ML20128F813

First Partial Response to Ripe Discovery Request Included in Case First Through Fifth Sets of Interrogatories & Requests to Produce.Certificate of Svc Encl.Related Correspondence

ML20128F813
Person / Time
Site:	Comanche Peak
Issue date:	07/05/1985
From:	Horin W BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
References
CON-#385-685 OL, NUDOCS 8507080371
Download: ML20128F813 (22)

Text

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MED CORM July 5, 1985 UNITED STATES OF AMERICA SC NUCLEAR REGULATORY COMMISSION S

BEFORE THE ATOMIC SAFETY AND LICENSING BOAR JUL -5 P3:53 saa s%

BRNCk El In the Matter of )

) Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC ) 50-446 COMPANY, ET AL. )

) (Application for (Comanche Peak Steam Electric ) Operating Licenses)

Station, Units 1 and 2) )

APPLICANTS' FIRST PARTIAL RESPONSE TO RIPE DISCOVERY REQUESTS I. INTRODUCTION Pursuant to 10 C.F.R. 5 52.740b and 2.741, and in accordance with Applicants' Report Regarding Status of Replies to CASE Interrogatories, filed June 7,1985, Applicants hereby provide their first partial response to ripe discovery requests included in CASE's first through fifth sets of interrogatories and requests to produce "re: credibility."1 Applicants' responses are governed by the May 30, 1985, Memorandum (Clarification of LBP 85-16), wherein the Board indicated that Applicants should respond if the request is "likely to survive regardless of what the S taf f does. "

8507000371 850705 5 DR ADOCK 050 l_/ This first partial response addresses those ripe interrogatories concerning pipe support design.

Applicants' second partial response addresses the remaining ripe requests.

Applicants reached agreement with the intervenor on May 30, 1985, regarding the nature of and schedule for responses to these ripe discovery requests. Applicants have agreed to complete their responses by July 5,198 5. (See May 30, 1985, letter to Mrs. Ellis and Mr. Roisman from Mr. Reynolds, counsel for Applicants.)

II. APPLICANTS' RESPONSE TO CASE'S RIPE INTERROGATORIES A. CASE's Second Set of Interrogatories Applicants previously identified interrogatories 1 and 4 of CASE's second set as potentially ripe for response. However, upon further specification of the nature and scope of the Stone &

Webster review, subsequent to Applicants' June 7, 1985, Report, Applicants no longer consider these questions to be ripe for response. Applicants' position regarding the status of pipe support design issues is set forth in Applicants' Management Plan, filed June 28, 1985.

[ B. CASE's Fourth Set of Interrogatories l Applicants previously identified interrogatories 2, 5 and 8 of CASE's fourth set as potentially ripe for response. However, upon further specification of the nature and scope of the Stone &

Webster review, subsequent to Applicants' June 7, 1985, Report, Applicants no longer consider questions 2 and 5 to be ripe for response. Applicants' position regarding the status of pipe support design issues is set forth in Applicants' Management Plan, filed June 28, 1985.

Applicants are responding to interrogatory 8, concerning the upper lateral restraint. The CPRT intends to review previous analyses of this structure. Thus, information presented in Applicants' motion may ultimately be considered further in this proceeding. Accordingly, Applicants are responding to this interrogatory.

Regarding the Upper Lateral Restraint:

8. a. Isn't it true that LOCA was not considered in the original design of the upper lateral restraint?

b. What was Applicants' rationale for not considering LOCA in the original design of the upper lateral restraint?

c. Provide all documents (as defined on page 2, item 3, of this pleading) regarding your answer to b.

-preceding.

Response

Question 8.a.: No. LOCA was considered in the original design of the upper lateral restraint in terms of mechanical loads. The loads resulting f rom the thermal expansion of the beam following a LOCA were not considered in designing the beam because the AISC Code does not require it, and even if one were to consider the upper lateral restraint as a Section NF support (which it is not), the ASME Code (Section NF-3231.1) does not require calculations to be performed to account for such thermal effects on the beam.

Question 8.b.: The reasons for not considering LOCA thermal loads on the beam itself are indicated above. Because thermal expansion loads on the concrete walls were not considered, based <

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on engineering judgment, Applicants prepared the analyses J presented in the affidavit to assess those loads.

Question 8.c.: Pertinent documentation as referenced in the above answers will be supplied as Exhibit 8.1.

