ML20092H521
| ML20092H521 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/21/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| OL-1, NUDOCS 8406260152 | |
| Download: ML20092H521 (7) | |
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214/946-94h6
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(CITIZENS ASSN. FOR SOUND ENERGY)
'84 J' 25 R2:07 June 21, 1984 Administrative Judge Peter B. Bloch, ASLB Chairman Dr. Kenneth A. McCollom, ASLB Member Dr. Walter H. Jordan, ASLB Member Gentlemen:
SUBJECT:
In the Matter of Application of Texas Utilities Generating Company, et al. for An Operating License for Comanche Peak Steam Electric Station Units #1 and #2 (CPSES)
Docket Nos. 50-445 and 50-446 CASE's Answers to Applicants' Motions for Summary Disposition
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Pursuant to the Board's verbal Order during the 6/15/84 telephone conference call and subsequent instruction 6/20/84, we are supplying our best current estimate of the dates on which CASE will be able to file our Answers to Applicants' Motions for Summary Disposition.
These estimated dates are predicated and dependent upon when we receive responses from Applicants to questions and requests for documents which we have made (which includes a request to supply CASE with the same information Applicants supply to the Staff).
It should be noted that we have not yet received any responses to the items requested during the 6/6/84 (over two weeks ago) or 6/11/84 Applicants / Staff / Case telephone conference calls.
Also, we received the transcript of the 6/8/84 Applicants / Staff Bethesda meeting on 6/14/84 (with attached documents) and are still reviewing it.
(It appears in some instances to raise more questions than were answered, especially regarding certain portions which were inaccurately transcribed or marked " inaudible." We anticipate that further clarification from Applicants or Staff will be necessary for some portions.) Also, we have not yet received the transcript of the 6/11/84 Applicants / Staff / CASE telephone conference call, and our response is based on our rather sketchy notes of that call. And obviously we have not yet received a transcript of the Applicants / Staff Bethesda meeting which was scheduled for yesterday (possibly continuing into today).
We have tried to include a realistic estimate of the amount of time which will be necessary (for example, we have to review 182 drawings and calculations regarding item 1; we have to review 60 drawings, then perhaps ask for calculations on some of them, then review those calculations, as well as review test reports, regarding item 9; etc.).
It may be, with Applicants' cooperation, that we can file before our target dates.
8406260152 840621 1
PDR ADOCK 05000445 A
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a As discussed previously, both Messrs. Walsh and Doyle have been having to put in a lot of overtime on their jobs and anticipate that this will be continuing at least for the next several weeks. We will certainly do the best we can to respond as quickly as possible. However, it must be noted that it appears obvious that Applicants did not prepare these Motions overnight; they are obviously the product of many months of work by the staffs of both Applicants and their consultants and agents. We have attempted to make realistic estimates, considering the limitations of CASE's small organization and two engineers who are iarking overtime at other full-time jobs.
Messrs. Walsh and Doyle have indicated the Friday dates by which they can have the necessary information to me; the dates for responses (on the following Monday) therefore include time for typing, copying, collating, and preparing for mailing, which is more realistic. Again, these schedules are dependent on cooperation by Applicants in supplying the requested information; response dates will vary in direct proportion to any slippage by Applicants.
We will sivise the Board as soon as we are aware of any changes in these estimates, as well as nn estimate regarding items 11, 12, 13, and for those items which we have not yet received.
Respectfully submitted, CASE (CITIZENS ASSOCIATION FOR SOUND ENERGY)
WM E
Mrs.) Juanita Ellis President Attachments l
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i 6/21/84 SCHEDULE FOR RESPONSES (Item Nos. correspond to attached list of APPLICANTS' MOTIONS FOR
SUMMARY
DISPOSITION TO CASE.)
To be placed in mail Monday, 7/9/84 (or before), if received from Applicants by 6/22/84:
2.
Damping Factors for OBE and SSE Loading Conditions 3.
AWS and ASME Code Provisions (Design) i 5.
Section Property Values 7.
Upper Lateral Restraint 10.
U-Bolts Acting As Two-Way Restraints To be placed in mail Monday, 7/16/84:
4.
Friction Forces To be placed in mail Monday, 7/23/84:
6.
Gaps To be placed in mail Monday, 7/30/84:
1.
A500 Steel To be placed in mail Monday, 8/6/84:
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8.
Safety Factors l
9.
Generic Stiffnesses Unable to estimate at this time; will advise:
1 11.
Richmond Inserts I
12.
Stability 13.
