve accuation" which you contend could occur for each of the valves identified in your response to Interrogatory 89-3.
92-3. What are your bases (legal and/or other) for your responses to Interrogatories 75-3 through 91-37 93-3. Describe in detail the actions which you contend the Applicants must take to demonstrate that the' concerns raised in Contention 18 are adequately dealt with.
94-3. Describe in detail the actions which you contend the NRC Staff must take to demonstrate that the concerns raised in Contention 18 have been adequately dealt with.
95-3. What are your bases (legal and/ ,r other) for your responses to Interrogatories 93-3 and 94-3?
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Contention 19: The CPSES design fails to protect against corrosion within the steam generators which causes cracking of pipes and leakage of radioactive water.
96-3. What is your basis for Contention 19? Please list all documents not elsewhere identified in your responses to these interrogatories on which you rely with respect to Contention 19.
i Please provide copies of all such documents for inspection and copying.
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- 97-3. Have you prepared any report, study or analysis with respect to Contention 19? If s:, please identify each such report, study or analysis by subject and author, including.the author's professional and educational uackground. please provide each such report, study or analysis for inspection and copying.
98-3. Have you caused others to prepare any report, study or analysis with respect to Contention 197 If so, please identify each such report, study or analysis by subject and author, including the professional and educational background of the author. Please provide for inspection and copying each such report, study or analysis on which you intend to rely.
99-3. Have you had any meetings or contacts with the other intervening parties with respect to Contention 197 If so, please specify the purpose of such meetings or contacts and the results of such meetings or contacts.
100-3. What are the dates of the meetings or contacts you have had with persons other than the inter-vening parties with respect to Contention 19?
Please identify the purpose of those meetings or contacts, the other persons involved, and the results of such meetings or contacts.
101-3. Do you plan to participate in r.he upcoming hearing with respect to contention 19? If so, what will be the extent of your partici-pation?
102-3. Do you plan to file testimony in the upcoming hearing with respect to Contention 19? If so, who will be the sponsor (i.e. , witness) of that testimony?- Please set forth the nature of such T testimony and the professional and educational background of the witness. Please provide copies of that testimony. Also, please identify by title, subject matter and author, and provide for inspection and copying, any documents which any such testimony will rely upon.
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103-3. Do you plan to call any witness in the upcoming hearing with respect to Contention 19? If so, please provide a summary of his or her pro-fessional and educational background. Also, set forth any information which has a bearing on his or her qualifications to testify in this proceeding on Contention 19.
104-3. If you plan to call any witness in the upcoming hearing with respect to Contention 19, please '
specify the nature and scope of that person's testimony. Please provide copies of such testimony. Please state whether that witness has conducted any research or made any studies on which the witness intends to rely. Also, identify by title, subject matter, and author, and provide for inspection and copying, any document on which such witness will rely in their testimony with regard to Contention 197 105-3 Have you reviewed the Applicants' Final Safety Analysis Report ("FSAR")? If not, please explain.
If so, please answer the following:
- a. Do you object to any of the information, data, or analysis contained or referenced therein with respect to protecting against corrosion in the steam generators as postulated in Contention 197
- b. If your answer to a. is in the affirmative, please identify those objections by the section of the FSAR to which you object and the substance of your objections.
- c. If your answer to a. is in the affirmative, please explain how the information, data, or analysis contained in the FSAR with respect -
to protecting against corrosion within
- the steam generators fails to address the specific concern raised in Contention 19.
- d. What are the bases (legal and/or other) for your responses to a. through c?
106-3. Please specify the structures, systems or components, which you contend are included in the "CPSES design" as that term is used in Contention 19.
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. 107-3. Please describe precisely the failures in the CPSES design with which you are concerned in Contention 19 regarding protection against corrosion in the steam generators.
108-3. Please specify the manner in which the failures identified in your response to Interrogatory 107-3 relate to each aspect of the "CPSES design" ident-ified in your response to Interrogatory '106-3.
109-3. Please describe the type of measures (e.g. materals, procedures, etc.) which you contend in Contention 19 must be taken in order to protect against corrosion in the steam generators.
110-3. Do you contend that the measures you contend in Contention 19 must be taken must completely prevent corrosion within the steam generators?
111-3. Please specify each of the procedures, designs and/or materials which you contend must be utilized to " protect against corrosion within the steam generators?"
112-3. Please specify the type of " corrosion" which you contend could occur "within the steam generators."
113-3. Do you contend that the procedures , designs and/or materials which you identified in your response to Interrogatory 111-3 would be able to " protect" against the " corrosion" identified in your response to Interrogatory 112-3.
114-3. Please specify precisely the location "within the steam generators" which you contend would be susceptible to the corrosion with which you are concerned in Contention 197 115-3. Please identify t'he type of corrosion as specified .
in your response to Interrogatory 112-3 which you contend would occur at each location in the steam generators which you identified in your response in Interrogatory 114-3.
i 116-3. Over what time period do you contend the corrosion identified in your response to Interrogatory 112-3 would occur at each of the locations identified in your response to Interrogatory 114-37 specify the extent and consequences of the corrosion as
( a function of time at each of those locations.