C. CASE's Fifth Set of Interrogatories Applicants identified interrogatories 8.a. and c.; 15-25; 27; and 29-31 as potentially ripe for response in their June 7, 1

1985, Report. However, upon further specification of the nature and scope of the Stone & Webster review, subsequent to Applicants' June 7, 1985, Report, Applicants no longer consider 4- questions 8.a. and c.; 23; 25; and 29-31 to be ripe for response.

Applicants' position regarding the status of pipe support design issues is set forth in Applicants' Management Plan, filed June 28, 1985.

Applicants are responding (to the extent answers are not i otherwise being provided in connection with Applicants' responses regarding tests and samples) to interrogatories 15-22, 24 and 27, which concern Richmond Insert and Cinched U-Bolt data. Stone &

Webster's review of that material is ongoing. The data regarding these topics may, ultimately, be utilized in this proceeding if Stone & Webster considers it appropriate to do so in conjunction

(_

f with their reanalyses. Consequently, Applicants respond to those requests now to provide CASE with this information at the

{ earliest possible time.

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Regarding Richmond Inserts:

Where an affidavit is referenced, it is the 6/1/84 Affidavit of John C. Finneran, Jr., Robert C. Iotti and R. Peter Deubler Regarding Design of Richmond Inserts and Their Application to Support Design, which is Attachment 1 to Applicants' Motion for Summary Disposition Regarding Design of Richmond Inserts and Their Application to Support Design.

15. Affidavit at page 9, last paragraph, continued on page 10:

a. How many supports are there in Unit 1 and common areas which employ Richmond inserts?

How many in Unit 27 I

b. Provide the rationale for reviewing only 912 supports in Unit 1 and common areas.

c. Provide and rationale for reviewing the specific 912 supports which were reviewed.

d. What was the reason for the review (i.e., what was the stated purpose, what triggered the review, etc.)?

e. Provide any and all documentation for your answers to

a. through d. preceding?

Response

Question 15.a.: Our review of the support drawings for Unit 1.and common, conducted in preparation for the affidavit, indicated that there were 912 supports which utilized Richmond Inserts. Applicants have since conducted an additional review and have found that the approximate number of safety-related i

! supports utilizing Richmond inserts are:2 i

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l 2/ CASE should note that Applicants have not yet corrected the affidavit to reflect these numbers.

Applicants are currently committed to provide the Board with corrections to all affidavits.

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Unit X Unit 1 (Common)

Large Bore 930 6 Small Bore 30 3 All of these inserts will be assessed by Stone & Webster as part of their ongoing effort. We did not review the drawings of Unit 2 supports. Applicants object to providing information regarding Unit 2 supports as unduly burdensome. Applicants would need to review each of the thousands of supports in Unit 2 to obtain that information.

Question 15.b.: See response to Question 15.a.

Question 15.c.: See response to Question 15.a.

Question 15.d.: The review was prompted by the questions raised by CASE. The purpose of the review was to address those questions.

Question 15.e.: The only pertinent documentation to respond to the request would be the thousands of drawings we reviewed. Applicants object to providing these drawings as unduly burdensome.

16-18. Responses are provided in Applicants' third partial response to CASE's fifth set _of interrogatories re: credibility.

19. Affidavit at page 21, answer, middle of page:

a. How many supports were reviewed?

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b. Provide any and all documentation that the finite element analyses provided results which are representative of the actual conditions at CPSES.

c. (1) Did the analyses consider the variability of the tube steel material properties, length end conditions; i.e., welded plates, angularity of the rod and insert?

(2) Isn't it true that the effect of the top of the tube would resist the load first, and then the bottom would resist, as demonstrated in the drawing below:

Drawing not reproduced (3) Provide any and all documentation of your answers to (1) and (2) above.

Response

Question 19.a.: Applicants reviewed approximately 100 supports which are listed in Table 1 of the Affidavit as having 4 x4 tube steel. Another approximately 50 supports had tube steel of different dimensions.

Question 19.b.: The finite element analyses (FEA) provided results for a combination of tube steel and Richmond Inserts which is quite prevalent at CPSES, i.e., 1-1/2 " insert with 4 x 4 x 3/8 " tube steel. The FEA was solely intended to assess the proper manner of determining torsional resistance of tube steel, i.e. , what arm length should be used to couple out the torsion applied to the tube steel, and not to analyze any specific configuration at CPSES.

Question 19.c.(1): No.

Question 19.c.(2): Not necessarily. That would depend on the direction of the load and the location of the bolt in the bolt hole.

l Question 19.c.(3): There is no documentation relating to 1

the answers to Questions c.(1) and c.(2).

