ML20206P784

Motion for Protective Order & Addl Answers to Credibility Discovery Requests of Case.Certificate of Svc Encl.Related Correspondence

ML20206P784
Person / Time
Site:	Comanche Peak
Issue date:	06/30/1986
From:	Horin W BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#386-748 OL, NUDOCS 8607020241
Download: ML20206P784 (75)

Text

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June 30 I 1988363 _ Nl; 7,h W & fps h ~7%ffcu 'D ,_

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matt'e'r of -

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.;- -!.  ; ) Docket Nos. 50-445 and- ' {i =

TEXAS UTILITIES ELECTRIC ) 50-446 - -'

COMPANY, . ET AL. . . - , ) e< ' ~i . , ,

(Application for m -

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(Comanche Peak Steam Electric ) Operating Licenses) .u

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Station, Units 1 and 2) )

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APPLICANTS' ADDITIONAL ANSWERS TO CASE'S " CREDIBILITY" f~ ~' r DISCOVERY REQUESTS AND MOTION FOR PROTECTIVE ORDER

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INTRODUCTION .

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't Applicants respond below to those questions in CASE's . ..

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" credibility" discovery requests which had not heretofore been' a-answered, in accordance with the Licensing Board's Memorandum and Order (Reconsideration of Misrepresentation Memorandum),

LBP-85-47 (November 25, 1985). By letter dated June 12, 1986, to the Licensing Board, Applicants committed to file these answers by June 30, 1986.

Documents produced in response to these requests will be made available for inspection and copying at Applicants' offices in Dallas. CASE should contact Susan Palmer (214/979-

! 8242) to arrange for inspection. Copies of documents will be i

made for CASE at 15 cents /page (see letters to Mrs. Ellis from Mr. Wooldridge, March 25, and June 11, 1986). For CASE's l

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O 86070ghghO 3903 .

information, there are approximately 20,000 pages of documents being produced for inspection and copying (10,000 pages of which are documents provided by Cygna in response to Question

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1(f) of CASE's Fourth Set).. .

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• Finally, further to Applicants' June 23, 1986, letter ,to?g mr m ".

y, CASE, the Attachment thereto should be corrected to reflectJ, , .' .

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that Question 1(e) (cable tray supports).. and Question 2 (A500 fi . -.e ,

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of +" :A-Steel) of CASE's Fourth ~S:et,~and Questions 1-3 (A500 =~, Steel)

CASE'S Fifth set also are not related to Applicants' Pla'n.i ' . . _  ; (CASE should note that Applicants previously responded to'sub-stantial portions of the questions related to A500 steel.)

Also, even though identified in the June 23,~1986, letter as not related to Applicants' Plan, Applican'ts respond herein to "-

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"'". -7 ' . .L - . L aspects of Question,24 of the Fif th Set'which we have subse- -

, ~.,c quently determined could be construed to be related to the ~~ .

Plan. .

APPLICANTS' ANSWERS TO CASE'S REQUCSTS CASE'S SECOND SET Question ,

4. (a) Provide documentation that Applicants have i provided the professor discussed in Applicants' Plan with all public documents from these

$ proceedings.

(b) Provide:

(i) a listing of all public documents (including pleadings, Proposed Findings, etc., filed by CASE) which have been provided to the professor (by Applicants or others); ,/

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. . . - -- ., , .- . , - - - - , . . . - . . - . ~ -- ,-,

(ii) a listing of all other documents which have been provided to the professor; (iii) all documents (such as cover letters, memoranda, etc) by which such documents were provided; (iv) if the documents were handed to the-

,,, professor on site, please so indicate;. . . . .

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- - '. .. 8 aa; . =: [c; w (v) who (name, organization, and title)'

._-.. provided each such document;

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(vi) the date on which each such document was supplied to the professor; and . . .

(vii) all documents (as defined on page 2, item 3, of this pleading) listed in (ii) preceding.

(c) Has the professor ever been on site? If so, -'

provide specific details of such site visit,-

including a listing of all documents reviewed, to whom he talked, a brief summary of all discussions onsite, the date of each site visit and discussion, and all documents (see- s definition under item 3, page 2 of this'- <_

pleading) relating to each site visit.- ._ , , ,_

(d) Provide copies of all contracts, letters of understanding, or other instructions to or from the professor as to the scope, criteria, protocol, and/or independence of the professor's review and activities regarding Comanche Peak.

, (e) Was there ever any kind of. understanding I

(written or oral) to the effect that the professor was to accept Applicants'-

representations at face value (similar to the agreement regarding J.J. Lipinsky's acceptance at face value of the statements made in Mr.

Brandt's affidavit)?

Response

4.(a)

R. C. Iotti transmitted to Dr. Boresi on May 1, 1984,

- technical materials relating to:

- instability of supports ,,e c

- cinching of U-bolts

- upper lateral restraints

- generic vs actual stiffness

- lateral capability of U-bolts ,

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- - distribution of forces in axial restraints' 4 :. ; ' 'f ."

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/ ::4J "~ - self excitation of support;ma'ss ? Q g.j @ ._a f,'

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- neglect of. rotational resistance :.-;-- ,s3- .

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- friction effects z. .

- restraint of radial growth At that time none of the material could be considered ,:: .-

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public documents. Nevertheless, much-of the material:

appearer* later in the affidavits supporting the motions

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_. .6 .y Dr. Boresi was also provided ' "

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for sum.aary disposition.

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copies of the SIT Report, the Board's December 28, 1983,,

Memorandum and order (Quality Assurance for Design)',-

Applicants' Plan (and Supplement), and comments thereon',

and applicable portions of CASE's Proposed Findings.

Applicants' counsel also transmitted copies of'the motions for summary disposition as they were filed.

l Further, CASE should recall that the Professor's role was only to assess the soundness of the engineering' principles employed and their application in the evaluations performed in connection with Applicants' Plan. (See Applicants' Plan, February 3, 1984, at 4.)

He was not asked or expected to define the issues or the i

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approach. .

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_ --_ _ _ _ _ _ _ _ , . _ _ _ _ _ _ _ _ _ _ _ _ _ _ -- __ .- + - - - - . - - - . - _ - . -

O 4.(b)(i)-(ii)

Applicants did not maintain a separate list of materials provided, although we have confirmed that the above described materials were provided to Dr. Boresi.

4.(b)(iii) .. -

Dr. Iotti cannot locate the cover letter transmitting ._

Y' the above technical material.\ Copies of th'e motions

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q. . , were transmitted with normal service. . In otheri.'

instances, formal transmittal letters were not used.

4.(b)(iv), (v)

Applicants do not recall handing any documents to .

Professor Boresi on site.

4.(b)(vi) -r- -

_ c-See item (a) above'.

4.(b)(vii)

Applicants have requested from Professor Boresi copies When of the technical materials identified in item (a).

received, these will be made available for inspection and copying as Attachment 2-4.(b)(vii). CASE already .

has copies of the remaining materials.

f .

4.(c)

Professor Boresi did visit the site once, for a day, at the time of the April 1984, hearings. The visit was informal, prior to Dr. Boresi becoming involved in the Plan. Chief engineers Jay Ryan and Peter Chang showed s

Dr. Boresi around the site. Dr. Boresi was shown 1

u examples of types of supports at issue in the proceeding. Those individuals do not recall which specific supports Dr. Boresi observed. Nor do they-recall providing documents to Dr. Boresi during that: __

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J Copies of these' materials will'be made availableEp foin f d' ' M

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inspection and copying as Attachment 2-4.(d)'.' - t. 4:lew ..

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4.(e) - ,

The answer is a definitive no. .

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CASE'S FOURTH SET  :

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, Question: .

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Regarding potentially unstable supports:' . '~',

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(f) In regard to Cygna's 2/19/85 letter 84042.035 t'o ~~

l Mr. J.B. George, under Subject of Stability of-Pipe Supports (copy of which is attached to' CASE's 2/25/85 Notification of New and Significant Information and CASE's Supplement to CASE's 10/15/84 Motions and Answer to .

Applicants' Motion for Summary DispositionT Regarding Stability of Pipe Supports, which is being sent in the same mailing with this ,

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pleading): .

y (1) Supply a list of the supports which.

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.Cygna identified on page 7 (last paragraph) as:

(i) the 37 supports which, in the total absence of the pipe, are stable; s'

(ii) the 124 supports which, in the absence of the pipe, would be unstable, but which Cygna I

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l considers to possess sufficient positive attachment to the pipe to ensure stability; and (iii) the 65 supports which Cygna considers to be potentially unstable.

(2) Supply the drawings and calculations ~

which Cygna reviewed for each supporth -

listed in'(1) preceding. (If these are .

already included in the Cygna Reportsj

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please indicate where they 'can be. founds ~*  ; " '"

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in the Report. If these are the same drawings and/or calculations supplied by.

Applicants in their answer to (b)- -

preceding, please so indicate. Be - -

specific.)

(3) Supply all drawings, calculations, or other documents (as defined on page 2, item 3, of this pleading) generated byl J' ' .

Cygna or its agents in Cygna's review of each support listed in (1) preceding.

(If this has already been provided,

' -- -- please identify, for each support, the,g; _ . ~-

specific document provided and the'date '

s and Cygna identification number for >each _. ^

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such cover letter by which it was provided.) ,

(4) Did Cygna attempt to ascertain whether.

or not Applicants had promptly identified and corrected the problem of potentia 1' instability?

(5) Did Cygna attempt to ascertain whether or not Applicants had trended each of the supports were potentially unstable?q (6) If the answer to (4) and/or (5) r I

preceding'is yes, for each of the supp' orts listed in your answer to (1) preceding, provide all documentation which Cygna reviewed which indicated that Applicants identified such support as potentially unstable, including copies of all deficiency paper (i.e.,

l NCR's, CMC's, DCA's, IR's, and any other

' paper used by Applicants to identify

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such deficiency, 10 CFR 50.55(e) reports, etc.). Include all supporting

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l documentation for such deficiency reporting, as well as all documentation relating to the consideration of how to handle or correct the problem, including all documentation relating to the final disposition of the problem.

4 Also include all documentation-that each

) - - - -

" *J of the potentially unstable supports; ..1.: "

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were included in. trending.

(If any of this information has already p- ._

been provided in response to.(c);=~... @ ,,g f

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preceding, please identify specifically . . ,

~g which such information reviewed by Cygna _*-M r

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-- i has already been supplied.) m .

