ML19326B099
| ML19326B099 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 01/18/1971 |
| From: | Charnoff F, Charnoff G CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE, TOLEDO EDISON CO. |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8003060904 | |
| Download: ML19326B099 (9) | |
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- UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of -
)-l. '9 l THE TOLEDO EDISON COMPANY and THE CLEVELAND ELECTRIC ILLUMINATING CC aANY Docket No. 50-346 Davis-Besse Nuclear Power Station APPLICANTS' REPLY TO MOTION FOR PRODUCTION OF DOCUIENTS AND TO INTERROGATORIES TO
. APPLICANTS SERVED BY INTERVENORS LIVING IN A FINER ENVIRONMENT, IRWIN I. OSTER AND WILLIAM E. REANY ON JANUARY 12, 1971 t
I. Motion for Production of Documents
- 1. On January 5,1971, the Atomic Safety and Licensing Board
(" Board") granted interve .or status to Irwin I. Oster, William E. Reany and Living in a Finer Environment (collee-tively referred to herein as " LIFE") based on LIFE's December 26, 1970, motion for reconsideration of the i Board's denial of LIFE's previous late petition for leave to intervene. In its supporting memorandum, LIFE asserted that it does "not intend duplication of other intervenors'
^
efforts" (pages 10.and 14). The only two matters in con-troversy proposed by LIFE in its supporting memorandum re-lated to contentions by LIFE that:
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(a) the present proceedings violate the National Environ-mental Policy Act of 196o, and (b) the present radiation protection sbandards are not within the Commission's authority and are not a reasonable exercise of the broad discretion given the AEC by.the Atomic Energy Act of 1954, as amended.
- 2. The Board admitted LIFE for the limited purpose of con-sidering contentions (a) and (b) above and determined that (a) is " essentially a matter of legal considera-tion" to be briefed by the parties without any intro-duction of evidence (tr. 618-620) and that LIFE may present evidence as to (b) consistent with the Commis-q sion's memorandum in the Calvert Cliffs proceeding in AEC Docket Nos . 50-317 and 50-318 (tr. 611) . The Board further stated:
"In accordance with the regulations of the Commission and in the interest of an orderly proceeding, direct evidence, cross examination, motions for discovery, motions for depositions, proposed findings of fact and conclusions of law and similar oppor-tunities afforded Intervenors are to be confined to those contentions determined by the Board at the time of admission to the proceeding to have been properly raised by that Darticular Intervenor."
(tr. 763).
3 On January 12, 1971, LIFE served on Applicants a Motion for Production of Documents pursuant to sectio'n 2 741'of the Commission's Rules of Practice, and a Supporting Memorandum, requesting twenty-nine documents or categories
9 of documents. In support cf the motion, LIFE implicitly acknowledged that all or part of the documents requested may not be relevant to the matters put in controversy by its participation in the hearing, and may be relevant only to the contentions of other parties to the proceeding, in that LIFE cites a portion of section 2.741 suggesting that the documents to be produced may relate to "the claim or defense of the examining party or to the claim or defense of any party. " It need only be observed that section 2.741 provides that the movant for the production of documents must show good cause for the production of the documents and that the Commission may, but is not required to, order the production of documents rega rding any matter that is relevant to the subject matter involved in the pending action. Section 2.741(b) further requires that the evidence sought must be reasonably calculated to lead to the discovery of admissible evidence. To be admissible such' evidence must be relevant to the matters in con-
-troversy in the instant proceeding. Thus, if the docu-ments do not relate to matters in controversy, they need not be produced.
- 4. In its Supporting Memorandum, LIFE asserts with respect to the. documents' designated in items 1 through 8, which are all identified as Babcock & Wilcox documents:
"By examining these documents LIFE and its expert witnesses will be able to understand the Applicants ' contentions as to safety pre-cautions and engineered safety devices that have been utilized in the design of this L
4 . 1 plant. There documents should clarify the extent to which .there is scientific basis for the App 1f. cants ' intended design. "
The contents of the documents designated in items 1 through 8 are desceibed in the affidavits attached here-
. . to as Appendix A. It is clear -that such documents are not relevant to LIFE's contentions.
5 With respect to the documents designated in items 9 through 12, LIFE asserts:
"In terms of safety and compliance with justifiable radiological production [ sic]
standards there is a question raised =as to the nature and adequacy of the pro-posed' reactor design. Items 9 through 12 and other items listed herein relate to the design of the proposed reactor, especially those parts most heavily subjected to rediation, and for the associated structures, as well as the nature and quality of the fuel."
The contents of these documents are described in the affi-davits attached hereto as Appendix B. They are not relevant in any respect to LIFE's contentions. LIFE's contention (b) is solely related to the validity of the Commission's radiation protection standards. It does not include any question with respect to the ability of the proposed reactor design.to assure compliance with such standards.
- 6. With respect to item 13, LIFE asserts that:
" Tritium concentration levels have been referred to but not fully dis-cussed by the Applicants in response to the AEC questions at the prehearing.
It is expected that further clarifica-tion will be obtained from the report i requested in item 13."
l i
Presumably LIFE was referring to Applicants' response to question number 1 asked by the Board at the prehearing conference. That answer states that, "During station operation, a sampling network will be set up to monitor local tritium background levels. At this time, however, no record of Lake Erie background determination has been made." The request by LIFE in item 13 is not sufficiently specific to allow a positive response by the Applicant.
Furthermore, as noted in Applicants' above quoted response, the applicant has no records available of Lake Erie back-ground tritium levels.
