ML20080D200

Answers & Objections to First Set of Interrogatories on Contention 4.Certificate of Svc Encl

ML20080D200
Person / Time
Site:	South Texas
Issue date:	08/26/1983
From:	Silverman D JOINT APPLICANTS - SOUTH TEXAS PROJECT, LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	TEXAS, STATE OF
References
ISSUANCES-OL, NUDOCS 8308300232
Download: ML20080D200 (17)

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I 00CKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD

'83 ALG 29 R2:50 In the Matter of 5 (C rf nm rg,7 g

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HOUSTON LIGHTING AND POWER S Docket Nos. 50-498 OL COMPANY, ET AL. S 50-499 OL S

(South Texas Projects, S Units 1 & 2) S APPLICANTS' ANSWERS AND OBJECTIONS TO STATE OF TEXAS' FIRST SET OF INTERROGATORIES TO APPLICANTS ON CONTENTION 4 Pursuant to 10 CFR SS 2.740 and 2.740b, Applicants hereby provide their answers and objections to the State of Texas' First Set of Interrogatories to Applicants on Contention 4.

I. General For several of the interrogatories Applicants have provided answers and at the same time objected on the grounds that the interrogatories seek information that is neither relevant to Phase II nor reasonably calculated to lead to the discovery of admissible evidence. While Applicants have provided answers which they believe to be fully responsive to the interrogatories, Applicants nevertheless wish to point out and preserve their objections to such interro-gatoriva.

II. Specific Answers and Objections Interrogatory 1. Do the Applicants contend that there are no recorded hurricanes 8308300232 830826

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a. in the Gulf of Mexico

b. in the North Atlantic Ocean in which the fastest mile wind speed, 30 ft. above ground has been higher than 125 mph?

Answer:

a. No.

b. No.

Interrogatory 2: Please define " fastest mile wind speed" as used by the Applicants in answering interrogatory 1.

Answer: Fastest-mile wind speed is defined as the highest average speed of one mile of air passing an anemo--

meter for a particular period of time. For example, a fastest-mile speed of 120 mph means that it took 30 seconds for a " mile" of wind to pass the anemometer.

Interrogatory 3: If the answer to interrogatory 1 is "no,"

a. please identify hurricanes whose fastest mile wind speed, 30 ft. above ground exceeded 125 mph and provide the speed for each hurricane.

b. please explain the selection of 125 mph as the design wind velocity for the fastest mile wind speed at STNP.

c. please identify all studies of documents relied upon in answering 3a and 3b.

Answer: In order to develop its answer to this inter-rogatory, Applicants reviewed pertinent literature on i

. burricanes. The document which provided the information given below is USNRC NUREG/CR-2639: " Historical Extreme Winds for the United States - Atlantic and Gulf of Mexico Coastlines." Applicants also consulted " Meteorological i

Criteria for Standard Project Hurricane Windfields, Gulf and i

East Coasts of the United States," NOAA Technical Report NWS 23, September 1979 and " Hurricane Allen 3-10 August 1980",

US Army Engineer District, Galveston. The NOAA document provides useful information about, inter alia, the dates and locations of landfall for historic hurricanes. The Corps of i

Engineers document provides some wind speed information for hurricane Allen, which was too recent to be addressed in the NRC document. The NRC document gives maximum reported sustained wind speeds for land based meteorological stations.

A wind speed for hurricane Allen of 138 mph at an oil drilling platform in the Gulf of Mexico is not included in the list below because it is not considered representative of wind speeds that might be measured on land. Hurricane Anita, referenced in interrogatory 4, did not make landfall in the U.S. and is thus not considered representative of wind speeds at the South Texas Project site. Therefore Anita was not investigated. Based on the foregoing, Applicants believe that the information requested is as follows:

a. Gulf of Mexico l

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i. Hurricane of September 14, 1919, 154 mph at 30 meters at Corpus Christi. Given the wind speed at 30 meters, it is reasonable to assume that the fastest-mile wind speed at 10 meters exceeded 125 mph.

ii. Hurricane Celia (August 3, 1970), 128 mph at 10 meters at Corpus Christi.

North Atlantic Ocean

i. Hurricane of August 18, 1879, at Cape Lookout, North Carolina, 139 mph at 10 meters.

b. USNRC NUREG-0800 defines design wind as the 100 year return period fastest mile of wind. Bases for selection of 125 mph for the South Texas Project are defined in Section 2.3 of the FSAR.

c. The documents relied upon are identified in the answer to each question.