-f.4 4'if-(7) If the answer to (4) or (5) precedingis-1 yes, what are Cygna's current _ .

conclusions regarding the adequacy of Applicants' prompt identification and ,.

correction of the problem' of. : + ~f instability, as well as the adequacy _ofi Applicants' trending and whether or not such trending accomplishes the purpose-

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S---- e d ,. of promptly identifying trends which-may: -

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adversely' affect quality?

J' Q-1 Which (identify by each support's1 (8) number) of the supports reviewed by

.Cygna fit into each of the following -

categories (this information is not clear from Cygna's listing of the top of

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page 8): ,

(i) box frame with zero-inch gap attached to a single strut or snubber?

~ single strut with cinched-down

' (ii)

U-bolt?

, .7 box frames modified by " indexed

$ .(iii) lugs"?

f (iv) box frames modified by

" additional struts"?

box frames modified by cinching l (v) l down U-bolt?

i l (vi) single struts with U-bolt and a thermal gap? , '

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o (vii) single struts with U-bolt and a thermal gap, modified by adding supplementary steel to create

" stability bumpers"? (Answer-appears to be 2; is this correct?)

(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? Q ~

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(x)' double strutted frames . . _ . _,

" supporting a single pipe with ~ m uncinched U-bolts?

(xi) double strutted frames supporting a single pipe with cinched-down U-bolt?

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(xii) double strutted trapeze supports' with uncinched U-bolt? (Answer appears to be 3; is this _

~> - - - -- correct?)., . _

(xiii) double strutted trapeze supports ' '

with cinched-down U-bolt?-

(xiv) multi-strutted trapeze supports with uncinched U-bolt?

(xv) multi-strutted trapeze supports with cinched-down U-bolt?

(xvi) multi-strutted box frame?

(Answer appears to be 8; is this correct?)

(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?

(Answer appears to be 1; is this

- correct?)

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(xx) double strut trapeze with box I frame? (Answer appears to be 2; is this correct?)

(xxi) triple strut box frame? (Answer appears to be 1; is this correct?)

. ..' ,(xxii) other configurations noti . _

specifically listed in the","'

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preceding? .. -.

5 mi.

"~ Also supply any additional information5 ~

which might assist.in understanding the "-R

configurations discussed in the' j ,

preceding.

"(

(9) Do Applicants' agree that the copy of' Cygna's (2/19/85 letter 84042.035 to Mr.

J.B. George, under Subject of Stability of Pipe Supports, which was attached to CASE's 2/25/85 Notification of New and' .. _

Significant Information and CASE's! "

Supplement to CASE's 10/15/84 Motions and Answer to Applicants' Motion.for Summary Disposition Regarding Stability. .

of Pipe Supports (which is being sent in the same mailing with this pleading), is ,

an authentic and correct copy of the' -

letter received by Applicants from Cygna (with the exception of the date on which CASE received the letter, which has been hand-written in the upper right-hand corner of the letter)?

(10) If the answer to (9) preceding is no, supply an authentic and correct copy of such letter. _

i (11) Does Cygna consider the 226 pipe supports which they received as part of its Phases 2, 3 and 4 review to be a J. representative sample of the pipe j - supports at Comanche Peak?

(12) Do Applicants consider the 226 pipe supports which Cygna reviewed as part of its Phases 2, 3 and 4 review to be a representative sample of the pipe

- supports at Comanche Peak?

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(13) If the answer to (12) preceding is no, please explain in detail Applicants' rationale for having chosen the particular systems which they had Cygna.

review to help alleviate the Board's concerns about the design of Comanche Peak. .

Response:mga;h, .;g _

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1.(f)(1)-(8),(11) . ~

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.These questions concern information related to Cygna's' '

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review of, and conclusions regarding, piping and m:o

"' T supports at Comanche Peak. Because the details of such-evaluations and conclusions are at this time known only

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to Cygna, Applicants requested that Cygna respond to -

these questions. Cygna's response will be made available for inspection and copying (Attachment 4 ,. _

1.(f): Cygna letter 84056.099, to Mr. J. Finneran, dated.  : -

March 24, 1986 with Attachments and enclosures).

Approximately 10,000 pages of material were provided by Cygna in response to these questions.

1.(f)(9),(10)

Applicants object to these requests. These requests-seek an admission of authenticity regarding a Cygna letter. That question is an evidentiary matter appropriately addressed in the context of a hearing and, thus, is premature. At such time as a hearing may be conducted, Applicants will the opportunity to

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object to admission of that letter (if CASE chooses to seek its admission). Applicants will acknowledge now that the copy of the letter transmitted with CASE's requests appears to be a copy of the same letter -

Applicants]receivedfromCygna._ - 7+ y.7 .,.

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if l.(f)(12),(13)5 ~ //A - ' ' i. b oF"'*[k p._ q

y Applicants consider the systems reviewed by Cygna'in'the. Y

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basis for assessing the various design and construction ..

activities identified in the definition of scope- ,

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established for each of the phases. With respect'to the pipe supports on those systems, Applicants remind CASE , _

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that some of the systems selected for Cygna's ' review: ~

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were selected to skew the sample of supports toward

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inclusion of supports which exhibited conditions _

challenged by CASE's pipe support allegations. (See~

" Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design)," February 3, 1984, at 11.) Thus, Cygna's review of piping and supports is not

" representative" in the sense Applicants assume CASE is

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4' using, or intends to use, the word, i.e., statistically valid, random sample of supports drawn from the entire plant.

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Question:

3. Regarding AWS vs. ASME:.

a. With regard to Affidavit of J. C. Finneran, R.

C. Iotti and J. D. Stevenson Regarding Allegations Involving AWS vs. ASME Code Provisions, Attachment 1 to Applicants' 5/17/84

-t_, 4. e 1 Motion for Summary Disposition of Certain. CASE -

Allegations Regarding ANS and ASME Codeif 4f:

Provisions Related to Design Issues:

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- (1) Beginbing on page 4 of the Affidavit,g ' ,. ~

Applicants' affiants discuss at'some~ ~

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length the provisions of Appendix xvii,,

' - paragraph 221(c) of Section III of-the: - -

- ~ 1974 ASME Code:

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(i) Where is it stated in ASME that this is a compensatory requirement? ,

(ii) Isn't it'a fact that Appendix XVII, Paragraph 2211(c) was subsequently deleted in the.

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Winter 1978 Addenda?.

(iii) Isn't it alsd a fact that-Applicants adopted the deletion of Appendix XVII, Paragraph 2211(c)?

(iv) What was the purpose of' Applicants' discussion of Appendix XVII, Paragraph 2211(c), in their Affidavit, and how was it relevant to the issue under discussion?

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(v) Why didn't Applicants' affiants state that Appendix XVII, Paragraph 2211(c), had been subsequently deleted and that such deletion has been adopted by the Applicants?

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Response: ,

3.a.(1)(i)

The ASME Code does not specifically state that this is a compensatory requirement. Applicants' use of the term

" compensatory" is_ fully explained.in the d,

" Affidavit'of'

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-, edr e ;Mt 't Iotti Regarding".^

John C. Finneran, Jr. and Robert C.

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.C 7 Corrections and. Clarifications,to Affidavits Supporting & . - . . . <= . u . , . .

Motions for Summary"bisposition_of' Pipe Support Design y. .;_ .3._ y.'-

Allegations" (hereinafter referred to as " Applicants'. , m ..

Corrections Affidavit"), filed November 12, 1985, at 22-

23. ^

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" c 3.a.(1)(ii)

Yes..

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3.a.(1)(iii)' .

Yes. As stated in Applicants' Corrections Affidavit at '" .

.e 23, Applicants adopted the 1978 Code Addenda in 1982.

3.a.(1)(iv)

See Applicants' Corrections Affidavit at 22-23. .-

3.a.(1)(v) at' As explained in Applicants' Corrections Affidavit, -

22-23:

1) The large majority of Applicants' designs were accomplished prior to our adoption of the addenda.

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2) Applicants never relied on this compensatory measure to qualify welds in lieu of an a

assessment of skewed fillet welds.

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Question:: .

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4. Regarding axial restraints:- _

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conducted October 13-December 2, 1982 and

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January 18,.1983), it.is stated that:(j- c.

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" subsequent discussions with the Applicant indicated that this rotational _

restraint had also been identified during the Applicants' normal design review and that the pipe stress analysis

• was being modified to consider this1~

rotational restraint."

However, Applicants have now changed their .

position on this (as indicated on pages 3 and C.'. 4 -

of the Affidavit of Robert C. Io'tti and John Finneran, Jr. Regarding Consideration of Force Distribution in Axial Restraints, which was -

attached to Applicants' 7/9/84 Motion for Summary Disposition Regarding Allegations Concerning Consideration of Force Distribution in Axial Restraints).

Regarding this: '

(1) What has changed since Applicants' told the SIT that they were going to modify their pipe stress analysis to consider this rotational restraint? Provide specific details.

I (2) Provide all documents (as defined on page 2, item 3, of this pleading) which

, indicate that Applicants has advised the NRC of Applicants' change in position regarding this prior to 7/9/84.

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Answer:

4.a.(1)

Nothing has " changed" since Applicants told the SIT that they were going to modify their pipe stress analysis to

-A consider this rotational restraint. The particular;'~~

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commitment quoted by CASE -(page 39 of the SIT report)[ '

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' concerned a single stress problem _( AB-1-03) .~ ,, The pgep *- 3:qy ,

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stress analysis for this problem and those df otherl.~malii _y.ya

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1 3-steam lines were modified to consider the rotationa.l4 m .

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constraint of the trurinions. Results of those analyses were formally transmitted by Gibbs & Hill to TUGCO in , g-

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H May, 1983. ..

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--The discussion at pages 3 and 4 of the Affidavit do not'

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address the specific prdblem investigat'ed by the sI b ". ^^;'^

Rather, they focus on the general method of modelling-employed by Applicants. There was no change in position- -

regarding modification o.f the stress analysis of the . _

problem investigated by the SIT. .

4.a.(2) . .

No documents exist as there has been no change in

j g position by Appl.icants.

x

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O Question:

5. Regarding damping factors:

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a. Regarding the Affidavit of Robert C. Iotti Regarding Alleged Errors Made in Determining Damping Factors for OBE and SSE Loading

' Conditions, which was attached to Applicants'

- 5/16/84 Motion for Summary Disposition Regarding ~

" - Alleged Errors Made in Determining Damping ("< .

c Factors for OBE and SSE Loading Conditions:?w Affidahit at page 4:[ Dr. Iotti' W~.

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(1) discusses a statement in the SIT Report'~'

.J. . .- . at page 48:-- :m::,_ J- -

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"The Special Inspection Team' concluded that these response spectra characteristics, together with the fact that the SSE damping value of 4 percent is twice the OBE damping value.

