ML20138R876
| ML20138R876 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/14/1985 |
| From: | Tyler T TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#485-209 OL, NUDOCS 8511190177 | |
| Download: ML20138R876 (6) | |
Text
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at1An.u coalu'_wusuf',so Filed: November 14, 1985 O
185 mig Ai0:33 UNITED STATES OF AMERICA ~"r/c(,,
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Si NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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Docket Nos. 50-445 TEXAS UTILITIES GENERATING
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50-446 COMPANY et al.
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(Application for an (Comanche Peak Steam Electric
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Operating License)
Station, Units 1 and 2)
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SUPPLEMENT TO APPLICANTS' RESPONSES TO
" CASE'S 8/27/85 INTERROGATORIES TO APPLICANTS AND REQUESTS TO PRODUCE" AND REQUEST FOR PROTECTIVE ORDER The Applicants hereby supplement their answers, filed and served October 22, 1985, to " CASE's 8/27/85 Interrogatories to Applicants and Regeust to Produce."
Interrogatory / Request No. E-15 Question / Request:
E-15. Please provide all documentation' relied on by Applicant as the basis for the statement on page 2 of Mr. Counsil's letter that:
" Fatigue loading is not a factor for these welds."
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Answer:
See answer to Interrogatory / Request No. E-24.
Interrogatory / Request No. E-24 Question / Request:
E-24. Please provide complete copies of all review (s) and/or engineering evaluations performed by Gibbs
& Hill which forms the basis for the acceptance criteria and which " concluded that the criteria are applicable to the non-ASME structural welds at Comanche Peak."
(Cf. page 3 of Mr. Counsil's letter.)
Response
The statement made was based upon knowledge of the code requirements apolicable to, and employed in, the design of supports and knowledge of the FSAR requirements applicable thereto, together with verbal confirmation from the designer that fatigue loading was not a factor in the design of the welds in question.
No documentation was necessary to make, or obtained as a basis for making, the statement.
The d<rsigner's concurrence in the use of VWAC is documented in DCA Nos. 23107.(Rev. 1), 23108 (Rev. 1) and 23109 (Rev. 1),
which will be produced in accordance with paragraph 2 of " General Responses," as set forth in the answers filed by the Applicants on October 22, 1985. _
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Signatures As to Answers:
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Terry G.
Tyler, being first duly sworn,Ido depose and say that I am the Program Director of the Comanche Peak Response Tem ("CPRT") (see " Comanche Peak Response Team Program Plan," 6/28/85), that I am familiar with the information contained in the CPRT files and available to CPRT third-party personnel, that I have assisted in the preparation of the foregoing answers, and that the foregoing answers are true, except insofar as they are based on information that is available to the CPRT (third-party personnel) but not within my personal knowledge, as to which I, based on such information, believe them to be true.
Jmo.1 Terry gf./ Tylef S
n to before me this of November, 1985:
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-m Notary Public
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My Commission Shires:
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As to Objections:
klW Thomas G. Dignan, Jr.
R. K. Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for the Applicants O
M' CERTIFICATE OF SERVICE I,
Robert K. Gad III, one of the attorneys for the Applicants herein, hereby certify that on November 14, 1985, I made service of the within document by mailing copies thereof, postage prepaid, to:
Peter B. Bloch, Esquire Herbert Grossman Chairman Alternate Chairman Administrative Judge Administrative Judge Atomic-Safety and Licensing Atomic Safety and Licensing Board Board 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 Administrative Judge Docketing & Services Branch 881 W. Outer Drive U.S. Nuclear Regulatory Comrission Oak Ridge, Tennessee 37830 Washington, D.C.
20555 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Stuart A. Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission 7735 Old Georgetown Road Room 10117 Bethesda,Margand 20814
5 Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O.
Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C.
20555 Anthony Roisman, Esquire Joseph Gallo, Esquire Executive Director Isham, Lincoln & Beale Trial Lawyers for Public Justice 1120 Connecticut Avenue, N.W.
2000 P Street, N.W.,
Suite 611 Suite 840 Washington, D.C.
20036 Washington, D.C.
20036 Dr. Kenneth A. McCollcm Mr. Lanny A.
Sinkin Administrative Judge 3022 Porter Street, N.W., #304 Dean, Division of Engineering, Washington, D.C.
20008 Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74078 Ms. Billie Pirner Garde Mr. Robert D. Martin Citizens Clinic Director Regional Administrator, Government Accountability Project Region IV 1901 Que Street, N.W.
U.S. Nuclear Regulatory Commission Washington, D.C.
20009 Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esquire Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O. Box X, Building 3500 U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Maryland National Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Nancy Willd.ams Mr. James E. Cummins Cygna Energy Services, Inc.
Recident Inspector 101 California Street Comanche Peak S.E.S.
Suite 1000 c/o U.S. Nuclear Regulatory San Francisco, California 94111 Commission P.O.
Box 38 Glen Rose, Texas 76043
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k Robert K. Ga /III
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