ML20084Q872
| ML20084Q872 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/17/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8405210562 | |
| Download: ML20084Q872 (17) | |
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i 5/17/84 DOCKETED U3?iRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 84 ffAY21 All:24 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of I
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TEXAS UTILITIES GENERATING l
Docket Nos. 50-445-1 COMPANY, et al,-
l and 50-446-1 l
I (Comanche Peak Steam Electric Station i
Station, Units 1 and 2) l CASE'S MOTION FOR DISCOVERY REGARDING APPLICANTS' 4/11/84 RESPONSE TO PARTIAL INITIAL DECISION REGARDING A500 STEEL On April 11, 1984, Applicants filed their Response to Partial Initial Decision Regarding A500 Steel n /.
In the Board's 10/6/83 Partial Initial Decision (page 8), Applicants were ordered to file analyses demonstrating that pipe supports manufactured with A500 Steel for Comanche Peak have adequate safety margins; the Board also stated that the other parties and participants would have 15 days from the date of filing of the analyses to file their responses.
J CASE received Applicants' Response on 4/12/S4. Under the Board's ruling that time in hearings and the week-ends immediately preceding hearings were to be excluded in counting tima fer f11ings, the date for CASE to respond to Applicants' Response was 5/10/84. Following the off-the-record conference call with the Board Chairman, the Staff, and the Applicants on 5/17/84, the writer did some further digging to determine when the parties were advised that we wanted discovery on the A500 Steel matter. There are two specific items which I found which indicate: -(1)
From 4/18/84 conference call transcript: "We attempted to call Mr. Horin 11/ Board's 10/6/83 Partial Initial Decision (Change in Material Properties for A500 Steel).
I 8405210562 840517 PDR ADOCK 05000445 O
l yesterday" (which would have been Tuesday, 4/17/84).
"We attempted to l
catch him or get back to him regarding the A500 steel matter."
(Tr.
12,128/10-13.) (2) My notes from the 4/16/84 off-the-record conference call (copy of applicable page attached) indicate regarding A500 Steel:
Typewritten notes outlining what we wanted to cover in the call f2/: "Want discovery on A500 steel answer just filed by Apps.
This was contemplated in Board's 10/25/83 Order. Want to see basis and documents." Handwritten notes regarding what was discussed in the call: " file disc. req. -- call first with specifics." (= file discovery request; call Applicants first and give them specifics, try to work out informally if possible).
It should be noted that at no time during any of those discussions did anyone object to CASE's request for discovery regarding this matter.
Further, there was at no time any mention of Applicants' Response either being, or being treated as, a Motion for Summary Disposition, and CASE certainly did not consider it as such. We therefore assumed that (although obviously there might be objections by Applicants to specific portions of our requests) thete ware no objections to our having discovery regnrding Applicants' A500 Steel Response.
Following the hearings which ended 5/3/34, CASE was heavily involved in responding ta Applicants' 4/5/94 Motion for Summary Disposition of Certain CASE Allegations Regarding AWS and ASME Code Provisions Related to Welding Issues which was due to be filed 5/9/84 (which we had not had time to work on previously because of necessary preparations for hearings).f3/
On 5/10/84, CASE briefly discussed our discovery requests regarding A500 Steel with Mr. Horin and indicated that, since there were several items f2/ This was an instance when we were better prepared for the. conference call and had prepared typewritten notes in advance.
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-involved, we would send a listing of them to him by overnight mail so that he would have them in hand when we talked further.
The letter to Mr. Horin to which were attached our discovery requests was taken to the Main Post Office on 5/10/84 and received at the service window at 3:56 P.M. marked "MUST DEL 1VER FRI. 5/11/84" (see attached mail receipt).
i We offer this detailed background due to the fact that there appear to be some differences in recollections regarding these matters. As can be i
seen from the preceding, CASE has at all times acted responsibly and in good faith in this matter. Further, it should be remembered that Applicants did not respond for six months to the Board's Order. Applicants chose not to respond during the time when there were some four months between hearings but waited to file their response until we were on a stringent and extremely heavy time schedule in preparation for hearings on very difficult, time-consuming, detailed technical issues.
It is obvious from Applicants' response that they were not spending that time in doing l
the analyses which the Board had ordered. There is no good reason Applicants could not and should not have responded to the Board's order in a timely fashion. CASE submits that this was a deliberate and calculated move on Applicants' part to cut down en the time CASE could devote to discovery and to make it more difficult for CASE to respond.
