ML20140G127
| ML20140G127 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/31/1986 |
| From: | Horin W BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#286-600 OL, NUDOCS 8604010275 | |
| Download: ML20140G127 (13) | |
Text
'
-s Y% CORRESPONpgq 00CMETE0 USHRC
"*r9Bs MR 398hli:47 3
UNITED STATES OF AMERICA 0FFl:E " :
NUCLEAR REGULATORY COMMISSIO!CMLif t f.
cF <;!
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)
)
AP PLICAl'TS ' ADDt"IONAL ANSWERS TO CASE'S INTERROGATORIES RE:
CREDIBILITY I.
INTRODUCTION Pursuant to 10 C.F.R.
SS2.740b and 2.741, Applicants hereby provide additional responses to CASE's credibility discovery requests.
The Board directed that Applicants file answers to certain of those r equests in its Memorandum and Order (Reconsideration of Misrepresentation Memorandum), November 25, 1985, and Memorandum and Order (Period for Discovery; Motion for Reconsideration), December 12, 1985.
Documents responsive to the requests answered below are enclosed with CASE's copy of the responses.
Answers to additional questions will be forthcoming.
O B604010275 8ADOCK O5000445 PDR PDR O
i T
5-II.
ANSWERS TO CASE'S DISCOVERY REQUESTS A.
CASE'S SECOND SET Request-1.
(a)
How long have applicants been committed to Manufacturer's Standardization Society (MSS) publication MSS SP-58
(" Pipe Hangers and Support-Materials and Design")?
(b)
How long have Applicants been committed to Manufacturers' Standardization Society (MSS) publication MSS SP-69
(" Pipe Hangers and Supports-Selection and Application")?
(c)
Was or is Applicants' commitment to MSS SP-58 and/or MSS SP-69 contained in any document other than Design Specification 2323-MS-46A?
(d)
If the answer to (c) above is yes, list all other such documents.
(e)
Supply copies of the pages from Design Specif'ication 2323-M-46A which contain Applicants' commitment to MSS SP-58 and/or MSS SP-69 (including the page which contains the Section on Codes and Standards); supply for the original and each revision of MS-46A.
(These should be the pages which correspond to pages 3-15 through 3-20 of Revision 5 of MS-46A.)
(f)
Supply copies of the pages from each of the documents listed in (d) preceding which contain Applicants' commitment to MSS SP-58 and/or MSS SP-69 (including the page which contains the section which sets forth the section); supply for the original and each revision of each document listed in (d) preceding.
(g)
Has there ever been any discussion, instructions, or any other communication (either orally or in writing) between Applicants and Cygna Energy Services regarding MSS SP-58 and/or MSS SP-69?
(h)
If the answer to (g) preceding is yes, supply copies of all documents (using the broad definition on page 2,
item 3, of this pleading) by Applicants, Cygna or anyone else regarding this matter.
If not already indicated on the document (for instance, in the case of handwritten notes) supply the name of the person whose notes they were, the person to whom the notes were written, and the date of such notes; i.e.,
I' n.
include sufficient specific. details so that the.
document being supplied is readily understandable.
(i)
If the answer to (g) preceding is yes, but there are no documents in answer to (h) preceding, provide a brief statement containing the details of such i
discussion, instructions, or other communication.
Include specific details of who was involved in such communication, the date of each such communication, and a brief summary of the substance of such communication.
Include sufficient specific details so that.he information being supplied is readily understandable.
Response
1.(a)&(b)
MSS-SP-58 and MSS-SP-69 have been listed in che Codes and Standards section of M3-46A from Revision 0 of that specification until the present.
Revision 0 of MS-46A was dated June 2, 1975.
CASE should note that although these documents are listed in MS-46A, by their own terms they are reference material, utilized only for guidance.
In contrast, ASME Code Section III, Subsection NF is the governing code which establishes design requirements.
In fact, the role of the MSS standards in the design process is explained in MSS-SP-69, where it states, as follows:
All MSS standards and practices recommended are advisory only.
i There is no agreement to adhere 'to any MSS standard or recommended practice and their use by anyone is entirely voluntary.
These standards are not copyrighted and may be used at will.
[ MSS-SP-69 (1966 Edition), at 2.]
Finally, Applicants note that the applicable editions of these documents for Comanche Peak are
i n the 1966 Edition of MSS-SP-69 and the 1975 Edition of MSS-SP-58.
