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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20155F7031988-06-10010 June 1988 Applicant Supplemental Responses to Case Discovery Requests.* Suppls Responses to Interrogatories 31 & 32 & Interrogatory 32 .W/Certificate of Svc. Related Correspondence ML20155F6751988-06-0808 June 1988 Applicant Supplementation to Answers to Case 850827 Interrogatories to Applicant (850827).* No Further Documents Will Be Provided in Response to Interrogatories H-3 & H-6. Certificate of Svc Encl.Related Correspondence ML20148D4911988-03-22022 March 1988 Applicant Supplementation to Answers to Case Interrogatories to Applicant (870825).* Certificate of Svc Encl.Related Correspondence ML20148D0571988-01-22022 January 1988 Applicant Supplementation to Answers to Case Interrogatories to Applicants (850827).* W/Certificate of Svc.Related Correspondence ML20236X2161987-12-0404 December 1987 Permittees Supplemental Response to Meddie Gregory Interrogatories & Request for Documents (Set 5).* Response to 870409 Interrogatories Re Seismic Design of Control Room Ceiling.Certificate of Svc Encl.Related Correspondence ML20236X3191987-12-0404 December 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant 850827.* Related Correspondence.Certificate of Svc Encl ML20236X3301987-12-0404 December 1987 Supplemental Response to Intervenors Document Production Request Dtd 870619.* Related Correspondence.Certificate of Svc Encl ML20235W1931987-10-0707 October 1987 Supplemental Response to Intervenors Document Production Requests.* Applicants Will Make Listed Matls Available to Intervenors Representatives for Exam & Copying in Dallas,Tx Ofcs.W/Certificate of Svc.Related Correspondence ML20235F2521987-09-22022 September 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant (850827).* Updated Organization Charts Available for Review.Resumes Will Be Obtained Upon Request. W/Certificate of Svc.Related Correspondence ML20237L7181987-08-19019 August 1987 Supplemental Responses to Case Interrogatories Re Mac Rept & Issues Raised by Mac Rept ML20238A7531987-08-14014 August 1987 Responses to Consolidated Intervenors (870619) Interrogatories & Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20237K1941987-08-10010 August 1987 Further Answers to Comanche Peak Review Team Interrogatories (Set 12) Re Reinsp Program for Random Errors.* Related Correspondence ML20236E8041987-07-22022 July 1987 Applicants Supplementation to Answers to Case Interrogatories to Applicants (850827).* Certificate of Svc Encl.Related Correspondence ML20235G5011987-07-0606 July 1987 Case Supplementary Response to Applicants Interrogatories to Consolidated Intervenors (Set 1987-1) & Motion for Protective Order.* Certificate of Svc & Three Oversize Newspaper Articles Encl ML20215J8801987-06-19019 June 1987 Consolidated Intervnors Interrogatories & Reguest for Production of Documents to Applicant Texas Utilities Electric Co (870619).* Related Correspondence ML20215J7741987-06-19019 June 1987 Applicants Interrogatories to Intervenor (Set No. 1987-9).* Certificate of Svc Encl.Related Correspondence ML20215K2951987-06-15015 June 1987 M Gregory Response to Applicants Interrogatories to Consolidated Intervenors (Set 1987-1) & Motion for Protective Order.* Certificate of Svc Encl ML20214W5711987-06-0808 June 1987 Applicant Supplemental Responses to Case 860630 Interrogatories & Request for Documents.* Info Requested from Stone & Webster Submitted as Interrogatory 32.W/ Certificate of Svc.Related Correspondence ML20214W5601987-06-0606 June 1987 Case Response to Applicant Interrogatories to Consolidated Intervenors (Set 1987-1).* Case Would Object to & Moves for Protective Order Against Having to Go Into More Extensive Detail Pending Completion of Discovery ML20214P0861987-05-28028 May 1987 Further Answers to Interrogatories (Comanche Peak Response Team Sets 1-7).* Applicant Suppls Responses to Certain Interrogatories Propounded by Case,Per Board Orders Rendered on 861215.W/Certificate of Svc.Related Correspondence ML20214N1021987-05-21021 May 1987 Applicants Supplementation to Answers to Case Interrogatories to Applicants (850827).* Related Correspondence ML20206M4411987-04-15015 April 1987 Permittees Final Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20206H0201987-04-13013 April 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Responds to Interrogatories Re Housekeeping & Sys Cleanliness. Certificate of Svc Encl.Related Correspondence ML20206H0941987-04-13013 April 1987 Permittees Further Responses to Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20206H0031987-04-13013 April 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20205M2781987-03-30030 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Cables Must Be Separated from Conduits Inside Panels by Min Distance of 6 Inches.W/Certificate of Svc.Related Correspondence ML20205L8151987-03-30030 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20205L8281987-03-28028 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-4) & Motion for Protective Order.