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~~~/3/ Our Answer was filed on 5/14/84 in order to allow CASE time to file a response to Applicants' 5/1/84 proposal regarding possible settlement of certain design and desig'n QA Aspects of CASE's Contention 5; see CASE's 5/10/84 letter to William A. Horin (Discovery Requests -- A500 Steel), and CASE's 5/11/84 letter to Nicholas S. Reynolds (Possible Settlement Regarding Certain-Design and Design OA Aspects of CASE's Contention 5).
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CASE'S SPECIFIC DISCOVERY REQUESTS Following the off-the-record conference call with the Board and parties this morning, CASE perceives the need to clarify with some specificity our discovery requests.
1.
Re: Page 5, footnote 6 (of Applicants' 4/11/84 Response):
Documentation showing the contract dates for all piping on which the tube steel supports are placed.
Applicants refer to the Board's determination that the contract date for the piping on which the support is placed governs Code Case applicability, and Applicants rely on this contract date in making their arguments.
CASE is asking for documentation of those contract dates because:
(1) It is our understanding that the PSE Group was formed after the contract date Applicants are relying on, and that NPSI was not involved prior to 1977 or so.
This presents the possibility that Applicants should have i
applied the later code case to begin with.
(2)Section III, Division 1, Subsection NA, Section NA-1140 addresses EFFECTIVE DATES OF CODE EDITIONS, ADDENDA, AND CASES, and states, in part:
"(c) The Code Edition, including Addenda, which is mandatory on the contract date for a component shall determine the mandatory rules for the manufacturer and installation of that component, including its materials, parts, and appurtenances.
Earlier editions shall not be used.
"(d) The Code Edition, including Addena, which is mandatory on the contract date for core support structures and component supports shall determine the mandatory rules for manufacture and 4
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installation of core support structures and component supports including their materials.
Earlier editions shall not be used.
"(e) The contract date for an entire nuclear power system does not govern the Code Edition, Addenda, and Cases applicable to the component, core support structure, and component supports.
"(g) Caution is advised when using Addenda or Cases that are less restrictive than former requirements without having assurance that they are acceptable to the enforcement authorities having jurisdiction at the nuclear plant site."
Thus, it is obvious that discovery regarding the contract dates for piping on which the tube steel supports are placed is vitally important to the issues at hand, and necessary for CASE to adequately respond to Applicants' Response.
2.
Re: Page 5, footnote 6: The signed contract dates with documentation for ITT Grinnell, NPSI, and PSE; i.e., dates when they had the pipe supports within their scope of work.
(Answer for each.)
This is important to the issues at hand, and necessary for CASE to adequately respond to Applicants' Response for the same reasons as discussed in 1. above.
3.
Re: Page 5, footnote 6: Dates of approved Revision 0 to the design criteria for NPSI, ITT Grinnell, and PSE for Comanche Peak.
(Answer for each.)
This is important to the issues at hand, and necessary for CASE to adequately respond to Applicants' Response for the same reasons as discussed in 1. above.
In addition, it is CASE's understanding that the PSE design criteria did not come out until about 1982, which could affect what is applicable.
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4.
Re: Page 5, footnote 6: Documentation showing mutual consent of owner, manufacturer and installer.
Applicants, in an off-the-record conference call today, stated that they are not relying in any way on the statement 4
referenced and that it was just included, as indicated, "For the Board's information." However, if they are not relying on it, it is not supportive of their arguments or designed to influence the Board's thinking and decision, why is it contained in their pleading? Further, it is required for the use of a code case.
For the Board's information, it should also be noted that e
i NA-1140(f) which Applicants reference states:
" Code Editions, Addenda, and Cases which have not become mandatory on the contract date for a component may be used I
by mutual consent of the Owner or his agent and Manufacturer or Installer on or after the dates permitted by (a) through (d) above.
It is permitted to use specific provisions l
within an Edition or Addenda provided that all related requirements are met."
(Emphasis added; footnotes omitted.)
For the Board's further information, it should be noted that the 11/18/83 ASME Interpretive Letter to Texas Utilities (Finneran Affidavit, Attachment) to which Applicants refer, 4
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states, in part (page 2 of 2):
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" Question 3: If a component support is ordered under a Design Specification which required compliance with an Edition and Addenda of the Code which was issued prior to final approval of Case N-71-10, and the contract date for the support is after the date of Council approval of Case N-71-10, does the Code allow the construction of the support under the provisions of Case N-71-97 j
" Reply 3:
Ves, in accordance with NA/NCA-1140." (Last emphasis added.)
