ML20054H890

Second Set of Interrogatories Re Commission Questions 1,2 & 5

ML20054H890
Person / Time
Site:	Indian Point
Issue date:	06/24/1982
From:	Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	CONSOLIDATED EDISON CO. OF NEW YORK, INC.
Shared Package
ML20054H891	List: ML20054H890 ML20054H894
References
ISSUANCES-SP, NUDOCS 8206250144
Download: ML20054H890 (5)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEf1 SING BOARD In the Matter of )

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CCriS0LIDATED EDIS0N COMPANY ) Docket flos. 50-247-SP 0F flew YORK (Indian Point, Unit 2) ) 50-286-SP

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POWER AUTHORITY OF THE STATE OF ) June 24, 1982 NEW YORK (Indian Point, Unit 3) )

NRC STAFF SECOND SET OF INTERR0GATORIES TO CONSOLIDATED EDISON COMPANY OF NEW YORK CONCERNING THE COMMISSION'S QUESTIONS 1, 2 and 5 INTRODUCTION The itRC Staff hereby requests that Consolidated Edison Company (Con Edison) 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.

I INSTRUCTIONS AND DEFINITIONS l

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

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

l e o ume re be n p e e or re er e j requested in these interrogatories, identify them by author, title, date 8206250144 820624 Ol PDR ADOCK 05000247 I O PDR

.2-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 f

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 -

require prompt supplemental answers should Con Edison obtain or identify I _. ._

supplemental infonaation or documents which call into question the correctness of earlier answers.

9. In the event any word, term, or phrase is unclear to Con Edison 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 Con Edison, 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 o

originals thereof are not in the possession, custody or control of Con Edison.

INTERROGATORIES Interrogatory 1 i

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 capacity.

l Interrogatory 2 ,

! Have uncertainties due to design and construction errors been -

i 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) provice the detailed basis for the development of masonry wall fragilities for both strengthened and non-strengthened cases.

Interrogatoryl 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 f pipeline gas fire which threatens the plant is about 5 x 10,9 aThis 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 ventilation intakes.

Interrogatory 10 It is stated in Section 7.9.2 of the IPPSS that log-normal distribution is & good mathematical representation to describe observed sustained-accpleration. 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

fragility 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,

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.Q+ (' j" Hen J. McGurren Counsel for NRC Staff Dated at Bethesda, Maryland this 24th day of June, 1982.

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