ML20207M001

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Signed & Notarized Affidavit,Correction to Portions of Affidavit of Case Witness J Doyle Re Case 861230 Partial Response to Applicants 861201 Response to ASLB Concerns.* Certificate of Svc Encl
ML20207M001
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 01/05/1987
From: Ellis J
Citizens Association for Sound Energy
To: Bloch P, Jordan W, Mccollom K
Atomic Safety and Licensing Board Panel
References
CON-#187-2133 OL, NUDOCS 8701130059
Download: ML20207M001 (7)


Text

2/33

, C A S E==e' 214/946-9hh6 (CITIZENS ASSN. FOR SOUND ENERGY)

'87 3 4 'l E 3 9 January 5, 1987 g

DOC a Administrative Judge Peter B. Bloch Dr. Kenneth A. McCollom*

U. S. Nuclear Regulatory Commission 1107 West Knapp Street Atomic Safety & Licensing Board Stillwater, Oklahoma 74075 Washington, D. C.

20555 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830

Subject:

In the Matter of Texas Utilities Electric Company, et al.

Application for an Operating License Comanche Peak Steam Electric Station, Units 1 and 2 Docket Nos. 50-445 and 50-446 - O(,

Signed and Notarized Affidavit, Correction to Portions of Affidavit of CASE Witness Jack Doyle, Regarding CASE's 12/30/86 Partial Response to Applicants' 12/1/86 Response to Board Concerns As stated in our 12/31/86 letter to the Board, CASE Witness Jack Doyle advised that he wished to correct some portions of subject affidavit; he dictated the changes to me by telephone, and they were attached to our 12/31/86 letter.

And, as stated in our 12/31/86 letter, we are now attaching Mr. Doyle's si'gned and notarized affidavit.

Please note that Mr. Doyle has made one slight additional change, so that the beginning of item 77 on page 52 now reads:

"77. The only point regarding the steam generator upper lateral restraint raised by TERA independent of exterior sources in Appendix B of the ' Civil / Structural Generic Issues Report,'

(Emphasis added to indicate additional change.)

This slight additional change appears to be necessary for accuracy, since there are other specific points raised by TERA independent of exterior sources regarding the steam generator restraints on page C-2 (apparently erroneously in this section, which has to do with "the design for other Seismic Category I Concrete Structures such as the Auxiliary Building, Fuel Building, Safeguard Building, and Pipe Tunnel") and on page E-2 (" pertaining to the design for the pipe rupture protection hardware").

8701130059 870105 1

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.1 For.the convenience of-the Board, these items state:

From page C-2:

i "C.

Poor Documentation and Missing Input / Output Latest loads for steam generator restraints not incorporated into final design calculations" From page E-2:

"(C) Poor Documentation and Missing Input / Output Lack of calculations for the steam generator side of restraint. The RCP side is designed for PSAR and preliminary WNES criteria WPT-797.. Calculations do not include coverage of anchor bolt design.

(SRB-111C)"

It should also be noted that NRC Inspection Report 50-445/86-07, 50-446/86-05, under cover letter of December 22, 1986 (received by CASE on 12/30/86, after Mr. Doyle's affidavit had been completed) appears to support Mr.

Doyle's affidavit at pages 49 and 50, item 72, (see Inspection Report, Deviation 445/8607-D-19, at: APPENDIX B, NOTICE OF DEVIATION, page 4, Deviation H; and pages 30 and 31, item 5.c.).

We are attaching hereto copies of corrected page 52 and of Mr. Doyle's 1/3/87 signed and notarized affidavit. We again apologize for any inconvenience this may have. caused.

Respectfully submitted, CASE (Citizens Association for Sound Energy) l

.rs.) Juanita Ellis i

President l

cc:

Service List 2

O*

the Applicants believe that the number of previous NPS employees, whether many or few, is irrelevant to the ability of the SRT to accomplish the tasks set forth in DSAP IX."

It may be noted that we believe, and as a result of the expansion of the CPRT effort feel corroborated, that these people couldn't follow the original procedures and therefore we have no assurance that they could follow another set of procedures.

See also our response in item Nos. 22 and 25.

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77.

The only point regarding the steam generator upper lateral restra e

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AWE)\\plXB'of raised by TERA independent of exterior sources in[the " Civil / Structural Generic Issues Report," 11/20/86, by Stone & Webster /11/, may be found

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at Appendix B. Page B-1, item 1.1 (A)', the first bullet. This finding by TERA states:

"(A) Technical Errors in Calculations Design of concrete wall did not consider end moments from Steam Generator Restraint Beam" h

In reference to the above, we have never been satisfied with Applicants' procedures relative to qualifying the upper lateral restraint, basically because the strese ratio which was finally arrived at by Applicants is within a hairline of catastrophic failure (concrete has effectively no ductility), and any oversight or error could be fatal to the ability of the b am to restrain the steam generator.

/11/ Portions of which (including page B-2) are attached for the Board's convenience to the 12/30/86 letter to the Board from CASE's Mrs. Ellis, under subject of: Potentially Significant Items, being sent the same date as this pleading.

