ML20099H235
| ML20099H235 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/13/1985 |
| From: | Horin W, Reynolds N BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#185-044, CON-#185-44, CON-185-44 OL, NUDOCS 8503150212 | |
| Download: ML20099H235 (12) | |
Text
O4L}
' ~?** *'m
... - - n.
Y W
<> d:
C
. 'W,ye y
March 13g985 W 14 A9:26 UNITED STATES OF-AMERICA NUCLEAR REGULATORY COMf1ISSION frrg e RSC th gSECRETARv BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3RA C
- EN
'l In the Matter of
)
/
+
)
Docket Nos. 50-445 and"
(
TEXAS UTILITIES ELECTRIC
)
)
)
( Application for (Comanche Peak Steam Electric
)
Operating Licenses)
Station, Units 1 and 2)
)
APPLICANTS' RESPONSE TO CASE'S FOURTH SET OF INTERROGATORIES AND REQUESTS TO PRODUCE "RE: CREDIBILITY" I.
INTRODUCTION Pursuant to 10 C.F.R. $$2.740b and 2.741, Applicants hereby respond to CASE's Fourth Set of Interrogatories and Requests to Produce Ret Credibility, filed February 25, 1985.
Applicants' response is governed further by the Board's February 15, 1985, Memorandum (Motion for Protective Order), whereat the Board granted, in part, Applicants' motions for protective orders by restricting Applicants' obligation to respond to CASE's discovery requests regarding credibilityl "to discovery related to the validity or reliability of tests and samples" (ftemorandum at 1).
1 Accordingly, Applicants respond only to those requests which are 8503150212 850313 PDR A W K 05000445 Q
PDR 1
These discovery requests sore authorized by the Board in t e. S December 10, 1984, Memoran. lum (Reopening Discovery; flis-leading Statement).
3SQ3
I e within the scope of the authorized discovery.
Those discovery requests to which a response is not provided are deemed by Applicants to be beyond that scope.2 4
1 II.
APPLICANTS' RESPONSE TO CASE'S FOURTH SET OF INTERkOGATORIES 2.
Regarding A500 Steel:3 a.(5)(ii):
Do Applicants consider that the sample of pipe supports discussed at the top of page 6 was a randomly selected representative sample?
4
~.<;
Response
Yes.
I a.(5)(iii):
Provide documentation of the specific criteria j
which Applicants originally used in selecting the sample of pipe supports discussed at the top of page 6.
Response
There is no documentation delineating specific criteria.
The " criterion" employed was simply a mechanical j
selection process from a list of all supports in Unit 1 and i
2 Applicants also consider CASE's first through third sets of interrogatories "res credibility"-(filed January 17, February 4 and 25, 1984, respectively) to be outside of this authorized scope in their entirety.
Accordingly, separate
]
responses regarding those requests are not provided.
3 Applicants filed their Response to the Board's Partial Initial Decision Regarding A500 Steel on April 11, 1984.
CASE previously submitted interrogatories regarding this 4
Response on May 17, 1984, with a motion for discovery.
Upon resolution of Applicants' objections, Applicants responded to the~ authorized requests orally and/or-in writing.
4
1:
. I common, which was described in the affidavit accompanying Applicants' April 11, 1984, Response as follows:
5 To generate the sample of supports for this analysis, Applicants first developed alpha-1 betical listings of all Unit I and common area ASME supports for each support design organization (NPSI, ITT-Grinnell and PSE).
Applicants then selected every hundredth support (PSE selected every 90th) from the list.
If the selected. support did not utilize A500 tube steel, the next support on j
the list which did was chosen.
j 4
f l
a.(5)(iv):
hho (name, title, organization at the time)
I determined the specific criteria which Applicants originally used in select i ng the sample of pipe supports discussed at the top of page 6.
Response
John C.
Finneran, Jr.,
Pipe Support Engineer, Pipe Support F.ngineering Group, Comanche Peak Steam Electric Station.
i a.(5)(v):
Who (name, title, organization at the time) actually selected the specific pipe supports included in the sample of pipe supports discussed at the top of page 6?
Response
Three engineers were responsible for identifying the supports in accordance with the predetermined selection j
" criteria".
These individuals were l
G.
M.
Chamberlain for PSE (large bore) i D.
Y. Chuang for PSE (small bore) 1 1
D. M. Rencher for ITT-Grinnell and-NPSI c
O
. a.(5)(vi):
Provide all documentation that the supports assessed by Applicants were worst case supports.
Response
CASE appears to have misinterpreted Applicants' statement regarding " worst case supports" at the top of page 6 of the affidavit accompanying Applicants' Response (see also answer to questions 2.a.(6), below).
There it was stated "
Applicants have examined the actual yield strengths for A500 tube steel in a sample of pipe supports and conservatively assessed the worst case supports."
Applicants did not intend to suggest that the sample of supports selected was itself comprised of the " worst case" supports.
Rather, for all supports in the sample Applicants evaluated the effect of using the revised yield strengths (see Affidavit at 6-7).