- 7. With respect to item 14, LIFE states:
"Much of the Applicants ' contention con-cerning the safety of the propos.ed plant depends upon the Ph.D. thesis referred to in Amendment 5 to Volume 1 of the PSAR. This thesis, however, was not yet completed at the time the Amendment was prepared. Since crucial aspects of the public health and safety depend upon the conclusions drawn in this unfinished Ph.D. thesis, the thesis
- in its final form should be 'adem avail-able for further evaluation and study by this intervenor and by its expert witnesses." ;
The PhD thesis'is referenced at the end of Amendment No. 5 to the PSAR which is. a description and progress report of the comprehensive limnology study undertaken for the Applicants by the Great Lakes Research Division, Institute of Science and Technology at the University of Michigan.
The purpose of the 11mnology study is to gather lake data which will be used to establish certain station design 1
)
4 criteria such as flood protection criteria. The PhD thesis involves the -evaluation of Fontocoreia affinis, a benthic amphipod native to Lake Michigan, as a monitor of radio-nuclides found in radioactive wastes. This information will be -considered in designing the radiological environ-mental monitoring program. The safety of the proposed plant obviously does not depend upon the PhD thesis.
- 8. LIFE' asserts that items relating to studies of the need for power and feasibility of alternative sources of power (presumably referencing items 15 and 16), "directly bear on the question of whether on balance this plant is suffi-ciently safe to justify its construction at this time and are therefore relevant and important to this intervenor's preparation." This assertion patently is not true and does not provide good cause for the production of such documents. Furthermore-the documents contain no material relevant to LIFE's contention (b), the only matter contro-verted by LIFE with respect to which evidentiary material is appropriate. Item 16 is the subject of an affidavit attached hereto as Appendix C.
9 Nothing is said in LIFE's supporting memorandum justifying the production of items 17 through 29 other than perhaps the general statement on the last page of the memorandum which states that ."[a]11 of the items requested are directly related to the issues in contention and are I
l 1
needed by this intervenor to prepare its case." (Items 18 and 20 are the same as items 8 and 7 respectively.)
Thus there is no showing of good cause for the production 4
of such documents as required by section 2.741 of the Com-mission's Rules of Practice. The contents of the documents identified in these items are attached hereto as Appendix D. None of these documents bear any relevance to the matters placed in controversy by LIFE.
- 10. Item 29 is a broad request for any of the documentation underlying the conclusions stated in the PSAR. Applicants have no way of responding to this vague request and are unable to interpret this request in relation to the matters controverted by LIFE in this proceeding. '
- 11. In view of the foregoing, Applicants object to LIFE's motion for the production of documents except as it relates to the documents designated in items 14 and 15 both of which are being made available to LIFE without waiver of any objection by Applicants to their relevancy to the matters controverted in this proceeding by LIFE.
II. Interrogatories to Acolicants
- 12. Accompanying _ LIFE's Motion for Production of Documents was a document entitled " Interrogatories to Applicants" con-sisting_of a list of 52 questions which LIFE directed be answered under oath by_r.ppropriate person or persons designated by the hpplicants. ;
"- B
- s 13 The request for interrogatories is deficient in that it was not filed in the form of a motion to the Board re-questing an order that the Applicants' deposition be taken by written interrogatories, as required in section 2.740 of the-Commission's Rules of Practice. More impor-tantly, by failing to file such a motion along with a supporting memorandum or brief, LIFE has not shown good cause why such interrogatories should be ordered, as 1 required by section 2.740. Good cause at a minimum would require that LIFE nust disclose the relevance of the pro-posed questions to the matters in controversy in this proceeding. LIFE has failed to offer any such showing
,. of relevance.
- 14. With the possible exception of interrogatories 17, 18, 19 and 21, all of the interrogatories addressed to the Appli-cants are patently not relevant to the matters controverted by LIFE and Applicants respectfully object to such irrelevant
' interrogatories. Applicants are responding to interrogatories 17, 18, 19 and 21 without waiver of any objection by Appli-cants to their relevancy to the subject matter involved in 1
the hearing.
15 If the Board wishes, the Applicants are prepared to intro-duce answers to LIFE's irrelevant interrogatories as if such questions were asked by limited appearors in this
r Nag proceeding, and Applicants would do so when they reply to--the limited appedrors at the conclusion of the hearing.
Respectfully submitced, SHAW, PITTMAN, POTTS, TROWBRIDGE & MADDEN By IAA ( t1 5 ,
Gerald Charnoff [{/
Counsel for The Toledo Edison Company Dated January 18, 1971 G
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,__ , . Appandix A UdITEDSTATES0FAMERICA Itern 1
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,3 - ATOMIC r'UERGY COIGISSION I
w
-In the Matter of )
)
THE TOLEDO EDISON COMPANY. )
)
and ) Docket No. 50-3h6
)
THE CLEVELAND ELECTRIC ILLUMINATING C0!?ANY ) ,
, , -)
' Davis-Besse Nuclear Power Station )
AFFIDAVIT I, William S. Little, being first duly.sovrn, depose and say that;
-1) 'I am the Babcock & Wilcox Company's Licensing Supervisor for the Toledo Edison contract.
- 2) I am fully ' knowledgeable with the centent of Eabcock & Wilcox Company document BAW-10009, "Effect of Fuel Rod Failure en Emergency Core Cooling Effectiveness".
- 3) Babcock & Wilcox Company document BAW-10009, "Effect of Fuel Rod Failure on Emergency Core Cooling Effectiveness $' , contains only the folleving information:
a) Analytical investigation of the effect of fuel rod failure at three levels of cceplexity: single channel, single fuel assembly, and the entire core, b) Research and development test results used to substantiate the models and the geometry used in the analysis of post-LOCA reactor core cooling.
c) Conclusion that neither analysis nor tests have revealed any potential 4
fuel failure mechanisms, that would prevent adequate cooling of the core following a LOCA. ,?
