ML20083F571
| ML20083F571 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/26/1983 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8401030175 | |
| Download: ML20083F571 (6) | |
Text
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12/26/83 UNITED STATES OF AMERICA COLMETED NUCLEAR REGULATORY COMMISSION UNC BEFORE THE ATOMIC SAFETY AND LICENSING B0$t3D g g In the Matter of prg gg m, APPLICATION OF TEXAS UTILITIES g
< CNinac 4 wa.,
g Docket Nos3R50 845' GENERATING COMPANY, ~ET AL. FOR AN OPERATING LICENSE TOR and 50-446 COMANCHE PEAK STEAM ELECTRIC I
STATION UNITS #1 AND #2 I
(CP3ES)
CASE'S ANSWER TO NRC STAFF MOTION TO RE0 PEN RECORD TO ADMIT THE AFFIDAVIT OF DR. JAI RAJ N. RAJAN On December 13, 1983, the NRC Staff filed its Motion to Reopen Record to Adnit the Affidavit of Dr. Jai Raj N. Rajan; attached to that motion was the Affidavit of Jai Raj N. Rajan on Support No. CC-1-028-039-S33R.
In his affidavit, Dr. Rajan finally admits that his calculations for this su:. port were in error (without ever admitting that CASE witness Jack Doyle was correct in this regard).
However, Dr. Rajan's affidavit is noteworthy in other aspects, to which we call the Board's attention.
Background regarding this matter can be found in CASE's 8/22/83 Proposed Findings of' Fact and Conclusions of Law (Walsh/Doyle Allegations); see especially pages I): - 7 through 13.
Including in this citation are quotations from Tr.
6651-6655, which state, in part:
DR. RAJAN:
... we did not go to the extent of exactly determinir,g the stresses... (our analysis showed) We came close to allowab'e...
when we looked at the support and we made a determination, we found that it is either within allowable, or close to allowable, and it is sr.ill in the iterative design cycle."
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_2-CASE did not receive Dr. Rajan's calculations for five months after the Board ordered the Staff to supply them (on October 15, 1983, the Saturday afternoon before hearings began on the following Monday, October 17). After receipt of Jack Doyle's affidavit (attached to CASE's 11/4/83 Response to NRC Staff's Affidavits on Open Items Relating to Walsh/Doyle Allegations), Dr.
Rajan stated in his affidavit:
"... it was my understanding that the design for this support at the time of the SIT inspection had been changed to correspond to the configuration shown in my calculational notes for this support (and in Figure 4, Detail A of Mr. Doyles affidavit). Because of my under-standing of this support's configuratior., my calculations were based on the assumption that the support. design was cquivalent to that shown in my calculational notts and Figure 4, Detail A...
"Upon further review of.my files, and following discussions with Mr.
John Finneron (sic), Pipe Support Engineering Supervisor at CPSES, Applicants, I am unable to find any materials which document the s.upport corfiguration for Support No. CC-1-028-039-S33R which I modeled in my
}@cula tion 5.
Therefore, I conclude that my calculations for this.
support are not appropriate to this support."
(Emphases added.)
Dr. Rajan then indicates that Applicants have modified the support desig1, so there's no problem anyway.
A review of the record regarding this matter shows that Dr. Rajan's testimony in this regard was shifting at best.
Further, Dr. Rajan's affidavit raises still further questions which should be answered:
How did Dr. F.ajan come to have his " understanding" to begin with? To what extent was he relying on what Applicants told him? Tc what extent has he relied (or have otter NRC Staff witnesses relied) on what Applicants have told them, rather than upon doctsnentation, regarding other matters raised in these proceedings?
What role did NRC Staff witness Taylor have in all this?
Have NRC Sta#f witnesses made other errors such as this, regarding which they have testified in these proceedings and upon which the Board will rely in making its decisions?
o
. As indicated in the transcript (see page IX - 11 of CASE's Proposed Findings),
other such supports are typically handled in the same manner that this one is.
What exactly does this mean? Dr. Rajan states in his affidavit (page 2):
j
... I now understand that Applicants have modified the support design so that the use of flange steel members is no longer employed.
- Instead, tube steel members are now utilized in this support's design..."
(Emphasis added.)
There is no indication that other similarly designed and constructed supports have been changed; only that this one support was changed. Are j
there others with the same problem which have not been changed, which are already constructed and still in place at Comanche Peak? What assuran:e does the Board have, one way or another, regarding this?