20. Response is provided in Applicants' third partial response to CASE's fifth set of interrogatories re: credibility.

21. Affidavit at page 24, continuing on page 25:

a. Provide the screening criterion and any and all documentation regarding it or its results.

b. How does this criterion relate to bolt holes that are offset?

c. Why wasn't the gap between the bolt and hole considered?

-d. How do Applicants account for the offset in designs less than 1.757

e. Isn't it true that it is standard industry practice to use a factor of 1.0, rather than the 1.75 used by Applicants?

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f. What-is Applicants' rationale for using a factor of 1.75 rather than following standard industry practice?

g. Based on the test data, what confidence level is there i that he connection will behave as intended with relation to the

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1.75 factor proposed by Applicants and the 1.0 factor that is i used in all designs except for Richmonds?

h. Provide any and all documentation for your answers to

a. through g. preceding.

Response

Question 21.a.: The screening criterion is provided in the

-Affidavit (at 25), as is the pertinent documentation.

Question 21.b.: Consideration of offset bolt holes was included in the analysis which produced the interaction ratios which were measured against the screening criterion of 1.75 (See

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Table 1 of the Affidavit for offsets). This is described on page 26 of the Affidavit.

Question 21.c.: The gap was assumed to be in the worst configuration, i.e., producing maximum torsion.

Question 21.d.: See response to Question 21.b.

Question-21.e.: There is no standard industry practice for

. combination of shear, tension and bending in bolts.

Question 21.f.: See response to Question 21.e.

l Question 21.g. , h.: The answer to this question was, in part, provided as Attachment F to the Affidavit. Also, the confidence level that a connection will have an adequate safety margin when evaluated against an interaction ratio allowable of l.75 is discussed at pages 29 and 30 of the Affidavit.

Applicants note there that the factor of safety of the connection is greater than four.

In addition, in the attached chart (Figure 21.g.(a)/(b)) we have plotted the interaction ratio equation for varying values of i the moment ratio Mb ! ba where M ba

= 0.75 Fy. Also plotted on the chart are the results of the tests reported in Attachment F of i the Affidavit. These test points are approximate because the

, precise distribution of the load in shear, tension and bending l

cannot be established.

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22. Affidavit at page 34:

l a. Has a study been performed for lengths greater than 20 l

inches?

b. If the answer to a. preceding is no, why not?

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c. If the answer to a. preceding is yes, what are the results of such study (or studies) and how does this correspond to what has been stated in the Affidavit?

d. What were the effects when the concrete strengths varied?

e. What were the results when the concrete varied?

f. What were the stresses imposed on the concrete due to the bending in this analysis?

g. Provide any and all documentation for your answers to

a. through f. preceding.

Response

Question 22.a.: Yes. See September 24, 1984, response to NRC questions, section H(e).

Question 22.b.: Not applicable.

Question 22.c.: See response to Question 22.a.

Question 22.d.: Concrete strength variation effects were not studied.

Question 22.e.: See response to Question 22.d.

Ques tion 22. f. : Stress on concrete was not specifically calculated. However, it is our opinion that stresses would still be below those that would be computed on the basis of the coupling out method, i.e., resolving the torsion into tension in the bolt and compression in the concrete, because bending of the bolt relieves some of the compression in the concrete. In resolving the torsion of the tube steel into increased bolt tension and concrete compression, stresses in the concrete are computed and, if limiting, determine the maximum acceptable torsional load on the tube steel. When bolt bending is considered, the bending stiffness of the bolt reduces the compressive load of concrete for an equal torsional load.

Question 22.g.: The only documentation is an NPSI chart illustrating the relationship between concrete compression and increased bolt tension. The chart has been forwarded to CASE as Exhibit 22.1.

24. Response is provided in Applicants' third partial response to CASE's fifth set of interrogatories re: credibility.

Regarding Cinched-Down U-Bolts:

Where an affidavit is referenced, i is the Affidavit of Robert C. Iotti and John C. Finneran, Jr. Regarding Cinching Down of U-Bolts, which was Attachment 1 to A glicants' 6/29/84 Motion for Summary Disposition of CASE's Alleg tions Regarding Cinching Down of U-Bolts. See also CASE's 11/5/ 4 Motions and CASE's Answer to Applicants' Response to Board Request for Information Regarding Cinching Down U-Bolts.

27. Regarding the raw data underlying Table 2 contained in Applicants' Motion for Summary Disposition on cinched-down U-bolts:

a. What criteria was [ sic] utilized to select.the particular supports which were included in the sample?

i b. Regarding the 10/8/82 Brown & Root procedure for torquing U-bolts:

l l (i) How many of the supports included in the sample I

had their U-bolts cinched down after the 10/8/82 Brown & Root procedure went into effect?

