ML20080B503

Sixteenth Set of Interrogatories & Requests to Produce Listed Documents Re Cygna Rept.Certificate of Svc Encl

ML20080B503
Person / Time
Site:	Comanche Peak
Issue date:	02/02/1984
From:	Ellis J Citizens Association for Sound Energy
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8402070171
Download: ML20080B503 (8)

Text

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00CwETED UNITED STATES OF AMERICA U:.2/2/84

.. NUCLEAR REGULATORY COMMISSION.

BEFORE THE ATOMIC SAFETY AND LICENSING $0dki)-6 P2:54 In the Matter of I

'..: y APPLICATION OF TEXAS UTILITIES I Docket Noh;.,' '50-445 GENERATING COMPANY, ET AL. FOR I I

and 50-446 AN OPERATING LICENSE FOR COMANCHE PEAK STEAM ELECTRIC I STATION UNITS #1 AND #2 (CPSES) g CASE'S SIXTEENTH SET OF INTERROGATORIES AND REQUESTS TO PRODUCE TO APPLICANTS Pursuant to 10 CFR 2.740b and 2.741, CASE (Citizens Association for Sound Energy), Intervenor herein, hereby files this, its Sixteenth Set of Interrogatories and Requests to Produce to Applicants.

Please answer the following interrogatories and requests for documents in the manner set forth herewith:

1. Each interrogatory should be answered fully in writing, under oath ar affirmation. ,

2. Each interrogatory or document response should include all perti-nent infoma. tion known to Applicants, their officers, directors, or employees, their agents, advisors, or counsel. Employees is to be construed in the broad sense of the word, including specifi-cally Brown and Root, Gibbs & Hill, Ebasco, any consultants, sub-contractors, and anyone else perfoming work or services on behalf of the Applicants or their agents or sub-contractors.

3. Each document provided should include a sworn statement of its -

authenticity.

8402070171 840202 DR ADOCK 05000 4 4 558

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4. Answer each interrogatory in the order in which it is asked.. numbered to correspond to the number of the interrogatory. Do not combine answers.

5. Identify the person providing each answer, response, or document.

6. These interrogatories and requests for documents shall be continuing in nature, pursuant to 10 CFR 2.740(e) and the past directives of the Licensing Board. Because of the time restrictions under which we are presently working, we request that supplementation be made on an expedited basis.

7. For each item supplied in response to a request for documents, identify it by the specific question number to which it is in response. If the item is excerpted from a document, identify it also by the name of the document. Please also provide the copies in the correct order (rather than in reverse order).

8. The tenn " document's" shall be construed in the broad sense of the word and shall include any writings, drawings, graphs, charts, photographs, reports, studies, slides, internal inemoranda, hand-written notes, ' tape recording, calculations, and any other data compilations from which infonnation can be obtained.

CASE'S INTERROGATORIES AND REQUESTS T0-PRODUCE TO APPLICANTS The following are requests for documents in connection with the upcoming

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hearings (February 20-24) on the CYGNA Report. (We had planned to file ,

this request early last week, but as explained. to Judge McCollom 1/29/84, some of our key CASE workers have been ill recently and unable to assist.)

CASE'S-REQUEST FOR DOCUMENTS.- Page 1

1. From Observation PS-02-01,' drawings and calculations for supports SI-1-325-002-S32R Rev.1, and RH-1-021-001-S22R, Rev. 3

'2. From Observation PS-09-01, drawings and calculations for support SI-1-042-002-S22K, latest' revision; also the seismic displacement in all directions of the pipe at that support location

3. From Observation PS-12-01, drawings and calculations for support RH-1-062-002-S22R, Rev. 5; also the table, chart or the method used to determine the allowable load on the PUS and PUH U-bolts

4. In Observation PI-02-04, drawings and calculations involved in support SI-1-037-005-S32A; also the calculations performed by CYGNA on the reinforcing pad

5. PI-02-05, all calculations and drawings performed by CYGNA in arriving at their calculated value of .98

6. CTS-00-01, CYGNA Tech, file 11.2.1.50, all. drawings and calculations.

reviewed by CYGNA referenced in 3.2 of. observation record

7. CTS-00-02, documentation showing " care was taken to ensure that maximum member loads, which were equal to the absolute sum of the dead and each seismic load component, were selected for use in the member design."

