ML20024A065

Response Opposing Citizens Assoc for Sound Energy (Case) 830604 Motion to Reopen Record Re Upper Lateral Steam Generator Support.Case Should Be Admonished for Raising New Issues Premised on Speculation.Certificate of Svc Encl

ML20024A065
Person / Time
Site:	Comanche Peak
Issue date:	06/10/1983
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8306150366
Download: ML20024A065 (7)

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'83 JUN 13 P1 :45 June 10. 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, et al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)

APPLICANTS' ANSWER TO CASE'S MOTION TO REOPEN RECORD REGARDING UPPER LATERAL RESTRAINT On June 4, 1983, CASE filed a motion seeking to reopen the record regarding the design of the upper lateral steam generator support, a matter addressed in detail during the May 1983, hearing session. In support of its motion, CASE has cubmitted an affidavit alleging a " potential problem," which it represents cannot be further specified without the production by Applicants of additional documents. As demonstrated below, this motion is simply another in a long series of " potential problems" which CASE seeks to raise at the last minute based on nothing more than mere suspicion and vague speculation. The Board should deny CASE's motion and direct CASE again to refrain from raising spurious questions that have no basis in fact.

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I. APPLICANTS' ANSWER TO CASE'S MOTION CASE has a long history of raising " issues" in this proceeding at the last minute without meaningful specification of the concern and without demonstrating why such matters could not have been raised at an earlier date or why the matter is significant from the standpoint of the public health and safety.

In this instance, CASE even admits that whatever concern it had on this matter arose no later than May 19, 1983. Yet CASE waited more than two weeks to formally pursue its " concern,"

transmitting material for receipt by the parties only a week -

before the next hearing session. Such disregard for the orderly conduct of these proceedings should not be countenanced by the Board. The status of these proceedings is such that any attempt to raise new matters must clearly present a significant, well-founded issue with serious implications for the public health and safety. CASE has failed to demonstrate that such an issue exists -

in this instance.

This matter is simply another example of CASE's attempts to litigate all aspects of the design and construction of the plant

.by challenging any information that comes to its attention which it is unable fully to understand by claiming it is "new and potentially significant information." In this instance, CASE 1

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supports its claim by an aNfidavit that simply alleg'es a U

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" potential problem. The affickavit la founded only on s

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MU unsupported assertions that there "c{iuld be a problem" with the a ,

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dqnstraint of confr\ action,of the reactor coolant loop, the

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. e+s 4 dim,ensi(on'o{ i which""we [ CASE 3 currently don't know.",To rectify 5' i >s

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q i the wholly specula'tive nature of ,itsw claims, CASE would have\the

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[,3 [.-Applic' ants produce et more io,cuments"~ (in additio ' to\

the tens r ,. \, ( a i ff thousands of paigot already oduced). Such trial by' ,

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. speculation, m.ust be fttp to end ,by this Board.

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CASE's use of such unsupported assertions in this instance s

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.t is'even more aggregious in that material"already in the record in 1

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3 (Thisproceedingwhollydiscounts those , claims. Applicants'.;[ [

t. n Exhibit M7, which is a.I drawing of the' steam generator% uppee\3, . t , i, 1

tw .. lateral support arrangement at Comanche Peak,% indicates first6q .u i )m U.s ,

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s, upper lateral supports whefi.,f 5the system"i's -(in the', hot 'positidn ~ - , . .

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s, and second that cleaEances are,'also prov,ided,)in the cold T, ja W {, $

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• provide that minimum 4nd maximum gaps forothe cold position must 3 p N y '

t ,. '~K, j ', po provided,.,g g ese gaps are measured and'gvy ihied g.jring,Ahu hot l- 4 t -m,< .% '"/, , g yq functi,onal, {. testing performed aell in advance of Velhlgspfn. g.

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This will as'sure that no . constraint of the Q ermal movement \

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(gither expansion or contr lon) of the steam generator by these ,

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4 Further, all vertical supports for thesreactor,c'oolant loop components at Comanche Peak are designed to allow for thermal growth of the system. See FSAR $5.4.14.2.' In particular, the.

i vertical supports for both the reactor coolant pumpl and steam generator provide for thermal movement of'the system during t

heatup and cooldown. See FSAR $$5.4.14.2.2 and 5.4.14.2 3. The typical designs for the reactor coolant pump and steam generator

., s supports are shown in FSAR Figures 5.4-13 and 14'. These designs allow for movement of the system in the direction af; thermal ~

expansion of the reactor coolant system. Id. Intirestingly, Mr.

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Doyle appears to recognize the nature of the design of these supports (Affidavit at 2) but fails to address its significance to his allegations.

In sum, the record is clear that neither the steam generator nor the reactor coolant pumps are " locked in place" as Mr. Doyle alleges. Rather, the thermal expansion and contraction of the reactor coolant system under normal operating conditions is accounted for both by design clearances and component support design. Mr. Doyle's concern regarding constraint of this thermal expansion and contraction is unfounded.

1 Mr. Doyle's reference to " recirculating pumps" is not accurate. The PWR design at Comanche Peak utilizes reactor coolant pumps to perform the functions apparently attributed by Mr. Doyle to recirculating pumps.

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4 II. CONCLUSION

, For the foregoing reasons, Applicants oppose CASE's motion and urge the Board to deny it in its entirety.

Further, we urge the Boa'rd to admoni~sh CASE from continuing to raise "new issues" i

premised on unfound,ed speculation and suspicion.

V- Respec fu y submitted, e e Nicholqp S/'Reynolds f

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. . William A. Horin DEBEVOISE ; LIBERMAN

, 1200 Seventeenth Street, N.W.

Wshington, D.C. 20036 (202) 857-9817 Counsel for Applicanta June 10, 1983 i

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

)

TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, et al. ) 50-446

)

(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' Answer To CASE's Motion To Reopen Record Regarding Upper Lateral Restraint," in the above-captioned matter were served upon the following persons by hand delivery (*),

express delivery (**) or by deposit in the United States mail, first class postage prepaid, this 10th day of June 1983.

• Peter B. Bloch, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Liceneing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• Lucinda Minton, Esq.

• • Dr. Walter H. Jordan Atomic Safety and Licensing 881 W. Outer Drive Board Oak Ridge, Tennessee 37830 U.S. Nuclear Regulatory Commission

• • Dr. Kenneth A. McCollom Washington, D.C. 20555 Dean, Division of Engineering Architecture and Technology

• Marjorie U. Rothschild, Esq.

Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Legal Director U.S. Nuclear Regulatory Chairman, Atomic Safety and Commission Licensing Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission ** David J. Preister, Esq.

Washington, D.C. 20555 Assistant Attorney General Environmental Protection Division P.O. Box 12548 Capitol Station Austin, Texas 78711

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Mr. John Collins Mrs. Juanita Ellis Regional Administrator, President, CASE Region IV 1426 South Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 Mr. Scott W. Stucky Docketing & Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Y)

Wi;.liam A. Horin cc: Homer C. Schmidt Spencer C. Relyca, Esq.

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