, (ii) How many of the supports included in the sample

! were torqued after the procedure went into effect?

l (iii) How many of he supports included in the sample were inspected for torquing after the procedure went into effect?

(iv) How many of the supports in Unit I had their U-bolts cinched down?

(a) before the 10/8/82 Brown & Root procedure went into effect?

(b) after the 10/8/82 Brown & Root procedure went into effect?

(v) How many of the supports in Unit 1 were torqued:

(a) before the procedure went into effect?

(b) after the procedure went into effect?

(vi) How many of the supports in Unit 1 were inspected for torquing:

(a) before the procedure went into effect?

(b) after the procedure went into effect?

(vii) Indicate which of the following multiple choices is/are correct:

The 10/8/82 procedure was:

(a) utilized in the torquing of U-bolts of Unit 2, whereas it was not utilized, in most cases, in Unit 1 and common.

(b) utilized in the torquing of all U-bolts in Unit 2.

(c) utilized in the torquing of all U-bolts in Unit 1.

(d) utilized in the torquing of all U-bolts in Common.

(e) utilized in the torquing of (20%, 30%, 40%,

50%, 60%, 70%, 75%, 80%, 85%, 90%, 95%)

(choose the percentage which is the most nearly accurate for each] of the U-bolts in:

Unit 1 common Unit 2

c. List each support referenced in your answer to b.

preceding.

d. Regarding the listing attached to Applicants' 10/23/84 Response to Board Request for Information Regarding Cinching Down U-Bolts:

(1) For each support listed, state which building the support is in.

(2) For each support listed, state whether or not it is safety-related.

(3) Provide any and all documentation that the supports in the sample are representative of the supports?

(i) in Unit 1.

I (ii) in common.

(iii) in Unit 2.

1 (iv) in Unit 1, in common, and in Unit 2 (i.e.,

throughout the entire plant)

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e. Was there any type of reliability analysis performed so that one could extract the confidence level as to whether the supports would be stable utilizing.the cinched-down torque values (i.e. , as to whether there

, is sufficient torque applied to assure stability)?

. (1) Provide any and all documentation for your answer.'

I f. Provide any and all documentation for each of your answers to a. through d. preceding.

Response

Question 27.a.,-b(i),(ii) and (iii): The answers to these 3 questions have 'already been provided in " Applicants' Response to Board Request for Raw Data Regarding Cinching Down U-Bolts",

' dated November 9, 1984, " Applicants' Reply to CASE's Motion Concerning Information Regarding Cinching Down U-Bolts" dated November 19, 1984, and " Applicants Motion for Reconsideration of Licensing Board's Memorandum (Reopening Discovery, Misleading Statement)", dated January 7,1985. Applicants elaborated

further on these topics in their presentation to the NRC Staff on April 22, 1985. CASE should note that the information in these documents does not relate to all the U-bolts in the sample.

Within the time available to provide responses, Applicants reviewed construction packages for the safety-related supports, ,

approximately 120 of the 160 U-bolts sampled.

Question 27.b.(iv)(a): Applicants do not know this number because only the sampled supports were examined. Providing further information would require a review of several documents with respect to each of hundreds of supports. Accordingly, Applicants object to providing such information as unduly burdensome. This question is irrelevant in any case, because there is no difference in torquing practices before or after the 10/8/82 date.

Question 27.b.(iv)(b): See response to Question 27.b.(iv)(a).

Question 27.b.(v): See response to Question 27.b.(iv),

" torqued " and " cinched down" in this context are synonymous. .

Question 27.b.(vi): See responses to Questions 27.b.(iv) and (v).

Question 27.b.(vii)(a): A not inconsiderable number of Unit 1 and comnon U-bolts were cinched down after 10/8/82, although most of the Unit 1 and Common U-Bolts were torqued prior to this date.

j Question 27.b.(vii)(b): A not inconsiderable number of Unit 2 U-bolts were torqued prior to 10/8/82.

Question 27.b.(vii)(c): False.

Question 27.b.(vii)(d): False.

Question 27.b.(vii)(e): Applicants do not know.

Question 27.c.: Applicants have prepared a list of the Unit 1 and Common cinched U-bolts on single struts and snubbers, which will be provided to CASE as Exhibit 27.1. To assemble a list of all other supports in Units 1 and 2, and in common, would be extremely burdensome. Accordingly, Applicants object to doing so. CASE should also refer to the list of supports Applicants reviewed in determining that there were no differences in torquing practices before and after 10/8/82. That list is attached to the Affidavit submitted to the Board in " Applicants' Response to Board Request for Raw Data Regarding Cinching Down U-Bolts," dated November 9, 1984.

