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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
[Table view] Category:PLEADINGS
MONTHYEARML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A6131993-01-0707 January 1993 Motion for Leave to File Out of Time & Request for Extension of Time to File Brief.* Petitioners Did Not Receive Order in Time to Appeal & Requests 15 Day Extension from Motion Filing Date to Respond.W/Certificate of Svc ML20127A7911992-12-31031 December 1992 Petitioner Amended Motion for Continuance to File Appeal Brief.* Petitioners Requests Until C.O.B. on 930108 to File Appeal Brief.W/Certificate of Svc ML20127A7641992-12-30030 December 1992 Petitioner Motion for Continuance to File Appeal Brief.* Counsel Requests That Petitioners Be Granted Until 930109 to File Brief in Support of Notice of Appeal.W/Certificate of Svc ML20128C9751992-12-0303 December 1992 NRC Staff Response to Motion to Compel Disclosure of Info Secreted by Restrictive Agreements & Notification of Addl Evidence Supporting Petition to Intervene by B Orr,D Orr, J Macktal & Hasan.* W/Certificate of Svc ML20128B8721992-11-27027 November 1992 NRC Staff Response to Motion for Rehearing by RM Dow, Petitioner.* Motion for Rehearing Should Be Denied for Reasons Explained in Encl.W/Certificate of Svc ML20128A0271992-11-25025 November 1992 Texas Utilities Electric Co Answer to Motion to Compel Disclosure of Info Secreted by Restrictive Agreements.* Util Requests That Petitioners 921118 Motion to Compel Be Denied in Entirety.Certificate of Svc Encl ML20127P8181992-11-25025 November 1992 Texas Utilities Electric Co Answer to Notification of Addl Evidence Supporting Petition to Intervene.* Petitioners Notification Procedurally Improper & Substantively Improper & Should Be Rejected by Board.W/Certificate of Svc ML20116M4591992-11-19019 November 1992 TU Electric Opposition to Motion for Rehearing by RM Dow.* RM Dow 921110 Motion for Rehearing Should Be Denied.W/ Certificate of Svc ML20127M4271992-11-15015 November 1992 Motion to Compel Disclosure of Info Secreted by Restrictive Agreements.* Petitioners Bi Orr,Di Orr,Jj Macktal & SMA Hasan Requests That Board Declare Null & Void Any & All Provisions in Settlement Agreements.W/Certificate of Svc ML20116M3181992-11-10010 November 1992 Motion for Prehearing by RM Dow,Petitioner.* Requests Period of Ten Days to File Supplemental Pleading to Original Petition.Certificate of Svc & Statement Encl ML20106D8881992-10-0808 October 1992 Opposition of Util to Motion for Extension of Time to File Brief by SL Dow Doing Business as Disposbale Workers of Plant & RM Dow.* Request for Extension of Time & to Become Party to Proceeding Should Be Rejected.W/Certificate of Svc ML20106D2821992-10-0505 October 1992 Motion for Extension of Time to File Brief by SL Dow Doing Business as Disposable Workers of Comanche Peak Steam Electric Station & RM Dow.* Petitioner Requests 30-day Extension.W/Certificate of Svc ML20101P5891992-06-30030 June 1992 Response of Texas Utils Electric to Comments of Cap Rock Electric Cooperative,Inc. Dispute Strictly Contractual Issue Involving Cap Rock Efforts to Annul Reasonable Notice Provisions of 1990 Power Supply Agreement ML20127K8141992-05-19019 May 1992 Request to Institute Proceeding to Modify,Suspend or Revoke License Held by Util for Unit 1 & for Cause Would Show Commission That Primary Place of Registration for Organization Is Fort Worth,Tarrant County,Tx ML20096A6281992-05-0707 May 1992 Applicants Reply to Opposition cross-motions for Summary Disposition & Responses to Applicants Motion for Summary Disposition.* Applicants Conclude NRC Has No Authority to Retain Antitrust Licensing Conditions.W/Certificate of Svc ML20095C4691992-04-17017 April 1992 TU Electric Answer to Application for Hearings & Oral Argument by M Dow & SL Dow.* Concludes That NRC Should Deny Application for Oral Argument & Hearings on Petition to Intervene & Motion to Reopen.W/Certificate of Svc ML20091E2561992-04-0606 April 1992 Application to Secretary for Hearings & Oral Argument in Support of Motion for Leave to Intervene out-of-time & Motion to Reopen Record Submitted by SL Dow Dba Disposable Workers of Comanche Peak Steam Electric Station & RM Dow.