ML19296D818
| ML19296D818 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/07/1980 |
| From: | LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL, PORTLAND GENERAL ELECTRIC CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19296D792 | List: |
| References | |
| NUDOCS 8003130279 | |
| Download: ML19296D818 (5) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PORTLAND GENERAL ELECTRIC COMPANY,)
Docket No. 50-344 ct al.
)
(Control Building
)
Proceeding)
(Trojan Nuclear Plant)
)
)
ARGUMENT AND DOCUMENTATION IN SUPPORT OF MOTION FOR
SUMMARY
DISPOSITION OF COALITION FOR SAFE POWER' S CONTENTION NO. 20 I.
The Contention At the prehearing conference on March 29, 1979, Coalition for Safe Power's Contention No. 20 was admitted to read as follows (Tr. 3083):
Inadequate assessment of the effects of drilling in the control building walls during modification has been made.
II.
Material Facts As To Which There Is No Genuine Issue To Be Heard A.
Precautions will be taken to avoid reinforcing steel during drilling in the walls of the Control Buildling.
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.
8003180'2,'] %
. B.
Drilling in the Control Building walls during the modification work will not reduce the cross-section-al 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 in cross-sectional area on any plane will be insignificant and since the bolt holes will not traverse the entire wall along any single plane.
Any partly drilled holes 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 equipment attached to the wall and must be located so as to provide a gap of more than 2 inches between the wall and any piece of adjacent equipment.
Such distances should preclude the drilling from contacting any equipment attached to or adjacent to the wall.
G.
As an additional ~ precaution, workers will be assigncd 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 control over the bit, a warning from the monitoring worker will be suffi-cient to prevent harm to adjacent equipment.
H.
Since the diamond-tipped drills will cut slowly and cleanly through the concrete, vibration and concrete fragments from the drilling will be minimal and will not affect equipment attached or adjacent to either side of the wall.
These material facts are suported in the attached affidavits of Dr. William H. White and Mr. Richard C. Anderson on Coalition for Safe Power's Contention No. 20.
III. Discussion The material facts listed above and the attached affi-davits of Dr. White and Mr. Anderson demonstrate that the effects of drilling in the Control Building walls have been completely analyzed.
At the prehearing conference CFSP indicated that the primary thrust of its contention is concern over the effects of drilling necessary to perform the modification work on th.a seismic capacity of the walls in the Control Building (Tr. 3081).
Though CFSP's responses to Licensee's and NRC Staff's discovery requests are not entirely clear, it appears that CFSP believes that drilling could affect the seismic capacity of Control Buildling walls in the fo'11owing ways:
striking the reinforcing steel bars (rebar) in the walls with a drill bit could damage the rebar; the pattern of holes to be drilled in a wall might weaken the wall; there might be an adverse effect from abandon-ing 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 in the walls could affect the equipment sup-ported by the walls.
(See CFSP's supplemental responses to Licensee's Interrogatory 10 (First Set) and to NRC Staff's Interrogatory C20).
The affidavit of Mr. Anderson describes (paragraphs 6-8) the precautions that will be taken to avoid reinfor-cing 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 (para-graph 5) the drilling to be done will not damage the rein-forcing 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 ares 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 affi-davit, 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.
(Anderson affidavit, paragraph 8; White affidavit, paragraph 11)
With respect to the effects of drilling on existing cracks in Centrol Building walls, a visual inspection of the area 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 affidavi?., paragraph 9)
Mr. Anderson's affidavit (paracraphs 9-11) explains the meesures 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 with respect to the effects of drilling are without merit.
Since no factual issues have been raised by CFSP which contradict the facts in the affidavits of Dr. White and Mr. Anderson, Licensee's motion for summary disposition related to CFSP's Contention No. 20 should be granted as a matter of law.
- /In resporse to a discovery request by NRC Staff, CFSP identified a crack in the Control Building wall as being one on which drilling could take place.
(Response to NRC Staff Interrogatory C20-4)
The only crack to which CFSP could have been referring is markedly different in dimension from that specified by CFSP, and drilling thereon would have no effect on the wall's shear capacity.
(White affidavit, paragraph 10)