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Appandix A Ite m 2 UNITED STATES OF AIERICA
,/
ATOMIC ENERGY C01C4ISSION m
In the-Matter of )
)
THE TOLEDO EDISOU COMPANY ) ,
)
and ) Docket No. 50-346
)
THE CLEVELAND ELECTRIC ILLUMINATING COMPANY )
)
Davis-Besse Nuclear Pcuer Station )
. AFFIDAVIT I, William S. Little, being first duly sworn, depose and say that;
- 1) I as the Babcock & Wilcox Company's Licensing Supervisor for the Toledo Edison contract.
- 2) I am fully knowledgeable with the content of Babcock & Wilcox Company document BAW-100lk, " Analysis of Sustained Departure from Uncleate Boiling Operation".
- 3) Babcock & Wilcox Ccapany document BAW-1001h , " Analysis of Sustained Departure from Hucleate Boiling Operation", contains only the following informaticn:
s) A su': mary of the thermal-hydraulic methods used to investigate the -
effects of the postulated sustained operation of a reactor fuel pin at departure from nucleate boiling conditiens, b) A discussion of the results of the analyses for sustained DNB operation.
c) An evaluation of the results relative to the possibility of fuel pin damage or DNB propagation.
William S. Little Sworn to before me and subscribed in my presence this / day of January,1971.
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Notary Public f f ty Commissbn Exp;res 03hr 11, lh72 A M i OQ
Appendix A
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.- UNITED STATES OF A! ERICA
=?
ATOFEC EIIERGY COIMISSION In the Matter of )
THE TOLEDO EDISOU COMPANY )
and ) Docket No.50-34o THE CLEVELAND ELECTRIC ILLUMINATING COF'PANY )
Davis-Besse Nuclear Power Station AFFIDAVIT I, Willian S. Little, being first duly sworn, depose and say that;
- 1) I a= the Babcock & Wilcox Company's Licensing Supervisor for the Toledo Edison contract.
- 2) I am fully knowledgeable with the content of Babcock & Wilcox Company document BAW-10018, " Analysis of the Structural Integrity of a Reactor Vessel Subjected to Thermal Shock".
- 3) Babcock & Wilcox Company docunent BAW-10018, " Analysis of the Structural Integrity of a Reactor Vessel Subjected to Thernal Shock", centains cnly the following information:
a) A description of the thermal, hydraulic and stress analyses perforced for a Babcock & Wilcox PWR vessel during thermal shock induced by emer6ency core cooling system operatien following a postulated loss-of-coolant accident, b) A discussion of the results obtained frcn the analyses and en evaluation of the structural integrity of the reactor pressure vessel based on these results, ,,,' '
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. Appendix A
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Item 4,; Part 1
-UNITED STATES OF AMERICA ,
ATOMIC ENERGY COMMISSION
'In the' Matter of )
.. )
-THE TOLEDO EDISON COMPANY )
)
and ) Docket No. 50-346
)
THE CLEVELAND ELECTRIC ILLUMINATING COMPANY
)
)
' Davis-Besse Nuclear Power Station )
AFFIDAVIT I, William S. Little, being first duly 'svorn, depose and say that;
-1) I am the Babcock & Wilcox Company's Licensing Supervisor for the Toledo Edison contract.
- 2) I-am fully knowledgeable with the content of Babcock & Wilcox Company document BAW-10006, Part 1, " Reactor Internals Stress and Deflection Due to Loss-of-Coolant Accident and Msximum Hypothetical Earthquake" .
- 3) Babcock & Wilcox Company document BAW-10008, Part 1, " Reactor Internals Stress and Deflection Due to Loss-of-Coolant Accident and Maximum Hypo-thetical Earthquake", contains only the folleving information:
a) Bases for calculating loads and allevable stresses on the reactor internals.
b) Reactor vessel dynamic model end enalytical methods used for internals stress analysis.
c) Conclusion that internals can withstand the combined effects of an earthquake and a loss-of-coolant accident. ,
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. ,ht $4m [kff~'5D William S.' Lit'tle Sworn to before me and subscrit d in my presence this / Y da-/ of January,1971.
L L O 14 4 Aud Notary Public M r M A My Commissica Egrcs Octeer 11,,19Q,
,. . Appendix A
. Item 4, Part 2 CIITED STATES OF A! ERICA
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- - - ATOMIC EllERGY CO?GIISSION In the Matter of )
)
THE TOLEDO EDISCN COMPA'TY )
)
and ) Docket No. 50-3h6
)
THE CLEVEIRID ELECTRIC ILLL7IINATING COMPANY )
)
Davis-Besse Nuclear Power Staticn )
AFFIDAVIT I, William S. Little, being first duly svern, depose and say that;
- 1) I am the Babcock & Wilcox Cc=peny's Licensing Supervisor for the Toledo Edison contract.
- 2) I am fully kncvledgeable with the content of Babcock & Wilcox Company document EAW-10008, Part 2, " Fuel Assembly Stress and Deflection Analysis for Loss-of-Coolant Accident and Seismic Excitation".
- 3) Eabcock & Wilcox Cc=pany docu c.2nt EAW-10008, Part 2, " Fuel Assembly Stress and Deflection Analysis for Loss-cf-Coolant Accident and Seismic Excitation",
contains only the follcuing infornation:
a) Description of the reactor vessel and internals with a detailed descrip-tion of the fuel assembly and the structural design criteria.
b) Discussion of nodels used in analysis of the fuel assembly and the tests conducted to verify these models.
c) Conclusion that the fuel assenblies can withstand a LOCA, the cc=bined effects of a LOCA and a design basis earthquake (DEE), a DBE, and an operational basis earthquake without exceeding the respective allevable f limits.
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William S. Little Sworn to before te and subscribed in my presence this ^ 's/ day of Jenuary ,1971.