Interrogatory 4: If the answer to interrogatory 1 is "yes," please provide Applicants' position on the fastest mile wind speed for each of the following:

a. The hurricane of September 27 through October 6, 1949 making landfall near Freeport, Texas

b. Hurricane Carla (196J) i

c. Hurricane Hilda (1964)

d. Hurricane Betsy (1965)

e. Hurricane Celia (1970)

f. Hurricane Allen (1980)

g. Hurricane Anita Answer: Not applicable.

Interrogatory 5: Please identify all studies or documents relied upon in answering Interrogatory 4.

Answer: Not applicable.

Interrogatory 6:

a. What is the peak hurricane wind gust value used by Applicants in designing STNP?

b. Where is this value documented in Applicants' filings with the NRC7 Please provide a copy of said filing.

c. Please identify all studies or documents relied upon in answering interrogatory 6.

Answer:

a. In designing the STP to withstand hurricane wind gusts, a particular gust wind speed is not determined.

Instead, the appropriate gust factor is applied in calculat-ing wind pressure loadings, in order to account for the additional loading effects resulting from wind turbulence in excess of the fastest-mile of wind, and in consideration of the intensity and randomness of gust loading over structural surfaces. The gust factors applied at 30 feet for buildings and structures and parts or portions of buildings and structures l

(e.g. windows, girts, purlins, spandrels) are in accordance with ANSI A58.1-1972. These factors vary with elevation.

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b. The gust factors are taken from ANSI A58.1-1972, "American National Standard Minimum Design Loads for Buildings and other Structures," and documented in the FSAR l

in Section 3.3.1.1.2.

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c. ANSI A58.1-1972 and the STP FSAR Section 3.3.

Interrogatory 7: Do the Applicants contend that there are no recorded hurricanes.

a. in the Gulf of Mexico

b. in the North Atlantic Ocean in which the peak wind gust has been higher than the value given in response to interrogatory 6a?

Answer:

a. & b. Since a specific peak wind gust speed is not identified in response to interrogatory 6a, it is not possible to respond to these interrogatories.

Interrogatory 8: If the answer to interrogatory 7 is "no,"

a. please identify the hurricanes whose gusts

exceaded the value given in answer to interrogatory 6.

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b. the highest gust for each hurricane identified,

c. please explain Applicants' selection of the value given in answer to interrogatory 6a.

d. please identify all studies or documents 1

relied upon in answering 8a and 8b.

Answer:

a. b. c. d. Summaries of gust values for hurricanes are not available in the literature as is the case for fastest mile wind speeds. Reports on individual hurricanes frequently include information on peak gusts but these l values are generally acknowledged to be estimated and not fully reliable. Applicants have not attempted to identify l

hurricanes as requested in this interrogatory because, as stated in the answer to interrogatory 6.a., specific gust wind speeds are not a part of the South Texas Project design basis. Instead, an appropriate gust factor is applied in calculating the wind pressure loadings which the plant must be designed to withstand.

Interrogatorv 9: Please produce a copy of the non-published private correspondence dated June 1974 referenced in the October 15, 1982 Memorandum and Order of the ASLB in this proceeding (and apparently also referenced in FSAR Section 2.3.1.2.6., at p. 2.3-6a).

Answer: The requested private correspondence was a telephone conversation between Michael Septoff (NUS) and Floyd Garland (National Climatic Center) . The telephone call is documented in the FSAR and PSAR. No other records of the telephone call have been located.

Interrogatory 10: What is the Applicants' position on the extent of the " surrounding area" required to be con-1 sidered by 10 CFR Part 50, Appendix A, Criterion 27 Please explain the basis for Applicants' position.

! Answer: The meaning of " surrounding area" for purposes of applying Criterion 2 depends on the particular natural phenomenon under consideration.

Applicants' evaluation of the design wind, through the use of composite meteorological data, takes into considera-tion an area represented by the wind speed records of Galveston, Corpus Christi, and Victoria. This is described in FSAR Section 2.3.1.2.1.

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Interrogatory 11: Would the design of STNP differ if the Applicants had selected a fastest mile speed of 185 mph rather than 125 mph? If so, please describe generally how the design would have differed. If not, please explain why not.

Answer: Applicants have not conducted the detailed analyses which would be necessary to determine whether or not the design of the STP would change if a fastest mile wind speed of 185 mph were selected.

Interroaatory 12: Would the design of STNP differ if the Applicants had selected a peak gust value of 200 mph rather than the value given in response to interrogatory 6a?

If so, please describe generally how the design would have differed. If not, please explain why not.

