ML20063B309

Response to 820820 Twelfth & Thirteenth Sets of Interrogatories.Certificate of Svc Encl

ML20063B309
Person / Time
Site:	Comanche Peak
Issue date:	08/23/1982
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
References
NUDOCS 8208250333
Download: ML20063B309 (8)

Text

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1. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Cfr/c . i 00CdE'TISI3fR"py BEFORETHEATOMICSAFETYANDLICENSINGBOARDBkqcy!I(1itc In the Matter of )

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

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

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. APPLICANTS' RESPONSES TO CASE'S TWELFTH AND THIRTEENTH SETS OF INTERROGATORIES AND REQUESTS TO PRODUCE Pursuant to 10 C.F.R. $$2.740b(b) and 2.741, Texas Utilities Generating Co., et al. (" Applicants")'hereby submit their responses to CASE's Twelfth and Thirteenth Sets of Interrogatories and Requests to Produce, served August 9, 1982. These responses are in accordance with the Board's directives set forth in the August 20, 1982 conference call with the parties.1 CASE's Twelfth Set l

, 1. On August 16, 1982, Applicants telephoned CASE to provide

, the names of Applicants' rebuttal witnesses. A letter confirming those names was transmitted the same day by

, 1 A conference call with the Board and parties was placed by CASE on August 20, 1982.. The purpose of the call was to address CASE's Motion to allow discovery on Contention 5, I served Augustt 17, 1982, with respect to its Twelfth and

, Thirteenth Sets of Interrogatories, served-August 9, 1982.

During that call the Board ruled on each of CASE's discovery requests.  ;

8200250333 820823 PDR ADOCK 05000445 O PDR

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overnight delivery. The qualifications and expected areas of testimony of these witnesses are being provided to CASE at the depositions being taken by CASE.

2. Yes.

3. Dr. Peter S.Y. Chang is an expert in the STRUDL Code and its applications. His training and experience with STRUDL is, as follows:

I Lectures and Seminars In March, and April 1972, Dr. Chang attended and participated in a series of lectures titled,

" Applications of the Matrix Displacement Method in Structural Mechanics, Using the STRUDL Program,"

presented by R.P. McBean and H.J. Salane at the University of Missouri. These lectures were presented to the faculty and graduate students in Civil Engineering, Mechanical and Aerospace Engineering, and Physics. They consisted of ninety-minute sessions held every week for six consecutive weeks. The six sessions were devoted to the following topics: matrix displacement method fundamentals, basic STRUDL commands; further concepts, advanced STRUDL commands for framed structures; space frames, idealization considerations; the finite element method for plane stress and plane strain, STRUDL commands for these problems; displacement functions, plate bending, STRUDL for plate problems; three-dimensional problems, present capabilities of STRUDL. Ten example STRUDL problems.were included to illustrate these topics. STRUDL projects were assigned in each of the first five sessions.

In July, 1974, Dr. Chang attended a series of seminars titled " Seminars on use of STRUDL in Advanced Structural Analysis, including the Finite Element Method," presented by R.P. McBean of Black & Veatch, Consulting Engineers, Kansas City, Missouri. This series consisted of five ninety-minute presentations, covering advanced structural application of STRUDL problems involving the following topics:

(1) Matrix Displacement Method, (2) The Finite Element Method,

R (3) STRUDL Commands for Finite Element Method, (4) Comparative Discussions of STRUDL, NASTRAN, ANSYS, SAPIV, and ELAS, (5) Discussion of Computer Analysis Capabilities at Black & Veatch for Structural Analysis.

Related Graduate Course Work University of Missouri, Columbia (1970-1972)

Advanced Numerical Method in Engineering Theory of Elasticity Theory of Elastic Stability Advanced Structural Analysis Dynamics of Structures Ottawa University, Canada (1968-1970)

Theory of Plates Theory of Shells Finite Element Method Matrix Analysis of Structures Theory of Vibrations Energy Method

4. At the depositions of Applicants' rebuttal witnesses being conducted on August 20, 21, 23 and 24, 1982, Applicants have brought (or will bring) with them the documents which at the present time Applicants believe may be relied upon by their rebuttal witnesses.

5. In accordance with the Board's ruling during the conference call on August 20, 1982, Applicants will provide the personnel records of Messrs. Atchison, Walsh and Stiner, and Mrs. Stiner, directly to those individuals upon receipt of a letter requesting those records and waiving any right to privilege and confidentiality.