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117-3. Please describe the "cr acking" with which you are l concerned in Contention 19. Please specify the type l of " cracking" by location, type (e.g. circumferential or longitudinal), etc.
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118-3. Please identify the pipes which you contend would be subject to the cracking identified in your response to Interrogatory 117-3.
119-3. Please describe the mechanism by which you contend the " leakage" which is the subject of Contention 19 would occur.
120-3. Please identify the source of " radioactive water" which you contend would be susceptible to the leak-age described in your response to Interrogatory 119-3.
121-3. What rate of leakage do you contend would occur under the scenario with which you are concerned in Contention 197 122-3. What type and amount of radioactivity do you contend would be present in the " radioactive water" with which you are concerned in Contention 197 123-3. Do you contend that no " leakage of radioactive water" should be permitted under the scenario with which you concerned in Contention 197 124-3. If your response to Interrogatory 123-3 is in the affirmative please specify the bases for your response, including the NRC requirements that provide no leakage should be permitted.
- If your response to Interrogatory 123-3 is in the 1
negative, please specify the rate of leakage which you contend may be permitted.
125-3. Do you contend that routine inspections would be able to detect the corrosion, cracking or leakage which yce are concerned with in Contention 197 126-3. If your response to Interrogatory 125-3 is in the
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affirmative, do you believe'that such inspections -
would identify the corrosion, cracking or leakage in sufficient time to prevent any hazard to the public?
127-3. What do you contend the Applicants must show to demonstrate that the concerns of Contention 19 are adequately dealt with?
128-3. What do you contend the NRC Staff must show to demonstrate that the concerns of Contention 19 are adequately dealt with?
129-3. What are your bases (legal and/or other) for your responses to Interrogatories 106-3 through 128-37
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Contention 21: The CPSES design fails to protect against accidents involving the movement and handling of heavy loads in the vicinity of spent fuel at the facility.
130-3. What is your basis for Contention 217 Please list all documents not elsewhere identified in your responses to these interrogatories on which you rely with respect to Contention 21.
Please provide copies of all such documents ,
for inspection and copying.
131-3. Have you prepared any report, study or analysis with respect to Contention 217 If so, please identify each such report, study or analysis by subject and author, including the author's professional and educational background. Please provide each such report, study or analysis for inspection and copying.
132-3. Have you caused others to prepare any report, study or analysis with respect to Contention 21?
If so, please identify each such report, study or analysis by subject and author, including the professional and educational background of the author. Please provide for inspection and copying each such report, study or analysis on which you intend to rely.
133-3. Have you had any meetings or contacts with the other intervening parties with respect to contention 217 If so, please specify the purpose of such meetings or contacts and the results of such meetings or contacts.
134-3. What are the dates of the meetings or contacts you have had with persons other than the inter-vening parties with respect to Contention 217 -
Please identify the purpose of those meetings or contacts, the other persons involved, and the results of such meetings or contacts.
135-3. Do you plan to participate in the upcoming hearing with respect to Contention 21? If so, what will be the extent of your partici-pation?
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- 136-3. Do you plan to file testimony in the upcoming hearing with respect to Contention 217 If so, who will be the sponsor (i.e., witness) of that testimony? Please set forth the nature of such testimony and the professional and educational background of the witness. Please provide copies of that testimony. Also, please identify by title, subject matter and author, and provide for inspection and copying, any documents which any such testimony will rely upon.
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137-3. Do you plan to call any witness in the upcoming hearing with respect to Contention 217 If so, please provide a summary of his or her pro-fessional and educational background. Also, set forth any information which has a bearing on his or her qualifications to testify in this proceeding on Contention 21.
138-3. If you plan to call any witness in the upcoming hearing with respect to contention 21, please specify the nature and scope of that person's testimony. Please provide copies of such testhmony. Please state whether that witness has conducted any research or made any studies on which the witness intends to rely. Also, identify by title, subject matter, and author, and provide for inspection and copying, any document on which such witness will rely in their testimony with regard to Contention 21?
139-3. Have you reviewed the Applicants Final Safety Analysis Report ("FSAR")? If n please explain.
If so, please answer the follow,ot, ing:
- a. Do you object to any of the information, data or analysis contained or referenced therein with respect to protecting against accidents involving the movement and handling of heavy -
loads in the vicinity of spent fuel at Comanche Peak?
- b. If your answer to a. is in the affirmative, please identify those objectione by the section of the FSAR to which you object and the substance of your objections.
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- c. If your answer to a. is in the affirmative, please explain how the information, data or analyses contained in the FSAR with respect to protecting against accidents involving the movement and handling of heavy loads in the
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vicinity of spent fuel at the facility fail to address the specific concern raised in Contention 21.
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- d. What are the bases (legal and/or other) for your responses to a. through c.?
140-3. Describe the specific structures, systems, and components Which you contend constitute the "CPSES design" as described in Contention 21.
141-3. Specify the specific structures, systems, components or other aspects of the "CPSES design" which you consider " fail to protect" against the accidents of the kind which are the subject of contention 21..
