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WTED CORRESPONDENCE' pi;i D

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UNITED STATES OF AMERICA a.NUCLEAR REGULATORY COMMISSION

,91 ,, ,, l 9 n ,, .dL

DEFORE THE ATOMIC SAFETY AND LICENSING DOARD

)In the Matter of ) Nos. 50-528-OLA, 50-529-OLA-2

) and 50-530-OLA-2

ARIZONA PUBLIC SERVICE )COMPANY, et al. ) (Allowable Setpoint Tolerance)

)(Palo Verde Nuclear Generating ) ASLBP No. 91-633-05-OLA-2Station, Units 1, 2 and 3) )

)

PETITIONERS' FIRST SET OF INTERROGATORIESAND REQ _UESTS FOR PRODUCTION OF DOCUILENTS

Petitioners Allan L. Mitchell and Linda E. Mitchell hereby

serve their First Set of Interrogatorios and Requests for

Production of Documents to Licensees, Arizona Public Service Co. ,

et al. (" Licensees" or "APS"), pursuant to 10 CFR SS 2.740b and.

2.741.

General Instructions

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 Licensees after exercising due

diligence, cannot answer any portion of any of the interrogatoriesin full, Licensees shall so state, shall answer the interrogatories

to the extent possible, shall explain in detail the inability ofthe Licensees to answer the remainder of the interrogatories, and

shall state when Licensees expect to be able to answer any

unanswered portions.

9108270132 910815PDR ADOCK 05000528 3O PDR 90

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This discovery request is deemed to be continuing, and any |i

other additional information which is discovered and responsive to |!

this request requires supplementation to these answers, up to and i

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including the time of the hearing in this proceeding. !!

The word " leg" in the following interrogatories refers to the

two legs of the Contention, as identified by the Licensing Board.- ji

The word " basis" in the following interrogatories means an ,

explanation _-of the Licensees' rationale, including identification|

of specific books, reports, papers, studies, data, analyses, fcalculations, expert opinions or other documents or statements of }

!!potential witnesses that Licensees may rely upon.!

The word " identify" for-a document means the date, author, ;

i

title, and specification of pertinent page or pages. For a person I

it means full name, address, job title, and telephone number.

The_ word "setpoint" means the normal pressure at which ar

-safety valve is set to actuate or " lift". The word "liftpoint" i|

means the pressure at which a safety valve actually lifts, as !'

L demonstrated in periodic tests of the-safety valve. .

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The word " document" shall mean every writing of every type and |7

description, and every other instrument or device by which, through =|

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which or on which information has been recorded and/or preserved, ;

including but not__ limited to memoranda, including those reflectingi

meetings, discussions or conversations, notes, letters, drawings, [;

files, graphs, charts, maps, photographs, deeds, agreements, |;

contracts, handwritten notes, diaries, logs, ledgers, studies, data !

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sheets, notebooks, books, receipts, vouchers minutes of meetings, ;:

pamphlets, computations, calculations, accounting (s), financial jt!

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statements, voice and other data compilations, devices or media on

which or through which information of any type is transmitted,

recorded or preserved. The term " document" also means every copy

of a document when such copy is not an identical duplicate of the

original.

Interrogatories and Document Requests

1. Identify each person Licensees 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 designatedas an expert witness; and provide a summary of the witness's

anticipated testimony in this proceeding.

2. Identify. all books, reports, papers, studies, analyses,

calculations and other documents that Licensees intend to rely

upon in this proceeding, whether for purposes of exhibits,direct examination, cross-examination, or for any other

purpose. For each such document, identify the specific

portions relied upon, summarize the purposes for which thedocument is relied upon, and produce the- documents for

copying.

3. Regarding Licensee's November 13, 1990 Application for

amendment of the Technical Specifications ("The Application") ,

the Palo Verde Updated Final Safety Analysis Report, or any of

the references cited therein; identify all documents, books,

reports, studies, analyses, calculations, experts or otherbasis relied upon by Licensees in support of their position.

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4. Identify the basis for Licenscos' 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, statchients or witnesnes orexpert opinion that support Licensecs' assumption.

5. State how licensees will be able to comply with the proposed

HPPT response time of less than or equal to 0.5 seconds? If

co, identify all documents, books, reports, papers, studies,

analyses, calculacions, or export opinions relied upon byLicensees in support of their position.

6. For each study, calculation, and analysis mentioned in

response to these Interrogatories, identify and produce for

copying all documents that describe the assumptions,

methodologies or results of such studies, calculations oranalysis..

(1)'. Identify all persons who were involved in conducting such

studies, calculations or analysis and describe each such

person's contribution thereto.

7. For all data mentioned 'in response to Interrogatory 6,

identify the source of such data and identify and produce for1

copying all documents that describe the time, place and method

of collection of such data.

8. Identify all persons who have personal knowledge of the basis

for the Application.

9. Identify any studies, calculations, analyses or data, other

than those referenced which show the effects of PSV setpoint

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drif t on - pressures resulting from a LOCV.

10. For each study,- calculation, and analysis mentioned in

response to Interrogatory 9, identify and produce for copying i

all documents that describe the accumptions, methodologies or f?

results of such-studies, calculations or analysis.

I(1). Identify all persons who were involved in conducting such,

'studies, calculations or analysis and describe each such

person's contribution thereto, ,

11. For all data mentioned in response to Interrogatory 9,,

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 ane m.uthod of collection of such data.'

12. Have Lic< nsees reviewed any LERs filed by Licensees regarding

PSV or MSSV setpoints? If so, answer the following: {-

[A] Identify all such LERs reviewed by Licenscos. !!

(B) Do any of those LERs show 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-conclusion.

f (c) Produce for copying all LERs reviewed and/or -identified. }!