1.(c)&(d)
The Manufacturers Standardization Society - (MSS)
-is referenced in MS-100, Piping Erection Specification, but SP-58 and SP-69 are not specifically referenced.
1.(e)
Applicants will provide.with CASE's copy of this
~
response the applicable'pages from Revision 0 of MS-46A, through the current revision, Revision 6.
1.(f)
Applicants will provide with CASE's copy of this response the applicable pages from Revision 0 of MS-100 through the current revision, Revision 8.
1.(g),(h)
No.
Applicants have been unable to identify any f
(i) communication (oral or written) between Applicants l
and Cygna regarding MSS SP-58 or SP-69.
B.
CASE'S FOURTH SET Request 1.
Regarding potentially unstable supports:
(a)
Supply.a complete list of all supports which
~
Applicants have ever identified as being potentially unstable.
In your answer, include the location of each support.
Also include a brief description of the history of each such support (i.e., when, why, how, and because of whom it first became potentially unstable; when, why, how, and by whom it was first identified as being potentially unstable; when, why, how, and by whom it was initially corrected; when, why, how, and by whom it was finally corrected);
include specific dates, specific names, titles, and organization, and specific details.
Supply the requested information (1) for Unit 1 and common and (2) for Unit 2.
I a- (b)
Supply drawings and calculations for each support
. listed-in (a) preceding, at each step of the process (i.e., as the support was when it was first identified as being potentially unstable, when it was initially corrected, and when it was finally corrected).
(If any of this information has already_
been supplied, please specify the cover letter by which it was supplied, etc., in sufficient detail so that we can identify the information.)
(c)
L'or each of the supports listed in your answer to (a) p.eceding, provide all documentation that Applicants identified such support.as potentially unstable, including copies of all deficiency paper (i.e.,
NCR's, CMC's, DCA's, IR's, and any other paper used by~Apolicants to identify such deficiency, 10 C.F.R. 50.55(e) reports, etc.).
Include all supporting documentation relating to the consideration of how to handle or correct the problem, including all documentation relating to the final disposition of.
the problem.
Also include all documentation that each of the potentially unstable supports were included in trending.
(d)
Which-(identify by each support's number) of the supports listed in your answer to (a) preceding fit into each of the following categories?
(i) box frame with zero-inch gap attached to a single strut or snubber?
(ii) single strut with cinched-down U-bolt?
(iii) box frames modified by " indexed lugs"?
(iv) box frames modified by " additional struts"?
(v) box frames modified by cinching down U-bolt?
(vi) single struts with U-bolt and a thermal gap?
(vii) single struts with U-bolt and a thermal gap, modified by adding supplementary steel to create " stability bumpers"?
(viii) single struts with U-bolt and a thermal gap, modified by cinching down U-bolt?
(ix) double strutted frames supporting two or more pipes?
6
. (x) double strutted frames supporting a single pipe with.uncinched U-bolts?
(xi) double strutted frames supporting a single pipe with cinched-down U-bolt?
(xii) double strutted trapeze supports with uncinched U-bolt?
(xiii) double strutted trapeze supports with cinched-down U-bolt?
(xv) multi-strutted trapeze supports with cinched-down U-bolt?
(xvi) multi-strutted box frame?
(xvii) single snubber with cinched-down U-bolt?
(xviii) double-strut, double trunnion with uncinched U-bolt?
(xix) double-strut, double-trunnion with cinched-down U-bolt?
(xx) double strut trapeze with box frame?
(xxi) triple strut box frame?
(xxii) other configurations not specifically listed in the preceding?
Also supply any additional information not' specifically listed in the preceding?
Response
1.(a) Regarding potentially unstable supports:
Applicants are providing the requested.ist.
This list covers only those supports which Applicants had considered to be potentially unstable in their Motion for Summary Disposition, as corrected, regarding this issue.
- Thus, the list will not include such supports as the cinched U-Bolt supports with single struts or snubbers and the
~
I
,. trapeze supports.
The NRC Staff indicated after Applicants filed their motion for summary disposition that they considered these' types of supports potentially unstable.
These supports are included in.the current i
Stone &-Webster requalification effort.
The list (Table t
I 1A, attached) contains the support number, the document which reflects the initial potentially unstable
{
condition, the document which initiated a stability modification, the document representing the final corrected condition of the support, the organization, responsible for the support design, and the category of the support as requested in CASE request 1.(d).