Answer: Applicants have not conducted any detailed analyses to determine whether or not the design of the STP would change under the given circumstances because specific gust wind speeds are not a part of the STP design basis.

Instead, as indicated in the answer to interrogatory 6, the appropriate gust factor is applied in calculating the wind pressure loadings which the plant must be designed to withstand.

Interrogatory 13: Please identify each witness Applicants intend to call on Contention 4 and summarize the testimony of each.

Answer: Applicants have not as yet identified the witnesses they intend to call on Contention 4. Upon their l

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identification, Applicants will supplement this response with the requested information.

Interrogatory 14: Is the Applicants' position that having designed parts of STNP to withstand missiles carried by tornado winds of 360 mph, these same parts of STNP are therefore designed to withstand a fastest mile wind speed of 360 mph? Please explain.

Answer: No. Applicants' position is that in the design of all of the safety related structures at STP the effects of both the design wind (125 mph; non-tornadic, but including hurricanes) and the effects of a postulated design basis tornadic wind (360 mph) have been considered in various combinations with other applicable loads. The safety-related structures must be capable of performing their safety functions under each of these various load combina-tions. The various load combinations considered in the STP design are shown in ESAR Tables 3.8.1-1 and 3.8.4-1. As shown in those tables, and as required by the various I

applicable industry codes (ACI 318 or AISC, depending on type of structure), these load combinations include certain load factors which systematically increase certain loads to account for uncertainties in their selection and in the consistency of construction. The load factor applied to the design wind (100 year recurrence interval fastest mile wind) in these combinations is 1.7, i.e., the calculated wind pressure caused by the design wind is increased by 70

percent to account for such uncertainties. Because the occurrence of a tornado at any specific location is recognized to be an extremely rare event, the codes utilize a load factor of one (no increase) for the loads associated with tornadoes (wind pressure, pressure differential and tornado missile loads).

Another factor that differentiates hurricane or design winds from the design basis tornado is that due to friction with the land surface, a straight wind, such as a hurricane, varies in intensity with elevation above ground level. The design basis tornadic winds are assumed not to vary with elevation. The standard height at which design winds (including hurricane winds) are measured is 30 feet. Design analyses take into account the increase in wind velocity with elevation by utilizing a standard engineering formula, which is reproduced in FSAR Section 3.3.1, to convert from the 30 ft. wind to higher wind velocities at higher elevations.

Because the design wind and the tornado wind are considered in different load combinations, different load factors are used in those load combinations, and design basis tornadic winds are assumed not to vary with elevation, one can not directly compare the velocities of the design basis tornado wind and design wind to determine whether a change in the design wind velocity would require a design change. However, in the design of STP the load combinations that consider the design wind loads, including hurricanes, I

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l were not the controlling loads and a substantial increase in l the design wind could be accommodated without those load combinations becoming the controlling load combinations.-

Thus, the design wind velocity could be increased substan-tially without necessarily requiring a change in plant design.

Interrogatory 15:

a. What is the heaviest rainfall Applicants have considered in the design of STNP?

! b. Please identify studies of documents Applicants relied upon for their answer to Interrogatory 15.

Objection: Applicants object to interrogatory 15 on the grounds that the information sought is neither relevant l nor reasonably calculated to lead to the discovery of admissible evidence. CCANP Contention 4 addresses the i

! design of STP Category I structures to withstand hurricane wind loadings and hurricane generated missiles and does not address the amount of rainfall considered in the design of the STP.

Answer:

a. The normal drainage system for the drainage of roofs of plant structures has been designed for a maximum intensity of 8"/hr. The probable maximum precipitation considered for local intense precipitation over the 4.5 square mile drainage area into Little Robbins Slough is 38.10 inches in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. For a more detailed description of these rainfall considerations see STP FSAR Section

2.4.2.3. Effects of Local Intense Precipitation. STP FSAR Section 2.4.3.1 Probable Maximum Precipitation contains a discussion of the estimates of probable depths and durations of rainfall for the various areas considered in the analysis of flood conditions at the STP site,

b. STP FSAR Section 2.4 and references listed therein.

Interrogatory 16:

a. What is the highest flood crest on the Colorado River Applicants have considered in the design of STNP?

i b. Please identify all studies or documents Applicants relied upon in answering interrogatory 16.