142-3. In what way do those structures, systems, components or other aspects of the "CPSES design" fail to protect against the accidents which are the subject of Contention 21?
143-3. Specify the precise functions which those aspects of the "CPSES design" identified in your response to Interrogatory 141-3 should perform but which you contend they do not perform in order to protect against the accidents which are the subject of Contention 21.
144-3. Please describe the specific accidents which you contend in Contention 21 should be protected against.
For each of those accidents describe the entire accident scenario, including the initiating events, the chain of events and the consequences of each accident.
145-3. What are the probabilities of each of the accidents which you describe in your response to Interrogatory 144-37 146-3. Please identify the specific " heavy loads" which you contend would be involved in the accidents which are the subject of Contention 21.
147-3. Please describe exactly the " movement" of the " heavy ~
loads" identified in your response to Interrogatory 146-3, which " movement" would be involved in the accidents which are the subject of Contention 21.
148-3. Please describe exactly the " handling" of the
" heavy loads" identified in your response to Interrogatory 146-3, which " handling" would be involved in the accidents which are the subject of Contention 21.
149-3. Please specify precisely the location at the Comanche Peak site which you contend constitutes the " vicinity of spent fuel." ,
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- 150-3. Do you contend that the accidents which are the subject of Contention 21 would involve release of radioactivity to the environment.
151-3. If ycur response to Interrogatory 150-3 is in the affirmative, please specify the amount of radio-activity which you contend might be released to the envirr . ment for each of the accidents which 4 you descr2ce in your re'sponses to Interrogatory 144.-3.
152-3. Do you contend that the accidents which are
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the subject of Contention 21 would be caused by a me'chanical malfunction?
! 153-3. If your response to Interrogatory 152-3 is
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in the affirmative, please specify the equipment which you contend would malfunction.
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154-3. Do you contend that the accidents which are
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the subject of Contention 21 would be caused
. by human error?
1 155-3. If your response to Interrogatory 154-3 is in the affirmative, please identify the personnel which you contend could commit the errors which would 4
cause accidents and describe the specific errors which you contend could occur.
156-3. What other types of errors or malfunctions besides mechanical and human, do you contend could cause the accidents which are the subject of Contention 217 157-3. Do you contend that any administrative procedures regarding the movement and handling of heavy 4
loads near spent fuel are inadequate to protect against the accidents which you contend in Contention 21 might occur? -
158-3. If your answer to Interrogatory 157-3 is in the affirmative, please specify the precise inadequacies which you contend exist in administrative controls.
1 159-3. Specify the procedures, measures, equipment or other actions which you contend the Applicants must take to protect against the accidents which
, are dae subject of Contention 21.
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160-3. What do you contend the Applicants must do to demonstrate that they have taken the actions which you have identified in your response '?
Interrogatory 159-3?
161-3. Please identify the specific NRC requirements which you contend require that the Applicants take the actions which you specified in your response to Interrogatory 159-3. -
162-3. What are your bases (legal and/or other) for your responses to Interrogatories 140-3 through 161-37 Respectf lly submitted, I
%O Nicho s 5. Reynolds kd d.h William A. Horin Debevoise & Liberman 1200 Seventeenth Street, N.W.
Washington, D.C. 20036 (202) 857-9817 April 10, 1981 Counsel for Applicants
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of' )
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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, -et al. ) 50-446
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(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' Third Set of Interrogatories to ACORN and Requests to Produce," in the above captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 10 day of April, 1981:
Valentine B. Deale, Esq. Chairman, Atomic Safety and Chai rman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory 1001 Connecticut Avenue, N.W. Commission Washington, D.C. 20036 Washington, D.C. 20555 Dr. Forrest J. Remick, Member Marjorie Ulman Rothschild, Esq.
Atomic Safety and Licensing Office of the Executive Board Legal Director 305 E. Hamilton Avenue U.S. Nuclear Regulatory -
State College, Pennsylvania 16801 Commission Washington, D.C. 20555 Dr. Richard Cole, Member Atomic Safety and Licensing David J. Preister, Esq.
Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Protection Commission Division Washington, D.C. 20555 P.O. Box 12548 l Capitol Station :
Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S . Nuclear Regulatory Mr. Richard L. Fouke Commission CFUR Washington, D.C. 20555 1668B Carter Drive
- Arlington, Texas 76010
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Arch C. McColl, III, Esq. Mr. Geoffrey M. Gay 701 Commerce Street West Texas Legal Services suite 302 100 Main Street (Lawyers Bldg.)
Dallas, Texas 75202 Fort Worth, Texas 76102 Jeffery L. Hart, Esq. Mr. Chase R. Stephens 4021 Prescott Avenue Docketing & Service Br-anch Dallas, Texas 75219 U.S. Nuclear Regulatory Ccmmission Mrs. Juanita Ellis Washington, D.C. 20555 President, CASE 1426 South Polk Street Dallas, Texas 75224 1
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William A. Horin cc: Homer C. Schmidt Spencer C. Relyea, Esq.
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