ML20082H669
| ML20082H669 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/12/1991 |
| From: | Gutterman A ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR, NEWMAN & HOLTZINGER |
| To: | Mitchell A, Mitchell L MITCHELL, A.L., MITCHELL, L.E. |
| References | |
| CON-#391-12121 91-633-05-OLA-2, 91-633-5-OLA-2, OLA-2, NUDOCS 9108260220 | |
| Download: ML20082H669 (17) | |
Text
.
/ E l 2-) \
pnATED CORRESP0t40ENCE m3e
'c.,
UNITED STATES OF AMERICA NUCLEAR REOULATORY COMMISSION .g g g p4 g BEEORE_THE_ ATOMIC _SAFETLANDlICENSING_DQARD att u NI Q .3 , /
- In the Matter of )
) Nos. 50-528-OLA-2, 50-529-OLA-2 ARIEONA PUBLIC SERVICE ) and 50-530-OLA-2 COMPANY, et al. )
) (Allowable Setpoint Tolerance)
(Palo Verde Nuclear Generating )
Station, Units 1, 2 and 3) ) ASLBP No. 91-633-05-OLA-2
)
LICENSEES' FIRST SET OF INTERROGATORIES AND_ REQUESTS FOR_ERODUCIlON_QE_DQCUMENTS Arizona Public Service Co., et al. (" Licensees" or APS).
hereby serve their First Set of Interrogatories and Requests for Production of Documents To Intervenora, Allan L. Mitchell ar.d Linda E. Mitchell (the "Mitchells"), pursuant to 10 CFR SS 2.740b and 2.741.
Gentral Inntructient l
Each interrogatory.herein is to be answered fully, in writing, and under oath or affirmation ~within-.14 days'after service. Each answer-should clearly indicate the interrogatory to which it is intended to be responsive. -If Intervonors after exercising due diligence, cannot answer any portion of any of the interrogatories-in full, Intervenors shall so-state,_shall' answer l the interrogatories to the-extent possible,.shall explain in-detall the inability _of the Intervenors-to.answar the remainder l
l 9100260220 910012 0 ADOCK 0500 0 3
_PDR 0
of the interrogatories, and shall state when Intervenors expect to be able to answer any unanswered portions.
One Contention has been admitted in this proceeding, Intervenors' Contention No. 1. In admitting the this Contention, the Board limited the Contention by accepting only two of its bases for litigation. Arizona Public Service Co.. et al. (Palo Verde Nuclear Generating Station), LBP-91-19, slip op, at 2, 32 (May 9, 1991). All other contentions and bases were rejected.
Idi at 3, 33. The Board has construed the admitted contention as having two legs:
(1) It challenges the analysis in the safety evaluation by challenging the_High Pressurizer Pressure Trip response-time assumption, but (2) Even accepting the LOCV analysis (and its.HPPT response-time assumption) as correct, the magnitude of possible setpoint drift could cause the 9.1 psia safety' margin calculated in the analysis 1to-be exceeded.
LBP-91-19, slip op, at 22-23.
The word " leg" in the following_ interrogatories refers to these two legs.of-the Contention, as-identified by the Licensing' Board.
The word " basis" in the following interrogatories means an explanation-of-the Intervenors' rationale,: including- -
identification of specific' books, reports,: papers,Lstudies, data,- !
analyses, calculations, expertiopinions1or other documents-or
-statements of potential witnesses that Intervenors may_-rely upon.
l q.
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ - _ _ _ _ . _ _ . _ _ _ . _ _ . A-___-_.~_-.'.
_- O
I The word " identify" for a document means the date, author, title, and specification of pertinent page or pages. For a person it means full name, address, job title, and telephone number.
The word "setpoint" means the normal pressure at which a safety valve is set to actuate or " lift". The word "liftpointa means the pressure at which a safety valve actually. lifts, as demonstrated in periodic tests of the safety valvo.
Interrogatories and Document Requests
- 1. Identify each person Intervenors intend to call as a witness in this proceeding. For.each such person, state the-person's name, address, telephone number, and professional qualifications; state whether the witness will be designated as an expert witness; and provide a summary of the witness's anticipated testimony in this proceeding.
- 2. Identify all books, reports, papers, studies,;cnalyses, calculations and other documents that Intervenors-intend to rely upon in this proceeding, -whether:. for tpurposes of L 1 i
exhibits, direct examination,: cross-examination, or for: any- 1 other purpose.. For each such document, identify-the.
specific portions relied upon, summarize the purposes for 1
. - , .~,, -
.., - . - - - .~ . - .. ,
. which the document is relied upon, and produce the documents for copying.