Further, it appears from Dr. Rajan's statement above that he is still relying on Applicants for his " understanding" of the present configuration and cesign of this support.
It does not say that he personally looked at the suport and saw that tube steel members are now utilized instead of flange steel nembers.
It does not even say that Dr. Rajan saw any documentation that even this one support had actually been changed.
Under the circumstances, of what use to the Board is Dr. Rajan's current "unders tanding"? What assurance is there that his current understanding is any more accurate than his former erroneous understanding?
CONCLUSIONS CASE believes that Dr. Rajan's affidavit should be admitted into evidence for the limited purpose of supporting CASE witness Jack Doyle's statements I
. that Dr. Rajan's calculations were in error and that were the correct calcu-lations used, a severe problem would still have existed with this support, and to help complete the record regarding the credibility and/or competence of NRC Staff witnesses.
CASE does not support the acceptance af Dr. Rajan's affidavit as offer-ing any proof or assurance that the design or configuration of this particular support has been changed or that other similar supports have been changed, for the reasons stated herein.
Respectfully submitted, s
(ANrs.) Juanita ETTis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 l
~
UNITED STATES OF AMERICA
~
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l
1 APPLICATION OF TEXAS UTILITIES
{
GENERATING COMPANY, ET~AL. FOR l
Docket Nos. 50-445 AN OPERATING LICENSE FOR
{
and 50-446 COMANCHE PEAK STEAM ELECTRIC Q
STATION UNITS #1 AND #2 (CPSES) l CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's ANSWER TO NRC STAFF MOTION TO RE0 PEN RECORD TO ADMIT THE AFFIDAVIT OF DR. JAI RAJ N. RAJAN have been sent to the names listed below this 26th day of December
, 1983, by: Express Mail where indicated by
- and First Class Mail elsewhere.
(dropped into Express Mail box at mail post office)
- Administrative Judge Peter B. Bloch Alan S. Rosenthal Esq., Chairman U. S. Nuclear Regulatory Comission Atomic Safety and Licensing Appeal Board 4350 East / West Highway, 4th Floor U. S. Nuclear Regulatory Comission Bethesda, Maryland 20014 Washington, D. C.
20555
- Dr. Kenneth A. McCollom, Dean Dr. W. Reed Johnson, Member Division cf Engineering, Atomic Safety and Licensing Apoeal Board Architecture and Techrology U. S. Nuclear Regulatory Ccmission Oklahoma State University Washington, D. C.
20555 Stillwater, Oklahoma 74074
- Dr. Walter H. Jordan Thomas S. Moore, Esq., Member Carib Terrace Motel, Apt.10 Atomic Safety and Licensing Appeal Board 552 N Ocean Blvd.
U. S. Nuclear Regulatory Comission Pompano Bcach, Florida 33062 Washington, D. C.
20555 t
- Nicholas 5. Reynolds, Esq.
Atomic Safety and Licensing Appeal Panel Debevoise & Liberman
~
U. S. Nuclear Regulatory Comission 1200 - 17th St., N. W.
Washington, D. C.
20555 l
Washington, D. C.
20036 Docketing and Service Section (3 copies)
- Marjorie Ulman Rothschild, Esq.
Office of the ' Secretary Office of Executive Legal Director, USNRC U. S. Nuclear Regulatory Comission Maryland National Bank Building Washington, D. C.
20555 7735 Old Georgetown Road - Room 10105 Bethesda, Maryland 20814 l
Atomic Safety. and Licensing Board Panel U. S. Nuclear Regulatory Commission i
Washington, D. C.
20555
Certificate of Service Page 2
- David J. Preister, Esq.
Assistant Attorney General Enviromental' Protection Division i
Supreme Court Building.
Austin, Texas 78711 John Collins Regional Administrator, Region IV U. S. Nuclear' Regulatory Conmission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Lanny A. Sinkin 114 W. 7th, Suite 220 Austin, Texas 78701 R. J. Gary, Executive Vice President Texas Utilities Generatir.g Company 2001 Bryan Tower Dallas, Texas 75201
() CASE (Citizens Association for Sound Energy)
- 1rs.) Juanita Ellis, President 1426 S. Polk Dallas, Texas 75224 214/946-9446 l
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