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of 2 percent led to the condition expressed in Mr.

Doyle's concern."

._. -,g- c.~ '

Dr. Iotti then states that "The SIT was~

. not clear that the use of 2 and 4 ~

percent damping factors in the analysis of OBE and SSE conditions to which it refers was with respect to that aspect of the analysis in which closely spaced modal responses are combined using a .

coupling factor." ,

(i) When (specific date) did Dr.

~ Iotti begin working on this issue for Comanche Peak?

' ~

(ii) What was the basis for Dr.

Iotti's conclusion thatDid "The SIT was not clear . . ."

someone tell him? If so, who (name, title, and organization),

and what was the basis for Did such individual's conclusion?

Mr. Iotti discuss this matter with anyone on the SIT or with the NRC? Did Dr. Iotti assume

' that the SIT had meant to say something else in the SIT l Report? Give specific details as to his basis. .

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(iii) Provide all documents (as defined on page 2, item 3, of

' this pleading) which indicate that Applicants or any of their agents informed the SIT or the NRC that "The SIT was not clear

. . ." regarding this matter, as well as all documents relating

,- _m , , . , to the SIT's or 'the NRC's: ..

1~ response (s).. - . " "?> M g.. O s l O ' 3.: '

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4 Dr. Iotti began working on the damping factor issue ~,(

in-'. ; "4 .' .

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February 1984. . .

m 5.a.(1)(ii)

Westinghouse (W. Lapay) told Dr. Iotti that the 2 and 4 ?

percent damping factors referred to coupling parameters

.w and not to the damping values used for the response u.., .. ,

.-n

- a- . .;

~~

spectra selection of problem 1-41. Dr. Iotti reviewed; , ... ~.;

the input data of problem 1-41 personally and found' -

Westinghouse's statement to be correct. The original Affidavit reflects this po,sition. Further review of ,

stress problem 1-41 indicated that the SIT probably had

~i not looked at the same stress problem as Dr. Iotti,.but This was discussed at public at an earlier version.

\

meetings with the NRC on 6/20/84 and 8/8-9/84. CASE may

!7 tl '

verify such discussiens by reviewing the transcript of I those meetings.

I I

/ -

1 ,

e

. I 19 -

During those meetings it was also agreed that Dr. Chen of the SIT would identify the particular problem which the SIT reviewed. Dr. Chen subsequently provided a date of the problem he reviewed (March 29, 1981). The revision of the stress problem with that date was :_p ~

~ ~_ -

obtained by Applicants. However, reviews of that and.

' ~

~

other revisions of. stress problem l-41, revealede (1) 2 ,

, 7,

. and 4 percent damping spectra were never used by - . . . . ,

Westinghouse for that problem and; (2) the 2 and 4 l

percent coupling parameters were used in the most recent revision, but not the revision presumably reviewed by , . .

u the SIT.

The history of this matter is addressed in ApplicantAV~

Corrections Affidavits, at 30-35. To summarize, at the time of Dr. Iotti's original review (the results of which were reflected in the Affidavit) the only l

reference to 2 and 4 percent damping in stress problem i

1-41 which he could identify was in the coupling parameter. He assumed, therefore, that the SIT had l

misread the input to that problem and had thought that the 2 and 4 percent damping referred to the spectra used. As explained above, the-SIT statement has become even more confusing since there apparently is no record that a 2 and 4 percent damping was ever used on stress problem 1-41 (either for input spectra or as coupling s'

4 e

a h

I

'E parameters) except as a coupling parameter in a later  :

revision (submitted with the Affidavit) which Applicants have since learned was not the stress problem which the SIT reviewed. Applicants can provide no further 2~ explanation of the SIT's findings., c ,

m.

( g h,

'"i s , , ya

' n, - -1 ., q , r .

'2- i>, f,-, -

.,,.s r_

, a : ~ C Y ~:, T '" ',~ n ' = -

f .g

.5.a. (1)(iii)? :Y::: ~

a . -

r. .

Documents, indicating that Applicants informed the NRC1__ -~-

4

, . , , , - . .y .

'~

are the transcripts of the aforementioned meetings.and Applicants' Corrections Affidavit, at 30-35, and documents provided with that Affidavit. . . . -

Question: - ~ ~ ~ - ,: . ;. . ..

Regarding Differential Displacements:

6.

Regarding the Affidavit of R. C. Iotti and J. C.

a.

Finneran, Jr. Regarding Differential -

Displacement of Large Frame Pipe Supports,'

Attachment 1 to Applicants' 6/22/84 Motion for Summary Disposition of CASE Allegations Regarding Differential Displacement of Large-Framed, Wall-to-Wall and Floor-to-Ceiling Pipe Supports:

On page 7 of the Affidavit, Applicants' affiants discuss the " prompt attention" the problem received:

(1) Provide all documents (as defined on

?

( .page 2, item 3, of this pleading) indicating that the problem received prompt attention, including all deficiency paper and its disposition.

(2) Provide the justification for proceeding with construction of these supports even

,' though they were known to be "not in strict compliance with the PSE guideline" (i.e., what procedure /

gives

/

3

i Applicants the authority to ignore such guidelines, on whose authority was such a decision made (name, title, organization), etc.). (We have read what is said in Applicants' Affidavit, so you need not repeat what is said there in answer to this question.)

(3) Why should the Licensing Board believe."~"' .

(EJ that this problem would have been-v~

adequately resolved if.the SIT had not -

raised the issue?. n  ;. -

% _+x t ;.f-~-

- = ;m __ .

. y- .

' ~- -

In Applicants' Affidavit, they state ~~ '~

(4) '

- ~ '

r that "only these four supports were in;g_. _

~

violation of the guideline." They ; 91 ~.

further state (page 8) that Applicants' -

(at the recommendation of the SIT) made' the guideline regarding this issue _

applicable to ITT and NPSI._

r If the same PSE Guideline had also been in effect prior to that time for ITT and-NPSI, would there have been additional ITT and NPSI supports which would have

- been in violation of the guideline? i, , _ . , _ ..

(5) Provide all documents (as defined on.

page 2, item 3, of this pleading) in-support of your answer to (4) preceding.

(6) Have Applicants or any of their employees (as defined on pages 1 and 2, item 2, of this pleading) subsequently discovered additional supports which would have been in violation of the PSE Guidelines in effect during the time ,

period discussed in the preceding (i.e.,

1981-1982)?  :

l (7) If the answer to (6) preceding is yes, supply a list of, and complete details and all documents regarding, each such l support.

(8) On page 26 of the SIT Report (first full paragraph), it states:

"During the course of the inspection, the Applicant informed the Special Inspection Team that these supports would be unable to withstand /

l' i

i . w I

i I

differential seismic displacements and were being redesigned."

Considering this statement, what was the basis for Applicants' belief (discussed on page 7 of the Affidavit) that "the~

designs, although not in strict compliance with the PSE guideline, were-  :

y 4 ,, adequa,te"? . ,

..  ;=.;.,

.~ u. .. ~ . ,

y

. 3- _ Swyg . _

y O. -z (9). Who (name, title, organization) made the- ' 0' '+

7.

• - statement (quoted in (8) preceding)ito?S" ~~ , .

the SIT 7. Is this individual-(or+ @>1= E e rr 3

r : ;c n , > ' ' " ' ' '

individuals) still employed at Coman'chE N-Peak? If.not, supply such individual (s); .

3

. _~ . ;, _ _

last known address and telephone'numbery, _c~.

~

(10) Provide al'1 documents which' led such i , ' ' ~" ^.

individual (s) to the conclusion that "these supports would be unable to ~

withstand differential seismic displacement." -

_- 1. S'", y;; .x (11) Provide all documents (including detailed analyses) which reflected that ~_

. _ i_

"similar supports designed by ITT and _

' ' NPSI" "were adequate including "N i . - . .'

consideration of differential seismic' .JJ. _

, - ..^ ., M. 4 -

displacement" (as stated on page 8' oft ~ -

Applicants' Affidavit).. _

Response: ,

6.a.(1)

There is no deficiency paper or other documentation --

reflecting the initial identification of this condition.-

~

It was the affiants' understanding that, at the time,-

g Applicants' design groups were awaiting as-built piping analysis loads for all four pipes on these frames in order to conduct a complete structural assessment of the frames. These analyses involved six different stress problems, the last of which was transmitted at the end

/

/

s e

,e o

of October, 1982. Applicants will provide copies of the letters transmitting these stress problems (Attachment 4-6.(a)(1)). Prior to taking further action on these supports, however, and in conjunction with the ongoing

~

SIT review, Applicants decided to modify the supports .- , -

? :: - --

- 3; . .

. rather than perform further analyses.

6.a.(2), .

Q ; ;; I f=;: _ ,

7,[ ' _ , y { 7-W . 1 D.'

As stated in the Affidavit, we do not know why the h5

~

. yz designer and reviewer had not followed the PSE.

guideline, and released the design for construction.

There.is no authority for an engineer to ignore a ..

guideline'. If an engineer chooses not to follow a-guideline, he must provide adequate justification for' T

• not doing so. Applicantshavenof~1dentifiedany .

documentation reflecting such justification. _

i s

6.a.(3)

Because different engineers were-involved in the final' certification program, and they were to review the -

supports against the guidelines.

6.a.(4)

This question'does not make much sense. If CASE is asking whether there were any supports in the plant not ,

previously disclosed to CASE that, regardless of who i

designed them or what criteria were applied, did not .

satisfy the PSE guidelines in this regard, the answer is -

i s no (see response to Question 6.a.(6).). If CASE is

/ ,

/

• \

asking whether, assuming the PSE guideline had been in place at ITT and NPSI at an earlier date, those companies would have designed supports in direct violation of the applicable guideline, Applicants cannot say. To answer that question would require specula' tion

sc

. , , g ::.y .-, 3 ., _ .- g; , 3 ,y and conjecture as to how past events would be altered by. <$'

q

- - 4,% . -

conditions which never existed. Applicants-will note',N:y;;; x.sfi ,

. 3

. y / :.

m 4p;.

~ ;.l.

however, that in that situation those design w 1i?~'

'~' ' n .;s -

~

.a. L. *; ' n

~

-:f .

organizations shouldl comply with guidelines unless;~ -

~"{ u .. .

adequate justification to do otherwise is provideda ,

6.a.(5) -

~ ~ *

-? ~ 7~

There'ar'e none.

6.a.(6) , ,

. , - 3 . . , , , . _

=--  : -' ~ -

3 .