- 3. If the representations made in the contention or in the bases for either log of the contention, are based in whole or in part on Intervenore' belief that there are errors or deficiencies in Licensee's November 13, 1990 Application for amendment of the Technical Specifications ("the Application"), t!,e Palo Verde Updated Final Safety Analysis Report, or any of the references cited therein; (a) identify: (1) the particular document that Intervenors contend to be deficient and (ii) the portion of such document in which the deficiency exists; (b) explain the bacis of Intervenors' assertion that the document is deficient; and (c) Identify all documents, books, reports, studies, analyses, calculations, experts or other basis
[
relied upon-by Intervenors in support in its position.
- 4. Identify the basis for Intervenors challenge to the assumption of 0.5 seconds for the high pressurizer pressure trip (HPPT) response time in the Application. Include specific references to any studies, reports, data, other documents, statements of wJcnesses or expert opinion that supports Intervenors' challenge to this assumption.
._.-4
- 5. Do Intervenors contend that the proposed Technical Specification amendment which would require that the HPPT response time be less than or equal to 0.5 seconds would be inconsistent with any NRC rule, regulation, or guidance? If so, identify with particularity which rule, regulation, or guidance Intervenors rely upon and all documents, books, reports, papers, studies, analyses, calculations, or expert opinions relied upon by Intervonors in support of their position.
- 6. Do Intervenors contend that licensees wil'1 be unable to comply with the proposed HPPT response time of less than or equal to 0.5 seconds? If so, identify all documents, books, reports, papers, studies, analyses, calculations, or expert opinions relied upon by Intervenors in support of their position.
i l
- 7. Do Intervenors agree that a reduction in the HPPT response time would reduce the peak pressures in the primary and a secondary systems that would result from a loss of condenser vacuum (LOCV) event? If Intervenors do not-agree that peak-pressures would be-reduced, explain the basis for-Intervenors' position.
t
- 8. oo Intervenors contend that the proposed reduction in the HPPT response time would result in violation of a safety limit or other NRC requirement? If so, identify all safety limits and other NRC requirements that would be violated and the bases for Intervonors' position that such a violation would occur.
- 9. Intervenors' contention in this proceeding states:
Contention No. la The request to amend the setpoint tolerances for the Main Steam Safety Valves (NSSVs) and the Pressurizer Safety Valves (PSVs) would cause a safety limit violation in the event of a loss of condenser vacuum (LOCV).
Setpoint drift in the increasing direction of the pressurizer safeties setpoint with a setting high in the band would exceed the safety limits.
(Intervenors' Supplemental Petition at 2)
Please provide the following information about this contentions
- a. Identify each safety limit that Intervenors contend may be violated.
(1). For each such safety limit, identify all studies, data, calculations or analyses-that intervenors may rely upon in
- . - . - .- -. . - . - = - . - . . . - . - . . - - . . - _ - . . . - _ - . . . _ _ - . ..-
t .
1 i
support of their contention thst such safety limit may be l violated.
(ii). For each study, calculation, and analysis 1
mentioned in response to Interrogatory 9.a.(i.), identify and 4
- produce for copying all accuments that describe the assumptions, methodologies or results of such studies, calculations or j analysis.
{ (111). Identify all persons who were involved in 6 conducting such studies, calculations or analysis and describe j each such person's contribution thereto.
l (iv). For all data mentioned in response to .9.a.(i.),
l identify the source of such data and identify and produce for-i j copying all documents that describe the time, place and method of collection of such data.
{ (v). Identify all persons who have-personal' knowledge f of the basis for this contention.
t
! b. Explain what Intervenors mean by "a setting high in'the >
band" (as used in'Intervenors'-Supplemental Petition at 2).
Include inLthat explanation answers to the'following:
._(1).-Doec the word _" band": refer'to the: proposed-
, setpoint tolerance range for'PSVs of between +3%"and:-l%? If not, explain in detail, with precise quantification wherever possible, _
- i. what band is referenced.
l I:
l l
i
-I
.. + -e.--. we,. . .wa, # -.~, . . , ,-..v.... s-- , --
(ii). Does the term " setting" refer to the lift pressure of one or more PSVs? If not, explain in detail, with precise quantification wherever possible, what setting is referenced.
(iii). Does the term "high" refer to PSV liftpoints between +1% to +3S? If not, explain in detail, with preciso quantification wherever possible, what Intervenors mean by "high."
- c. Identify any studies, calculations, analyses or data, other than those referenced in the response to Interrogatory 2 which show the effects of_PSV setpoint drift on pressures resulting from a LOCV.
(1). For each study,_ calculation, and analysis mentioned in response to 9.c., identify and produce for copying all documents that describe the assumptions, methodologies or results of such studies, calculations or analysis.
(ii). Identify all persons who were involved in conducting such studies, calculations or analysis and' describe each such person's contribution thereto.