5.
Re: Page 14, first full paragraph: Dated documentation showing how the Applicants considered the significance' of the revised 6
yield values.
Here we are asking for supportive documentation as to when and how "..
Applicants first considered the significance of the revised yield values set forth in Code Case N-71-10..."
If no such documentation exists, it will affect CASE's response to Applicants' pleading in this regard.
6.
Re: Page 16, first full paragraph: That portion of the design criteria from PSE, NPSI, and ITT Grinnell that indicates level B allowables are to be used with level C loads.
(Answer for each.)
Here we are asking for documentation of Applicants' statement.
If no such documentation exists, it will affect CASE's response to Applicants' pleading in this regard.
7.
Re: Page 17, first full paragraph: Dated documentation showing that the " Applicants were aware of such conservatisms at the time the A500 yield strengths were revised and thus, were satisfied that the adequacy of designs using the original yield values was assured."
We are asking for documentation of Applicants' statement.
If no such documentation exists, or if Applicants' conclusions were based on preliminary drawings rather than as-built or vendor certified drawings, it will affect CASE's response in this regard.
8.
List of.the referenced 182 supports on page 19.
We are asking for a list of the supports which were the j
basis of Applicants' analysis which " demonstrates that all stresses in the sampled tube steel support membars remained below 7
even the reduced allowable stresses" etc. We plan to utilize this list in conjunction with item 9. following.
9.
Re: Page 19: Calculations and drawings for the 182 supports reviewed, at the time of the review, referenced on this page.
As mentioned in today's informal conference call, CASE does not want copies of all the calculations and drawings; however, we would like to review them, in conjunction with the list requested in item 8. preceding, and perhaps get copies of some of them.
This review will encompass the complexity of the support to determine whether or not this was an adequate and representative sample. If the Applicants are relying in any way upon these i
supports in arguing their case, we should be allowed to review the basis for Applicants' statements and conclusions. It should he well established by now that, anytime Messrs. Walsh and/or Doyle have the opportunity to review documentation, calculations, and drawings, the results often turn out to be different from what was stated by Applicants. CASE cannot accept (and the Board l
should not accept) Applicants' representations absent supportive documentation.
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10.
Re: Page 19: Percentage of supports from ITT Grinnell, NPSI, and PSE that utilized tube steel in their original design. - (Answer for each.)
1 It is CASE's understanding that ITT Grinnell did not use 3
tube steel in its original design, but that field engineers made.
changes in which they used tube steel; i.e., modifications to supports were made by field engineers via the Component 8
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Modification Card (CMC) process, where no permanent calculations were made prior to the change and the original design did not contain tube steel but the modifications did. Applicants' response to this question will have a bearing on CASE's response.
11.
Re: Page 2 of 2 of attachment to affidavit of John C. Finneran:
documents showing the Applicants are a holder of a Certificate of Authorization.
This more properly chould also have asked whether Applicants receive Mechanical Engineering magazine. What we are interested in is whether or not Applicants would have been aware (and if so, how) if there had been a notification by ASME if there had been one.
12.
Re: Page 1 of 2 of
Attachment:
Letter Applicants sent to ASME for the interpretation.
13.
All documents (construed in the broad sense to include all handwritten notes, etc.; if in doubt, see definition contained within CASE's requests for documents and interrogatories) which the Applicants made while discussing the interpretation with ASME.
14.
Supply the names of the individuals who were on the ASME Committee who made the code interpretation.
12., 13., and 14.: CASE is concerned about what gives the -
appearance of possible bias on the part of ASME regarding their
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interpretation. We want to emphasize that we are not making sny prejudgements or accusations in this regard. However, as demonstrated below, there are certain questions which have been 9
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raised which must be answered if CASE and the Board are to have confidence in Applicants' assertions or in ASME's interpretation.
The reasons we seek reassurance in this regard are:
(1) From ASME's interpretive letter attached to Applicants' pleading, it appears that Applicants' letter was dated October 25, 1983, and that ASME responded on November 18, 1983, less than a month later.
Mr. Walsh requested an interpretation from ASME on May 22, 1983; ASME did not respond until May 7, 1984 -- a year after it was requested.