No.. . _

' ~1

. 6.a.(7) 7 _

Not Applicable. ,

6.a.(8)

The statement made in the Affidavit refers to Applicants'opinionatthetimethesupportshad$ ben-originally identified and the decision made to obtain ~

all as-built loads to allow further assessment of the-supports. At that' time Applicants believed that a detailed analysis would show the supports were adequate.

However, when the SIT raised questions regarding these supports, a quick hand calculation was performed using x

conservative assumptions and seismic displacements from

/

/

- - -- ^ -

j .

the building adjacent to the tunnel where the supports are located. This rough calculation, using conservative assumptions, indicated the columns were overstressed.

This information was verbally communicated to the SIT f

s :, ,

team. . Nonetheless, Applicants still were of.the opinion -

y'~ '

-:g. .

that a detailed analysis was likely to show the supports

~-

adequate. However, it would have taken an 6nwarranted:

. p. . ' amount of time to develop and' assimilate'the necessary  ; s-

. 4 input data (e.g., seismic displacement data for the

~ ~

tunnel) to perform that calculation. Accordingly, the decision was made to modify the supports in order to

~

.+, ,, ,

quickly settle the issue.

6.a.(9) ^

Applicants do not recall who specifically related the' above l'nformation'to the SIT.- ~

4 6.a.(10)

Because the rough calculation mentioned above was not part of the official calculation for the supports as

~

l presently designed, it was not retained.

6.a.(ll) __

Applicants assume CASE is referring to wall-to-wall / floor-to-ceiling supports designed by ITT and NPSI

! without slip joints. Applicants will make available for inspection and copying documents related to such supports (Attachment 4-6.a(ll).

x

/

/

/

~ - . . , . - - , . - . - , - , , - - . - . - , , -. , - - - -

Question:

7. Regarding Richmond Inserts:

a. Answer the following questions regarding the Affidavit of John C. Finneran, Jr., Robert C.

Iotti and R. Peter Deubler Regarding Design of Richmond Inserts and Their Application to

%;-g w. . Support Design (Attachment 1 to Applicants'?2,. . ...

nVAy 6/2/84 Motion for Summary Disposition Regarding:

WM c..

Design of Richmond Inserts and Their Application '; 'i

~ ..

to support Design):

- j. u 4; A. ..; 3 - c ; .x,;5; & - ~ ^ :Q : - , . , f..

. :'~S : .:

+ -

(1) _On page 27 of the Affidavit, a Providel bolt "' . _ ~. $ _ . _

interaction equation is given..

f ; -/> ._ _' all documents (as defined on page 2,,sc', " ~1 ;n, item 3, of this pleading) which gives. '

• the basis for this equation (i.'e.,. s _

design guidelines, specifications, procedures, codes, standards, recognized authorities, etc.). -

~

r . . _ . .

'p-- y,. n ~ ,

With further reference to (1) preceding,-

(2) why isn't the tensile stress due to

~ bending added to the direct tensile

':,. - stress T?- . ..g w -. , n , .

(3) on page 25 of the Affidavit, Applicants'_.

affiants discuss an interaction value of~

1.75. Where else within the industry is an interaction value greater than 1- -

considered to be acceptable? Provide-all documents (as defined on page 2, item 3, of this pleading) which support the acceptable of an interaction value greater than 1 (i.e., design guidelines, -

specifications, or procedures other than-for Comanche Peak, codes, standards,.

recognized authorities, etc.).

Response

j

( 7.a.(1)

The basis for this equation was provided in two documents:

(1) Letter to the NRC, dated July 11, 1984, in response to a question posed during the meeting of 6/20/84,

/

/

' *\

1 in which the Affidavit formula is compared to another, theoretically derived, interaction formula.

(2) Answer to Questions 21.(g) and (h) of the Fifth set

=.

1, , _- . of _ ".~ credibility"

,  ;- . requests ' ( Applicants' First, , ., ,. ,

~

Partial Response, 4/25/85) which compared margins .

4

^7 T provided by the equation to failure data'derivedh from tests. There are no other document's providing. . ._ - _

the basis for this equation.

7.a.(2)

The tensile stress due to bending is added to the direct , ,

tensile stress. As stated on page 27 of the Affidavit,

- the tension (T) in the equation " equals the applied; external tensi n plus any coupled out tension'resulting from torsion." Torsion is what produces bolt bending 7 7.a.(3)

In general, for bolts, there are no documents which

! address the acceptability of interaction equations measured against values greater than 1. For other items, however, interaction equations with acceptable

' values greater than 1 exist, although they are not' common. They are not common because it is customary to revise allowable values for stresses rather than revise the right hand side of the equation (interaction i

values). For bolts, most interaction formulas are derived from tests and are normalized to 1. Applicants

/

, , - , ,y-,--.--,-.--.- , -r ,.,.-y - _ _ , . , . . . . .- , . , . - - - - - - - . - , - ~ _ _ , _ -

also could have, but did not, normalize their equation to 1. An example of interaction values greater than 1 is found in ASME Code Appendix XVII, 1980 Edition, Equation XVII-2215.1. There the interaction value is 1.5 when both primary and secondary bending stresses are ~ , . .

utilized. -

s.  :# -

.. n ...

- - my - -

Question: - ' _ u* . - -

-- T E - ' :A. , . a,a ,

24. a. Isn't it true that virtually all of the supportsC5c .r .

in the North Yard Tunnel have now been changedgu ' - -

due to design changes? .c- .

b. Isn't it true that many or most of the changes referenced in a. preceding were made to floor-to-ceiling hangers?

Isn't it true that many or most of the chan es

~

c.

referenced in a. preceding were to change the hangers so that they now have slip joints?

d. Isn't it true that many or most of the changes: _; >

referenced in a. preceding were made in response to the Walsh/Doyle allegations?

~

e. Isn't it true that the change to slip joints was one of the recommendations made by Messrs. Walsh-

and/or Doyle in the operating license proceedings? ,

f. Provide a list of all supports / hangers in the North Yard Tunnel which have been modified or.

redesigned; include in your answer whether or not such supports are safety-related, the class t

of each support, and the system of which each j support is a part.

f

g. Provide. drawings and calculations (the ones just

~

prior to the change, and the ones where the change was made) for each support / hanger listed in f. preceding. Also provide any other documents (as defined on page 2, item 3, of this l

pleading) relating to such change.

For each support / hanger listed in f. preceding, h.

l state exactly how the support was changed and l

I the specific reason for the cha,nge.

[ A

O

1. (i) How many other hangers / supports have been modified or redesigned in response to the Walsh/Doyle allegations?

(ii) Supply a list of all such supports, each support's location, the system each support is part of, whether or not each support is safety-related, and the class g u. , ,,

of each support, and the system of which -

each support is a part.

" . (iii) Provide drawings and calculations (the ones just prior to the change, and the .

_.~

. cc f ones where the change was made) for each"

> support / hanger listed in (ii) preceding.-

~

Also provide any other documents-(as - 3: -

defined on page 2, item 3, of this pleading) relating to such change.

(iv) For each support / hanger listed in (ii) preceding, state exactly how the support -

- was changed and the specific reason for the change.

Response

Although these particular supports were not specifically addressed in Applicants' Plan, we have responded to the extent issues addressed in the Plan may be considered to relate to the supports.

i 24.(a)

As with other pipe supports, supports in the North Yard Tunnel have been subjected to some design changes.

24.(b)

Some of the supports in the North Yard Tunnel are floor-to-ceiling supports. Some design changes were made to those supports for reasons not related to this issue.

24.(c)

No. These supports were released for construction in 1979, and have always had slip joints./

. T

, ~ _,

- 30 -

24.(d)

No.

24.(e)

Yes. However, Applicants were already using slip joints _

long before Walsh and Doyle came to-CPSES (see answer C-4to

~

/

.: . & .2

~ ~

~

(c) above).g n _,

1,.;

24.(f),(g),(h). and (i);w .a;r. - s /dyg; --[ 4 -.. - ..

q , ;gi. ,

Applicants will provide for inspection :j- -

and copying.G 5, : (:

N ", , , .

- m ,:a c. . , . ,.

~-

(Attachment 4-24.(f))'a copy of the' original l.;.f construction drawings for the North Yard Tunnel ,

supports. The remaining portions of the questions . _, z..

covering the North Yard Tunnel supports may be answered by examining the documents provided. To the extent g; y- . -

information sought by these questions relates to the

~

m. '

supports addressed in Applicants' Plan, Applicants' ' .

addressed the identification of particular support' deficiencies in the Affidavits, documents provided therewith, or in response to previous discovery requests. CASE may review the documents and information t

already provided to obtain the remaining requested information. Applicants further object to providing-g t such information.in that such would require independent research and data gathering (Houston Lighting & Power Co. (South Texas Project, Units 1 and 2), LBF-80-11, 11 NRC 477, 478 (1980)).

/

e

- - . - - .-. - , . . _ _ , _ . . - . . _ . , . - . , . . . = _ , - . - . , _ _ . _ _ . - . _ _ . . . . - _ ,

- - - _ _ , , . _ e--. _ _ _ . _ , . . - . -.- -

o CASE'S FIFTH SET Regarding A500 Steel:

Unless otherwise indicated, where an affidavit is referenced, it is the Affidavit of John C. Finneran, Jr., Regarding A500 Tube Steel, which was attached to Applicants' 4/11/84 Response to Partial Initial Decision-Regarding A500 Steel: 1.- _ ,@ g,

. .. -c _

1. Affidavit at page 5, second paragraph: _ ,

~

^'l e-

~

a.- How many shipments of tube steel have been .

received at Comanche Peak? .y

?-: ' - .. _ _ _

b. Provide a breakdown of the test data (whichi-fi~ '

Applicants state that they receive with each~

shipment of steel) in a tabular or similar form indicating the yield strength (we would assume that some document, such as handwritten notes, etc., already exists which contains this

information). What we are looking for is 9_ ,

something such as:

the test data for 3 shipments of tube steel indicated an actual "' yield strength of 36 ksi the test data for 5 shipments of tubs steel indicated an actual yield strength of 56 ksi

, . . . etc.

c. Provide for inspection and copying any and all test data received with each shipment of tube steel at Comanche Peak.

I 2. Affidavit at page 6, first full paragraph, middle of page: Provide and and (sic] all documentation regarding Applicants' statement that "This analysis demonstrates that all stresses in tube' steel support members remain below even the reduced allowable stresses and that, in fact, the stresses in the vast majority of supports l

remained significantly below those allowables" (including, but not limited to, such items as interoffice memos which requested that such analysis be performed and/or set forth the goal which Applicants wished to achieve, notes of meetings at which such analysis was discussed, etc.)