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Appendix A Itsm 5 7
Uti1TED STATEC OF Airdli1CA ATOMIC FRE'.tCY C0!"IIGG30:1 In the 14atter of )
)
Tile TOLEDO EDICO:! COYTA IY )
)
ar.d ) Dochet I!o 50-3L6
)
TIIE CLEVEL/dlD ELECTRIC ILLU'41I!ATII G COIT/JiY )
)
Davis-Besce Iluelcar Pover Station )
AFFIDAVIT I, William S. Little, being first duly sworn, depose and say that;
- 1) I cra the Babcock & Wilcox Company's Licencing Supervicor for the Toledo Edison contract.
- 2) I am fully knowledgeable vith the content of Babcock & Wilcox Comp:.ny .
document EAU-1333, " Scoping Study - The Problem of Prempt Detection of Grocs Fuel Failure". ;
I
- 3) Eabcock & Wilcox company document BAW-1338, "Scopinc Study - The Preblem of Prompt I:etection of Crces Fuel FailuFe", containe caly the fellowin.;
information:
c) Calculation of pessible primary ecolant activities which could occur as a result of defective fuel.
b) An evaluation of the ability to detect these coolent activity levels during normal reactor operation.
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Uillion G. Little Sworn to before me ma subscribed in my presence thin ! '
day of January ,1971. )
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Hotary PebJ ie, Thomas L. Catha My Commission Expires July 1, 1974.
t Appendix A NITED STATES OF AMERICA Ite m 6 X;.. .
ATOMIC ENERGY COMMISSION
- ?
& In the Matter of )
THE TOLEDO EDISON COMPANY )
and ) Docket No. 50-346 THE CLEVELAND ELECTRIC )
ILLUMINATING COMPANY )
Davis-Besse Nuclear Power Station )
AFFIDAVIT I, William S. Little, being first duly sworn, depose and say that;
- 1. I am the Babcock & Wilcox Company's Licensing Supervisor for The Toledo Edison contract.
- 2. I am fully knowledgeable with the content of the Babcock &
Wilcox Company s+udy being performed to evaluate anticipated reactor transients without reactor trip.
- 3. This work has not been completed and therefore a report on the subject has not been written. The work now in progress includes the analysis of the following transients assuming no reactor trip:
- a. Loss of load
- b. Load increase
- c. Loss of feedwater
- d. Loss of primary flow
- e. Tota 11oss of offsite power
- f. Inactive loop startup
- g. Rod withdrawal at zero power
- h. Rod withdrawal at full power
- i. Opening of the largest single primary system valve
- j. Control rod maloperation
- k. Boron dilution
- 1. Loss-of-coolant resulting from a small line break Sworn to before me and subscribed in my presence this 15th day of
' January, 1971.
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l William S. Little Thomas L. Catha, Notary Public l l
My Commission Expires July 1, 1974. l l
Appandix A Item 7
. UHITED STATES OF AIERICA AT0!GC ENERGY COMUSSION In the Matter of )
)
THE TOLEDO EDISON ColTANY )
)
and ) Docket No. 50-3k6
)
THE. CLEVELAND ELECTRIC ILLUMINATING C0!&ANY )
)
Davis-Besse Huclear Power Station )
AFFIDAVIT I, William S. Little, being first duly svorn, depose and say that;
- 1) I am the Babcock & Wilcox Company's Licensing Supervisor for the Toledo Edison contract.
- 2) I am fully knowledgeable with the content of Babcock & Wilcox Company document BAW-10006, " Reactor Vessel Material Surveillence Program".
- 3) Babcock & Wilcox Company document EAW-10006, " Reactor Vessel Material Surveillance Program", centains only the following information:
a) A description of the reactor vessel material specimen requirements including a discussion of specimen source, preparation, identification
.and dosimetry, b) A discussion of the design of the surveillance capsules and specimen holders with a description of the supporting design analyses.
c) A su==ary of the integrated surveillence program with emphasis on the integrated withdrawal schedules and disposition of withdrawn specimens.
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'..T 1 2 l:6:, . W ?,.h D William S. Litf,le Sworn to before me and subscribed in my presence this /*'/ day of January,19 (1.
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Hota / Fublic My Commisba Spires Omtn 11,1972 9 e bct h-Qf: M
Appendix A Ite m 8 UNITED STATES OF AFERICA ATOMIC ENERGY C0:MISSIO?i In the Matter of )
)
THE TOLEDO EDISCU COMPAIIY )
)
and ) Docket No. 50-346
)
THE CLEVELAND ELECTRIC ILLUMINATI:!G COMPAIlY )
)
Davis-Besse Nuclear Power Station )
AFFIDAVIT I, William S. Little, being first duly swcrn, depose and say that;
- 1) I am the Babcock & Wilcox Company's Licensing Supervisor for the Toledo Edison contract.
- 2) I am fully knowledgeable with the content of Babcock & Wi!.cox Ccmpany document EAW-10002, "Once-Throu6h Steam Generator Research and Develep-ment Report."
- 3) Babcock & Wilcox Ccapany document BAW-10002, "Once-Through Steam Generator Research and Development Report", centains enly the follcuing information:
a) Results of 7, 37 and 19 tube steam generator tests ccnducted to obtain data on heat transfer, control and dynamic response, structural integrity and vibratien, feedvater heating, secondary cleanliness , tube leckage ,
and primary side ficv.
b) Applicability of test results to the steam generator design, c) Field test program to confirm the perfer cnce of a full sise unit.
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William S.' Little Suorn to before me cnd subscribed in my presence this / day of January,1971.
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- mgh heti ( f4 Commissica Expirrs O&tcr 11,1972
Appendix B
.. , Item 9 UNITED STATES OF AMERICA ATOMIC E:IERGY CC:GISSIO:I In the Matter of )
)
THE TOLEDO EDISCII CCMPAIIY ) Docket No. 50-346
)
and )
)
THE CLEVELAND ELECTRIC ILLUMINATING COMPA*!Y ) AFFIDAVIT
)
Davis-Besse Nuclear Power Station )
I, Lovell E. Roe, being first duly sworn, depose and say that;
- 1. I am Chief Mechanical Engineer for The Toledo Edison Company.
