ML19209A328
| ML19209A328 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/27/1979 |
| From: | PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML19209A316 | List: |
| References | |
| NUDOCS 7910030610 | |
| Download: ML19209A328 (7) | |
Text
s UMITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIt!G BOABD In the Matter of
)
)
PORTLAND GENERAL ELECTRIC COMPA!!Y, )
Docket No. 50-344
-et al.
)
(Control Building
)
Proceeding)
(Trojan Nuclear Plant)
)
ARGUMENT AND DOCUMENTATION IN SUPPORT OF MOTION FOR SUIDIARY DISPOSITION OF COALITIOt! FOR SAFE POWER'S CONTEtITION NO. 2 0 AIID CONSOLICATED INTERVENORF' CONTENTION NO. 11 I.
e Contentions At the prehearing conference on March 29, 1979, Coalition for Safe Power's Contention ?!o. 20 and Consolidated Intervenors' Contention No. 11 were conbined and rephrased.
(Tr. 3081-3083)
The contentio.s were then admitted (Tr. 3083) and read as follows:
Inadequate assessnent of the effects of drilling in the control building walls during modification has been made.
II.
Material Facts As To Which There Is !!o Genuine Issue To Be Heard A.
Precautions will be taken to avoid reinforcing steel during drilling in the walls of the Control Buildinge Even if reinforcing steel were encountered by the drill bit during the modification work, the damage would be limited to some polishing or, at most, a small nick and would not affect the shear capacity of the walls as determined by the flexure equation.
1910 030 ( /i G) 1086 053
. B.
Drilling in the Control Building walls during the modifica-tion work will not reduce the cross-sectional area on any plane through any wall by more than 6%.
Such small reduction will not make the shear mode of failure controlling and thus will not reduce the shear capacity of the walls.
C.
The pattern of bolt holes to be drilled in a wall will not reduce the shear capacity of any wall since the reduction ir. cross-sectional area on any plane will be insignifi mnt and since the bolt holes will not traverse the entire wall along any single plane.
Any partly drilled holc s which are abandoned because reinforcing steel is encountered will be grouted before a replacement hole is drilled.
D.
The effect of drilling on any existing cracks in the Control Building walls will not affect the strength of the walls, since any cracks where drilling might take place are hairline cracks which do not indicate a plane of weakness in the wall.
E.
Although it is not expected that any drilling would be done at an alleged crack identified in CFSP's Response to Staff's Interrogatory C20-4, any such drilling would have no effect on the shear capacity of the wall.
F.
Equipment attached or adjacent to the walls will be located by survey before drilling begins.
All holes to be drilled must be centered at least 9 inches from equip-ment attached to the wall and must be located so as to provide a 9 p of more than 2 inches between the wall 1086 054
. and any piece of adjacent equipment.
Such distances should preclude the drilling from contacting any equip-ment attached to or adjacent to the wall.
G.
As an additional precaution, workers will be assigned to monitor the area opposite the penetration and will be in direct communication with the drill operator.
Because of the drill's slow penetration speed and the drill operator's positive contrcl over the bit, a warning from the monitoring worker will be sufficient to prevent harn to adjacent equipment.
H.
Since the diamond-tipped drills will cut slowly and cleanly through the concrete, vibration and concrete frag-ments from the drilling will be minimal and will not affect equipment attached or adjacent to either side of the wall.
These material facts are supported in the attached affidavits of Dr. William H. White and Mr.
E.
W.
Edwards on Coalition for Safe Power's Contention No. 20 and Consolidated Inter-venors' Contention No. 11.
III.
Discussion The material facts listed above and the attached affi-davits of Dr. White and Mr. Edwards demonstrate that the effects of dril. ling in the Control Building walls have been completely analyzed.
At the prehearing conference CFSP and CI indicated that the primary thrust of their contention is concern over the effects of drilling necessary to perform the modification 1086 U,-,30
-4 vork on the scismic capacity of the walls in the Control Euild-ing.
Tr. 3081-3082.
Though CFSP's responset to Licensee's and NRC Staff's discovery requests are not entirely clear, it appears that CFSP believes that drilling could affect the seismic Japacity of Control Building walls in *he following 4triking the reinforcing steel bars (rebar) in the w.; :
wai.
with a drill bit could damage the rel-r; the pattern of holes te be drilled in a wall might weaken t.'
wall; there might be an adverse effect from abandoning drilled holes if rebar is encountered; and drilling on existing cracks in a Control Building wall could cause them to expand, weakening the walls.
