ML20093B012
| ML20093B012 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/02/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#484-321 OL, NUDOCS 8410090429 | |
| Download: ML20093B012 (7) | |
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.~:n 10/2/84 DOCHET,ED
~USHRv UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 84 DCT-9 gio:4y BEFORE THE ATOMIC SAFETY Af D LICENSING BOARD OFFICE rc [et$.l" In the Matter of l
00CHEring
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BFANCH TEXAS UTILITIES GENERATING l
Docket Nos. 50-445-D C.
COMPANY, et al.
l and 50-446-() {
l (Comanche Peak Steam Electric Station
]
' Station, Units 1 and 2) 1 1
CASE'S ANSWER TO APPLICANTS' REPLY TO CASE'S ANSWER TO APPLICANTS' MOTION REGARDING ALLEGED ERRORS MADE IN DETERMINING DAMPING FACTORS FOR OBE AND SSE LOADING CONDITIONS CASE (Citizens Association for Sound Energy), Intervenor herein, hereby files this, its Arswer to Applicants' Reply to CASE's Answer to Applicants' Motion Regarding Alleged Errors Made in Determining Damping Factors for OBE and SSE Loading Conditions.
As discussed in CASE's 10/1/84 Answer to Applicants' Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Consideration of Friction Forces, it is CASE's belief and understanding that additional responses are permitted when new information is contained is Applicants' replies, and when additional responses are necessary in order for the Board to have a complete record on which to rule.
As discussed in our 10/1/84 Answer, it is absolutely essential that the Board have a complete record in order for the Board to have an adequate basis to make an informed, reasoned judgement, especially in light of the unusual handling of the design / design 0A issues and the desire of the Board and all parties to handle these matters if at all possible in writing and without the necessity for additional hearings. Further, fairness requires that supplemental responses 1
8410090429 841002 DR ADOCK 05000
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- t-be allowed where necessary to clarify meanings or correct erroneous impressions, especially due to-the severe time restrictions under which CASE and its two engineering witnesses have had (and are still having) to operate, at times to the detriment of CASE, its witnesses, and the record.
It should also be noted that the NRC Staff has not yet answered Applicants' Motions for Summary Disposition on: Damping OBE/SSE; AWS/ASME (Design);
Friction; Section Properties; Gaps; Upper Lateral Restraint; Safety Factors; Generic Stiffnesses; U-Bolts As Two-Way Restraints; Richmond Inserts; Stability; Local Displacements; Differential Displacements; Cinched-Up U-Bolts; Design 0A; or Axial Restraints... although one of the reasons the Board placed CASE under such severe time restrictions was because we had to beat the Staff. It should also be noted that CASE has now answered 15 out of 18 of Applicants' Motions for Summary Disposition, often-times in great haste, with resultant prejudice to CASE unless we are permitted to supplement our responses.
It should further be noted that CASE does not have a staff of engineers available to check and re-check the work of our two lone engineers (as both Applicants and NRC Staff do), and many times Messrs. Walsh and Doyle have been placed in the untenable and unfair position of not having sufficient time to thoroughly check their own work, much less one another's work.
CASE believes that the Board is aware of all of these circumstances and recognizes the need for fairness and a complete record; however, we believe it is necessary to reiterate CASE's position here for the record.
In this particular instance, most of the information contained in Applicants' Reply is arguable and, we believe, has already been discussed s
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sufficiently in CASE's 8/6/84-Answer. However, as pointed out by Mr. Walsh in his Affidavit attached to CASE's 10/1/84 Answer to Applicants' Reply on friction forces (Affidavit at pages 8 and 9):
"It should be noted that.I have not even attempted to address Applicants' characterizations of statements made in CASE's Answer (although I do not agree with many of those characterizations), since they are arguable.
If the Board does not understand what we are disagreeing with in Applicants' Motion or feels thst it needs additional information to clarify any of the statements in our previous Answer (or in this Answer), we ask that they so advise and allow us the opportunity to provide such additional information. As the Board is aware, our Answers were prepared under severe time constraints which did not afford time for adequately rechecking our work.
In addition, it is difficult to put these details regarding design into words."
As stated by Mr. Walsh in the preceding regarding friction forces, we are not addressing here Applicants' characterizations of CASE's pleading (although we do not agree with many of those characterizations), because we believe that we have made our position clear and that the Board has sufficient information on which to base its decision without further argument being necessary. (If the Board believes otherwise, please advise.)
There is only one particular portion of Applicants' Reply on damping factors to which CASE would call the Board's attention.