(Mr. Walsh just received his answer, which is attached, today; at the time of our discovery request, he had received no response despite several follow-up telephone calls to ASME.) Further, it is the recollection of both Mr. Walsh and CASE that he was told verbally by phone at the time he made his request that the ASME code interpretation committee only met quarterly and that if one missed getting one's request 2
in in-time for one meeting, one had to wait for the I
next quarerly meeting. It appears that Applicants were e
under no such constraints, since they appear to have not only received their response less than a month after they filed it, but also to have filed it (and received an answer) between quarterly meetings.
(2) The ASME response changed some words included in Mr.
Walsh's request (compare attached copies of original letter to ASME with ASME's response).
( At this time, 4
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we have not assessed the substance of the changes.)
Thus, our requests in items 12. and 13. bear on this question.
(3) Obviously, if anyone who has testified in these proceedings on behalf of Applicants (such as Mr. Reedy) or who has been employed by Applicants or their agents (such as Mr. Bressler) were on the ASME code interpretation committee, it would raise further questions regarding ASME's impartiality in this matter.
In conclusion, for the reasons stated herein, CASE hereby moves that the Board order Applicants to supply the information CASE has requested on discovery regarding the A500 Steel matter.
The information requested is essential in order for CASE to properly and adequately respond to Applicants' 4/11/84 Response to Partial Initial Decision Regarding A500 Steel.
Respectfully submitted, Ajn Y. 0A *. )
prs.)JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 11
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I Object to Staff's new testimony's being considered at upcoming hearings.
Went out and talked to lots of people, reviewed lots of documents, and included lots of technical AWS/ASME code info. which will need to be addressed by
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Mr. Doyle. Unfair to hit him with this right before hearings.
Impossible I
to get info to him in time and even if we did, he wouldn't have adequate time to review it and prepare for cross-examination and rebuttal if necessary.
Want discovery on documents, etc. reviewed by Staff and names of people i
ffr[ i they interviewed.
Want to know how they detennined what to look at, who to 1
talk to, etc.
Chi :t te Cygna's new testimony.
Still have not answered many of questions.
M Have not supplied documents. This means, even if they now supply documents, we are going to be dumped on (in more ways than one) at the last minute again, just as happened before last' hearings.
But we want to go ahead with hearings on Cygna; it is time to get some information in the record before they change it again. But want to have opportunity to adequately review and rebut rest of documents, if and when we get them; also cross on them.
. g-6 }p Want discovery on A500 steel answer just filed by Apps.
This was contemplated g
- gy, in Board's 10/25/83 Order. Want to see basis and documents.
' ] Filing Motion to Compel adanswers to CASE's requests for documents and answ
<g to interrogatories today.
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Filing today answer to Apps. Motion for cut off on allegations.
Obviously premature. Also designed to keep the truth from Board about intimidation at CP, Would exclude anything regarding the T-shirt incident (answers to which we are just now receiving), also it is our understanding that there are people coming forward now at CP talking to the Task Force; CASE might also be in contact with some of those people.
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Want discovery with Staff on documents turned over to them by Apps.regarding /
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T-shirt incident.
Oppcied to Apps. motion to have hearings during April 24 on Hayward Hutchison, g, @,,
etc. Want discovery (as discussed in February hearings) on tape recordings, etc.
discussed by him, now that their investigation is over.
Need time to engage in i
h discovery; need time to possibly depose witnesses; constitutes surprise; need time to consider and set up witnesses to rebut; etc.
Haven't received Apps. Tolson/Brandt reverse classification response; when agreed no objections to 8-day delay, was with understanding that it would be received by Friday, 4/13/84. ~ &.
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Mayp2,1983 Mr. Kevin Ennis Ameri.can Society of Mechanical Engineers 345 East 47th St.
New York, N. Y.
10017
Dear Mr. Ennis:
Subject:
Code Interpretation As discussed by phone with you Friday, I would appreciate a Code interpretation of the following:
1.
In NF 3213.10 of the 1974 Code with Winter Addenda, is thermal expansion of component supports or pipe supports to be considered as an example of free-end displacement?
2.
In NF-3231.l(a) of the 1974 Code with Winter Addenda, does the phrase
" constraint of free-end displacement" exclude those stresses due to thermal expansion as used in the above examples of free-end displacement in NF 3213.10?
3.
Does thermal stress as defined in NF 3121.11 of the 1980 Code with Winter
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1982 Addenda and as used in NF ll21(a) of the 1974 Code with Winter Addenda include those stresses that result from constraint of free-end displacements due to uniform distribution of temperature which could result from environ-mental conditions?
If you should need clarification of any of the above questions, please let me know.
I would appreciate anything you can do to expedite the interpretation.