- 2. I am fully knowledgeable with all bid documents and quotations submitted by prospective suppliers for the nuclear steam supply system for the Davis-Besse nuclear Power Station.
3 The bid documents and quotations subnitted by prospective suppliers for the nuclear steam supply systc= for the Davis-Eesse !!uclear Power Station contain only the following inforcation:
A. Technical description of equipment and services offered.
B. Scope of supply offered.
C. Terms and conditions related to the offering.
D. Price information for the offering.
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Lovell E.' Roe Svorn to before me and subscribed in rgr presence this lhth day of January, 1971.
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GENEVA 1. LEAKE \- 1 f:::ny P.Kr '.: : c ,.;,,7, r gg )
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t Appendix B '
Item 10 1 UNITED STATES OF AMERICA
-9 ATOMIC ENERGY COMMISSION In the Matter of )
TIIE TOLEDO EDISON COMPANY ) Docket No. 50-346 and )
THE CIjEVELAND ELECTRIC )
ILLUMINATING COMPANY ) AFFIDAVIT Davis-Besse Nuclear Power Station I, Lowell E. Roe, being first duly sworn, depose and say that;
- 1. I am Chief Mechanical Engineer for The Toledo Edison Company.
- 2. I am fully knowledgeable with all proposal documents submitted by organizations to provide architect-engineering services, con-struction management services, and construction for the Davis-Besse Nuclear Power Station.
- 3. Proposal documents submitted by organizations to provide architect-engineering services, construction management s ervices, and construction for the Davis-Besse Nt: clear Power Station contain only:
A. Scope of services proposed.
B. Terms and conditions covering services proposed.
C. Cost information covering services propos ed.
kr* b& c. "l ?- -
Lowell E. Roe State of Maryland County of Montgomery Sworn to before me and subscribed in my presence this ISth day of January, 1971.
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Thomas L. .Catha, Notary Public My Commission Expires July 1,19'
._- _ Appendix B ftem 11 UNITED STATES OF AMERICA .
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ATOMIC ENLRGY COMMISSION -
In the Matter of )
THE TOLEDO EDISON COMPANY ) Docket No. 50-346 and )
l THE CLEVELAND ELECTRIC )
ILLUMINATING COMPANY ) AFFIDAVIT Davis-Besse Nuclear Power Station )
I, .Lowell E. Roe, being first duly sworn, depose and say that;
- 1. I am Chief Mechanical Engineer for The Toledo Edison Company.
- 2. I am fully knowledgeable with agreements with Babcock & Wilcox l overing the furnishing of the nuclear steam supply system and
~
initial fuel for the Davis-Besse Nuclear Power Station, and with
- Bechtel for architect-engineering and construction management services.
- 3. The agreements pertain to:
j A. Scope of supply for equipment and services.
B. Terms and conditions relating to the furnishing of the 4
equipment and services.
, C. Costs associated with the furnishing of the equipment and services.
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Lowell E. Roe .
State of Maryland
- County of Montgomery Sworn to before me and subscribed
. in my presence this 15th day of Janua ry, 1971.
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l Thomas L. Catha, Notary Public My Commis sion- Expires July 1,1974.
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Appendix B Item 12 UNITED STATES OF AMERZC..
ATOMIC ENERGY COMMISSION In the Matter of )
THE TOLEDO EDISON COMPANY ) Docket No. 50-346 and )
THE CLEVELAND ELECTRIC )
ILLUMINATING COMPANY ) AFFIDAVIT Davis-Besse Nuclear Power Station )
I, Lowell E. Roe, being first duly sworn, depose and say that;
- 1. I am Chief Mechanical Engineer for The Toledo Edison Company.
- 2. I am fully knowledgeable with the contents of all documents in The Toledo Edison Company's possession showing the stages of the project pres ently completed. ,
- 3. These documents contain only:
A. Major engineering, procurement and construction items.
B. Time schedule for these items.
C. Pres ent status of time schedules.
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'/y l <&" Q-Lowell E. Roe State of Maryland County of Montgomery Sworn to before me and subscribed in my presence this 15th day of January, 1971.
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Thomas L. Catha, Notary Public My Commis sion Expires July 1, 1974.
s Appendix C UNITED STATES OF A! ERICA Item 16
-C .' ATOMIC EIIERGY CC:CIISSICII r
In the Matter of )
)
THE TOLED0 EDISD:I CC::FA'iY ) Docket I!o. 50-3h6
)
and )
)
THE CLEVELAIID.ELECTR. ILd1MIITATII;G CC:'PAI!Y ) AFFIDAVIT
)
Davis-Eesse IIuclear Fovar Station )
I, Lowell E. Roe, being first duly sworn, depose and say that;
- 1. I an Chief Mechanical Engineer for The Toledo Edison Cc=pany.
- 2. I am fully fezailiar with coct analysic data used to ctudy an alter-nate type of generating unit for the Davis-Eesse Iiuclear Power Station.
3 Cost analysis data uced to study an alternate type of generating unit for the Davis-Eesse IIuclear ?cuer Station contains only:
A. Capital ecst data.
B. Fixed cost, fuel cost and other operating cost data.
,- ./h sp e c W,, ' % q/:2J' Lowell E. Roe Sworn to before me and subscribed in my presence this lhth dry of Jannery,1971.