* Applicant Discovery Conflicts W/Board Assurance That Case Will Have Sufficient Time to Analyze Data.W/Certificate of Svc ML20205R5201987-03-27027 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20204B7441987-03-20020 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-6) & Motion for Protective Order.* Identification of Experts Not Discoverable Due to Irrelevancy of Opinions Based on Work in Progress.Certificate of Svc Encl ML20205M1831987-03-20020 March 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant (850827).* Updated Charts Available for Review. Resumes Obtained & Will Be Provided If Specifically Requested.W/Certificate of Svc.Related Correspondence ML20204B7211987-03-20020 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-5) & Motion for Protective Order.* Applicant Requests Premature & Unanswerable by Case Until Comanche Peak Response Team Discovery Complete.W/Certificate of Svc ML20204B6651987-03-18018 March 1987 Applicant Interrogatories to Consolidated Intervenors (Set 1987 -1).* All Instances of Alleged Applicant Intentional Conduct to Delay Const of Unit 1 Requested.Certificate of Svc Encl.Related Correspondence ML20212N5981987-03-0505 March 1987 Applicants Interrogatories to Intervenor (Set Number 1987-8).* Interrogatories Concern Application for Ol. Certificate of Svc Encl.Related Correspondence ML20212D0511987-02-26026 February 1987 Applicant Interrogatories to Intervenor (Set 1987-6).* Set of Interrogatories Re Identifying Experts Consulted W/Or Retained by Intervenor W/Respect to Problems in Facility. Related Correspondence.Certificate of Svc Encl ML20212C8581987-02-26026 February 1987 Applicants Interrogatories to Intervenor (Set No 1987-7).* Info Re Walsh/Doyle Issues &/Or Allegations Requested. W/Certificate of Svc.Related Correspondence ML20212D1381987-02-24024 February 1987 Applicants Interrogatories to Intervenor (Set No. 1987-5).* Interrogatories Re Application for Ol.Certificate of Svc Encl.Related Correspondence ML20211F5681987-02-18018 February 1987 Applicants Interrogatories to Intervenor (Set No 1987-4).* Certificate of Svc Encl.Related Correspondence ML20211C9641987-02-13013 February 1987 Permittees Supplemental Response (Motion for Protective Order) to Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Related Correspondence ML20211D0011987-02-10010 February 1987 Permittees Supplemental Responses to M Gregory Interrogatories (Set 5).* Suppls Responses to M Gregory Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20210E4481987-02-0303 February 1987 Permittees Initial Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Related Correspondence ML20209B0791987-01-29029 January 1987 Applicant Interrogatories to Intervenor (Set 1987-3).* W/Certificate of Svc.Related Correspondence ML20209B0321987-01-29029 January 1987 Applicant Interrogatories to Case (Set 1987-1).* Related Correspondence ML20209B0581987-01-29029 January 1987 Applicant Interrogatories to Case (Set 1987-1).* Related Correspondence ML20212R6211987-01-27027 January 1987 Supplemental Staff Answers to Case Interrogatories.* Suppls 861205 Answers to Case 860922 Discovery Request & Interrogatories 2,4 & 8.Affidavit & Certificate of Svc Encl. Related Correspondence ML20212K6991987-01-21021 January 1987 Applicants Supplementation to Answer to Case Interrogatories to Applicants (850827).* Certificate of Svc Encl.Related Correspondence ML20207Q2721987-01-16016 January 1987 M Gregory Request for Production of Documents (Set 6).* Certificate of Svc Encl.Related Correspondence ML20212E7501986-12-30030 December 1986 Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20211M8661986-12-0808 December 1986 Response to Case 860918 Eleventh Set of Interrogatories Re Adequacy of Design Aspects of Comanche Peak Response Team Program Plan.Applicant Moves for Protective Order.W/ Certificate of Svc.Related Correspondence ML20211M8901986-12-0808 December 1986 Answers to Case 860918 Tenth Set of Interrogatories Re Adequacy of Design Aspects of Comanche Peak Response Team Program Plan.Applicant Moves for Protective Order.W/ Certificate of Svc.Related Correspondence 1988-06-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
[Table view] |
Text
f s-f _
~'N y May 8,1981
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g o)
/
In the Matter of i j 'h Cocg
= l - -- , U '-
TEXAS UTILITIES GENERATING i Docket Nos. 50-445 t :44'/ J y%
gI > -11 COMPANY, et al~~ i 50-446 3 C' i \ ,h %etty y' (Comanche Peak Steam Electric i (Application for ' *1, ofge$eh)dgWee Ecc c
Station, Units 1 and 2) ! Operating license) .p w
CFUR'S SUPPLEMENT TO ANSWERS TO APPLICANTS' FIRJT SET OF INTERROGATORIES TO CFUR AND REQUESTS TO PRODUCE COMES NOW CFUR, one of the Intervenors in this proceeding and files this Supplement to Answers to Applicants' First Set of Interrogatories to CFUR and Requests to Produce.