CFSP is also concerned that drilling ir the walls could affect the equipment supported by the walls.
(See CFSP's supplemental responses to Licensee's Interrogatory 10 (First Set) and to NRC Staff's Interrogatory C20).
CI furnish 4 no useful infornation in response to discovery requests of Licensee and NEC Staff; nowever, it appears that its concerns are similar in nature to those of CFSP.-*/ (See CI's response to Licencee's Interrogatory 7 (First Set) and to FRC Staff Interrogatory Cll-1 to Cll-3).
- /
CFSP and CI have failed to identify any other concerns re-lating to this contention.
In response to Licensee's In-terrogatory 7 (First Set), CI indicated that it " questions the advisability of some of the suggested practices" described in Section 5.3.4 of PGE-1020 and believes that further anal-yses are needed to support "conclusory statements" in Section 5.3.4 of PGE-1020.
However, C1 wholly failed to respond to Licensee's Interrogatory 20 (Second Set) which requested specific information relating to those matters (notwithstanding the Board's Order of June 5, 1979, ordering it to respond to Licensee's Interrogatories).
1086.056 The affidavit of Mr. Edwards describes (paragraphs 6-8) the precautions that will be taken to avoid reinforcing steel during drilling in the walls and the limited effect on the reinforcing steel even if it were encountered by the drill.
As the affidavit of Dr. White shows (paragraph 5) the drilling to be done will not damage the reinforcing steel in Control Building walls so as to reduce their shear capacity.
The mass which will be removed from any wall by drilling will not reduce its shear area by more than 6 percent and thus will not have any effect on the shear capacity of the wall.
(White affidavit, paragraphs 6 and 7)
The pattern of bolt holes in any wall will not reduce the shear capacity of the walls.
(White affidavit, paragraph 8)
Should rebar be encountered while drilling, and another hole be started a few inches away, the previous hole will be grouted and there will be no adverse effect on the strength of the wall.
(White affidavit, paragraph 11)
With respect to the effects of drilling on existing cracks in Control Building walls, a visual inspection of the areas where drilling is to take place has confirmed that the only cracks in the vicinity of the drilling are so small that, even if drilling were to be done directly on them, the shear capacity of the wall would not be affected. / (White affidavit, paragraph 9) 7 In response to a discovery request by MRC Staff CFSP identified a crack in the Control Building wall as being one on which drilling could take place.
(Response to NRC Staff Inter.
atory C20-4)
The only crack to which CFSP could have been refer _.ng is marhedly different in dinension from that snecified by CFSP, and drilling thereon would have no effect on the wall's shear capacity.
(White affidavit, paragraph 10) 1086 057
. Mr. Edwards' affidavit (paragraphs 9-11) explains the measures which will be taken to preclude damage to equipment attached or adjacent to the walls during drilling and shows that the drilling will not affect any such equipment.
Thus, taken together, the affidavits demonstrate that the effects of drilling in the Control Building walls have been fully evaluated, and that the concerns of CFSP and CI with respect to the effects of drilling are without merit.
Since no factual issues have been raised by CFSP or CI which contradict the facts in the affidavits of Dr. White and Mr. Edwards, Licensee's motion for summary disposition related to CFSP's Contention No. 20 and CI's Contention No. 11 should be granted as a matter of law.
In addition, both CFSP and CI have failed to respond adequately to relevant interrogatories relating to these con-tentions. /
Moreover, CI is in clear default- / on the Licensing Board's Order of June 5, 1979, ordering it to respond to Licensee's interrogatories.
Therefore, with respect to CI, pursuant to 10 CFR S2.707 (a) the Board is entitled to " find.
the facts as to matters regarding which the order [ issued
-*/ Though CFSP did file responses to Licensee's Interrogatory 17 (Second Set) addressed to CFSP's Contention No. 20, those responses were in large measure inadequate, as pointed out in Licensee's Motion to Compel, dated June 11, 1979 and Licensee's Supplemental Motion to Compel, dated July 10, 1979.
Those motions are nov pending before the Board.
- /
CI has never responded to Licensee's Interrogatory (Second Set of Interrogatories) addressed to CI's Contention No. 11.
See Licensee's Motion to Dismiss Mina Bell and Consolidated Inter-venors, dated July 13, 1979.
1086 0~58 pursuant to S2.740] was made in accordance with the claim of the party obtaining the Order.
Thus, the Board should now find in favor of Licensee, and in a manner adverse to CI, as to the factual matters set out in the atfidavits of Dr. White and Mr. Edwards.
1086 059