13. Have Licensees filed any LERs regarding PSV or'MSSV setpoints

between 1989 and the present? If so, answer the following:

(A) Identify all such LERs filed by Licensees. .

(B) Produce for copying all such LERs filed by Licensees..

- 13. Explain Licensecs' position regarding testing frequency. As

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part of the explanation identify and produce for copying alldocuments that describe any commitment, study, calculation or

analysis that supports sucn position. Identify all persons

who were involved in conducting such commitments, calculations

or analyses and describe each such person's contribution

thereto.

14. Have the Licensees in the past committed to the imC that they

will test all MSSV's and/or PSV's once per refueling cycle

(approx. every 18 mos.)? If so, answer the following:

(1). When was such commitment made?

(ii). Explain all reasons why such commitment was made

and the complete basis for such commitment?

(iii). Identify all persons who were involved in making

such commitment?

(iv). Produce for copying all documents that describe

such commitment and any study, calculation,

analysis or other basis related to such commitment.

15. Have-the Licensees determined that they will no longer' test

all MSSV's and/or PSV's once ~per refueling cycle (approx.

every 18 mos.)? If so, answer the following:

(1). When was such determination made?

-(11). Explain all reasons why such determination was made

and the complete basis for such determination?

(iii). Identify all persons who were involved in making

such determination?

(iv). Produce for copying all documents that describe

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such a determination and any study, calculation,

analysis or other basis related to such a

determination.

16. Do Licensees contend that drift in the MSSVs in the positivo

direction (beyond the proposed maximum tolerances) would not

have a significant impact upon the RCS peak pressure in the

event of a LOCV? If so, identify the basis for this position

and any studies, calculations, analyses, references, or

statements of experts that Licensees may rely upon in support

of this position.

17. Do Licensees coatend that drift in the MSSvu in the negativo

direction would not cause a safety limit violations? If so,

explain the basis for this contention and identify any

studies, calculations, analyses, references, or statements of

experts that licensees may rely upon in support of this

-position.

18. Do Licensees believe that the proposed reduction in the

auxiliary feedwater ("AFW") flowrate from 750 gpm to 540 gpm-

would have any affect upon the pressures in the event of a

LOCV? If so, explain the basis for this belief. 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 person who were involved in

conducting such studies, calculations or analyses and descri"e

each such person's contribution thereto.'

19. Produce for copying all documents that contain test results

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for each test of the MSSV's and PSV's from 1989 to present. f1

i20. Produce for copying all documents that contain MSSV and PSV

maintenance and test procedures between 1989 and present. f

21. Produce for copying all EER's, PCR's, PRO's related to the {!

design, testing and maintenance of MSSV's and PSV's between a

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1989 and present.

22. Produce for copying all industry and regulatory bulletinsreceived by the Licenscos concerning the design, testing and i

maintenance of MSSV's and PSV's between 1989 and the present.

23. Produce for copying all documents identified or relied upon in

answering these interrogatories.

24. Separately for each response von to every one of these

interrogatories, identify the person, other than counsel,

responsible for providing the information for, or formulating

a such response and identify each document relied on in

formulating such response.

Respectfully submitted,i-

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|David K.i dolapipfo /

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Kohn, Kohn &_Colapinto, P.C.517 Florida Avenue, N.W.Washington, D.C. 20001(202) 234-4663

Counsel for Petitioners

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August 15, 1991

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UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION

'91 E' 19 P 3 56

)In the Matter of ) Nos. 50-528-OLA-2, 50-529-OLA-2

) and 50-530-OLA-2 ',

ARIZONA PUBLIC SERVICE )COMPANY, et al. ) (Allowable Setpoint Tolerance)

)

(Palo Verde Nuclear ) ASLB No. 91-633-05-OLA-2Generating Station, )Units 1, 2 and 3) )

)

CERTIFICJ_T_E OF BERVICE

I hereby certify that on August 15, 1991, copies of" PETITIONERS' FIRST SET OF INTERROGATORIES AND REQUESTS FORPRODUCTION OF DOCUMENTS" in the above-captioned proceeding wereserved, by first class mail, postage prepaid, except Counsel forLicensees, who was served by hand delivery.

U.S. Nuclear Regulatory CommissionAtomic Safety and licensing Board PanelAdjudicatory FileU.S. Nuclear Regulatory CommissionWashington, D.C. 20555(two copies)

Office of the SecretaryU.S. Nuclear Regulatory CommissionWashington, D.C. 20555

Attention: Chief, Docketing and Service Section(Original plus two copies)

Administr0tive Law JudgeIvan W. Smith, ChairmanAtomic Safety and Licensing BoardU.S. Nuclear Regulatory CommissionWashington, D.C. 20555

Administrative JudgeJerry R. KlineAtomic Safety and Licensing BoardU.S. Nuclear Regulatory CommissionWashington, D.C. 20555

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Administrative JudgeWalter H. Jordan ,

Atomic Safety and licensing Board !|883 West Outer Drive I

Oa1 Ridge, TN 37830

Edwin J. Reis, Esq. [

Lisa B. Clark, Esq.Office of General CounselU.S. Nuclear. Regulatory Commission !-

Washington, D.C. 20555 |?.

Nancy C. Loftin, Esq.Corporate Secretary and Corporate Counsel :

Arizona Public Service Company-'

P.O. Box 53999Mail Station 9068 ;

Phoenix, AZ 85072-3999 )!.

Alvin H. GuttermanHowman & Holtzinger, P.C.Suite 1000 ;

,

1615 L Street, N.W. ;

Washington, D.C. 20036 e

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David K. jofapinto V [Kohn, Kohn & Colapinto, P.C. ,

517 Florida Ave., N.W. i

Washington, D.C. 20001 |(202) 234-4663

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August 15, 1991

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