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GENEVA 1. LEAKE fichry .5b!:c. L:nas Cc r.ty. Ohio i4 Comr.n:!cn E.crcs Sgt. 2. M7.1
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Item 17
- j , UIIITED UTATES OF A! ERICA
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AT0!JJC ENERGY C0!GIISSI0Il In the 14atter of )
)
THE TOLEDO - EDISON - C0!&ANY )
)
and )- Docket No. 50-316 6
)
THE CLEVELAND ELECTRIC ILLUMINATING C0;&ANY )
)
Davis-Besse Nuclear Power Station )
AFFIDAVIT I, William S. Little, being first duly sworn, depose and say that;
- 1) Isem the Babcock & Wilcox Company's Licensing Supervisor for the Tcledo Edison contract.
- 2) I am knowledgeable with the content.of Babecek & Wilcox Compa- docunent,
" Stress Analysis of Closure Report #3, ELW Contract 620-0003-51 and 52, Section B-20, Rotation of Flanges . (Gasket Scaling)" .
- 3) Babcock & Wilcox Cc=pany document, " Stress Analysis of Closure Report #3, B&W Contract 620-0003-51 and 52, Section B-20, Rotation of Flanges (Gasket Sealing)", contains only the ' fclleving information:
Analysis of flange rotation and gasket behavior for'the cost adverse flange rotation: a ramp heatup of 100 F/hr. Analysis shows chat the outer "0": ring Sasket vill gain ec=pression and vill therefore remain sealed.
a n,.l.. ,p4off m
William S. Little 4
Sworn to before me and- subscribed in my presence this '1I ' d'ay of January,1971. ;
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My Commission Expires July 1,1974. I l
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- .. Appendix D Item 19 U:llTED STATi;3 0F A ERICA ATOI'IC E::ERGY CO:0 IOGIO:I In the !*.atter of )
)
TifE ".JLEDO EDISCI; COMPAIIY )
)
and ) Docket !!o. 50-3h6
)
Tile CLEVELA!!D ELECTRIC ILLUMII!ATII'G COI'?A!!Y )
)
Davis-Besse Iluelcar Pcver Station )
AFFIDAVIT I, William S. Little, being first duly sworn, depese and say i. hat;
- 1) I am the Babcock & Wilcox Cc=pany's Licensing Supervisor for the Toledo Edison contract.
- 2) I am knculedgeable with the content of ASTM-E-185 66, "Recenrended Practice for Surveillance Tests en Structural Materials in !!uclear Ecactors".
- 3) American Society fer Testing Materials doeurent ASTM-E-185 66, "Recc: rended i
Practice for Surveillcr.ce Tests en Structural Ma.terials in !!uclear Reactors",
contains culy the folleving information:
a) Type and preparaticn of test specimens b) Irradiation cenditions c) Method of censuring neutron exposure d) Type and cethod of tests to be perforned on the test specimens e) Requirements for reporting test information.
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Willian S. Little t
3 Sworn to before te and subscribed in ny presence this ! :-- 1 * -s day of January,1971.
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Ilotary Public, Thon as L. Catha My Commis sion Expire s July 1, 1974.
Appendix D Item 21 UNITED STATES OF AMERILes ATOMIC ENERGY COMMISSION In the Matter of )
THE TOLEDO EDISON COMPANY )
and ) Docket No. 50-346 THE CLEVEIAND ELECTRIC )
ILLUMINATING COMPANY )
Davis-I5 esse Nuclear Power Station )
AFFIDAVIT I, William S. Little, being first duly sworn, depose and say that;
- 1. I am the Babcock & Wilcox Company's Licensing Supervisor for The Toledo Edison contract.
2 I am knowledgeabic with the content of Babcock & Wilcox Company documents BAW-3647-3, " Physics Verification Program-Final Report" and BAW-3647-4, " Physics Verificatiop Program, Pa rt II".
- 3. Babcock and Wilcox Company Document BAW-3647-3, " Physics Verification Progra:n-Final Report" descri' sed Part I of this work and contains only the following information:
Experimental verification of the analytical models used to calculate reactor core neutron flux, power distribution, critic 11ity and reactivity.
Babcock h Wilcox Company document BAW-3647-4, " Physics Verification Program, Part II", contains only the following information:
Description of a test program carried out jointly with the U.S.
Atomic Energy Commission to determine the count rate of in-core and out-of-core startup detectors as a function of reactor coolant moderator boron concentration.
Sworn to before me and subscribed in my presence this 15th day of January, 1971.
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Exhibit D
. U11ITED STATES OF A!GHICA Item 22 ATOMIC EliF.RGY C0i'MlCSIO!!
In the lhtter of )
)
THE TOLEDO EDICCI: COV.PA!;Y )
)
and ) Docket flo. 50-346
)
THE CLEVSLA!iD ELECTRIC ILLUVII ATII;G COMPN!Y )
}
Davis-Besse I uclear Power Station )
AFFIDAVIT I William i S. Little, being first duly sworn, depose and say that,
- 1) I am the Babcock & Wilcox Company's Licensing Supervisor for the Toledo Edison contract.
- 2) I at kncwledgeable with the centent of ASI2: Paper l'o, 63-WA-100, " Reactor-Vessel Design Considering Radiation Effects".
- 3) Amerieen Society of Mechanical EnsIneers document AS C Paper Iro. 63-WA-100,
" Reactor-Vessel Design Considering Radiaticn Effects", contains only the following infor aticn:
Design steps to be taken to cope with the reactor vessel materials property changes as a result of fast-neutron irradiatien effects .
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William S. Litf ,le
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't Svorn to before te and subscribed in g presence this - day of January,1971.
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Notary Public, Thomas L. Catha My Commission Expires July 1, 1974.
-, ., Exhibit D Item 23 s
UIIITED STATES OF AMERICA AT0!UC EllERGY COIC4ISSIC:!