* ML20094K4161992-03-16016 March 1992 TU Electric Answer to Petition to Intervene & Motion & Supplemental Motion to Reopen by M Dow & SL Dow & TU Electric Request for Admonition of Dows.* Concludes That Motion Should Be Dismissed.W/Certificate of Svc ML20091A0461992-03-13013 March 1992 Suppl to Motion to Reopen Record.* Requests That NRC Reopen Record & Suspend License Pending New Hearings on Issue. W/Certificate of Svc ML20090C4241992-02-24024 February 1992 Motion to Reopen Record.* Requests That NRC Reopen Record & Suspend OL for Unit 1 & CP for Unit 2,pending Reopening & Final Decision.W/Certificate of Svc ML20090C4431992-02-21021 February 1992 Petition for Leave to Intervene Out of Time.* Requests That Petition for Leave to Intervene Out of Time Be Granted for Listed Reasons.W/Certificate of Svc ML20086Q3811991-12-26026 December 1991 Case Response to Portions of Motion of R Micky & Dow to Reopen Record.* Submits Responses to Motions to Reopen Record ML20086Q3121991-12-26026 December 1991 Case Motion for Leave to File Response to Portions of Motion of R Micky & Dow to Reopen Record.* Requests That NRC Recognize J Ellis as Case Representative for Filing & Pleading Purposes.W/Limited Notice of Appearance ML20091G2511991-12-0202 December 1991 Licensee Answer to Motion to Reopen Record by M Dow & SL Dow.* Requests That Petitioners Motion Be Denied for Listed Reasons.W/Certificate of Svc & Notices of Appearance ML20086G7381991-11-22022 November 1991 Motion to Reopen Record.* Requests That Licensing Board Reopen Record & Grant Leave to File Motion to Intervene. W/Certificate of Svc ML20006C4811990-02-0101 February 1990 Applicant Answer to Request for Stay by Citizens for Fair Util Regulation (Cfur).* Cfur Failed to Satisfy Burden to Demonstrate Necessity for Stay & Request Should Be Denied. Certificate of Svc Encl ML20006B1691990-01-27027 January 1990 Second Request for Stay Citizens for Fail Util Regulation.* Requests That NRC Stay Fuel Loading & Low Power Operation of Unit 1 Until 900209.Certificate of Svc Encl ML20248J3601989-10-15015 October 1989 Request for Stay Citizens for Fair Util Regulation.* Requests That Commission Retain Authority to Order That Fuel Loading & Low Power License Not Be Immediately Effective,Per Util Intent to Request License.Certificate of Svc Encl ML20246B8671989-08-17017 August 1989 Motion for Reconsideration of NRC Memorandum & Order CLI-89-14.* NRC Should Excuse Itself from Consideration on Matters Re Jj Macktal & Should Refer All Issues on NRC Requested Subpoena to Independent Adjudicatory Body ML20248D6291989-08-0202 August 1989 Jj Macktal Statement Re Motion for Recusation.* Macktal Motion Considered Moot Due to Commission No Longer Having Jurisdiction to Consider Motion Since Macktal Not Party to Proceeding Before Nrc.W/Certificate of Svc ML20247Q3851989-07-26026 July 1989 Withdrawal of Motion to Reopen Record.* Withdraws 890714 Motion to Reopen Record.W/Certificate of Svc ML20245J7331989-07-26026 July 1989 Request of Cap Rock for Reevaluation of Director'S Determination That No Significant Changes in Licensee Activity Warrant Antitrust Review at OL Stage.Certificate of Svc Encl ML20247B5901989-07-19019 July 1989 Motion to Reopen Record.* Requests Board to Reopen Record & Grant Leave to Renew Earlier Motion for Intervention Status. W/Supporting Documentation & Certificate of Svc ML20248D5731989-07-0303 July 1989 Motion for Reconsideration.* Requests Reconsideration of NRC 890122 Order on Basis That NRC Subpoena Filed for Improper Purposes & NRC Lacks Jurisdiction Over Matters Presently Before Dept of Labor ML20248D5541989-07-0303 July 1989 Motion for Recusation.* Requests That NRC Recuse from Deciding on Macktal Cases on Basis That NRC Will Not Be Fair & Impartial Tribunal.W/Certificate of Svc ML20245J9411989-06-30030 June 1989 Response of Texas Utils Electric Co to Request of Cap Rock Electric Cooperative,Inc,For Order Enforcing & Modifying Antitrust License Conditions ML20248D4891989-06-13013 June 1989 Motion for Protective Order.