ML20054H894

Second Set of Interrogatories Re Commission Questions 1,2 & 5.Certificate of Svc Encl

ML20054H894
Person / Time
Site:	Indian Point
Issue date:	06/24/1982
From:	Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
Shared Package
ML20054H891	List: ML20054H890 ML20054H894
References
ISSUANCES-SP, NUDOCS 8206250147
Download: ML20054H894 (8)

Text

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A UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSOLIDATED EDISON COMPANY Docket Nos. 50-247-SP OF NEW YORK (Indian Point, Unit 2) 50-286-SP POWER AUTHORITY OF Tile STATE OF ) June 24, 1982 fiEW YORK (Indian Point, Unit 3) )

NRC STAFF SECOND SET OF ItiTERR0GATORIES TO POWER AUTHORITY OF THE STATE OF NEW YORK CONCERNING THE COMMISSION'S QUESTIONS 1, 2 AND 5 INTRODUCTION The NRC Staff hereby request that Power Authority of the State of New York (the Authority) pursuant to 10 C.F.R. $% 2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce or make available for inspection and copying all documentary material identified in responses to the interrogatories below.

INSTRUCTIONS AND DEFINITIONS

1. Information sought in these Interrogatories shall include information within the knowledge, possession, control or access of driy agents, employees and independent contractors of the Authority.

2. Answer each Interrogatory separately (by part) in writing under oath or affirmation of the individuals who contributed thereto. ._

Documents produced shall indicate in response to which specific request

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the documents are being produced, i.e., 1(a). For all referer.ces requested in these interrogatories, identify them by author, title, date of publication and publisher if the reference is published; and if it is

,not published, identify the document by the author, title, the date it was written, the qualification of the author relevant to this proceeding, and where a copy of the document may be obtained.

3. In your answer, repeat each Interrogatory set forth herein and then set forth an answer thereto separately and fully. As to any Interrogatory, section or subsection of said Interrogatory that you refuse to answer for any reason, separately state the grounds for any such refusal. Where a complete answer to a particular Interrogatory, section or subsection of said Interrogatory is not possible, such Interrogatory, section or subsection of said Interrogatory should be answered to the extent possible and a statement made indicating the reason for the partial answer.

4. Identify any documents used as the basis for the answer to the Interrogatory.

5. If any Interrogatory or part thereof is objected to, state separately (by part) the objection and basis therefor.

6. If privilege is claimed as to any document, identify what is being withheld, the date of the document, the sender (s), the receipient(s) of all copies, the privilege claimed, the basis for the assertion of privilege, and the present location of the document.

7. -If any document requested is unavailable, explain the -

circumstances of such unavailability.

8. In accordance with 10 C.F.R. 5 2.740(e) these Interrogatories l

require prompt supplemental answers should the Authority obtain or identify supplemental information or documents which call into question the correctness of earlier answers.

9. In the event any word, term, or phrase is unclear to the Authority it is requested that oral clarification be requested of the undersigned Staff counsel. Any word, term, or phrase is to have its generally accepted meaning.

10. " Documents" mean all writings and records of every type in the possession, control or custody of the Authority, its directors, officers, attorneys, employees or agents, including, but not limited to, memoranda, correspondence, reports, surveys, evaluations, charts, books, minutes, notes, agenda, diaries, logs, transcripts, microfilm, accounting state-ments, telephone and telegraphic communications, speeches, and all other records, written, electrical, mechanical or otherwise.

" Documents" shall also mean copies of documents, even though the originals thereof are not in the possession, custody or control of the Authority.

INTERR0GATORIES Interrogatory 1 Please provide the basis for the application of the definition of damage efffective ground acceleration used in the IPPSS to structures such as buried pipe which depend on functional operation as opposed to ductile strength tapacity. -

Interrogatory 2 Have uncertainties due to design and construction errors been considered in the seismic analysis in Section 7.9.3 of the IPPSS?