1.(b) Provided with CASE's copy of this response are.the 4
available drawings and calculations requested with l
respect to supports identified in.the response to question 1.(a) and at the specific stages of the design j
process requested by CASE.
There may have been instances i
in which earlier calculations were supplemented and/or revised for a particular design revision.
To the extent prior calculations were replaced by the supplemented or revised calculations, they would not have been retained.
Applicants also note that additional calculations related i
to these supports will bo produced in response to Questions 1.(f)(2) and (3).
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. 1.(c) Applicants will provide with CASE's copy of this response documentation responsive.to this request, i.e.,
documentation related to the identification and disposition of potentially unstable supports listed in the response to question 1.(a).
Typically, there is documentation related to the identification of a suppo.rt as potentially unstable, and documentation such as calculations and drawings reflecting disposition'of the matter. -Applicants have been unable to identify separate documentation cencerning " consideration of how to handle or correct" these conditions, other than the calculations and drawings supporting and reflecting ultimate modifications.
1.(d) See Table 1A.
4 5
1
t
. Respectfully submitted, t
n LW Nicholas S.
Reynolds William A. Horin BISHOP, LIBERMAN, COOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 (202) 857-9837 Robert A. Wooldridge WORSHAM, FORSYTHE, SAMPELS
& WOOLDRIDGE 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201 (214) 979-3000 Roy P.
Lessy, Jr.
MORGAN, LEWIS & BOCKIUS 1800 M Street,.N.W.
Washington, D.C.
20036 (202) 872-5000 Thomas G.
Dignan, Jr.
R.K. Gad III ROPES & GRAY 225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 March 31, 1986 l
n Table 1A Initial Doctanent Stability Original Support Creating Potential Modification Initial _
Final Design CASE y.
Number Instability Initiated Correction Correction Orgnization Category AF1-004-003-S33R BRil R4 TSDR 3616 BRif R5 BRII R7 ITF v
CCl-020-001-A33K OC 45218 R0 TSDR 3841 BRH R1 BRII CP-1 ITF CCl-028-007-S33R OC 58106 R4 TSDR 3605 BRH R4 BRil CP-1 ITP i, v T1-028-034-S33R OC 9079 R0 TSDR 3157 BRIl R2 BRII R2 ITP iv, xvi CCl-087-002-A33R OC 39358 R3 TSVC 534 BRH R3 BRil R5 ITP i, v CCl-159-010-S43R O C 11293 R0 TSDR 3158 BRil R3 BRif R3 ITP iv, xvi CCl-234-005-C53R OC 72290 R0 TSDR N2355 BRII R3 BRil R7 NPSI CT1-008-008-S22K BRH R1 OC 53467 R1 BRH R2 BRil R5 ITF iii DDl-055-064-S55R BRil R2 TSVC 715 BRIl R3 BRH R3 ITP v
SIl-325-002-S32R O C 62011 R2 TSDR 3673 BRil R1 BRH R4 ITP i, v SWl-026-009-J03R O C 41272 R0 TSDR 3465 BRif R4 BRil CP-1 ITP i, v SWl-132-020-S43R O C 34854 R0 TSDR 3657 BRii R4 BRII 10 ITP i, v MSl-001-003-S72R ITP Orig. Design TSVC 611 BRII R1 BRi! CP-2 ITP viii MSl-001-004-S72R ITP Orig. Design TSDR 3880 BRII R1 BRil CP-1 ITP viii MSI-001-005-S72R ITP Orig. Design BRil R1 BRil R1 BRII CP-1 ITP viii MSI-001-006-S72R ITP Orig. Design BRil R0 BRII R2 BRil CP-1 ITP xv MS1-002-003-S72R ITP Orig. Design (R2) TSVC 629 BRII R1 BRif CP-2 ITP viii MSI-002-005-S72R ITF Orig. Design BRil R1 BRil R1 BRil CP-1 ITP viii MSl-002-006-S72R ITP Orig. Design BRII R1 BRif R1 BRif R2 ITP MS1-003-003-S72R ITP Orig. Design TSDR 3826 BRII R1 BRII CP-2 ITP viii MSI-003-004-S72R ITF Orig. Design OC 59293 R1 BRil R1 BRif CP-1 ITP viii MS1-003-005-S72R ITP Orig. Design BRII R1 BRII R1 BRH CP-1 ITP viii MSl-003-006-S72R ITP Orig. Design BRII R0 BRil R1 BRif CP-1 ITP xv MSl-004-003-S72R ITP Orig. Design TSDR 4314 BRH R1 BRil CP-2 ITP viii MSI-004-005-S72R ITP Orig. Design BRil R1 BRII R1 BRII CP-1 ITP viii MSl-004-006-S72R ITP Orig. Design BRi! R0 BRif R2 BRil R2 ITP CCl-048-007-A33R OC 37607 R0 TSVC 599 BRH R6 BRif R6 ITF xiii SB1-101-001-A55R O C 77263 R1 TSDR 3430 BRII R3 BRIl R4 ITP viii was box frame, now cinched U-bolt on single snubber was box frame, now standard clamp
- was single strut with uncinched U-bolt, now is rigid box frame lf Applicants have categocized these supports by what appears to be the most applicable categories presented by CASE. Of course, CASC will have the drawings and may categorize the supports oa their own.
