ML20207M055
| ML20207M055 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/05/1987 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#187-2134 OL, NUDOCS 8701130073 | |
| Download: ML20207M055 (1) | |
Text
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2/34 C A S E = =
214/946-9446 (CITIZENS ASSN. FOR SOUND ENERGY)
'87 JAN -7 P3 :19 January 5, 1987 cr!.
W Docketing and Service Section Office of the Secretary V. 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 Comanche Peak Steam Electric Station Units #1 and #2 (CPSES)
Jocket Nos. 50-445 and 50-446 C L 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) k
. trs.) 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 l
Attachment to Board l
l 1
8701130073 870105 PDR ADOCK 05000445 G
4
- C A S E==
(CITIZENS ASSN. FOR SOUND ENERGY)
December 31, 1986 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 Carib Terrace 552 North Ocean Boulevard Pompano Beach, Florida 33062
Dear Administrative Judges:
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 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 CASE Witness Jack Doyle has advised that he wishes to correct some portions i
of subject affidavit. He has dictated the changes to me by telephone, and -
l they are attached hereto. His signed and notarized affidavit will be forwarded shortly.
We apologize for any inconvenience this may have caused.
Respectfully submitted, CASE (Citizens Association for Sound Energy) p y Wn u,A C l (
in mo s u, u
.ej[
Mrs.) Juanita Ellis President cc: Service List
4 4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l
Docket Nos. 50-445 l
and 50-446 TEXAS UTILITIES ELECTRIC l
COMPANY, et al.
l l
(Application for an
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(Comanche Peak Steam Electric l
Operating License)
Station, Units 1 and 2) l AFFIDAVIT OF CASE WITNESS JACK D0YLE REVISING PORTIONS OF 12/26/86 AFFIDAVIT REGARDING CASE'S 12'/30/86 PARTIAL RESPONSE TO APPLICANTS' 12/1/86 RESPONSE TO BOARD CONCERNS I would respectfully request of the Board that I be allowed to correct my affidavit of December 26, 1986, Regarding CASE's 12/30/86 Partial Response to Applicants' 12/1/86 Response to Board Concerns, at item 77 (pages 52 and 53) and item 13 under In Conclusion (page 55).
The reason is as follows:
I engaged my pencil before I engaged my brain. I f ailed to read item 1.2 at the bottom of page B-1 or the second paragraph of item
1.0 INTRODUCTION
on page 4, and I had not realized that the portion I quoted from page B-2, item (A), was an E-DIR instead of a D-DIR. The result was a failure to accurately reflect the origin of the contents for paragraph (A), page B-2, which were exterior to those who were involved in the CPRT effort itself. Beyond this, none of the issues were raised by Stone & Webster, but were in most cases (about 90% of the first 260 problems found) discovered by Tera Corporation.
I would therefore like to replace pages 52 through 55 of my 12/26/86 Affidavit with the attached corrected pages 52 through 55.
I apologize for any inconvenience.
1
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3, A-the Applicants believe that the number of previous NPS
.esployees, 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.
- 77. The only. point regarding the steam generator upper lateral restra AWENplXB'cf raised by TERA independent of exterior sources in[the " Civil / Structural Generic Issues Report," 11/20/86, by Stone & Webster /11/, may be found 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" In reference to the above, we have never been satisfied with Applicants' procedures relative to qualifying the upper lateral restraint, basically because the stress 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 beam 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.
j date as this pleading.
52
(
In conclusion:
From Applicants' filing, several factors emerge which demonstrate Applicants' thinking and their position:
1.
Root cause will be pursued at Applicants' convenience.
2.
Applicants have devised a number of buzz words designed to-eliminate errors from serious consideration (for example:
(1) prudency; (2) latest industry practice; (3) safety significance; etc.) -- all of which are defined by Applicants alone.
3.
Applicants have no intention of complying with mootness criteria established by the Licensing Board.
4.
Applicants are not pursuing non-systematic errors with enthusiasm (to say the least).
5.
Applicants consider themselves as sole arbitor of what is to be considered for obtaining an operating license.
6.
Applicants consider 10 CFR, Part 50, Appendix B, to be (at best) a nuisance (see quote by Applicants at 35).
7.
CASE and indeed even the Board shall not query Applicants until Applicants state that the time is ripe.
8.
Applicants appear to be trying to overwhelm by purposely complicating the content of their reply, as may be noted in Applicants' pomposity in this, their Answer to the Board's Concerns.
9.
From the day Applicants started to pursue the development of a complex to produce energy from twin nuclear reactors at CPSES, they were under a handicap due to a lack of understanding of the requirements of l
53 l
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Congress as expressed in the Atomic Energy Act, as amended, and codified by the NRC in 10 CFR Part 50, Appendices A and B, as is more obvious from the above.
10.
Applicants have had their minds made up and do not wish to be confused by the introduction of facts; and among these facts are how extensive were the errors incorporated in safety-related components at CPSES?
11.
By Applicants' statements and actions, one receives the message that of the vast number of errors found in safety-related components, the only responsibility or cause lies with those who created the problems, and once these components are modified or replaced, a blanket pardon is bestowed by Applicants which effectively erases the fact that the error occurred.
12.
The introduction of the vast catalog of designer words by Applicants must be viewed with skepticism. These words are being defined by Applicants and the result of their choice of definition is erosion of their own culpability for all which has occurred in the plant and before the Board to date. With Applicants' track record for lack of candor, such definitions must be viewed in the light of reality and equity, with the safety of CPSES as the paramount objective.
13.
Applicants' position before the Board on the numerous errors in design and engineering of pipe supports and other restraints at CPSES is not only debatable, it is highly questionable. One striking example of this is contained in " Civil / Structural Generic Issues Report," 11/20/86, by Stone &
Webster; from the findings of TERA Corporation (at Appendix B, Page B-1, 54
t, i
)
item 1.1 (A), the first bullet), it appears that at a minimum the upper lateral restraint and shield walls are still exhibiting an area of distress which is open to question. Further, this appears to be yet another instance of Applicants' lack of candor which affects not only Applicants' attempts to justify, but also affects the confirmation of the NRC Staff consultant of Applicants' procedures regarding this matter. See item 77 preceding.
- 14. If Applicants' position is as set forth in their 12/1/86 Response to Board Concerns, they do not have a program equivalent to 10 CFR Part 50, Appendix B (or, for that matter, to 10 CFR Part 50, Appendix A).
t l
55
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t-I have read the foregoing affidavit, which was prepared under g personal direction, and it is true and correct to the best of g knowledge and belief.
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Date: rhsr A F)87 3;
STATE O
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COUNTY OF W M rrJ #[c On this, the h/'
day o
,1987, personally appeared a,m theid
, known to me to be the person whose te V
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name is subscribed to the foregoing instrument, and acknowledged to me that he executed the same for the purposes therein expressed.
Subscribed and sworn before me on the 7,e/
day of me, f
y l,
198].
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Mtary Public in and for the State of 1%rw/s vW I
My Connission Expires:
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