To a large extent, complete answers to many of Applicants' Interrogatories are dependent on CFUR receiving proper discovery from the Appliccnts. Since CFUR has not been aole to propound all necessary discovery to the Applicants and since the Applicants have been largely evasive in the discovery completed, CFUR reserves the right to further supplement its answers as may be required by subsecuent developments.
SUPPLEMENTARY ANSWERS Interrogatory 1.
The Applicants have chosen to include in the application for an operating license a number of computer codes to justify, in part, the requirements of 10 CFR 150.5~(a). The basis for the codes are most probably stated in a number cf reports referenced in the FSAR. The Staff has ostensibly looked at a number of the codes 0%
(with associated reports) and evidently put their stamp of approval on these. $
0I 81oy ou ogy G
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. _ _ __ :==W* 'GT _
However, a number of the codes (with associated reports) are evidently new and have not been blessed with NRC Staff approval.
In order to verify a mathematical representation of the real world, it is necessary to establish the accuracy of the predictions of the math model as measured from some recognized standard. The most recognized standard is the results of a controlled experiment. The large break series of experiments conducted at the LOFT facility repres,ent one source of experimental data. The small break series conducted at the same site represent a second set of experimental data.
CFUR submits that these results should represent, at least in part, the recognized standard referred to above. Yet, CFUR has seen no reference to any such standard as of yet.
Instances of goofs in the use of computer codes have been experienced - e.g.
Surry-2. A large number of codes have not yet been reviewed by the Staff. A review for app!!cability is clearly inadequate to make the findings required in 10 CFR !50.57(a). Thirty-three codes have been listed as being in this status. Some codes have possibily since been reviewed, but certainly not all.
See Supplement to Petition For Leave To Intervene By Citizens For Tair '
'~
- Utility Regulation (CFUR), May 7, 1979 (Contention 2-A); Report of CFUR's Position On Each Contention: April 10, 1980 (CFUR 2-A); and Transcript of Prehearing Conference April 30,1980 (CFUR 2-A).
CFUR reserves the right to modify this explanation of Contention 2 after the scope is further defined by the discovery process. See Pennsylvania Power & Light Comoany and Allegheny Electric Coooerative. Inc. (Suscuehanna Steam Electric Station. Units 1 and 2), (ALAB - 613, NRC (September 23. 1980), slip op.
at 30.
-2 I
l i
- 12. Section 1.6.of the CPSES/FSAR; Amendment 7.
- 15. Inadequate discovery at this time.
- 17. Section 1.6 of the CPSES/FSAR, Amendment 7.
- 20. . Inadequate discovery at this time.
- 23. Inadequate discovery at this time.
- 24. Demonstrate absolute accuracy of the prediction of the computer codes. Prove that the physical realm,of operation is replicable and predictable in accordance with what is stated in the report and/or computer code.
- 25. See response to Interrogatory 24 (as supplemented).
- 26. .In order to verify a mathematical representation of the real world, it is necessary to establish the accuracy of the predictions of the math model as -
measured from some recognized standard. The most recognized standard is the results of a controlled experiment. Both large and small break experiments have been conducted at the LOFT facility. CFUR contends that the results of these experiments should represent, in part, the recognized standard referred to above.
~
See answer: to Interrogatory 1; IEEE Std. 100-1977 and IEEE Std. 268-T979;-
i 10 CFR iS0.34(b).
- 27. Provide suitable verification to Staff with proof.
- 28. Check to insure that the absolute accuracy of the predictions of the computer codes are as claimed by Applicants. This would often entail independent verification.
. 2 9. The only way for the reports and codes to be used in the regulatory process is for the Applicants to prove suitable verification and the NRC Staff to evaluate the proof and independently verify the results.
i l
i
- 30. See responses to 24 and 27 (as supplemented). ,
- 31. See responses to 25 and 28 (as supplemented).
- 32. See' responses to 26 and 29 (as supplemented).