In Dr. Iotti's original Affidavit /1/, regarding whether or not Applicants use 1 and 2 percent, or 2 and 4 percent, damping values, he stated (page 4):
"Apparently, CASE was misled by the statement made in the SIT report at
- p. 48.
That statemcat is, as follows:
"'The Special Inspection Team concluded that these response spectra characteristics, together with the fact that the SSE damping value of 4 percent is twice the OBE damping value of 2 percent led to the condition expressed in Mr. Doyle's concern.'
fl/ Affidavit of Robert C. Iotti Regarding Alleged Errors Made In Determining Damping Factors for OBE and SSE Loading Conditions, attached to Applicants' Hotion for Summary Disposition Regarding Alleged-Errors Made in Determining Damping Factors for OBE and SSE Loading Conditions.
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i "The SIT was not clear that the use of 2 and 4 percent damping f actors in the analysis of OBE and SSE conditions to which it refers was with respect to that aspect of the analysis in which closely spaced modal responses are combined using a coupling factor.
." (Emphasis added.)
This statement would seem to indicate that Dr. Iotti had some knowledge of what the SIT actually reviewed, and that the SIT just did not make it clear or that the SIT itself was not clear regarding this.
However, in Dr. Iotti's second Affidavit /2/, he states (page 7):
"I have also reviewed the computer input for this stress problem prior to the time of the SIT review (dated March 29, 1981). That computer run employed I and 2 percent damping for both the spectra and, coupling coefficients.
In rum, we have not been able to determine why the SIT reported the 2 and 4 percent damping.
Based on my conversations with the Staff it appears there may simply have been a misunderstanding in verbal discussions with the SIT regarding the intent to use in later runs of the stress problem 2 and 4 percent dampine for the coupling coefficient." (Emphases added.)
See also discussion on pages 4 and 5, answer 3, of Affidavit of CASE Witness Mark Walsh f3/.
It appears to CASE that there are at least three possibilities here with which the Board must deal:
(1) The SIT reported the 2 and 4 percent damping because the documentation which they reviewed showed that was whatwas being used; f2/ Affidavit of Robert C. Iotti in Support of Applicants' Reply to CASE's Answer to Applicants' Motion Regarding Alleged Errors Made in Determining Damping Factors for OBE and SSE Loading Conditions, attached to Applicants' 9/21/84 Reply to CASE's Answer to Applicants' Hotion Regarding Alleged Errors Made in Determining Damping Factors for OBE and SSE Loading Conditions.
/3/ CASE's Answer to Applicants' Statement of Material Facts As to Which There Is No Genuine Issue Regarding Applicants' Consideration of Damping Factors for OBE and SSE Loading Conditions in the form of Affidavit of CASE Witness Mark Walsh, attached to CASE's 8/6/84 Answer to Applicants' Motion for Summary Disposition Regarding Alleged Errors Made In Determining Damping Factors for OBE and SSE Loading Conditions.
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(2) The SIT's originial statement was based on conversations with Applicants, rather than on review of documentation, and those conversations led the SIT to the conclusion that 2 and 4 percent damping were being used; or (3) The S1T Report was in error, as is suggested by Applicants.
If this is the case, there are certain questions which should be answered by the SIT, including but not limited to: Why has it 4
taken so long for the SIT to inform the Board and parties of their j
error? Ilow many other such errors may exist in the SIT Report?
In any event, it appears to CASE that this is an area which the SIT must clarify for the Board, along with a complete explanation of the circumstances regarding this matter.
Respectfully submitted, Luna dr, fD'n j~pfs.)JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 i
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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 Peak 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 Answer to Applicants' Reply to CASE's Answer to Applicants' Motion Regarding Alleged trrors Plade in Uetermining Udmping tactors Tor Ubt anc SSE Loading Conditions have been sent to the names listed below this 2nd day of October
,198_4, 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 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 Execucive Legal Bethesda, Maryland 20814 Director U. S. Nuclear Regulatory
- Dr. Kenneth A. McCollom, Dean Commission 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 Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 1
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.
20555 Austin, Texas 78711 John Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 l
Lanny A. Sinkin 114 W. 7th, Suite 220 Austin, Texas 78701 Dr. David H. Boltz 2012' S. Polk Dallas, Texas 75224 Michael D. Spence, President Texas Utilities Generating Company Skyway Tower 400 North Olive St., L.B. 81 Dallas, Texas 75201 Docketing and Service Section (3 copies)
Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C.
20555
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/s (M()()JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-5446 i
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