1 4
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' Additional Answers to CASE's Interrogatories Re: Credibility; that the same is true of his own knowledge except as to matters therein stated on information and belief, and as to that he believes them to be true.
%nC.Finneran,Jr.
State of Texas County of Somervell Subscribed and sworn to before me this 31st day of March 1986.
/& % &? - r
' Notary fublic,3rw re er remo s my u ma rssron exp/ Ae1 3-zs-pg
=1 t-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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' Additional Answers to CASE's Interrogatories Re: Credibility".in the above-captioned matter were served upon the following persons by express mail
(*),
hand delivery
(**),
or deposit in the United States mail, postage prepaid, on this 31st day of March, 1986.
- Peter B.
Bloch, Esq.
- Elizabeth B. Johnson Chairman, Atomic Safety Oak Ridge National and Licensing Board Laboratory U.S.
Nuclear Regulatory Post Office Box X Commission Building 3500 Washington, D.C.
20555 Oak Ridge, TN 37830
- Dr. Kenneth A. McCollom
- Anthony Z. Roisman, Esq.
Dean, Division of Engineering, Trial Lawyers for Public Architecture and Technology Justice Oklahoma State University 2000 P St.,
N.W.,
Ste. 611 Stillwater, OK 74074 Washington, D.C.
20036
- Dr. Walter H. Jordan
- Ellen Ginsberg, Esq.
881 West Outer Drive U.S.
Nuclear Regulatory Oak Ridge, TN 37830 Commission Washington, D.C.
20555 Mr. William L. Clements
- Stuart A.
Treby, Esq.
Docketing and Service Branch Office of Executive Legal U.S. Nuclear Regulatory Director Commission 7735 Old Georgetown Rd.
1717 H St.,
N.W.
Maryland Ntl. Bank Bldg.
Room 1100 Room 10117 Washington, D.C.
-20555 Bethesda, MD 20814
- Mrs. Juanita Ellis Lanny A.
Sinkin, Esq.
President, CASE Christic Institute 1426 South Polk St.
324 North Capitol St.
Dallas, Texas 75224 Washington, D.C.
20002
r-I t Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Board Panel Licensing. Appeal Panel U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 i
- Ms'.
Billie P. Garde Ms. Nancy Williams Trial Laywers for Public Cygna Energy Services, Inc.
Justice 101 California Street 2000 P St.,
N.W.,
Suite 611 Suite 1000 Washington, D.C.
20036 San Francisco,.CA 94111 Mr. Jim Bailey Joseph Gallo, Esquire Texas Municipal Power Agency Isham, Lincoln & Beale P.O.
Box 7000 1120 Connecticut Ave.,
N.W.
Bryan, TX 77805 Suite 840 Washington, D.C.
20036 Renea Hicks, Esquire Mr. Robert D.
Martin Assistant Attorney General Regional Administrator Environmental Protection Region IV Division U.S. Nuclear Regulatory P.O. Box 12548 Commission Austin, TX 78711 Suite 1000 Arlington, TX 76011 Mr. James E.
Cummins Resident Inspector / Comanche Peak Steam Electric Station c/o U.S. Nuclear Regulatory Commission P.O. Box 38 Glenrose, TX 76043 l
omb. h\\
eh David A.
RepRb cc:
Robert A. Wooldridge John W.
Beck