(111). For all data mentioned in response to 9.c.,
identify the source of such data, explain how the data shows the effects of PSV setpoint drift and identify and produce for
copying all documents that describe the data and the time, place and method of collection of such data.
- d. With respect to Intervenors' assertion that "[e]ven a drift of plus or minus 1% (approximately 50 psia) would exceed the limit of 2750 psia" answer the following:
(1). Does the quoted phrase concern drift from the PSV setpoints, that is, a liftpoint that is different from the setpoint of a PSV? If the phrase contemplates something other than drift from the PSV setpoints, explain in detail what is meant by drift.
(ii). Do Intervenors contend that a setpoint drift of minus 1% of one PSV would result in exceeding the 2750 psia safety limit for Reactor Coolant System (RCS)_ pressure? If the answer is yes, explain the basis for this assertion. If the answer is no, explain the basia for Intervenors' assertion that a drift of minus 1% would exceed the limit of 2750 psia. As-part of the explanation identify and produce for copying all documents that describe any study, calculation, analysis, or.other basis-for this assertion. Identity.all persons who were involved in conducting such studies, calculations or analyses and describe each such person's contribution thereto.
(iii). Do Intervenors assert that a one percent change in the liftpoint of one PSV will result in "approximately 50
psia" change in the peak pressure due to a LOCV? If the answer is yes, explain the basis for this assertion. If the answer is no, explain the basis for Intervonors' reference to "50 paia".
As part of the explanation identify and produce for copying all documents that describe any study, calculation, analysis, or other basis for this ar- ton. Identify all persons who were involved in conducting such studies, calculations or analyses and describe each such person's contribution thereto.
- e. With respect to Intervenors' assertion that "Given that' APS concedes that the MSSVs and PSVs have exceeded the plus-or minus 1% limit 'several times, necessitating the issuance of l
Licensee Event Reports (LERS),' almost any drift in the setpoints would result in a safety limit violation" answer the following:
(1). Do Intervenors assert that setpoint drift of-the MSSVs would result in a safety limit violation in the event of a -
LOCV? If the answer is yes, explain how the--MSSV setpoint drift _
would result in a safety limit violation.
(ii). Do Intervenors assert that a drift in'the MSSV-setpoint would result in exceeding thel 2750 psia safety limit:for-Reactor Coolant System (RCS) pressure? -If-th'e answer is yes, explain the basis for-this assertion. If the answer is no, explain the basis for the Intervenors' assertion quoted above' .-
As part of the explanation-identify and produce for copying:all
~
-- - ._____m____.__..__m__. _ _ _ _ . _ _ _ _ _ .__5 _ _ - . - . _ _ _ . . _
documents that describe any study, calculation or analysis that supports such assertion. Identify all persons who were involved in conducting such studies, calculations or analyses and describe each such person's contribution thereto.
(111). Do Intervenors assert that MSSV setpoiv .._rt, whether in the positive or negative direction, would result in a safety limit violation in the event of a LOCV? If the answer is yes, explain the basis for this assertion. If the answer is no, explain the basis for Intervenors' reference to "any drift" in the quoted sentence. As part of the explanation identify any study, calculation or analysis that supports such assertion that there would be a safety limit violation.
(iv). Have Intervenors reviewed any LERs filed by Licensees regarding PSV or MSSV setpoints? If so, answer the following:
[A). Identify all such LERs reviewed by Intervonors.
[B]. Do Intervenors contend that any of those LERs shows that a safety limit would have been exceeded in the event of a LOCV? If so, identify the specific LERs and the statements in such LERs that form the basis for such contention.-
l l
l
[
[C). Do Intervenors contend that any of those LERs contained an incorrect statement about safety limits?
If so, explain the basis for Intervenors' contention.
As part of the explanation identify the specific statements that were in error and identify and produce -
for copying all_ documents that. describe any study,-
calculation or analysis that supports such contention.
Identify all persons who were involved in conducting _
such studies, calculations or analyses and describe each such person's contribution thereto,
- f. With respect to Intervenors' assertion that "If the-amendment is granted, APS would reduce the frequency of testing
. . . " (Intervenors Supplemental Petition at~3) answer the-following:
4 2
(1), Explain the basis for the quoted statement..
Include in the explanation citation to'any documents, andcwritten or oralistatements:byLLicensees or other personsithat-Intervenors intend-to, rely upon to: support this: L assertion-.
(11) . Do Intervenors contendithat the frequency;of-testing should be different'.from the frequency (specified:by1the ASME Code? If the answer to thisl question is yes,; explain:the--
. testing frequency _that should be-required-and the-basisifor- j requiring testing attsuch frequency. _
If:the answer is?no, . _
- .n
~
,.J s
explain Intervenors' position regarding testing' frequency. As.
part of the explanation identify and produce for copying all documents that describe any study, calculation or analysis that supports such contention. Identify all persons who were. involved in conducting such studies, calculations or analyses and describe each such person's contribution thereto.