3. Affidavit at page 6, second full paragr,aph, bottom of -

page continued on page 7:

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

• P

a. Provide the " alphabetical listings of all Unit 1 and common area ASME supports for each support design organization (NPSI, ITT-Grinnell and PSE)."

b. (1) How many supports utilize A500 tube steel at Comanche Peak? Answer for each of the following:. -

~ *

- j' - '

In Unit l' * ~' ,Y -m $ -

- In common (those areas shared by- >

~ ' "

.  ? * -

. v. .

both Unit 1 and Unit;2) g g .

{'~ _

_~.;

h In Unit _2

~

v +

'If[

-- . . c

~

~"

(2) Are all of the supports in your answer to (1) above safety-related?

(3) If the answer to (2) above is no, how many are safety-related in: ~

~~

Unit 17 In common? _

- -.m- .,

Unit 27- - a Provide the drawing and calculation package for'

~

c.

each of the 182 supports utilized in the sample-(as they existed at the time the sample was taken and, if different, as they exist at this time.)

d. Provide any and all documentation of Applicants' statement that "The resulting selection of 182 supports contained an excellent mix of .,

buildings, systems, classes and types of supports." .. .

Applicants stated " Analysis of the above sample 1

e.

demonstrates that for over 95% of the sampled Ia supports the tube steel members seeing the

" maximum stress is stressed less than 50% of the reduced A500 allowable" (emphasis in the original).

i (1) Provide any and all documentation of l

' Applicants' statement.

(2) List each support which constituted the 5% of the sampled supp/ orts where the l

tube steel members seeing the maximum stress was stressed 50% or more of the reduced A500 allowable.

Include in your answer the maximum stress which was indicated for each such support.

A, f.. Applicants stated "In fact,.the average.

percentage of the allowable stress seen by all' C"

-: a -' -

such members,is,16.4%." , _

~

Ibi ~ ~

Provide any a all documentation for ~ . g .  : < . ,

Applicants' statement (including, but not  ;

limited to, the raw data for the listing on page.

7 of the Affidavit).- -

~

Y1 -

Response

1. -3 . . . .

Applicants have answered a significant portion of these questions already (see First and Second Sets of Partial Responses to Fifth Set, April 25 and June 28, 1985).: -

Further answers are noE required in that the A500 question was not part of Applicants' Plan.

9 I s

1

---

.,__-.,,_,,p ,_

Question:

4. Applicants stated:

"To verify the adequacy of these measures, we performed an evaluation of 13 skewed T-joint designs at CPSES selected at random, and in all cases these joints met or exceeded the load capacities required by AWS.' The

. highest stressed weld was only. stressed to 39 percent of g~".ag AWS allowables (21 ksi)."

=1. f

. ~. ~ ;.

a. How many skewed T-joint designs are there,at CPSES? }.- ' ;f.: _

j ,

,;; y_9

b. How many supports have skewed T-joint designs at CPSES?'--- *

= > : L=w / + ._

- How many skewed T-joints are the.re on all such supports

~~ "

c.

at CPSES? .

s -

• ~

d. How was it decided what the number of skewed T-joint

designs to be evaluated would be? Provide the basis for that decision and all details. ~

e. Provide any and all documentation of-Applicants' state-ments and or your answers to a, b, c, and d above.

Response

~

4.a.-d.

~ - - - .

. . . .~~

Applicants previously responded to these questions in ,

Applicants' second partial response to the Fifth Set, filed 6/28/85.

4.e.

Applicants will produce the calculations concerning the 13 T-joint designs, which had previously been objected to, as Attachment 5-4.(e).

}4 Regarding Axial Restraints:

Where an affidavit is referenced, it is the Affidavit of I Robert C. Iotti and John C. Finneran, Jr. Regarding 1

Consideration of Force Distribution in Axial Restraints, which was attached to Applicants' 7/9/84 Motion for Summary Disposit;on Regarding Allegations Concerning t

Consideration of Force Distribution in /Axial Restraints.

/

s

\

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

Question:

,7 . Affidavit at page 15, middle of page:

a. What is the basis for the statement that "These minimal (plastic] strains are of no consequence to the integrity of the pipe of the lug"?

Has any' analysis been performed to' verify the-~ ,

+

'/ ~ b. ~

statement referenced in a. preceding?

If the answer is yes, provide any and all - -

documentation of such analysis. .

c. Has any te b~been performed to verify the statement referenced in a. preceding?

If the answer is yes, provide any and all documentation of such test (s).

d. How does the sampling and/or analysis and/or NASTRAN analysis take into account cyclic loading?

~

e. Provide any and all documentation of your answer to d. preceding.

Response

I 7.a.

The basis for the statement is explained on page 15 of the Affidavit. The plastic strains which permit a 1/16 inch deflection of the lug are entirely localized on the surfaces of the lug and the pipe as shown in Figures 9 and 10 of Attachment 1 to the Affidavit. The remaining elastic material in the lug and pipe is quite capable of carrying the load without concern for the integrity of the pipe or lug. Moreover, the maximum plastic strains (see page 5 of Attachment 1 to the Affidavit) in both

/

the pipe and the lug are very low and are less than 1/20 of the ultimate strain of the material of either pipe or lug.

7.b.

The analysis which verifies the basis for the statement has been provided as Attachment 1 to the Affidavit.

7.c.

Applicants have performed no tests to verify the statement. However, numerous industry tests have been performed for ductile materials which indicate that at low plastic strain there is no concern with material ,

integrity. For instance, the standard governing design of pipe rupture restraints and behavior of pipe following the rupture limits the plastic strains to 1/4 of the ultimate strain so as to assure the integrity of both (see ANSI N58.2).

7.d.

No. The maximum strain corresponding to the 1/16 inch deflection, 0.007 in/in in the pipe shell, when multiplied by E=30x10 6 psi, produces an alternating j,

5 stress S 3 equal to 2.1x10 psi which gives a fatigue life of 90 peak cycles. The number of peak cycles of seismic excitation is 60 and, after the first, the strain of 1/16 would not occur since load is shared by other lugs. As a result, no specific consideratio. was given to cyclic loading.

,- -- - -- , , - - - - - ~ , , ,n -.- --

7.e.

Not applicable.

Regarding Damping Factors:

Where an Affidavit is referenced, it is the Affidavit of Robert C. Iotti in Support of Applicants' Reply to CASE's Answer to Applicants' Motion Regarding Alleged Errors Made in Determining Damping Factors for OBE and SSE Loading Conditions, which was attached to Applicants' 9/21/84 Reply to CASE's Answer to Applicants' Motion Regarding Alleged Errors Made in Determining Damping Factors for OBE and SSE Loading Conditions.

Question:

8. Affidavit at page 5, last paragraph continuing on page 6:

a. Provide the basis for Applicants' position that the use of damping values for "the preponderant portion of the system being analyzed" will result in a valid design for the unpreponderant portion of the system.

b. Have any tests been performed to support your answer to a. preceding?

c. Provide any and all documentation for your answer to a. and b. preceding.

Response

8.a.

Applicants have already explained their position on pages 35-36 of Applicants' Corrections Affidavit.

8.b.

No.

8.C.

Not applicable.

- - - - - , , - - ----.e--v.,-. y ,,n., --+

e , , - - - . .e -. ,- - - - - -

Regarding Differential Displacement (Wall-to-Wall / Floor-to-Ceiling:

Where an Affidavit is referenced, it is the 6/22/84 Affidavit of R.C. Iotti and J. C. Finneran, Jr.

Regarding Differential Displacement of Large Frame Pipe Supports, which was Attachment 1 to Applicants' 6/22/84 Motion for Summary Disposition of CASE Allegations Regarding Differential Displacement of Large-Framed, Wall-to-Nall and Floor-to-Ceiling Pipe Supports.

9. Affidavit at page 8, last paragraph continuing on page 9:

a. What is the basis for Applicants' belief that the three supports (CC-1-070-002-A33R, CS-X-004,004-A33R and SW-1-132-703-Y33R) are

" representative"?

b. Provide any and all documentation for your answer to a. preceding. ,

c. Provide all documentation (including, but not limited to, drawings and calculations) for the three supports analyzed (i.e., supports CC 070-002-A33R, CS-X-004-004-A33R, and SW-1-132-703-Y33R) as they existed at the time of the analysis,

d. Have these three supports been changed since the time of the analysis?

If the answer is yes, provide all documentation (including, but not limited to, drawings and calculations) for the three supports as they exist at this time.

Response

9.a.

This answer has aircady been provided in Section E. of Applicants' " Response to NRC Questions of Meeting of August 8-9 and August 23, 1984", a copy of which was sent to CASE on 9/24/84.

9.b.

See answer to 9.a.

9.c.

The requested drawing was furnished with the material provided in response to Staff questions (see answer 9.a.). The requested calculations will be made available for inspection and copying. (Attachment 5-9.(c).)

9.d. Some of these supports may have been changed since the analysis, but not for reasons related to this issue.

Regarding Friction:

Where an affidavit is referenced, it is the Affidavit of John C. Finneran, Jr. in Support of Applicants' Reply to CASE's Answer to Applicants' Motion for Summary .

Disposition Regarding Consideration of Friction Forces, which was attached to Applicants' 9/19/84 Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Consideration of Friction Forces. .

Question:

10. Affidavit at page 10, first paragraph:

f. Who (name, title, organization) were the engineers referred to in the next-to-the last sentence of the first paragraph where it is stated "I requested that my engineers review support drawings at random to identify these supports."

g. Were any of the individuals identified in your p

answer to f. preceding field engineers?

h a

Response

10.f.

Jimmy Sherrer (Design Engineering Supervisor -- Pipe support Engineering) and Mike Chamberlain (Lead Engineer

- Pipe Support Engineering).

10.g.

No.

Regarding Generic Stiffness:

Where an affidavit is referenced, it is the Affidavit of R. C. Iotti and John C. Finneran, Jr., Regarding Use of Generic Stiffnesses Instead of Actual Stiffnesses in .

Piping Analysis, which was attached to Applicants' 5/21/84 Motion for Summary Disposition Regarding Use of Generic Stiffnesses Instead of Actual Stiffnesses in Piping Analysis.

Question:

11. Affidavit at page 2, A3., continuing on page 3, regarding Applicants' discussion of the survey conducted by Gibbs & Hill in 1980 of 16 nuclear projects:

a. Were the 16 nuclear projects selected the only nuclear projects which met the criteria of "having construction permit dates within a +/-1 year time span of the construction permit date of Comanche Peak"?

b. If the answer to a. preceding is yes, list the 16 nuclear projects. Also identify the Engineering firm involved in each plant's

- design / construction. In addition, state the status of each of the 16 nuclear projects at this time.

c. If the answer to a. preceding is no, list all other nuclear projects which also met the criteria and the Engineering firm involved in each plant's design / construction.

d. Applicants discuss a survey of 16 nuclear projects and the surveyed Engineering firms.