Objection: Applicants object to interrogatory 16 on the grounds that the information sought is neither relevant nor reasonable calculated to lead to the discovery of admissible evidence. CCANP Contention 4 addresses the design of STP Category I structures to withstand hurricane wind loadings and hurricane generated missiles, and does not address the consideration of flood crests on the Colorado River.

l Answer:

a. STP FSAR Figure 2.4.2-2 presents a graph which shows the flood stage of the Colorado River at the Bay City l Gage Site vs. the flood stage at the FM 521 bridge. The

( maximum known stage at the USGS gage site at Bay City since 1

1869 is 56.1 feet. This translates to a stage at the FM 521 1

bridge near the STP site of approximately 28.3 feet. This level is well below the STP plant design flood level of 50.8 feet.

b. FSAR Section 2.4 and references therein.

Interrogatory 17:

a. What is the highest hurricane storm surge Applicants have considered in the design of STNP?

b. Please identify all studies and documents Applicants relied upon in answering interrogatory 17.

Objection: Applicants object to interrogatory 17 on the grounds that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. CCANP Contention 4 addresses the design of STP Category I structures to withstand hurricane wind loadings and hurricane generated missiles and does not address hurricane storm surge.

Answer:

a. The highest hurricane storm surge considered in the design of STP is a calculated value of 29.8 feet above mean sea level at the mouth of the Colorado River.

This calculated surge, plus the effects of wave action, results in a calculated maximum water level of plant structures of 31.7 feet above mean sea level. FSAR Section 2.4.5 l describes the methods used to arrive at these values.

b. FSAR Section 2.4.5 and references therein.

Interrogatory 18: Please identify the witnesses Applicants intend to call on Contention 4 and summarize their testimony.

Answer: Applicants have not yet identified the witnesses they intend to call on Contention 4. Upon their identification, Applicants will supplement this response with the requested information.

Respectfully submit ed, f a c,L)., m m Jack R. Newman Maurice Axelrad Alvin H. Gutterman Donald J. Silverman 1025 Connecticut Avenue,NW Washington, D.C. 20036 Finis E. Cowan 3000 One Shell Plaza Houston, Texas 77002 Dated: August 26, 1983 LOWENSTEIN, NEWMAN, REIS ATTORNEYS FOR HOUSTON LIGHTING

& AXELRAD, P.C. & POWER COMPANY, Project i 1025 Connecticut Avenue, NW Manager of the South Texas Washington, D.C. 20036 Project acting herein on be-half of itself and the other i BAKER & BOTTS Applicants, THE CITY OF SAN 3000 Shell Plaza ANTONIO, TEXAS, acting by and Houston, Texas 77002 through the City Public Service Board of the City of San Antonio, CENTRAL POWER AND LIGHT COMPANY, and CITY OF AUSTIN, TEXAS i

BEFORE ME, the undersigned authority, on this day personally appeared Mark R. Wisenburg, Manager, Nuclear Licensing, Houston Lighting and Power Company, who upon his oath stated that the foregoing " Applicants' Answers and Objections to State of Texas' First Set of Interrogatories to Applicants on Contention 4" were prepared under his super-vision and direction, and that all answers contained therein are true and correct to the best of his knowledge and belief.

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Mark R. Wisenburg SUBSCRIBED AND SWORN TO BEFORE ME by the said Mark R. Wisenburg on this ,V// day of (/ o a g # , 1983.

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otary Public My Conmission expires:

N ZCommission Expires Jmary 1,1989

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

)

HOUSTON LIGHTING AND POWER ) Docket Nos. 50-498 OL COMPANY, ET AL. ) 50-499 OL (South Texas Project, Units 1 )

and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Answers and Objections to State of Texas' First Set of Interrogatories to Applicants on Contention 4" have been served on the following individuals and entities by deposit in the United States mail, first class, postage prepaid, on this 26th day of August, 1983.

Charles Bechhoefer, Esq. Brian Berwick, Esq.

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

313 Woodhaven Road Harmon & Weiss Chapel Hill, NC 27514 1725 I Street, N.W.

Washington, D.C. 20006 Ernest E. Hill Administrative Judge Kim Eastman, Co-coordinator Lawrence Livermore Laboratory Barbara A. Miller University of California Pat Coy

! P.O. Box 808, L-46 Citizens Concerned About i

Livermore, CA 94550 Nuclear Power 5106 Casa Oro Mrs. Peggy Buchorn San Antonio, TX 78233 I

Executive Director Citizens for Equitable Lanny Sinkin Utilities, Inc. 2207-D Nueces Route 1, Box 1684 Austin, TX 78705 Brazoria, TX 77422

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0 1 6 Robert G. Perlis, Esq.

Office of the Executive Legal

! Director U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board l U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission 20555 Washington, D.C.

Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555 wAU ' ww c5' 1

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