In addition, Applicants selected from the sample of supports utilizing A500 tube steel the worst case supports, i.e.,
ten supports with most highly stressed support members (see Affidavit at 7-8), for additional assessment using actual yield strengths.
a.(5)(vii):
Provide a list of all pipe supports included in the sample of pipe supports discussed at the top of page 6.
Response
Cxcept for the PSE small bore supports, Appli-cants already furnished this information by letter dated September 6, 1984.
A list of the PSC small bore supports was not previously requested by CASE.
That list is encloseI with this response.
~
=_.._
. 1 r
a.(5)(viii):
Provide a list of the pipe supports from the sample identified in your answer to (vii) preceding which were considered by Applicants to be the worst case supports which Applicants " conservatively assessed."
Response
The worst case supports Applicants conservatively assessed (see' response to a.(5)(vi)) were the supports from i
the sample with the ten highest stressed members fabricated I
with A500 tube steel (see Applicants' Response (Affidavit at 7-8)).
These supports are:
1 LARGE BORE 4
1.
FW-1-100-002 l
2.
CC-2-028-704-A33A i
3.
4.
CC-1-008-015-S33R l
}
5.
BR-X-044-006-A53R 6.
SW-1-004-013-A33R I
7.
MS-1-004-003-S72R 8.
AF-1-001-035-Y33R SMALL BORE 1.
H-CH-2-AB-010-017-3 i
2.
H-FSI-X-2617-01-02-2 l
l l
In addition, CASE will recall that Applicants already provided CASE with a list of supports, and relevant docu-mentation for the supports, which-Applicants were informed CASE considered to be " worst case",
i.e.,
the 20 large bore
0
. supports with the greatest interaction values and any supports in Applicants' sample which utilized intermediate Richmond Inserts and which were not in the first group of twenty supports (there were three such supports) (see Applicants' letter to CASE dated September 6, 1984.)
a.(5)(ix):
Provide copies of all documentation (calcula-
+ ions, drawings, etc.) for each of the pipe supports listed
,in your answer to (vii) preceding.
1
{
2esponse:
Applicants object to this request as being duplicative, unduly broad and burdensome in light of the documentation already provided CASE.
The issue involved is
- narrow, i.e., whether A500 tube steel members in supports are adequately designed if one assumes the applicability of I
l revised yield values published in an ASME code case.
CASE's l
request is unduly broad in that it seeks material not relevant to the adequacy of the tube steel nembers (e.g.,
all calculations for the supports).
There fo r e, if discovery is to be had at all it should be limited to the portions of the design regarding the A500 tube steel members.
In addition, as previously noted, Applicants have already provided CASE with the drawings and calculations of 23 supports.
Thus, CASE's request is in part duplicative of material already provided.
Finally, the 23 supports for which documentation was already provided were, using CASE's own criteria, the " worst case" supports in the sample.
. Thus, to provide the information CASE now seeks would be unduly burdensome in view of the information already provided.
Applicants submit that no additional benefit would be gained by directing resources to gather and reproduce these documents when those which CASE previously considered were most important to the issue have already been provided.
2.a.(6)(1)-(vii). Response:
These requests duplicate requests 2.a.(5)(ii)-(vii) and (ix), respectively, in that the sample discussed at the top of page 6 in Applicants' affidavit is the same sample discussed in the middle paragraph of that page.
Accordingly, the answers to these two sets of questions are the same.
Respectfully submitted, d1.k l
Nicholas S.
Reptolds William A. Horin BISHOP, LIBERMAN, COOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 (202) 857-9800 counsel for Applicants flarch 13, 1985
State Of Texas
)
j County of Somervell
)
i John C. Finneran, Jr., being first duly sworn deposes and says:
That he is the Pipe Support Engineer, Pipe Support Engineering Group for Comanche Peak Steam Electric Stacion and knows the contents of the foregoing Applicants' Response to CASE's Tourth Set of Interro-Credibility"; that the same is gatories and Requests to Produce "Re:
true of his own knowledge except as to matters therein. stated on infor-macion and belief, and as to that he believes them to be true.
n C. Finneran, Jr.
.sr211 o rc -rw $
rev,v r y aw. L e w aa' Subscribed and sworn to before me this 13th day of March,1985.
hu CX-h.,% < - -
Notary kblic O
Dass 2. Henc.e=J e,y <-n ~.ssa. a t=><irue s u m.e nt,I9S t
/
This is a telecopy facsimile.