How many engineering firms were involved in the survey?

e. Identify the Engineering firm which is stated to be the "only one (which] gave specific instructions to the support design group to meet the range of values for support stiffnesses assumed in the analyses."

f. Identify the Engineering firm which is identified as "Another instructed the hanger vendor to meet the stiffness criteria for at - o liary steel only."

g. ,de .ify the remaining firms.

h. By what method has each of the remaining firms (including Gibbs & Hill) confirmed that the

" engineering approach to design supports for conservative load combinations," which they permitted the pipe support vendor to use, is in fact conservative. Provide specific details.

i. Provide any and all documentation for your answers to a. through h. preceding. -

Response

ll.a. .

Applicants have not stated that the 16 nuclear projects selected are the only nuclear projects having construction permit dates within +1/-l year time span of the construction permit date of comanche Peak. If CASE is interested in establishing whether they are the only ones, they can refer to the same publicly available

[ information as Applicants.

\

' 11.b.

The 16 nuclear projects are listed in Attachment 5.11.b.1, which will be made available to CASE for inspection and copying. CASE may refer to publicly available information to ascertain the status of each plant.

11.c.

Applicants do not possess that information. To respond to this question would require independent research and data gathering by Applicants. Accordingly, Applicants object to responding to the question. See South Texas, .

supra.

11.d.

The engineering firms involved in the survey are listed in Attachment 5.11.b.1. There are a total of 7 firms which would be considered engineering firms. Two more firms normally would be considered utilities with large engineering staffs.

11.e.

The engineering firm giving specific instructions to the support design group to meet the range of values for support stiffness is Stone & Webster.

11.f.

The firm giving instructions to hanger vendors to meet the stiffness criteria for auxiliary steel is Brown &

Root. The remaining firms are listed in Attachment 5-11 (b)(1).

ll.g.

The remaining firms are listed in Attachment 5-ll.(b)(1).

ll.h.

Applicants can only reply with certainty regarding the Gibbs & Hill method of confirmation. What the other firms may have done to confirm the conservatism of employing solely a deflection guideline is not directly available. In any case, Applicants have not claimed that the " engineering approach to design supports for conservative load combination" is conservative.

4 Applicants stated that those " firms, including Gibbs &

Hill, have permitted the pipe support vendor (s) to use

[their] own conservative engineering approach to design supports." Gibbs & Hill's concern, properly so, was .

that the stiffnesses developed into the supports by the vendor design process should correspond closely to the values which had been utilized by Gibbs & Hill to develop the loads, i.e., the generic stiffnesses. The method chosen by Gibbs & Hill was a comparison between the actual stiffness values produced by vendor designs and the generic stiffnesses. This comparison was accomplished using a sample of 60 pipe supports designed by NPSI selected on the basis of readily available calculations. (See Applicants' Third Partial Response to CASE's Fifth Set, July 1, 1985, response to Question 12(e).)

- ~ - . - -y ,-- - . , - . , - - , - - - , _ - - - - - . - , - - - - - - - - , - - - - - . - - . -

l l

. 1 I

l 11.1.

Specific details on the method employed by Gibbs & Hill have already been provided in response to Question 12 of the Fifth Set of Credibility Interrogatories (see

" Applicants' Third Partial Response to CASE's Fifth Set of Interrogatories Re: Credibility," filed July 1, 1985, pages 7-10).

Question:

14. Affidavit at page 4, A7., continuing on page 6:

c. Were the effects of mass participation (as ,

discussed by Cygna) included in the reanalyses?

d. If the answer to c. preceding is no, why not?

e. How did/will the inclusion of the effects of mass participation (as discussed by Cygna) affect the results of any reanalyses?

f. Provide any and all documentation for your answers to a. through e, preceding.

Response

14.c.

No.

14.d.

The objectives of the reanalysis were to determine the effects of stiffnesses variation from those originally assumed. Inclusion of the effects of mass participation could have masked some or all of the effects of different stiffnesses.

14.e.

Applicants performed a limited investigation of this effect. (see response to Question 29.) The conclusion of this limited effort was that the inclusion of mass participation tends, but is by no means an absolute rule, to reduce differences in results between the use of generic and actual stiffnesses.

14.f.

Applicants will produce for inspection and copying the analyses performed for this limited investigation (Attachment 5-14.(f)).

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 Applicant to Support Design, which is -

Attachment 1 to Applicants' Motion for Summary Disposition Regarding Design of Richmond Inserts and Their Application to Support Design.

Question:

23. Affidavit at page 38, last paragraph:

a. What assurance is there and/or what criteria required the NPSI designer to check for sufficient elongation?

What sampling program was used to assure that

[ b.

the criteria discussed in a preceding was actually utilized and implemented?

c. How many supports were included in this analysis?

d. List each support which was included in this analysis?

j S

e. Provide the drawings and calculations for each

-support which was included in this analysis.

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

Response

23.a.

There were no written criteria at that point in time, i.e. during the phase of work prior to the beginning of the as-built program referred to in the Affidavit at page 38, which expressly called for the NPSI designer to check for sufficient bolt elongation. There is, o therefore, no documentation that the designer would have .

done so in all instances. The designer was expected, however, to do so if in his judgment modelling of the connection as pinned would be improper. Applicants note that written criteria regarding this matter would not be expected in that, as we stated in the Affidavit, the industry practice it to model the joint as pinned (Affidavit at 38).

23.b.

Not Applicable 23.c.

CASE is not clear as to which " analysis" it is referring to. If CASE is referring to the sampling program in part b., there is no answer as the question is not relevant to a sampling program. If CASE is referring to

the analyses discussed in the second paragraph of page 39 of the Affidavit, then the number of supports is given in Table 2 of the Affidavit.

23.d.

See response to pat- c., above. Supports in Table 2 are provided given in the Affidavit.

23.e.,f.

Upon clarification by CASE, Applicants will ascertain which documents are responsive to this request.

Regarding Caps:

Question:

25. a. Have Applicants or their employees performed any tests or analyses regarding the effects of gaps which were not discussed in Applicants' Motion for Summary Disposition regarding gaps?

b. Provide any and all documentation for your answer to a. preceding. .

c. If the answer to a. above is yes, provide any and all documentation regarding such tests or analyses.

Response

25.a.

No.

25.b.

( Not applicable.

25.c.

Not applicable.

Regarding Cinched-Down U-Bolts:

Where an affidavit is referenced, it is the Affidavit of Robert C. Iotti and John C. Finneran, Jr. Regarding Cinching Down of U-Bolts, which was Attachment 1 to Applicants' 6/29/84 Motion for Summary Disposition of CASE's Allegations Regarding Cinching Down of U-Bolts.

See also CASE's 11/5/84 Motions and CASE's Answer to Applicants' Response to Board Request for Information Regarding Cinching Down U-Bolts.

Question:

29. Isn't it true that mass participation was not considered in any of Applicants' Motions for Summary Disposition?

a. If the answer is no, provide any and all documentation for your answer.

b. Is [ sic) the answer is yes, why wasn't it considered? Provide specific details. .

Response

29.a.

Yes. It was not considered in any of the motions for summary disposition. It was considered in response to an NRC inquiry regarding generic stiffnesses. (See Applicants' 9/24/84 Answers to NRC Staff Questions).

29.b.

See Answer to 14.d. of this set.

Question:

30. Which of the following was considered in sampling, analyses, and/or testing in Motions for Summary Disposition other than its own (i.e., were generic stiffnesses considered in any Motion for Summary Disposition other than the Motion for Summary Disposition regarding generic stiffnesses):

Reduction in yield strength of A500 steel Damping values

AWS/ASME (design)

Friction forces section property values Gaps Generic stiffnesses Effects of U-bolts acting as two-way restraints Richmond inserts Stability Local displacements Differential displacements Effects of cinched-down U-bolts Axial restraints Provide any and all documentation for your answer.

Response

'30. .

(a) Reduction in yield strength of A500 steel was not considered in any motion for summary disposition other than its own, because Applicants are not required, nor chose, to use a reduced value of yield strength.

(b) Damping values were considered directly or indirectly in several other motions. Damping

[

values determine the magnitude of the response spectra to be utilized for seismic analysis and design. Consequently, the choice of the damping values affects the loads seen by the supports.

)

1 T

1

\

Any motion which utilized loads to supports l l

would thus have indirectly considered damping  ;

values. More directly, damping values were considered in motions in which response spectra analysis were rerun; specifically, generic stiffness, effects of U-bolts acting as two-way restraints and axial restraints. (Results of the response spectra analyses performed for the generic stiffnesses, U-bolts acting as two-way, and axial restraint motions have already been provided.) Further, the Motion for Summary ,

Disposition on Damping values for OBE and SSE addressed a very narrow issue, specifically focussing on allegations that Applicants utilised improper damping values in a particular stress problem (stress problem 1-41). That concern does not require special consideration in any other motion, other than to assure that 1

proper damping values were used in each case.

(c),(d) AWS/ASME and friction forces were not explicitly ,

considered in other motions. Implicitly, they would have been considered in any of the other i

4 motions where Applicants evaluated the effect of loads on particular supports.

l

! (e) Section property values in agreement with the 8th Edition of the AISC Code were used whenever

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tube steel was encountered in evaluations conducted by PSE for the other motions. ITT Grinnell and NPSI employed the 7th Edition of the Code. CASE will recall that Applicants committed to reevaluate all tube steel members for 8th Edition values.

~

(f) Gaps are not addressed in any other motion because no other motion delves in geometric, non-linear behavior.

(g) Generic stiffness instead of actual stiffness k' was addressed in its own motion and in the Richmond Insert Motion, Affidavit at pp. 39-40.

(h) Effects of U-bolts acting as two-way restraints were addressed only in that motion.

(i) The principal issues addressed in the Richmond .

Inserts motion were considered only in the motion itself. However, data acquired from the test program conducted in connection with that motion was used in providing additional information to the NRC on the Motion on Gaps (see Applicants' letter to NRC dated July 11, 1984).

(j) Stability was also addressed in the motion on the cinched-down U-bolts, as were the effects of cinched U-bolts considered in the stability motion.

1 (k) Local displacements and stresses were considered in the motion on cinched-down U-bolts.

Documentation is provided in that motion (i.e.,

local stresses measured by test and determined by finite element analyses).