In the Matter of )
)
THE TOLEDO EDISCN CO:CANY )
)
and ) Docket No. 50-346
)
THE CLEVELAUD ELIC7RIC ILLUMINATII G C0!PANY )
}
Davis-Besse Nuclear Power Station )
AFFIDAVIT I, William S. Little, being first duly svern, depose and say that;
- 1) I am the Babcock & Wilcox Company'c Licencing Supervisor for the Toledo Edison centract.
b
- 2) I am fully kncvledgeable with the content cf Babecek & Wilcox Company dccument EAW-10001, "In-Core Inctrumentatien Test Procran".
- 3) Eabcoch & Uilcox Conpany decunent EAW-LOC 01, "In-Core Instrun.entatien Test Program", centains only the following information-a) The description of the In-Core Monitoring System and the cperational design basis, b) Environmental, pressure seal and techanical insertion-vithdrawal, and lifetime irradiation development tests to qualify instrutentation.
c) Conclusion that in-core instrumentation is accepttble from standpoint of detector lifetime, detector sensitivity, reproducibility of detecter capability, and assembly design, i i a:
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j' ' t U a. .. ./ -m 2;ff William S. Little Sworn to before me end subscribed in my presence thic /4 # day of Janunry,1971, f -m !/ 0u..,x n"'f y notan ruene 7 y c ~ ~,, . y n cc. .u,.
- - Exhibit D Item 24, Part 1 UNITED STATES OF A! ERICA ATOMIC ENERGY COW.ISSICII In the Matter of )
)
THE TOLEDO EDISON COIM!Y )
)
and ) Docket No. 50-3h6
)
THE CLEVELAUD ELECTRIC ILLGiINATII;G COMPAI1Y )
)
Davis-Besse Nuclear Power Station )
AFFIDAVIT I, William S. Little, being first duly sovrn, depose and say that;
- 1) I am the Babcock & Wilcox Company's Licensing Supervisor for the Toledo Edison contract.
- 2) I am fully kncvledgeable with the content of Babcock & Wilcox Company document EAW-10010, Part 1, " Stability Margin for Xenon Oscillations -
Modal Analysis".
- 3) Babcock & Wilcox Company document BAU-100lO, Part 1, " Stability Margin for Xenen Oscillations - Idodal Analysis", contains only the following information:
a) The results of analysis of xenon induced escil.!ations in Babcock &
Wile'ox's current PWR design as obtained by todal analysic techniques .
b) A discussion of the theory of modal analysis and the approxications and assumptions implicit in the method.
. /..' . ~ . .
.hy- f~/l, Uilliam S. Littie Sworn to before te and subscribed in my presence this / Y day of January,1971.
f4-i- ,u Notary Public
, 14 Cemrainn Ey;:res Cd'&r 11,1972
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c, s Exhibit D
. Item 24, Part 2 S ..
UlilTED STATES OF AMERICA
-w ..
& ATOMIC E!!ERGY CC:0!ISSION In the Matter of ) '
)
~THE TOLEDO EDISO:: COMPANY )
)
and ) Docket I!o. 50-3h6
)
THE CLEVELAND ELECTRIC ILLU:EIIATII!G CO SANY )
)
Davis-Besse nuclear Power Station )
AFFIDAVIT I, Willies S. Little, ~ being first duly sworn, depcce and say that;
- 1) I am the Babcock & Wilcox Ccepany's Licensing Supervisor for the Toledo Edison ccatract.
- 2) I am fully knowledgeable with the centent of Eabcock & Wilcox Cc peny document EAU-10010, Part 2, " Stability It'argin for Xenon Oscillations -
One Dimensional Digital Analysic".
- 3) Bal :k & Wilecx Cempany document EAW-10010, Part 2, " Stability Margin for Xenon Oscillations - One Dimensicnal Digital Analysic", ecntains cnly the following informaticn:
a) The theory and calculaticnal methcds used to study the effect of xenon induced oscillation in large PWRs by cne dirensicnal diffusien theory.
b) A description of the analyses which vere perferned for the current Babcock & Uilcox PWR design, c) A discussion and evaluation of the analytical results for xenon induced escillations with and without reactivity feedback. The ability of axial power she. ping red to centrol xenon cscillations is evaluated based en the analyses. '
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Exhibit D
Item 24, Part 3 UIIITED STATES OF A!/ZRICA ATOMIC EliERGY CC:.MISS10II In the Matter of )
)
THE TOLEDO EDIS0!! CC:GAIiY )
)
and ) Dochet lio. 50-346
)
THE CLEVELAIID ELECTRIC ILLUMI!!ATII!G CO SAITY )
)
Davis-Besse IIuclear Power Station )
AFFIDAVIT I, William S. Little, being first duly sworn, depose and say that;
- 1) I am the Babcock & Wilcox Company's Licensing Supervisor for the Toledo Edison contract.
- 2) I en fully kncwledgeable with the content of Babcock & Wilcox Conpany document EAW-10010, Part 3, " Stability Margin for Xenon Oscillaticns -
Two and Three Dimensient.1 Analyses".
- 3) Eabcock & Wilcox Ccepany document EAW-10010, Part 3, " Stability Margin for Xenon Oscillations - Two c.nd Three Dimensicnal Analyses", contains enly the following information:
a) A description of the two and three dimensional calculations performed for the purpose of studying renen oscillations in Babcock & Wilcox's current PWR design.
b) A discussion and evaluation of the culti-dimensicnal recults for varicus l l
l conditions, c) An evaluation of the adequacy of the axial power chtping rods in cen-
~
trolling axial oscillaticus. .-
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William S. Little Saorn to before ne and subscribed in my prescnce this / *i dcy of Jcnuary,1971.
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T, UNITED STATES OF AMERICA Item 25
- ATOMIC ENERGY COMMISSION
~ _
In the Matter of ) Docket No. 50-346
)
THE TOLEDO EDISON COMPANY )
)
and ) AFFIDAVIT
)
THE CLEVELAND ELECTRIC ILLL'MINATING COMPANY )
. )
Davis-Besse Nuclear Poker Station )
I, Howard W. Wahl, being first duly suorn, depose and say that;
~
- 1. I am*the Bechtel Project Engineer for the Davis-Besse Nuclear Power Station.