6. Applicants informed CASE by telephone on August 16, 1982 of the availability of this document for inspection and copying. CASE received a copy of this document on August 17, 1982.

7. Applicants will provide for inspection and copying notes of the March 3, 1982 meeting prepared by Mr. Gary Krishnan.

8. There are no documents which fall within the scope of this request.

9. Applicants do not possess a copy of this document. CASE should submit a request directly to NPSI at the following address:

NPS Industries, Inc.

One Harmon Plaza Secaucus, N.J. 07094

10. The only information in Applicants' possession regarding this topic is contained in the PSE Design Manual. See Response to Question 15. Any further information CASE seeks on this topic must be requested directly from NPSI or ITT Grinnel.

11. Applicants informed CASE by telephone on August 16, 1982 of the availability of this document for inspection and copying. CASE received a copy of this document on August 17, 1982.

12. Applicants do not possess a copy of this document. CASE should submit a request dirctly to ITT Grinnel at the following address:

, ITT Grinnel Corporation 260 W. Exchange St.

Providence, R.I. 02901

13. Applicants will provide this documentation for inspection and copying.

14. Applicants will provide this documentation for inspection and copying.

15. Applicants will provide this document for inspection and copying.

16. To the extent this information is within Applicants' possession, it is set forth in the PSE Design Manual.

See Response to Question 15. If CASE seeks any further information on this topic it should contact directly NPSI or ITT Grinnel.

17. Applicants do not possess this information. CASE should request the information directly from ITT Grinnel.

18. Applicants informed CASE by telephone on August 16, 1982 of the availability of this document for inspection and copying. CASE received a copy of this document on August 17, 1982.

CASE's Thirteenth Set

l. Pursuant to the Board's ruling during the August 20, 1982, conference call, these documents need not be produced.

2. Applicants will supply the microfilm copy of the American Welding Society Code for inspection and copying.

Applicants note that a hard copy edition should be available at the Dallas Public Library.or at the college and university libraries in the area.

3. Upon receipt of clarification from CASE, Applicants will provide the requested documents for inspection and copying.

. INSPECTION OF DOCUMENTS These documents will be available for inspection and copying pursuant to our usual arrangement. However, copies of the AWS Code from microfilm will be 30 cents per page.

Respectfully submitted, d .

Nicholas S. Rd/nold's l/w

._ William A. HoPTn ' #

l DEBEVOISE & LIBERMAN

! 1200 17th Street, N.W.

Washington, D.C. 20036 (202)857-9817 Counsel for Applicants August 23, 1982 e

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$ STATE OF TETAS ) l h

J C0!!NTY OF DA1.LA$ )9 L-l Heer C. Schmidt, being duly sworn, deposes and says:

. That he is Manager, h'uclear Services, Texas Utilities Services p Inc., and knows the contents of the foregoing Applicants' Responses j to CASE's Twelfth and Thirteenth sets of Interrogatories and Requests

, to Produce; that the same is true of his own knowledge except as to retters therein stated on information and belief, and as to that, he believes them to be true. -

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[t Homer C. ScMidt

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f Subscribed and sworn to before ne this # day of August 1982.

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/ , Thi.s is a telecopy f acsimile. The original will be b; transmitted under separate cover.

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

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

)

) (Application for (Comanche Peak Steam Electric ) Operating Licenses)

Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' Responses to CASE's Twelfth and Thirteenth Sets of Interrogatories and Requests to Produce," in the above-captioned matter were served upon the following persons by express delivery (*) or by deposit in .

the United States mail, first class postage prepaid this 23rd day of August, 1982:

~

• Marshall E. Miller, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Board 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. Kenneth A. McCollom Atomic Safety & Licensing Dean, Division of Engineering Board Architecture and Technology U.S. Nuclear Regulatory ,

Oklahoma State University Commission Stillwater, Oklahoma 74074 Washington, D.C. 20555

• Dr. Richard Cole, Member

• Marjorie Ulman Rothschild, Esq.

Atomic Safety and Licensing Office of the Executive Board Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission i Washington, D.C. 20555 Washington, D.C. 20555 Chairman, Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

David J. Preister, Esq. Mr. Scott W. Stucky Assistant Attorney General Docketing & Service Branch Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548 Washington, D.C. 20555 Capitol Station Austin, Texas 78711

• Mrs. Juanita Ellis President, CASE 1426 South Polk Street Dallas, Texas 75224 l I j i e

// a William A. Hofih cc: Homer C. Schmidt Spencer C. Relyea, Esq.

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