(1) Differential displacements were considered in the subject motion and in the motion regarding the upper lateral restraint. For the latter, differential displacements (both thermal and seismic) of the ends of the upper and lower lateral restraint were considered. ,

Documentation was provided with the affidavit supporting that Motion.

(m) Effects of cinched-down U-bolts were considered in the motion for stability.

(n) Axial restraints were considered only in the subject motion.

Question:

31. Have Applicants utilized any samples or performed any analyses or tests concidering the cumulative effects of the following:

Reduction in yield strength of A500 steel Damping values AWS/ASME (design)

Friction forces Section property values 4

w. - ,-- - - - , - - - , , _ , . . - - - - . . , - ,

Gaps Generic stiffnesses Effects of U-bolts acting as two-way restraints Richmond inserts Stability Local displacements Differential displacements Effects of cinched-down U-bolts Axial restraints Provide any and all documentation for your answer. ,

Response

i 31.

In the performance of the tests supporting the Motions for Summary Disposition, certain cumulative effects were present, whether or not intended or desired. Applicants performed four tests: stiffness of supports; lateral and axial capability of U-bolts; cinched U-bolts; and Richmonds. In all tests, gaps were no doubt present and i

their effects would have been reflected in the results.

l This is most clearly illustrated in the stiffness test where low stiffnesses were observed when the load was

,4 insufficient to take up slack produced by the gap.

in Stability was not considered "as a cumulative effect" the cinched U-bolt test. Rather, stability (or lack of it) was one of the answers sought by the tests. Except for those situations Applicants made no effort to

ascertain the cumulative effects of these mostly unrelated issues either-by test or in samples.

Cumulative effects in analyses are discussed in the answer to Question 30 above.

Question:

32. In regard to samples, for each of the items' discussed in questions 1 through 31 preceding, supply the following information (if it has not already been supplied in answer to a previous question):

a. Do Applicants consider that the sample was a randomly selected representative sample?

b. Do Applicants consider that the sample was a ,

randomly selected representative sample which is representative of the items:

in Unit 17 in common (those areas shared by both Unit 1 and Unit 2)?

in Unit 27 in Unit 1, in common and in Unit 2 (i.e., throughout the entire plant)?

c. Was there a specific procedure or instruction regarding the criteria which was to have been used to select the sample?

If so, identify each such procedure or instruction, and provide a copy of each.

- d. Provide any and all documentation regarding the specific criteria which Applicants used in selecting the sample, including any and all documentation of the representativeness of the sample of the items in Unitin1,common, in common, in Unit 2, and/or in Unit 1, and in Unit 2.

e. Did Applicants use any recognized authoritative sampling technique (such as Military Standard 105D-63, " Sampling Procedures and Tables for

- - - - . _ . . _ _ c. . ._,, , , .

i Inspection by Attributes") in selecting your sample and size of your sample?

If not, why not?

If so, what specific technique (s) did you Provide a copy of each such technique.

s utilize?

Provide any and all documentation that such technique (s) was/were used.

What is the confidence level (limit) (i.e., 95%

f.

confident that 95% of the supports will behave as predicted by the sample; 90% that 20% of the supports will behave as predicted by the sample; etc.) which one can expect (taking into consideration the sample size used, etc.)?

Provide the basis and any and all documentation for your answer.

g. What distribution of data was assumed or considered to arrive at the confidence level (limit) (i.e., Weibull, gamma, Rayleigh, etc.)?

Provide any and all documentation for your answer.

h. If the confidence level (limit) was not If not considered considered, why wasn't it?

before, please state now what the confidence -

level is based on the sample which was used?

Provide the basis and any and all documentation for your answer.

j

i. Who (name, title, organization at the time) l determined the specific criteria which Applicants used in selecting the sample?

j. Who (name, title, organization at the time) actually selected the specific items included in the sample?

i

/: k. Provide a list of all items included in the whether the sample. For each, also indicate:

item was in Unit 1, in common, or in Unit 2; and the time frame during which the sample was performed.

s

1. Provide copies of all documentation for each of the items included in the sample.

Response

32.

To best answer this question, we have identified the samples referred to in the prior 31 questions. Each of the parts of this question is answered for each sample by referring to its label. The following are the samples, letter label, and the reference to where it is discussed in the previous 31 questions.

Sample Question A. 182 A-500 Steel supports 3.c-f 13 skewed T-joints 4 B.

C. 3 diff. displac. supports 9.a 5 friction supports 10.b,1 D.

E. Concrete samples for Richmond Inserts 18.d.

F. Richmond Insert Samples of Table 2 24 U-bolt torque samples 27 G.

60 NPSI support stiffness sample 12.a, b H.

32.(a)

Applicants' position regarding randomness and representativeness of a particular sample is stated in the applicable Affidavit.

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y,_m- m

I

{

l l

32.(b) l It is affiants' opinion that the samples are  !

l

" representative" for the particular purposes they were used in the motions, as follows:

A- entire plant B- PSE design in entire plant (Refer to Attachment 2 of Affidavit for distribution of the sample supports in Unit 1, Unit 2 and common)

C- the sample supports are from Unit 1 and Common; but we believe that they would be representative of the entire plant D- the sample is all from Unit 1, but we believe it to be representative of the entire plant .

E,F - entire plant G- entire plant, although sample was taken from Unit 2 H- NPSI designs in the entire plant As noted below, no claim was or is presently made as to the particular statistical randomness of those samples.

f 32.(c)

No. See response to 32.(e).

32.(d)

To the extent information exists regarding sample selection and representativeness it was provided with

,/

e

the motions or in responses to prior discovery requests or Board inquiries.

~32.(e)

No specific sampling technique was utilized.

The reasons for not utilizing " recognized authoritative" sampling techniques vary. For the 182 supports utilizing A500 steel, a statistically selected, random sample was not chosen because Applicants di' not require establishment of new allowables or verification of existing design against new allowables. Applicants obtained a sample to provide a basis to quantify the ,

effect of using a lower yield strength if that requirement were imposed, which it was not.

The 13 skewed T-joints were selected from approximately every hundredth design out of about 1300 PSE designs at the date of the Affidavit. The latter were arranged without any particular bias and hence the sample may be considered random within the definition of MIL-STD-105D.

Although Applicants' did not specifically use this standard or suggest that they had, they were familiar with it and k:.w that selection of 1 percent of the population would be sufficient if all results of the sample were positive, which they were. With selection of 1 percent of the population in a single sample high confidence (95%) can be obtained that the fraction of

/

problem joints is less than 1 percent (see single sampling plan, special inspection S-3, pp. 9, 10, 38, 39 of the MIL standard).

The 3 differential displacement supports were chosen to show that floor-to-wall differential displacements are comparable to, or less than, differential displacements between floor-to-floor or wall-to-wall, and that consequently the floor-to-wall support design will be affected comparably to, or less than, the supports which are floor-to-floor or wall-to-wall. No statistical inference was ever suggested.

The five friction supports were added to supports flagged by CASE simply to provide additional evidence that the concern with friction was invalid. No statistical inference had been planned.

There was no need to statistically sample the concrete used in the plant, since the quality and strength of the concrete were covered by an extensive sampling program

[ by Brown & Root.

The sample of support configurations utilizing Richmond Inserts was chosen to compare stresses, deflections and stiffnessescomputedbySTRUDLmodelsunperdifferent e

O assumptions of constrained or unconstrained moments. No statistical inference was contemplated as the intent was to show that differences would be minor.

The statistical significance of the U-bolt torque samples has been amply discussed in filings responding to Licensing Board questions. Applicants never intended to use the sample for statistical conclusions on acceptability of torques, but simply to use the data to define torque ranges for testing. We will not elaborate further. ,

The 60 supports for which stiffness data was provided by NPSI to Gibbs & Hill were selected on the basis of availability of actual stiffness calculations. The purpose of the sample was to determine whether the deflection criterion, plus the NPSI method of design, would produce stiffness comparable to the generic values assumed by Gibbs & Hill. Since precision was not l required, i.e., there was no definitive deviation value l

at which the actual stiffness would be unacceptable, no statistical sampling was deemed necessary.

32.(f)

No attempt was made, with one exception, to establish confidence levels regarding the percentage of supports l

\ whose behavior would be unacceptable. The one exception i /

l

\ -

for which confidence levels had been explicitly derived is the sample of 182 supports using A500 steel. That calculation (uhich Applicants will make available for inspection and copying as Attachment 5.32.f.1) shows that there is 95% confidence that 98 percent or more of the supports will behave as those of the sample.

However, for the previously described reasons, we elected not to include this information in the 4

Affidavit. Also, we considered, though not explicitly, the confidence level of the sample for skewed T-joints (see answer (e), above).

Applicants object to providing a further response as it would require independent research and data gathering.

(South Texas, supra.) .

32.(g)

The answer to this question is only applicable for the samples for which confidence levels have been quoted in (e) and (f) above. For (e), the implied distribution is normal, and for (f), no distribution needs to be assumed.

2 d- 32.(h)

Confidence levels were not considered except as outlined in (f) above, because Applicants did not plan to draw statistical inferences from the samples. Applicants

,/

e

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w, -m,-

object to providing a further response as it would require independent research and data gathering. (South Texas, supra.)

32.(i)

A - Provided in response to prior discovery requests (Applicants' Response to CASE's Fourth Set, March 13, 1985).

B,C,D - John C. Finneran, Jr., Project Pipe Support Engineer, PSE.

E - R. M. Kissinger, Project Civil Engineer, CPPE (Mr. Finneran provided titles, organizations, .

etc.)

F,G - Mr. Finneran H - Applicants do not recall who determined the criteria or who actually selected the sample.

We believe it was one, or all, of the following:

A. Saha, Verlon Moore and/or Herman D'Errico of NPSI. (None of those individuals is currently employed at NPSI.)

32.(j) l A - See response to Question 32.(i).

B - Mike Chamberlain, Lead Engineer, PSE C - Mr. Finneran; Barry Hill, Design Engineering Supervisor, PSE D - See response to Question 10.(f)

E - Mr. Kissinger and John Eichler, Chief Engineer,

' Gibbs & Hill r-y- y , , , ..,-_, ,,_ ,.-.,---_ -_ -____y_mw, _ %. _ mm... _.-. _-_-- - -

63 -

F -

Mr. Chamberlain G - Jay Ryan, Chief Engineer, PSE; John Sampson and John Menpgen, Field Engineers, PSE H - See response to Question 32.(i), item H.

32.(k),(1)

This information has already been provided in the Affidavits or in response to a number of prior discovery requests.