- 2. I am fully knowledgeable with the contents of AUS D12.1-61,
" Recommended Practice for Welding Reinforcing Steel, Metal Inserts, and Connections in Reinforced Concrete Construction".
- 3. AWS D12.1-61, " Recommended Practice for Welding Reinforcing Steel, Metal Inserts, and Connections in Reinforced Concrete Construction" contains only recommended practices relative to all welding to be utilized in reinforced concrete con-s t ruc tion.. This project has used Section 3, Paragraph 303 for the Indirect Butt Uelding Procedure for sleeve splices of #14 and #18 reinforcing bars.
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Houard W. Wahl State of Maryland County of Montgomery Sworn to before me and subsc'ribed in my presence this i I' k day of . - . , 19 it .
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Thos. L. Catha, Notary Public My Commissica Expires July 1, 1974.
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Exhibn D .
., UNITED STATES OF AMERICA Itern 26 ATOMIC E::ERGY COMMISSION In the Matter of -
) Docket No. 50-346
)
THE TOLEDO EDISON COMPANY )
)
and ) AFFIDAVIT
)
THE CLEVELAND ELECTRIC ILLUMINATING COMPANY )
)
Davis-Desse Nuclear Power Station )
I, Howard W. Wahl, being first duly sworn , depose and say that;
- 1. I am the Dechtel Project Engineer for the Davis-Besse Nuclear Power Station.
- 2. I am fully knowledgeabic with the appropriate sections of ASCE - Manuals of Engineering Practice - No. 42,
" Design of Structures to Resist Nuclear Weapons Effects",
1964 Edition.
- 3. ASCE - Manuals of Engineering Practice - No. 42, " Design of Structures to Resist Nuclear Weapons Effects", 1964 Edition contains the following information used for this
, project:
- a. Chapter 7: " Dynamic Strength of Materials"
- b. Chapter 8: "Elasto-Plastic Behavior of Structural Elements"
- c. Chapter 9: " Dynamic Analysis"
- d. The Elasto-Plastic behaviors of the reinforced concrete and structural steel during dynamic loading due to a uissile (Chapter 8) and the dynamic anal-ysis of a missile on a simple or complex systems (Chapter 9) has been used in the dynamic analysis (Chapter 9) of the Reactor Vessel Building and its Class I systems.
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Howard W. Wahl State of Mary 1cnd County of Montgotery Sworn to before me and subscribed '
in my presence this . !' 'N day of . . 19 *i .
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Thos. L. Catha, Notary Public My Commission Expires July 1, 1974. l
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Exhibit D 12enn 27
,, UNITED STATES OF AMERICA A -.
7 ATOMIC ENERGY COMMISSION In the Matter of ) Docket No. 50-346
)
THE TOLEDO EDISON CO:!PANY )
)
and ) AFFIDAVIT
)
THE CLEVELAND ELECTRIC ILLUMINAT1MC COMPANY )
)
Davis-Besse Nuclear Power Station )
I, Howard W. Wahl, being first duly sworn, depose and say that;
- 1. I am the Bechtel Project Engineer for the Davis-Besse Nuclear Power Station.
- 2. I an fully knowledgeable of the appropriate sections of AD 221 586, " Effects of Impact and Explosion: Vol. I",
1946. -
- 3. AD 221 586, " Effects of Icpact and Explosion: Vol I", 1946 contains the following information used for this project :
- a. Ch,pter 6: " Terminal Ballistics of Armor Steel as a Protective Material"
- b. Chapter 7: " Terminal Ballistics of Concrete.
Nemograms for Estimating Penetration, Scabbing and Perforation of Concrete Targeto"
- c. Chapter 12: " Behavior of Materials Under Dynamic ifads"
- d. Chapter 15: " Structural Protection" Section 15.2.5 " Impact Tests of Reinforced Concrete Beams"
- c. Appendix: " Incident Summaries"
-continued-
. Exhibit D
- i Item 27 (cont'd) 7 ..
'- f. The experimental results, theories and information in the above listed four chapters and appendix were the main references and approaches used in the design and analysis for missiles (PSAR, Section 5.2.2.3.10).
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Iloward W. Wahi State of Maryland County of Montgomery Sworn to before me and subs'cribed in my presence this ii ~0-day of , . . 19 i .
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4 Exhibit D
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Itom 28 UNITED STATES OF AMERECA ATOMIC ENERGY C01@!ISSION 4
In the Matter of ) Docket No. 50-346
-)
THE TOLEDO EDISON COMPANY )
)
and ) AFFIDAVIT d
)
^
THE CLEVELAND ELECTRIC ILLUMINATING COMPANY )
)
Davis-Besse Nuclear Power Station )
I, Oscar M. Esteves, being first duly sworn, depose and say that;
- 1. I am the Bechtel Electrical Group Supervisor for the Davis-Besse Nuclear Power Station.
- 2. I am fully knowledgeable with the contents of IEEE 279,
- " Proposed IEEE Criteria for Nuclear Power Plant Protection Systems", August 1968.
- 3. IEEE 279, " Proposed IEEE Criteria for Nuclear Power Plant Protection Systems", August 1968 contains only the~following:
- a. Criteria establishing minimum requirements for the protection systems which in case of an emergency will cause the safe shutdown and isolation of the nuclear reactor.
These protection systems activate the reactor safety trip, containment vessel isolation, and containment j pressure reduction.
i.
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4 Oscar 11.' Esteves
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State of Maryland County of Montgomery Sworn to before me and subscribed in my' presence this (N day of J . . r, . .m r , . 19 9i .
i 7 ..n . (9. T-
.Thos. L. Catha, Notary Public My Commission Expires July 1, 1974.
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