* Requests That Jj Macktal Deposition Be Taken at Stated Address in Washington,Dc & That Testimony Remain Confidential.W/Certificate of Svc ML20011E8571989-02-10010 February 1989 Reply of Cap Rock Electric Cooperative,Inc to Comments of Texas Utils Electric Co.* Texas Utils Response Considered Irrelevant,Mainly Incorrect or Misleading.Certificate of Svc Encl ML20155A8251988-10-0303 October 1988 NRC Staff Response to Citizens for Fair Util Regulation First Suppl to Request for Hearing & Petition for Leave to Intervene.* Petition & Requests for Hearings Should Be Denied.W/Certificate of Svc ML20154Q2021988-09-28028 September 1988 Applicant Reply to Citizens for Fair Util Regulation (Cfur) First Suppl to 880811 Request for Hearing & Petition for Leave to Intervene.* Cfur Request Should Be Denied. Certificate of Svc Encl ML20150E2131988-07-13013 July 1988 Citizens Audit Motion for Stay & Motion for Sua Sponte Relief.* Requests Time to Review Concerns of J Doe & for Relief for Listed Items in Order to Act as Intervenor in Proceeding.W/Certificate of Svc ML20151A6181988-07-12012 July 1988 Motion for Petitioners to Appear Pro Se.* Petitioners Request to Appear Before Board at 880713 Hearing in Order to Present Arguments in Support of Petitioners Motions & for Stay of Proceedings.W/Certificate of Svc ML20150E1831988-07-12012 July 1988 Response of Applicant to Motions to Stay,To Intervene & for Sua Sponte Relief Filed by Various Petitioners.* Papers Filed by Petitioners Should Be Rejected & Denied & Dismissal of Proceedings Be Completed.W/Certificate of Svc 1993-03-19
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4 RELATED C=;cPONDENCE
!&'t 000KETED U%RC
- 04 E0 bbnh9$8, 1984 UNITED STATES OF AMERICA _ . u.
NUCLEAR REGULATORY COMMISSION' i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 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' MOTION FOR
SUMMARY
DISPOSITION REGARDING CONSIDERATION OF LOCAL DISPLACEMENTS AND STRESSES Pursuant to 10 C.F.R. I 2.749, Texas Utilities Electric Company, nt al. (" Applicants") hereby move the Atomic Safety and Licensing Board for summary disposition of the Citizens Association for Sound Energy's (" CASE") allegations regarding the consideration of local displacements and stresses. As demonstrated in the accompanying affidavit and statement of material facts, there is no genuine issue of fact to be heard regarding this issue. Applicants urge the Board to so find, to conclude that Applicants are entitled to a favorable decision as a matter of law, and to dismiss this issue from the proceeding.
I. BACKGROUND CASE has raised certain concerns regarding Applicants' c.o,nsideration of the effects of local stresses and displacements in pipe supports. In particular, CASE has raised four concerns:
190356 840618 "I ADOCK 05 M 45 PDR 'u
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(1) that the use of cinched U-bolts and zero clearance box frames will induce unacceptable stresses in piping as well as the U-bolts and box frames themselves because of the thermal expansion of the pipe and service loads from the piping system (CASE Proposed Findings,Section IV): (2) that Applicants' design process does not adequately account for the stresses induced in anchors due to thermal expansion of the pipe (CASE Exhibit 669B, Section 14); (3) that Applicants' design process does not adequately address the stresses in tube steel connections (CASE Proposed Findings at V-5); and (4) that local deflections and deformations have not been adequately incorporated into Applicants' deflection calculations in the design and analysis of i
pipe supports (CASE Proposed Findings at IX-1, IX-17).
In Applicants' Proposed Findings (at 50, 57-60 and 69-70),
we addressed the specific CASE allegations discussed in their Proposed Findings, viz, the ef fects of cinched U-bolts and zero-clearance box frames (item 1), local deflections (item 4) and tube steel connections (iten 3). We discussed these issues further in our Reply to CASE's Proposed Findings, at pagas 17-19, 21-22 and 30-31.