The original will be sent under separate cover.
l
e Small Bore Supports H-AF-1-SB-007-004-5 H-CH-2-AB-003-001-3 H-BR-1-SB-003-009-3 H-CH-2-AB-010-017-3 H-BR-X-AB-052-002-3 H-CH-2-AB-018-002-3 H-BR-X-AB-076-009-3 H-CH-X-AB-048-005-3 H-CC-1-AB-033-025-3 H-CH-X-FB-005-009-3 H-CC-1-AB-077-003-3 H-CS-1-AB-023-005-3 i
H-CC-1-RB-004-001-3 H-CS-1-AB-137-001-3 H-CC-1-RB-017-005-3 H-CS-1-AB-214-007-3 1
H-CC-1-RB-056B-006-3 H-CS-1-AB-239-010-2 H-CC-1-SB-001-021-3 H-CS-1-RB-013A-001-2 H-CC-1-SB-018-018-3 H-CS-1-RB-018-034-2 H-CC-1-SB-038-020-3 H-CS-1-RB-060-012-2 H-CC-1-SB-047B-001-3 H-CS-1-SB-099-020-2 H-CC-2-AB-027A-001-3 H-CS-1-SB-061-013-3 H-CC-2-EC-005-009-3 H-CS-1-SB-068-002-3 H-CC-X-AB-020-Oll-3 H-CS-2-AB-039-002-2 H-CC-X-AB-026-009-3 H-CS-2-AB-070-014-2 H-CH-1-AB-026-002-3 H-CS-X-AB-018-003-3 H-CH-1-AB-030-005-3 CS-1-106-701-C42R H-CH-1-AB-037-007-3 CS-1-ll4-703-C41R H-CH-1-AB-046-007-3 H-CT-1-SB-025-019-2 i
H-CH-1-SB-007-022-3 H-DD-1-AB-011-003-3 H-CH-1-SB-010A-026-3 H-DO-1-DG-004-004-3 H-CH-1-SB-020-012-3 H-DO-1-DG-012-027-3 H-CH-1-SB-025-014-3 3
t I
1 O 4 H-DO-1-DG-032-004-3 SI-1-027-719-C41R H-FSI-1-2106-14-01-103 SI-1-108-701-C42R H-FSI-1-2108-01-05-2 H-SW-1-AB-015-003-3 H-FSI-X-2107-05-02-123-010 H-SW-1-SB-001A-003-3 H-FSI-X-2617-01-02-2 H-SW-1-SB-008-001-3 H-GH-1-AB-Oll-001-3 H-SW-1-SB-017-012-3 H-GH-X-AB-004-005-3 H-SW-1-SB-023-009-3 H-GH-X-AB-015A-007-3 H-SW-1-YD-015-002-3 H-GH-X-AB-018B-008-3 H-SW-2-AB-027-019-3 H-OH-X-AB-025B-001-03 H-VA-X-AB-006-005-3 H-GH-X-AB-046-002-3 H-WP-X-AB-020-003-3 H-GH-X-AB-056-001-3 H-WP-X-AB-213-005-3 H-GH-X-AB-065-006-3 H-GH-X-AB-073-Oll-3 H-MS-1-RB-006-004-2
}
H-MS-1-RB-020-003-2 II-MS-1-RB-031-007-2 H-MS-1-SB-012-010-2 H-PS-1-RB-002-002-2 H-PS-1-RB-005-036-2 i
H-PS-1-SB-004-008-3
!!-RC-1-RB-043-006-2 RC-1-053-700-C41S H-Ril-1-SB-Oll-024-2 H-SF-X-AB-007-002-3 H-SI-1-RB-032-003-2 II-SI-1-SB-023A-010-2
,r.,..
_,;. r. av T'
,4
'l
- $$$E8
- KN114 A9 26 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IC #F sg BRANC UCI BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC
)
)
)
( Application for (Comanche Peak Steam Electric
)
Operating Licenses)
Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to CASE's Fourth Set of Interrogatories and Requests to Produce "Re:
Credibility", in the above-captioned matter were served upon the following persons by express mail (*) or deposit in the United States mail, first class, postage prepaid, this 13th day of March, 1985, or by hand delivery (**)
on the 14th day of March, 1985.
- Peter B.
Bloch, Esq.
Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. William L.
Clements
- Dr. Walter H.
Jordan Docketing & Service Branch 881 West Outer Drive U.S.
Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C.
20555
- Dr. Kenneth A.
McCollom Dean, Division of Engineering
- Stuart A.
Treby, Esq.
Architecture and Technology Office of the Executive Oklahoma State University Legal Director Stillwater, Oklahoma 74074 U.S.
Nuclear Regulatory Commission Chairman, Atomic Safety 7735 Old Georgetown Road and Licensing Board Panel Room 10117 U.S.
Nuclear Regulatory Bethesda, Maryland 20814 Commission Washington, D.C.
20555
e t Robert D.
Martin Elizabeth B. Johnson Regional Administrator, Oak Ridge National Laboratory Region IV Post Office Box X U.S.
Nuclear Regulatory Building 3500 Commission Oak Ridge, Tennessee 37830 611 Ryan Plaza Drive Suite 1000 Mrs. Juanita Ellis Arlington, Texas 76011 President, CASE 1426 South Polk Street Renea Hicks, Esq.
Dallas, Texas 75224 Assistant Attorney General Environmental Protection Lanny A.
Sinkin Division Executive-Director P.O.
Box 12548 Nuclear Information and Capitol Station Resource Service Austin, Texas 78711 1346 Connecticut Avenue, N.W.
4th Floor Washington, D.C.
20036 L
William A.
Horin cc:
John W.
Beck Robert A. Wooldridge, Esq.
k