Question 27.d.(1),(2): See Response to Question 3.d. in Applicants' April 25, 1985, first partial response.

Question 27.d.(3): See response to Question 27.a., b'(i),

(ii) and (iii).

Question 27.e.: No.

Question 27.f.: Applicants will provide the relevant l

documentation referenced above (Exhibit 27.1).

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Respectfully submitted G>d\~ h. W Nicholas S. Reynolds William A. Horin g{

BISHOP, LIBERMAN, COOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202) 857-9817 Counsel for Applicants July 5, 1985 4

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State of Texas County of Somervell 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 Station and knows the contents of the foregoing Applicants' First Partial Response to Ripe Discovery Requests; that the same is true of his own knowledge except as to matters therein stated on infomation and belief, and as to that he believes them to be true.

Gcd2F John C. Fint tan, Jr.

State of Texas County of Somervell Subscribed and sworn to before me this 3rd day of July,1985.

bEeW See Bill Hodges, Olbtary Pub 5-it My Commission Expires March 28, 1988.

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State of New York )

County of New York)

ROBERT C 10TTI, using first duly sworn deposes and says:

That he is Vice President of Advanced Technologies for Ebasco Services Inc, and knows the contents of the foregoing Applicants' "First Partial Response to Ripe Discovery Requests"; that the same is true of his own knowledge except as to matters therein stated on information and belief, and as that he believes them be true. ,.

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Robert C Iotti' )

State of New York )

County of New York)

Subscribed and sworn to before me this 3rd day of July, 1985.

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p o s. .

Notary Public

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8Trux ctrr N3+"Y Pssb!:c. State of New York No. 311444786 Que ;.ud .rs New York County Comowevse cegirvs Wr. 30,19#.

This is a telecopy facsimile. The original

, will be sent under separate cover.

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-o W TED q UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00C TED 0 C BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 15 JM. -5 P3 :53 0FFICE OF SEcath ,

In the Matter of ) 00CKETmG & SERVICL

) Docket Nos. 50-445 anyCH TE)RS UTILITIES ELECTRIC ) 50-446 COMPANY, ET AL. )

) (Application for (Comanche Peak Steam Electric ) Operating Licenses)

Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' First Partial Response to Ripe Discovery Requests" in the above-captioned matter-was served upon the following persons by express mail (*),

or deposit in the United States mail, postage prepaid, or by hand delivery (**) on this 5th day of July, 1985.

• • Peter B. Bloch, Esquire Chairman, Atomic Safety Chairman, Atomic Safety and and Licensing Appeal Licensing. Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C . - 20555 Washington, D.C. 20555

• Dr. Walter H. Jordan Mr. William L. Clements 881 West Outer Drive Docketing and Service Oak Ridge, Tennessee 37830 Branch U.S. Nuclear Regulatory

• Dr. Kenneth A. McCollom Commission Dean, Division of Washington, D.C. 20555 Engineering, Architecture and Technology **Stuart A. Treby, Esquire Oklahoma State University Office of the Executive

' Stillwater, Oklahoma 74074 Director U.S. Nuclear Regulatory

. Commission i Washington, D.C. 20555 i

e

_ . . - - . _ . - - - - ~ -

Chairman, Atomic Safety

• Elizabeth B. Johnson and Licensing Board Oak Ridge National Panel Laboratory U.S. Nuclear Regulatory Post Office Box X Commission Building 3500 Washington, D.C. 20555 Oak Ridge, Tennessee 37830 Robert D. Martin Renea Hicks, Esquire Regional Administrator, Assistant Attorney General Region IV Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12546 611 Ryan Plaza Drive Capitol Station Suite 1000 Austin, Texas 78711 Arlington, Texas 76011

• Mrs. Juanita Ellis Lanny A. Sinkin President, CASE 3022 Porter Street 1426 South Polk Street Suite 304 Dallas, Texas 75224 Washington, D.C. 20008 Nancy Williams Ms. Billie P. Garde Cygna Energy Services, Inc. Citizens Clinic Director 101 California Street Government Accountability Suite 1000 Project San Francisco, CA 94111 1555 Connecticut Avenue, N.W.

Suite 202 Washington, D.C. 20036 David A. Repka '\

cc: John W. Beck Robert A. Wooldridge, Esq.

.