Question:

33. If tests (actual physical tests, analytical tests, or other tests) were performed, for each of the items discussed in questions 1 through 31 preceding, supply l

the following information:

a. Do Applicants consider that the items te'sted were representative of worst-case conditions?

b. Do Applicants consider that the items tested were representative of worst-case conditions for the items:

in Unit 17 in common (those areas shared by both Unit 1 and Unit 2)?

in Unit 27 in Unit 1, in common, and in Unit 2 (i.e., throughout the entire plant)?

j I c. Was there a specific procedure or instruction regarding the criteria which was to have been used to determine which items were to be tested?

If so, identify each such procedure or instruction, and provide a copy of each.

d. Was'there a specific procedure or instruction regarding the criteria which was to have been used to determine which items were representative of worst-case conditions?

I

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-y. ---,

e. Provide any and all documentation of the specific criteria which Applicants used in determining which items were to be tested, including any and all documentation of the representativeness of the sample of the items in Unit 1, in common, in Unit 2, and/or in Unit 1, in common, and in Unit 2.

f. Did Applicants use any recognized authoritative testing technique (such as Military Standard 105D-63, " Sampling Procedures and Tables for Inspection by Attributes") in performing the test?

If not, why not?

If so, what specific technique (s) did you utilize? Provide a copy of each such technique.

Provide any and all documentation that such technique (s) was/were used. ,

g. What is the confidence level (limit) (i.e., 95%

confident that 95% of the supports will behave as predicted by the test results; 90% that 20%

of the supports will behave as predicted by the test results; etc.) which one can expect?

Provide the basis and any and all documentation for your answer.

h. What was the confidence level (limit) which the Applicants required prior to the sample's being taken?

Provide the basis and any and all documentation for your answer.

i. What distribution of data was assumed or considered to arrive at the confidence level (limit) (i.e., Weibull, gamma, Rayleigh, etc.)?

Provide any and all documentation for your answer.

j. If the confidence level (limit) was not considered, why wasn't it? If not considered before, please state now what the confidence level is based on the test results? Provide the basis and any and all documentation for your answer.

/

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k. Provide any and all documentation of the specific criteria which Applicants used in determining which items were representative of worst-case conditions.

1. Did Applicants use any recognized authoritative testing technique (such as Military Standard i

105D-63, " Sampling Procedures and Tables for Inspection by Attributes") in determining which items were representative of worst-case conditions?

2 If not, why not?

' If so, what specific technique (s) did you utilize? Provide a copy of each such technique.

Provide any and all documentation that such technique (s) was/were used.

4 m. What is the confidence level (limit) which one can expect that Applicants' tests were representative of worst-case conditions?

Provide the basis and any and all documentation for your answer.

n. What was the confidence level (limit) which the Applicants required prior to the test being -

performed?

Provide the basis and any and all documentation for your answer.

o. What distribution of data was assumed or considered to arrive at the confidence level (limit) (i.e., Weibull, gamma, Rayleigh, etc.)?

l Provide any and all documentation for your answer.

3 p. If the confidence level (limit) was not considered, why wasn't it? If not considered

( before, please state now what the confidence level is, based on the test results, that Applicants' tests were representative of worst-case conditions? Provide the basis and any and all documentation for your answer.

q. Who (name, title, organization at the time) l determined the specific criteria which Applicants used in determined which items were to be tested?

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r. Who (name, title, organization at the time) determined the specific criteria which Applicants used in determining which items were representative of worst-case conditions?

s. Who (name, title, organization at the time) actually selected the specific items to be included in the test?

t. Provide a list of all items included in the whether the test. For.each, also indicate:

item was in Unit 1, in common, or in Unit 2; and the time frame during which the sample was performed.

u. Provide a list of all items included in the sample which were considered to be representative of worst-case conditions.

f I v. Provide copies of any and all documentation for each of the items included in the test. ,

w. What is the basis for Applicants' belief that ,

the items tested are representative of worst-case conditions?

x. Provide copies of any and all documentation that '

j the items tested are representative of worst- ,

case conditions.

l

y. Were there any tests performed which were not '

3~ included in Applicants' discussions in their Motions for Summary Disposition? If the answer '

is yes, provide the answers to questions a, through x. preceding for each such test, as well as the results of, and any and all documentation regarding, each such test. ,

J

z. Have any additional tests been performed since the time when any of Applicant's Motions for j

Summary Disposition were filed?

If the answer is yes, provide a brief summary cf ,

each such test.

I If the answer is yes, provide the answers to questions a. through x. preceding for each such test, as well as the results of, and any and all ,

! documentation regarding, each such test.

aa. Is it anticipated that any additional tests will >

be performed? ,/

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If the answer is yes, provide a brieZ sumusty of each such test.

If the answer is yes, provide the answers to questions a. through x. preceding for each such test, as well as the results of, and any and all documentation regarding, each such test.

Provide the information as soon as any portion of it is available.

bb. Where your answers to any of questions 1 through 33 preceding concern an individual, for each of the individuals referenced in your &nswer, supply the following information:

(1) Is the individual still employed at Comanche Peak?

(2) What was the individual's position and job description at the time the referenced decision was made?

(3) Has the individual had a change in shifts, position, pay scale, etc., since the time the referenced decision was made?

(4) If the answer to (3) above is yes, supply complete details. Also supply all documents, including specifically -

job performance ratings, counseling reports, exit interviews, etc.,

regarding all such changes.

(5) Has the individual quit or been terminated since the time the referenced decision was made?

(6) If the answer to (5) above is yes, supply complete details, including whether or not such individual was fired or laid off, the reason for such action,

.and all other related details. Also f'

supply all documents, including specifically job performance ratings, counseling reports, exit interviews, etc. Also include the individual's last known address and telephone number.

Response

33. ,/

J The LEsts .d.10S ale Fertiner,t tc 'he question have been categorized as was done-for question 32.

Test Question A. Actual Stiffness 13b,c,e,g,h B. Richmond Inserts 16a(11)(12)(13)(14),17 C. U-bolt Test by ITT Grinnell 26 33.(a)

For A and C the answer is no because none of the tests had testing of worst case configurations as an objective. For B, Richmond Insert capacity was tested ,

under conditions representing actual concrete strength with typical minimum reinforcement that may be found in the plant. (See response to Question-18.(b), Third Partial Response to CASE's Fifth Set, July 1, 1985.)

33.(b)

With respect to A and B, not applicable. With respect to C, representative of entire plant to the extent described in the response to (a).

33.(c)

A - no B - yes; test procedures were prepared specifying the particular inserts to be tested. The test procedures will be produced (Attachment 5-33(C)(1)).

C - Applicants have requested information from ITT regarding any procedure in addition to that called out

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..n the test report (which CASE has a copy of). We will supplement this response when information is received.

33.(d)

No.

33.(e)

See answer to 33(c) 33.(f)

No. Not required.

33.(g)

A - not applicable B - confidence level was not required because recognized testing practice of ASTM 488-76 was utilized.

C - confidence level was not required because Section NF test requirements were utilized to establish allowable loads. .

33.(h)

See answer to g) above 33.(i)

Not relevant for A, and not applicable for B and C.

33.(j)

See answer to (g) above.

I 33.(k)

Not applicable (see (a) above).

33.(m)

Not applicable (see response to a. and b.). In-addition, the request does not make sense statistically.

33.(n)-(p)

See answer to (g) above

~33.(q)

A - John C. Finneran, Jr.

B - John C. Finneran, Jr., Richard M. Kissinger, Robert C. Iotti C - John C. Finneran, Jr., Robert C. Iotti 33.(r)

See answer to (g) above 33.(s)

A - Jay Ryan .

B - Richard M. Kissinger C - Applicants believe it was Nicholas M.

Patsalides. We have asked ITT to confirm this.

We will correct this response, if necessary.

33.(t),(v)

This information was provided in the original l

affidavits, in response to previous discovery requests, or in replies to NRC questions. CASE has received all this information.

i 33.(u)

See response to Question 33.(a), above.

33.(w)-(x)

See response to Question 33.(g), above.

33.(y)

-+p -. , . ..- -

A - Yes; an explanation was provided to CASE in the answer to Question 13 of Applicants' Third Partial Response to CASE's Fifth set.

B, C- No.

33.(z)

No.

33.(aa)

None, in regard to motions for summary disposition.

33.(bb)

This question does not relate to tests. Consequently, No response is possible in this context.

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MOTION FOR PROTECTIVE ORDER Pursuant to 10 C.F.R. 52.740(c), Applicants move

. for a protective order with' respect to those requests as to which Applicants objected, above, to providing further responses. ,

Respectfully submitted, Nicholas S. Reynolds

' William A. Horin BISHOP, LIBERMAN, COOK, PURCELL & REYNOLDS ,

1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202) 857-9800 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 Franulin Street Boston, Massachusetts 02110 (617) 423-6100 h T By Wb h /t' Tk William A. Ho'rin June 30, 1986

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l State of Texas County of Somervell John C. Finneran, Jr., being first duly sworn deposes and says:

That he is Assistant Manager Piping and Support Systems.

TUGCO Nuclear Engineering for Comanche Peak Steam Electric Station and knows the contents of the foregoing Applicants' Additional Answers to CASE's " Credibility" Discovery Requestag 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.

pnC.Finneran,Jr. //

s Robert C. Iotti, being first duly sworn deposes and says:

That he is Vice President of Advanced Technology for ERASCO Services, Inc. and knows the contents of the foregoing Applicants' Additional Answers to CASE's " Credibility" Discovery Requests; 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.

h Robert C. Iotti /

State of Texas County of Somervell Subscribed and sworn to before me this 30th day of June 1986.

b Q(b & r'

' Notary 1% 11c "

Ary demo.sswn exPike-s m4cM .29,198 7

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,_.,__,,-,,,.,,,-_w,,,_ --

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 ) 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' Additional Answers to CASE's " Credibility Discovery Requests and Motion for Protective Order" in the above-captioned matter were served upon the following persons by deposit in the United States ,

mail, postage prepaid, or express mail (*) on this 30 day of June, 1986, or hand delivery (**) on the 1st day of July, 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. I 1107 West Knapp Trial Lawyers for Public Stillwater, Oklahoma 74075 Justice 2000 P St., N.W., Ste. 611 Washington, D.C. 20036

• Dr. Walter H. Jordan ** Ellen Ginsberg, Esq.

U.S. Nuclear Regulatory l

881 West Outer Drive 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

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1426 South Polk St. 324 North Capitol St.

Dallas, Texas 75224 Washington, D.C. 20002

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

• • 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 l

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 d\

fi .

Mew William A.' Horin I

cc: Robert A. Wooldridge John W. Beck

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