Interrogatory 3 If the answer to Interrogatory 2 is no, please provide the basis for this lack of consideration.

Interrogatory 4 Provide the basis for using SD0F (single-degree-of-freedom) models for MDOF (multi-degree-of-freedom) structures for determining the contribution of inelastic behavior.

Interrogatory 5 Provide the basis and the procedure used for assigning numerical values to the randomness and uncertainty components for fragility curves of critical structures. Provide the basis for assigning any given variability to one or the other of these components in Section 7.9.3 of the IPPSS.

Interrogatory 6 Provide the basis for the assumption contained in Section 7.9.3 of the IPPSS that the collapse of a non-loadbearing masonry wall would essentially be a vertical collapse. a) please identify which masonry walls in Indian Point Unit 2 have been strengthened; b) provide the detailed basis for the development of masonry wall fragilities for both strengthened and non-strengthened cases.

Interrogatory 7 What are the bases for assigning subjective probability for the seismogenic zones mentioned in Section 7.9.1 of the IPPSS?

Interrogatory 8 Please provide the basis for the use of truncated exponential distribution used to represent frequency of earthquake occurrence.

Interrogatory 9 In the IPPSS it is concluded that the annual frequency pipeline gas fire which threatens the plant is about 5 x 10 pf a This value is based upon a 1arge break near the plant. Provide the bases for assuming that 5 x 10-7 per year is higher than the probability of a small break leading to ingestion of a flammable mixture of natural gas into the plant v6ntilation intakes.

Interrogatory 10 It is stated in Section 7.9.2 of the IPPSS that log-normal distribution is a good r,athematical representation to describe observed sustained acceleration. Can another type of distribution be used, and if not, why?

Interrogatory 11 In cases where design analysis results on plant-specific qualifi-cation reports were not available for deriving individual equipment f ragility levels, these fragility levels were based on generic consid-erations. a) Provide the justification for grouping equipment into these major categories for establishing fragility levels. b) Would grouping by additional subclasses within these categories appreciably change the fragility results. Provide the bases for your response. c) Are there individual pieces of equipment that are outliers to their particular category. Provide the basis for your response.

Respectfully submitted, I so.

Henry /J. McGurren s Counsel for NRC Staff Dated at Bethesda, Maryland this 24th day of June, 1982.

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certifi'd I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CONSOLIDATED EDISON COMPANY Docket Nos. 50-247-SP OF NEW YORK (Indian Point, Unit 2 50-286-SP POWER AUTHORITY OF THE STATE OF )

NEW YORK (Indian Point, Unit 3) )

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF SECOND SET OF INTERR0GATORIES TO CONSOLIDATED EDIS0N OF NEW YORK CONCERNING THE COMMISSI0t/S QUESTIONS 1, 2 and 5" and "NRC STAFF SECOND SET OF INTERR0GATORIES TO POWER AUTHORITY OF THE STATE OF NEW YORK.CONCERNING THE COMMISSI0tl5 QUESTIONS 1, 2 and 5" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 24th day of June, 1982.

. Louis J. Carter, Esq. , Chairman Paul F. Colarulli, Esq.

Administrative Judge Joseph J. Levin, Jr. , Esq.

Atomic Safety and Licensing Board Pamela 5. Horowitz, Esq.

7300 City Line Avenue Charles Morgan, Jr. , Esq.

Philadelphia, PA 19151-2291 Morgan Associates, Chartered 1899 L Street, N.W.

Dr. Oscar H. Paris Washington, D.C. 20036 .

Administrative Judge Atomic Safety and Licensing Board Charles M. Pratt, Esq.

U.S. Nuclear Regulatory Commission Thomas R. Frey, Esq.

Washington, D.C. 20555

• Power Authority of the State of New York Mr. Frederick J. Shon 10 Columbus Circle Administrative Judge New York, N.Y. 10019 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Ellyn R. Weiss, Esq.

Washington, D.C. 20555

• William S. Jordan, III, Esq.