Local Displacements and Stresses
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Design Quality Assurance Program
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Cinched-Up U-Bolts
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Axial Restraints 3
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APPLICANTS' MOTIONS FOR
SUMMARY
DISPOSITION TO CASE
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l Already Answered by CASE:
t 4/5/84 Re: Certain CASE Allegations Regarding AWS and ASME Code Provisions Related to Welding Issues
-- Answered 5/14/84 j
i Received by CASE:
1.
4/11/84 Applicants' Response to Board's Partial Initial Decision Regarding A500 Steel (to be treated as Motion for Summary Disposition, per Board) i 1
-- Received 4/12/84
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i 2.
5/16/84 Re: Alleged Errors Made in Determining Damping Factors for OBE
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and SSE Loading Conditions
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-- Received 5/17/84 3.
5/17/84 Re: Certain CASE Allegations Regarding AWS and ASME Code l
Provisions Related to Design Issues
-- Received 5/17/84 i
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4.
5/16/84 Re: Consideration of Friction Forces in the Design of Pipe Supports with Small Thermal Movements
-- Received 5/17/84 5.
5/18/84 Re: CASE Allegation Regarding Section Property Values
-- Received 5/19/84 6.
5/18/84 Re: Effects of Gaps on Structural Behavior Under Seismic Loading Conditions
-- Received 5/19/84 7.
5/20/84 Re: Upper Lateral Restraint Beam
-- Received 5/21/84 1
8.
5/20/84 Re: CASE's Allegations Regarding Safety Factors
-- Received 5/21/84 i
i 9.
5/21/84 Re: Use of Generic Stiffnesses Instead of Actual Stiffnesses in Piping Analysis
-- Received 5/22/84
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10.- 5/23/84 Re: CASE's Allegations Regardit.g U-Bolts Acting as Two-Way Restraints 7
-- Received 5/24/84 11.
6/2/84 Pe: Design of Richmond Inserts and Their Application to Support
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Design
-- Received 6/4/84 l
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r APPLICANTS' MOTIONS FOR
SUMMARY
DISPOSITION TO CASE (continued):
12.
6/17/84 Re: Stability of Pipe Supports
-- Received 6/18/84 13.
6/18/84 Re: Consideration of Local Displacements and Stresses
-- Received 6/20/84 Still to Be Received (see Applicants' 6/13/84 letter to Board):
Design Quality Assurance Program Effects of Cinched-Up U-Bolts Force Distribution in Axial Restraints l
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l-In the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket Nos. 50-445-1 l
COMPANY, et al.
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and 50-446-1 (Comanche Peak Steam Electric
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Station, Units I and 2)
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t CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's 6/21/84 letter to ASLB, re: CASE's Answers to Applicants' Motions for Summary Disposition (with attached List of Motions and Estimated Filing Dates) i have been sent to the names listed below this 21st day of June
,1984_,
by: Express Mail where indicated by
- and First Class Mail elsewhere.
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- Administrative Judge Peter B. Bloch
- Nicholas S. Reynolds, Esq.
U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor
& Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.
Washington, D.C.
20036
- Ms. Ellen Ginsberg, Law Clerk i
U. S. Nuclear Regulatory Commission
- Geary S. Mizuno, Esq.
4350 East / West Highway, 4th Floor Office of Executive Legal Bethesda, Maryland 20814 Director j
U. S. Nuclear Regulatory l
- Dr. Kenneth A. McCollom, Dean Commission l
Division of Engine'ering, Maryland National Bank Bldg.
l Architecture and Technology
- Room 10105 i
Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland 20814
- Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel 4
I Oak R.cge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 i
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Chairman Renea Hicks, Esq. '
Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C.
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John Collins Lanny A. Sinkin Regional Administrator, Region IV 114 W. 7th, Suite 220 U. S. Nuclear Regulatory Commission Austin, Texas 78701 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Michael D. Spence, President Dr. David H. Boltz Texas Utilities Generating Company 2012 S. Polk Skyway Tower Dallas, Texas 75224 400 North Olive St., L.B. 81 Dallas, Texas 75201 Docketing and Service Section Anthony Roisman, Esq.
(3 copies)
Trial Lawyers for Public Justice Office of the Secretary 2000 P St., N.W., Suite 611 U. S. Nuclear Regulatory Commission Washington, D. C.
20036 Washington, D. C.
20555 lb. Billie P. Garde Government Accountability Project 1901 Que Street, N. W.
i Washington, D. C.
20009 l
01&
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p.) Juanita Ellis, President l
CASE (Citizens Association for Sound Energy) i 1426 S. Polk I
Dallas, Texas 75224 l
214/946-9446 2
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