52

I have read the foregoing affidavit, which was prepared under my personal direction, and it is true and correct to the best of rqy knowledge and belief.

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(Signed) r,

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Date:

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}l STATE O COUNTY OF N 0?r u 2I On this, the S.4/

' day o zw #,,.

,1982,personallyappeared ku

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, known to me.to be the person whose V

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name is subscribed to the foregoing instrtsnent, and acknowledged to me that he executed the same for the purposes therein expressed.

' Subscribed and sworn before me on the "?f /

day of,wd uns 198].

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n cNotary Public in and for the State of 1huneA// m W My Consnission Expires:

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i C A S E==

(CITIZENS ASSN. FOR SOUND ENERGY)

January 5, 1987 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C.

20555

Dear Sir:

Subject:

In the Matter of Application of Texas Utilities Electric Company, et al. for An Operating License for Comantne Peak Steam Electric Station Units #1 and #2 (CPSES)

Docket Nos. 50-445 and 50-446 Correction to Portions of Affidavit of CASE Witness Jack Doyle We are attaching hereto the original signed and notarized affidavit of CASE Witness Jack Doyle, which was attached to CASE's 1/5/87 letter to the Licensing Board under subject:

Signed and Notarized Affidavit, Correction to Portions of Affidavit of CASE Witness Jack Doyle, Regarding CASE's 12/30/86 Partial Response to Applicants' 12/1/86 Response to Board Concerns.

Thank you.

Respectfully submitted, CASE (Citizens Association for Sound. Energy) rs.) Juanita Ellis President cc:

Service List: this cover letter, page 52, and signed and notarized signature page; remainder is same as was sent with CASE's 12/31/86 letter Attachment to Board 770//3 07 3

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i DOC ME TED O'iNPC 1B7 JAN -7 P3 :34 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFict n.

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60CMET!Nu13rnyfg' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD B7ANCH In the Matter of

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TEXAS UTILITIES ELECTRIC

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Docket Nos. 50-445 COMPANY, et al.

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and 50-446 (Comanche Peak Steam Electric

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Station, Unita 1 and 2)

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CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's 1/5/87 letter to Board, attaching Signed and Notarized Affidavit and currecceu page 52 to portions of Affiaavic of Ca5t witness Jack ooyie, negarding CASE's 12/30/86 Partial Response to Applicants' 12/1/86 Response to Board Concerns-tiniclaisy aLLacneo Lo Last s 14/ 01/co seller to coaro)

I have been sent to the names listed below this 5th day of January

,19 8_7_,

by: Express Mail where indicated by

  • and First Class Mail elsewhere.

Administrative Judge Peter B. Bloch Nicholas S. Reynolds, Esq.

U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell Atomic Safety & Licensing Board

& Reynolds Washington, D. C.

20555 1200 - 17th St., N. W.

Washington, D.C.

20036 Judge Elizabeth B. Johnson Oak Ridge National Laboratory Geary S. Mizuno, Esq.

P. O. Box X, Building 3500 Office of Executive Legal Oak Ridge, Tennessee 37830 Director U. S. Nuclear Regulatory Dr. Kenneth A. McCollom Commission 1107 West Knapp Street Washington, D. C.

20555 Stillwater, Oklahoma 74075 Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C.

20555 1

Chairman Renea Hicks, Esq.

-Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C.

20555 Austin, Texas 78711 Mr. Robert Martin Anthony Z. Roisman, Esq.

Regional Administrator, Region IV Trial Lawyers for Public Justice U. S. Nuclear Regulatory Commission 2000 P Street, N. W., Suite 611 611 Ryan Plaza Dr., Suite 1000 Washington, D. C.

20036 Arlington, Texas 76011 Mr. Herman Alderman Lanny A. Sinkin Staff Engineer Christic Institute Advisory Committee for Reactor 1324 North Capitol Street Safeguards (MS H-1016)

Washington, D. C.

20002 U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Robert A. Wooldridge, Esq.

Worsham, Forsythe, Sampels William Counsil, Vice President

& Wooldridge Texas Utilities Generating Company 2001 Bryan Tower, Suite 3200 Skyway Tower Dallas, Texas 75201 400 North Olive St., L.B. 81 Dallas, Texas 75201 Thomas G. Dignan, Jr., Esq.

Ropes & Gray Docketing and Service Section 225 Franklin Street (3 copies)

Boston,' Massachusetts 02110 Office of the Secretary U. S. Nuclear Regulatory Commission Ms. Nancy H. Williams Washington, D. C.

20555 Project Manager Cygna Energy Services Ms. Billie P. Garde 101 California Street, Suite 1000 Government Accountability Project San Francisco, California Midwest Office 94111-5894 I

3424 N. Marcos Lane Appleton, Wisconsin 54911 Mark D. Nozette, Counselor at Law Roy P. Lessy, Jr., Esq.

Heron, Burchette, Ruckert & Rothwell Wright & Talisman, P. C.

1025 Thomas Jefferson Street, N. W.,

1050 Seventeenth St., N.W.

Suite 700 Washington, D. C.

20036-5566 Washington, D. C.

20007 M,E W>

(giFs.) Jtianita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2

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