- 33. The' term '" conclusions" refers to final decisions,- reasoned deductions or reasoned inferences both prospective and retrospective in nature.
Taken in _ context with the statement "thus conclusions based upon these computer codes are invalid," the term " conclusions" refers in particular to prospective reasoned deductions er inferences reached from use of the computer codes which would lead to erecneous final decisions.
The et.aclusions CFUR is most concerned with are those to be made by the Hearings Examiner in regard to-compliance with 10 CFR {50.57(a).
However, CFUR does not acknowledge the . validity of any conclusion, retrospective or prospective, based on computer codes -incorporating reports not suitably verified and formally accepted - whether they are or have been mcdc by 'he Applicent::, St:ff or anycnc cIsc.
- 34. See response to interrogatory 33 (as supplemented).
^
r5. The conly way conclusions can be valid is if the premises upon which the conclusions are based are proper and verifiable.
i ; 3 9.' Inadequate discovery at this time.
40c. See . response to Interrogatories 12 and 17.
- 46. - CFUR has had inadequate discovery to determine the Applicants' intended meaning of " review" in Interrogatory 43 and is therefore unable to answer that
' Interrogatory and Interrogatory 46, which is conditioned or. Interrogatory 43, at this time.
E -
h_.__~ -
_ 2 l49. Since CFUR'does not know Applicants' purpose as referenced in Interrogatories 47 and 48, CFUR has insufficient knowledge. to answer Interrogatory 49 which is conditioned on Interrogatories 47 and 48.
52.. . Inadequate discovery at this time. -
t
- 54. See response to Interrogatory 52 (as supplemented). .
- 56. See response to Interrogatory 52 (as supplemented).
' 61. Unknown at' this time.
i62. ' Inadequate' discovery at . this time.
~ 6 3. Is the absence of clarification by the Applicants, CFUR construes "NRC
-requirements" in the context of this Interrogatory to.mean Code vf Federal
~
Regulations. 10 -CFR {50.34;-10 CFR'i50.57 and 10 CFR. !50, Appendix A.
While there are prot, ably other sections which Applicants have not satisfied in this context, CFUR is not aware of them atithis time.
- Interrogatorv 93.
Based en the current s ctus . Of di cevery, CFUR providas the follo,cing f
" specification or retinement of the broadly identified issues" cf Contention 7:
Foreign materiat (including loose rock) thrown into the excavation prior to the
- i. .
! pouring of concrete has jeopardized- the ability of CPSES to withstand seismic
- distrubances as described elsewhere in the FSAR because air pockets may exist due
, to the presence of such . foreign material.
~
CFUR reserves the right to modify this explanation of Contention 7 after the scope is further defined by the discovery process. See Pennsylvania Power 'z Light
-Company and Allegheny Electric Cooperative, Inc. (Suscuehanna Steam Electric Station. Units 'I and 2), ALAB-613, NRC (September 23, 1980), slip op.
at 30.
r 6
5-
'n-l?ll2 ' -
g' i
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- 98. Members of CFUR and its attorneys have conducted meetings with respect to Contention 7. The purposes and the results of those meetings were to formulate the issues to be encoumpassed by that Contention; prepare discovery on that Contention, and 'to discuss the ramifications of any facts disclosed.
These meetings have taken place over a period of time beginning shortly before Contention 7 was submitted by CFUR. There are no records of those meetings to pinpoint the dates. Other than CFUR members, its attorneys, and other parties and their attorneys, the only persons present during such meetings were
' George. Clancy and C. A. Thetford.
104. Applicants must determine the amount 'and location of loose rock and other material incorporated into the foundation of CPSES, determine the location and size of any air pockets formed, determine how the above have altered the physical properties of 'the CPSES structure, modify and' verify all applicable computer codes to acce * ' the structural changes in the CPSES structures, and cor. duct further 3... ..ic analysis.
105. See response to Interrogatory 116 (as supolemented).
10S; Inadequate discovery at this - time and inadequate time to perform other necessary preparations of data to respond to the related Interrogatories.
111. Inadequate discovery at this time.
112c. Inadequate discovery at this time.
112e. Due to the overexcavation of the bedrock beneath the foundation of CPSES, CFUR suspects that to save money through the use of less concrete. Applicants incorporated loose rock and other material into the foundation of CPSES.
112f. -See response to Interrogatory 112e (as supplemented).
114. Inadequate discovery at this time.
j w.. +. ,
l l
J O l
115. Yes. As set out in t!.se responses to Interrogatories 104,112 and 116 (as l l
supplemented), incorporation of loose rock and other foreigr. material and the formation of air pockets in the CPSES foundation will affect the static, dynamic and engineering properties of the CPSES structurts.