Sincerely, 4
v Mark A. Walsh 1426 5. Polk Dallas, Texas 75224 214/946-9446
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Il Tha Amcrican S2cinty of Mcchanical Enginscra E'S g
United EngineenngCenter
- 345 East 47thSt NewYork.NY.10017 a 212 7057722 + TWX-710581-5267 May 7, 1984 Mark A. Walsh 1426 S. Polk Dallas, Texas 75224
Subject:
Section III, Division 1; NF-ll21 Rules for Supports, NF-3213.10 Free End Displacement, NF-3231.1 Elastic Analysis 1974 Edition with Winter 1974 Addenda, NF-3121.ll Thermal Stress 1980 Edition with Winter 1982 Addenda
Reference:
Your letter dated May 22, 1983 ASME File #NI 83-64 Gentlamn:
Our understanding of the questions in your inquiry and our replies are as follows:
Question 1: In NF-3213.10 of the 1974 Code with Winter 1974 Addenda, is thermal expansion of ccxrponent supports or pipe supports to be considered as an exanple of free cnd displaccment?
Reply 1:
No.
Question 2: In NF-3231.l(a) of the 1974 Addenda, does the phrase " constraint of free-end displacement" exclude those stresses due to thermal expansion in the supports as used in the above exanples of free and displacenent in NF-3213.10?
Reply 2: Yes.
Question 3: In the design of pipe st:pports, does thermal stress as defined in NF-3121.ll of the 1980 Code with Winter 1982 Addenda and as used in NF-1121(a) of the 1974 Code with Winter 1974 Addenda include those stresses that results from constraint of free-end displacements due to uniform distributic.2 of temperature which could result frta environmental conditions?
Reply 3:
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- truly, s
2n Ennis BPVC Assistant Secretary (212) 705-7643 KE:CC ASME procedures provice for reconsideration of this interpretation when or if additional infermatir.n is available wnich (ne inquirer believes might affect the interpretation. Further. persons agg,tieved b, this enterpretation may appeal to tne cognizant ASME committee or subcommittee. As stated in the f orewont of the code documents. ASME coes not ' approve." certity,-' rate " or "encorse~ any item, construction. propnetary oevice or activity.
Member e American Association of Engineenng Societies. Accreditation Board for Engineering and Technology
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket Nos. 50-445-1 COMPANY, et al.
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and 50-446-1 (Comanche Peat Steam Electric.
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Station, Units 1 and 2)
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CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Motion for Discovery Regarding Applicants' 4/11/84 Response to Partial Initial Decision Regarding A500 Steel have been sent to the names liisted below this 17th day of May
,1984, by: Express Mail where indicated by
- and First Class Mail elsewhere.
- Administrative Judge Peter B. Bloch
- Nicholas S. Reynolds, Esq.
U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell i
4350 East / West Highway, 4th Floor
& Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.
Washington, D.C.
20036
- Ms. Ellen Ginsberg, Law Clerk U. S. Nuclear Regulatory Commission
- Geary S. Mizuno, Esq.
4350 East / West Highway, 4th Floor Office of Executive Legal l
Bethesda, Maryland 20814 Director U. S. Fuelear Pegulatory.
- Dr Kenneth A. McCollom Dean 0,camit si on Division of. Engineering, Maryland National Bank Bldg.
Architecture and Technology
- Room 10105 Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland 20814
- Dr. Walter H. Jordan Atomic Safety and Licensing Board 881 W. Outer Drive Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 i
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Alan S. Rosenthal, Esq., Chairman Renea Hicks, Esq.
Atomic Safety and Licensing Appeal Assistant Attorney General Board Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C.
20555 Austin, Texas 78711 Dr. W. Reed Johnson, Member John Collins Atomic Safety and Licensing Appeal Regional Administrator, Region IV Board U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Washington, D. C.
20555 Arlington, Texcs 76011 Thomas S. Moore, Esq., Member Lanny A. Sinkin Atomic Safety and Licensing Appeal 114 W. 7th, Suite 220 Board Austin, Texas 78701 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. David H. Boltz 2012 S. Polk Michael D. Spence, President Dallas, Texas 75224 Texas Utilities Generating Company Skyway Tower Atomic Safety and Licensing Appeal 400 North Olive St., L.B. 81 Panel Dallas, Texas 75201 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Docketing and Service Section (3 copies)
Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C.
20555 116 N>
Als Rfs.) Juanita Ellis, President ASE (Citizens Association for Sound Energy) 1426 S. Polk 2
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