Harmon & Weiss Brent L. Brandenburg, Esq. 1725 I Street, N.W., Suite 506 Assistant General Counsel Washington, D.C. 20006 Consolidated Edi' son Co. of New York, Inc. Jonathan D. Feinberg -

4 Irving Place New York State Public Service New York, N.Y. 10003 Commission Three Empire State Plaza Mayor George V. Begany Albany, New York 12223 Village of Buchanan 236 Tate Avenue Buchanan, N.Y. 10511 60k,

John Gilroy, Westchester Coordinator Stanley B. Klimberg Indian Point Project General Counsel New York Public Interest New York State Energy Office Research Group 2 Rockefeller State Plaza 240 Central Avenue Albany, N.Y. 12223 White Plains, N.Y. 10606 Marc L. Parris, Esq.

Jeffrey M. Blum, Esq. Eric Thorsen, Esq.

New York University Law School County Attorney, County of Rockland 423 Vanderbilt Hall 11 New Hempstead Road 40 Washington Square South New City, N.Y. 10956 New York, N.Y. 10012 t tion o  ; n a o nt Coordinator ,

The Port Authority of New York City Audubon Society New York and New Jersey 71 West 23rd Street, Suite 1828 One World Trade Center New York, N.Y. 10010 New York, N.Y. 10048 Greater New York Council on Ezra 1. Bialik, Esq. Energy Steve Leipsiz, Esq. c/o Dean R. Corran, Director Environmental Protection Bureau New York University New York State Attorney 26 Stuyvesant Street General's Office New York, N.Y. 10003 Two World Trade Center New York, N.Y. 10047 Honorable Richard L. Brodsky Alfred B. Del Bello Member of the County Legislature he r C6unty Executive stche ut ce u ding Westchester County q White Plains, N.Y. 10601 148 Martine Avenue '

White, Plains, New York 10601 Pat Posner, Spokesperson Parents Concerned About Andrew S. Roffe, Esq. Indian Point l New York State Assembly P.O. Box 125 Albany, N.Y. 12248 Croton-on-Hudson, N.Y. 10520 Ruthanne G. Miller, Esq. Charles A. Scheiner, Atomic Safety and Licensing Board Co-Chairperson Panel

. . Westchester People's Action U.S. Nuclear Regulatory Commission Coalition, Inc.

Washington, D.C. 20555

• P.O. Box 488 j White Plains, N.Y. 10602 l Honorable Ruth Messinger Richard M. Hartzman, Esq. -

i Member of the Council of the Lorna Salzman ._

l City of New York Friends of the Earth, Inc.

j District #4 208 West 13th Street City Hall New York, N.Y. 10011 ,

New York, N.Y. 10007 l

• Donald Davidoff Director Radiological Emergency Alan Latman, Esq. Preparedness Group 44 Sunset Drive Empire State' Plaza Croton-on-Hudson, N.Y. 10520 Tower Building, Rm. 1750 Albany, New York 12237 Zipporah S. Fleisher -

West Branch Conservation Renee Schwartz, Esg.

Association Paul Chessin, Esq. -

-443 Buena Vista Road Laurens R. Schwartz, Esq.

New City, N.Y. 10956 Margaret Oppel, Esq.

Botein, Hays, Sklar & Hertzberg Judith Kessler, Coordinator. 200 Park Avenue Rockland Citizens for Safe Energy New York, NY 10166 300 New Hempstead Road New City, N.Y. 10956 Amanda Potterfield, Esq.

Joan Holt, Project Director David H. Pikus, Esq. New York Public Interest Resear'ch Richard F. Czaja, Esq. Group, Inc.

330 Madison Avenue 9 Murray Street New York, N.Y. 10017 New York, New York 10007 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• David B. Duboff Westchester Peoples'., Action Coalition 4 A Safety and Licensing Appeal te ai NY 10601 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 * ,

Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission

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Henry J. McGurren Counsel for NRC Staff

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