The issue relating to stresses on pipes caused by cinching of U-bolts was addressed by the Board at pages 33-41 of its Memorandum and Order (Quality Assurance for Design) dated December 28, 1983. In regard to this issue, the Board concluded (id. at 37): "in the absence of any direct challenge to Mr.
Doyle's calculations and in the absence of any data supporting
'\
. 3 'the Staff's position, the Applicants' burden of proof has not been met." The Board did not specifically address the other allegations regarding local stresses and displacements.
In response to the Board's Order, Applicants have performed extensive tests and analyses regarding the effects of cinching down of U-bolts (see Affidavit of Iotti and Finneran Regarding Cinching Down of U-bolts, to be filed shortly). With respect to the other allegations, while the Board did not specifically address these, Applicants have undertaken to address these allegations by performing reviews as part of Item 12 of its Plan to Respond to Memorandum and Order (Quality Assurance for Design), filed February 3, 1984.s Plan Item 12 provides, as follows:
Provide evidence of a reevaluation of each individual support id'entified by Messrs.
Doyle and Walsh to determine the acceptability of the design of each support.
Accordingly, Applicants have evaluated those supports identified by CASE as being subjected to local stresses and displacements which CASE contends should have been, but were not, considered.
In addition, Applicants have also reevaluated other supports referenced by CASE (for other purposes) for these effects. These evaluations demonstrate that these local effects do not create any unacceptable stresses in the supports, contrary ta CASE's assertions. Accordingly,_ the Board should find that there is no l valid t, asis for CASE's allegations regarding local stresses and
- n displacements.
E
e 6
-4._
II. APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION A. General Applicants have previously discussed the legal requirements applicable to motions for summary disposition in their " Motion for Summary Disposition of Certain CASE Allegations Regarding AWS and ASME Code Provisions Related to Welding," filed April 15, 1984 (at'5-8). Accordingly, Applicants incorporate that discussion herein by reference.
.B. CASE's Allegations Regarding Consideration of Local Displacements and Stresses Should be Summarily Dismissed As indicated above, CASE has made four allegations regarding the consideration of local displaccinonts and stresses in Applicants' pipe support design process. Specifically, CASE claims that Applicants have not properly considered (1)' stresses induced by cinched U-bolts and zero clearance box frames due-to the thermal expansion of the pipe, (2) stresses induced in anchors due to the thermal expansion of the pipe, (3)-stresses induced in tube steel . walls due to welded attachments, - and ' (4) local deflections and deformations. Applicants address each'of i
L these allegations-in the accompanying affidavit of John-C.
Finneran. JAs' demonstrated =therein, Applicants' pipe support
' designs fully satisfy applicable-stress allowables even when these effects are included'in the' design.
i I
l-
- 1. Induced stresses from cinched u-bolts and zero clearance box frames CASE contends that the radial thermal expansion of the pipe and service loads from the piping system will induce unacceptable stresses in cinched U-bolts and zero clearance box frames, as well as the piping itself. Mr. Finneran's affidavit addresses the potential stresses from zero clearance box frames. The effects of cinched U-bolts will be addressed in the affidavit of Dr. Robert C. Iotti and Mr. Finneran, which will be filed shortly.
Applicants have identified 51 box frame supports with zero clearance (out of 17,000-18,000 total supports) in Unit 1 and common areas (Finneran Affidavit at 4). Only one box frame with 4
zero clearance exists on a piping run with a maximum water temperature greater than 200 F. This is support SI-325-002-S32R (CASE Exhibit 891 (also 928)). The maximum temperature of the pipe in this case is 350 F. (Finneran Affidavit at 4.)
,. To evaluate the effect of these local pipe stresses,
!. Applicants utilized the conservative allowables employed by Gibbs l
& Hill for assessing local pipe stresses associated with integral i
welded attachments. (Finneran Affidavit at 3-4.) (The ASME Code
, provides no quantitative criteria for the consideration of such '
-stresses, although it does provide qualitative guidance which l
leaves the designer free to determine the method for quantifying this guidance. (Finneran Affidavit at 3.))'
4 F
As for the stresses in the box frame itself, Applicants utilized a etandard methodology which accounts for the relative flexibilities of the pipe-frame system (see Finneran Affidavit at 4-5.) To assess the significance of the calculated stresses, Applicants applied ASME Code Section NF-3231(a) which governs the
. - consideration of these stresses. (Finneran Affidavit at 3.)