(iii). Do Intervenors' contend that reduced " frequency of testing would result in unacceptable setpoint drift?" If the answer is yes, explain the basis for this contention. As part of the explanation identify and produce for copying all documents that describe any study, calculation, analysis, or other basis for this-assertion., Identify all persons who were involved in conducting such studies, calculations or analyses and describe each such person's contribution thereto.
(iv). Do Intervenors agree that current NRC regulations-do not require that Licensees test every PSV and.MSSV once-per refueling cycle (approx. every-18 mos.)? If not, identify the-basis for this disagreement.
! (v). Do Intervenors agree that current-NRC regulations l would not require that Licensees test every PSV and MSSV!once per l
L refueling cycle (approx every 18 mos.) if the proposed license i
amendment were adopted? If not,-identify.the1 basis for-this- ;
l
-disagreement. j (vi). Identify the basis forfIntervenors' assertion -
that "[s]etpoint drift in the range-of plus or.minusL10%1to 20%-
could occur if the amendment is granted." As part of the explanation identify and produce for copying all documents that describe any study, calculation, analysis _or other basis for this assertion. Identify all persons who were involved in conducting such studiet, calculations or analyses and describe each person's contribution thereto.
- g. Do Intervenors agree that drift in the MSSVs in the positive direction (beyond the proposed maximum tolerances) would, not have a significant impact upon the RCS' peak pressure in the event of a LOCV? If not, identify the basis for.this disagreement and any studies, calculations, analyses, references, or statementF, of experts that Intervenors may rely upon in support of this position.
- h. Do Intervenors contend that drift in the MSSVs in the negative direction would cause a safety limit violation? -If so, explain the basis for-this contention and identify-any studies, calculations, analyses, references, or statements of experts that Intervenors may rely upon in support of this position,
- 10. Do Intervenors contend that.the proposed reduction'in the-auxiliary feedwater-(AFW)'flowrate from 750 gpm to 650 gpm l- would have'any cffect upon the_ pressures in the event ef:a.
LOCV? If so, explain the basis for_this contention. As
. part of the explanation identify and produce for copying all documents that describe any study, calculation, analysis, or other basis for this assertion. Identify all persons who were involved in conducting such studies, calculations or analyses and describe each such person's contribution thereto.
Respectfully submitted:
Y N ILe~
Alvin H. Gutterman Newman & Holtzinger, P.C.
1615 L Street, N.W.,
Suite 1000 Washington, D.C. 20036 (202) 955-6600 Counsel for:
Arizona Public Service Company Date: August 12, 1991
- August 12,,1991
...g.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1H ME 13 P4 :05
)
In the Matter of ) Nos. 5 0-5 2 8-OLA~-2, s 50-52 9-OLA-2
) and 50-530 VOLA-2; , '
ARIZONA PUBLIC SERVICE )
COMPANY, et al. ) (Allowable Setpoint Tolerance)
)
(Palo Verde Nuclear Generating )
Station, Units 1, 2 and 3) ) ASLBP No. 91-633-05-OLA-2
)
CERTIFICATE OF SERVICE I hereby certify that on August 12, 1991, copies of
" LICENSEES' FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS" in the above captioned proceeding were served on the following by deposit in the United States mail, first class, properly stamped and addressed, except for service upon Counsel for Allan &
Linda Mitchell, who was served by hand delivery.
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Adjudicatory File Washington, D.C. 20555 (two copies)
Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief, Docketing and-Service Section (Original plus two copies)
Administrative Judge Ivan W. Smith, Chairman .
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Administrative Judge Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l
l i
~ . - , - . . ~ , -
0.
l I
I Administrative Judge Walter H. Jordan Atomic Safety and Licensing Board 881 West Outer Drive Oak Ridge, TN 37830 ,
Edwin J. Reis,.Esq.
Lisa B. Clark, Esq.
Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C.- 20555 Nancy C. Loftin, Esq.
Corporate Secretary & Corporate Counsel Arizona Public-Service Company P.O. Box 53999.
Mail Station 9068 Phoenix, AZ 85072-3999' David K. Colapinto, psq.
Counsel for Allen & Linda Mitchell Kohn, Kohn & Colapinto, P.C.
517 Florida Avenue, N.W.
Washington, D.C.- 20001 (By Hand Delivery)
August 12, 1991-
<^ - Y?)j\ allbdi
'Alvin H. Gutterman
- Newman'&.Holtzinger, P.C.
1615 L Street,:N.W.
Suite'1000 Washington,'D.C. _ 20036 y ,_ _E , , ,~,,...y . ,m. - ,y ., _-, .,y yy ,y ,e