116. Since loose rock, air pockets and other foreign material have different l structural properties than does solid concrete, their incoporation and format'on in the foundation of CPSES will affect the static, dynamic and engineering properties of the structure.
118. Loose rock, air pockets and other foreign material modify the determination of the static and dynamic engineering properties of the material underlying the site.
120. See responses to Interrogatories 104 and 112 (a' 'upplemented). .
121. Because there appears to be extraordinary fissure repair C SES, CFUR i 1
suspects that Applicants' computer codes do not adequately predict the behavior of the CPSES during an earthquake. Contention 7 is broader than I
fissure repatr. ,
1
~ ~
122. Yes. Should surface or subsurface subsidence, uplift or collapse occur beneath ~
CPSES, the presence of loose rock and aber material and the formation of air pockets in the foundation of CPSES will advarsely affect the static, dynamic and engineering properties of CPSES. I 123. See response to Interogatory 116 (as supplemerited). i 125. Inadequate discovery at this time.
127. Inadequate discovery at this time.
129. Inadequate discovery at this time.
1 132. Inadequate discovery at this time. I
?
.. . - . ~ ...
133, 135, 136, 138, 139, 143a , 143 c, 144, 145, 146, 147, 148, 149, 150, 151, 153, 154, 155,158,160,161,163,164,165, and 167.
CFUR is unable to proceed further at this time with responses to Applicants' If it becomes able to proceed, Interrogatories addressed to Contention 8.
CFUR will provide responses to Applicants' Interregatories addressed to Contentibn 8 as soon as practicable.
CERTIFICATE I declare (or certify, verify or state) under penalty of perjury that the preceding CFUR's _ SUPPLEMENT TO ANSWERS TO APPLICANTS' FIRST SET OF INTERROGATORIES TO CFUR AND REQUESTS TO PRODUCE are true' of my own
- knowledge except as to matters therein stated on information and belief, and as to that, I be!!cve them to be trae.
. 6 %
RICH ARD L. FOUKE G
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f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.In the Matter of {
l TEXAS ' UTILITIES GENERATING i Docket Nos. 50-445 COMPANY, et _al
( 50-446 (Comanche Peak Steam Electric 4 (Application for Station, Units 1 and 2) 1 Operating License)
CERTIFICATE OF SER\' ICE
. I hereby certify that copies of the foregoing "CFUR's SUPPLEMENT TO ANSWERS TO APPLICANTS' FIkST SET OF INTERROGATORIES TO CFUR AND REQUESTS TO PRODUCE" were served upon the following persons by deposit in the . United States mail, first class postage prepaid this 8th day of May,1981:
Valentine B. Dcale, Esq. Chairman, Atomic Safety Chairman. Atomic' Safety and and Licensing Board Panel-Licensing Board U.S. Nuclear Regulatory 1001 Connecticut Avenue, N.W. Commission Washington, D.C. 2'1036 Washingten, D.C. 20555 Nicholas S. Reynolds,' Esq. Chairman, Atomic Safety and
' Debevoise & Liberman Licensing Appeal Panel - - - - - -
1200 - lith Street, N.W. U.S. Nuclear Regulatery Commission Washington. D.C. 20036 Washington, D.C. ' 20555 Dr. Forrest J. Remick, Member Marjorie Ulman Rothschild, Esq.
i- Atomic Safety and Licensing rffice.of the' Executive Legal Director Board U.S. Nuclear Regulatory Commission 305 E. Hamilton Avenue Washington, D.C. 20555 State College, Pennsylvania 16801
Dr. Richard Cole, Member David J. Preister, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Environmental Protection Division
. U.S. Nuclear Regulatory P. O. Bo:< 1254S
, . Commission . . Capitol Station Washington, D.C. 20555 Austin, Texas 78711
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- _ x =W - W. _
Mr. Richard L. Fouke Mrs. Juanita Ellis ,.'
CFUR President, CASE 1668B Carter Drive 1426 South Polk Street Arlington, Texas 76010 Dallas, Texas 75224 Jcffery L. Hart, Esq. Mr. Geoffrey M. Gay .
4021 Prescott Aver.ue West Texas Legal Services Dallas, Texas 75219 100 Main Street (Lawyers Building)
Fert . Worth, Texas 76102 Mr. Chase R. Stephens Mr. Arch C. McColl, III Docketing & Service Branch The Katy Building, Suite 302 U.S. Nuclee- Regulatory 701 Commerce Street Commission Dallas, Texas 75202
- Washington, D.C. 20555 y
RICHARD L. FOUKE
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4