Applicants first performed a detailed analysis of the support on the 350 F line, set forth in Attachment A to Mr.
{ Finneran's affidavit. The results of that analysis demonstrate
, that even when including the local stress induced in the frame from the thermal expansion of the pipe with other loads, all
- . stresses in the frame are less than Code allowables. With respect to the local stresses induced in the piping, Applicants' analysis demonstrates that all stresses in the pipe are also less
, than allowables.1 (Finneran Affidavit at 4-6.)
- .In addition, to address the validity of CASE's assertions regarding the loads between the support and the pipe, Applicants analyzed the support' identified by CASE in its. Proposed Findings in support of its position on this matter. Applicants i
conservatively assumed in that analysis that the temperature of the line was-200 F, although.the actual maximum temperatures is
- 130 F. By taking this conservative approach Applicants have 1
This support was also assessed by.Cygna (see NancyLH.
Williams' ' testimony ( Board April .1984 Exhibit ' No. 1) in response to'Doyle Question #15. Cygna's analysis.also-
~ demonstrated that the . stresses in both the pipe and the : box frame remained well=below applicable allowables even when both thermal and mechanical loads were combined.
l
4
- b l
effectively bounded the remaining supports on icw-temperature lines. The results of Applicants' calculation indicate that even at 200 0F, the resulting force between the pipe and the frame will be 454 lbs. This is obviously not even close to CASE's calculated force of 27,280 lbs. In short, CASE's assertion that the thermal expansion of the piping would result in large loads between the frame and the pipe even in these low-temperature lines is incorrect. (Finneran Affidavit at 6.)
- 2. Stresses induced in anchors I
CASE also alleged that Applicants had not adequately accounted for the stresses induced in anchors 2 due to thermal expansion of the pipe, and identified three supports (CASE Exhibit 669B, Section 14) for which it claims these effects should have been considered. Applicants have performed a conservative analysis of the three supports to assess the significance of these effects.3 As demonstrated in the analyses attached to Mr. Finneran's affidavit, conservatively including the thermal expansion effects of the pipe in the assessment of the supports produced no overstressed conditions (Finneran 2 The term " anchors" as used by CASE in this allegation refers to supports on the piping system which are designed to l restrain the movement and rotation of the pipe in all three directions.
3 One of these supports (CC-1-008-029-S33A) (see CASE Exhibit 669B, pages 14j - 14m) was completely redesigned (for unrelated reasons) subsequent to CASE's allegation.-
Nonetheless, Applicants included the new design in their analysis.
- a-t .
n e
Affidavit at 7-8.)4 In sum, these analyses demonstrate that there is no basis for CASE's assertion that these effects are significant and that they should be calculated in support designs.
- 3. Stresses induced in tube steel walls CASE alleges that Applicants have not adequately addressed stresses in the walls of tube steel members induced by welded attachments (see CASE Proposed Findings,Section V at V-5). Each i of Applicants' support design organization assess these effects L . on a case-by-case basis when deemed appropriate by the engineer.5 (Finneran Affidavit at 9.)
) CASE did not perform any calculations to substantiate its position regarding these effects. Rather, CASE premised its position on certain factors it believed indicated that analyses should routinely be performed to assess these effects.
CASE's premises for its position are, however, in error. In the first instance, CASE incorrectly implied (CASE Proposed Findings at V-5)'that the minimum width ratio of tube-to-tube connections that j Applicants used up to September of 1982 was 0.8. (CASE 4 Cygna analyzed a similar support for these same effects in i
'their response to Doyle Question 15 (see Testimony of Nancy i H. Williams, Board April 1984 Ex. 1 at 33.) Their results also. demonstrated that all stresses in the support were far 5
below applicable allowables. (Finneran Affidavit at 8.)
The NRC Staff'also reviewed Applicants' practices in this regard and had no concern regarding'the adequacy of Applicants'; practice. The Staff reviewed . a random ' sample of L. .100 vendor certified supports selected by the Staff'and j found Applicants had considered these local effects. (See l SIT Report (Staff Exhibit 207).at 42; Tr. 7030-32.)
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- apparently intended to refute a portion of the NRC Staff l
i' testimony with.this point.) However, CASE's argument is premised on a misinterpretation of a guideline which applies to the specification of weld type and has no relationship to Applicants' consideration of local stresses in tube connections in support design. (Finneran Affidavit at 10.) In addition, CASE i
incorrectly claimed that the tube-to-tube ratio for the support for which it contended these stresses should be considered was less than 0.4. The actual connection ratio is .5625. Applicants
! analysis of this connection indicated-that the actual stress for-this connection is 2261 psi, or 57% of the allowable. .Thus,
~i contrary to CASE's assertion, the design of this connection was clearly adequate. (Finneran Affidavit at 10-11.)
To assess the appropriateness of Applicants' design practice i regarding the consideration of these local stresses, Applicants i-performed a detailed local failure analysis for the worst case supports which CASE contends could be inadequately designed. In all cases the local stresses were found to be far less than the allowables. (Finneran-Affidavit at 11-12.)
- In short, there is no valid basis for CASE's assertion that Applicants' design practices with respect to the consideration of these effects would result in unacceptable support designs.
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- 4. Local deflections and deformations Finally, CASE alleged that Applicants did not include local deflections and deformations in their deflection calculations for 1
support designs-(CASE Proposed Findings at IX-1). Indeed, it has i
never been Applicants' practice to include local effects or stan-dard component deflections in calculating support deflections for class 2 and 3 supports. Thus, CASE's assertion is, in effect, cor-4 rect. Applicants' practice is, however, standard industry practice which is premised on sound engineering principles and results in
! adequate support designs.6 (Finneran Affidavit at 12-13.)
Applicants consider the deflections of the structural portions of each support in calculating deflections for comparison
, to the 1/16" deflection guideline. To assess the significance of these effects, Applicants selected 15 worst case supports from l CASE Exhibit 669B for assessing these effects, along with a support used by CASE in the cross-examination of the Staff on this i
- subject. Applicants assessed each of these support's deflections, including the local and component effects CASE contends should be i
~ included in the deflection calculations. (Finneran Affidavit at 13.)
Applicants' evaluation demonstrated that even with the consideration of these effects virtually all the support deflections remained below Applicants' deflection criterion.
6 In this regard Dr. Bjorkman testified that it was not i
industry practice to evaluate particular types of local deformations'which CASE alleged should be considered.(Tr.
[ 12482-83).
s t
Even for the supports for'which deflections did not remain below the' deflection criterion, the stiffnesses of the supports remained within the acceptable range of stiffnesses. Thus,
, ~ CASE's allegation that inclusion of these local effects would lead to excessive deflections is not valid. (Finneran Affidavit
, at 13-15).
I Further, as Mr. Finneran notes, if Applicants had intended t
to include these local effects in their deflection calculations, they would have set a deflection criterion higher than a 1/16".
As demonstrated above, although these local effects may result in potential deflections slightly greater than-1/16", there is no
, safety significance to this fact. Thus, Applicants could have selected a larger deflection criterion to account for these
- effects. (Finneran Affidavit at 15.)
CASE's final allegation regarding Applicants' consideration 1
of support deflections and deformations is that Applicants' support designs will have excessive deformations and, thus, Applicants will not have satisifed the guidance contained in Regulatory Guide 1.124. CASE apparently contends that the deformations and deflections in Applicants' support designs constitute:the" large deformations"' mentioned in the Regulatory Guide, where it is. stated:
Component supports are deformation sensitive because
! large deformations in them may'significantly change the stress distribution in the support system and its supported components. [ Regulatory Guide 1.124, Section B.]
(Finneran Affidavit'at:16.)
o 9
However, CASE'is in error 4.n two respects. In the first instance, Regulatory Guide . 124 is applicable specifically to Class 1 supports. Applicants in fact perform complete stiffness calculations for Class 1 supports, including consideration of local effects. (Finneran Affidavit at 16.)
In addition, irrespective of the support classification, the discussion in Regulatory Guide 1.124 regarding large deformations is related to the use of plastic analysis methods. With respect to support designs using elastic analysis, as Applicants use,
! Regulatory Guide 1.124 recognizes that deformations will be small.
, Thus, CASE's concerns regarding the consideration of deflection e f fects for support designs using elastic analysis are not valid.
(Finneran Affidavit at 16-17.)
III. CONCLUSION For the foregoing reasons, Applicants' motion for summary disposition should be granted.
Respectfully submitted, b
Nicholas S.
h Reynolds William A. Horin BISHOP, LIBERMAN, COOK, PURCELL
& REYNOLDS 1200 Seventeenth Street, N.W.
Washington, D.C. 20036 (202) 857-9817 Counsel for Applicants l
June 18, 1984
!