8. CTS-00-02, calculations (original and revised) referenced in 2.a of attachment A of Observation CTS-00-02

9. CTS-00-03, Gibbs & Hill Drawing 2323-S-0903, liev. 5, and Gibbs & Hill

, calculation No. SCS-101C, Set 1

10. Calculations performed by Gibbs & Hill that are referenced in 2a and 2b of the resolution of' Attachment A of CTS-00-03

11. CTS-00-04, Standard detail A from binder section Aj to A3 and DL (A, B, C, D) from binder section Dj to D5

12. Calculations perfonned by Gibbs & Hill that are referenced in 2.0 of the resolution of attachment A of CTS-00-04

13. Re: CTS-00-05:

(1) Gibbs & Hill calculation SCS-146C(II), Set 8, Sheet 21 (2) TU design change document CMC-88306, Rev. 4 (3) Gibbs & Hill calculations showing the stress in channel that is bent about its weak axis and its interaction with other stress in the channel.

CASE'S REQUEST FOR DOCUMENTS - Page 2

13. (continued):

(4) Calculations showing the design changes were acceptabl.e on all revisions:of CMC-88306.

(5) Calculations performed by Gibbs & Hill showing the design was acceptable as referenced .in 2.0 of Attachment A of CTS-00-05.

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(6) Calculations performed by CYGNA showing the design was acceptable as referenced in 2.0 of Attachment A of CTS-00-05.

14. Re: CTS-00-06:

(1) That portion of output binder, input binder, math model referenced in 3.1.

(2) Calculation No. SCS-104C, Set 1, Sheets 5, 6,10, 34, and 35.

(3) Calculations performed by Gibbs & Hill in the resolutions shown on Attachment A, paragraph 2.

15. Re: CTS-00-07:

(1) Drawing 2323-El-0601-01-S.

(2) Calculations of initial base plate analysis and calculations of second check referenced in description 1.0.

(3) Calculation No. SCS-104C, Set 1, Sheets 5, 6, 10,~34, and 35.

(4) CYGNA Tech file 11.2.1.50, all pages.

(5) Gibbs & Hill Calculations referenced in 2.0 resolution.

16. WD-01-01, all documents showing the lock nuts have been tightened.

17. WD-02-01, calculations by TU showing no interference.

18. WD-02-01, documentation of the originator that performed the original analysis and documentation at present that will assure relative moments will be considered in the design and final design analysis.

19. Observation WD-03-01:

(1) As-built drawing for SF-X-033-007-F43R. .

(2) VCD drawing for SF-X-033-007-F43R.

(3) VCD calculations for SF-X-033-007-F43R.

CASE'S REQUEST FOR DOCUMENTS - Page 3

19. _ (continued):

(4) The As-Built Re-Verification Report form 1267 as indicated in the Resolution.

(5) ~ The calculations used to show the " accept as-is" is valid.

(6) All referenced documents used to show " accept as-is" is valid, unless previously furnished.

20. Cable Tray checklist CTS-03, item 2, calculation No. SCS-146C(ll), Set 4, Sheet 10.

21. Cable Tray checklist CTS-04, item 2, SCS-146C (II) Set 4, Sheet 10, and SCS-101C, Set 3, Sheet 65.~

22. Cable Tray Check list' CTS-06, iten 2, Calculation No.146C(II), Set 8, Sheet 21.

23. Check List No. CTS-ll, Item #1, Item #3 and 4 referenced.

24. Cable Tray checklist No. WD-01, item #3:

(1) Documentation showing a PSA snubber is equivalent to that specified, as well as the VCD of SF-X-032-012-F53K.

(2) Item #31, DCA-#13177, and all calculations and reasoning for its basis.

(3) Item #44, DCA #9087, Rev. 5, and all calculations and reasoning for its basis.

25. WD-03, Item #25, VCD SF-X-005-020-F43R, drawing showing 5 in~. wide w 1/4" deep void under base plate, DCA '#9087, Rev. 5 to Spec. 2323-MS-100 and basis showing acceptance.

26. Item #64 VCD SF-X-Oll-001-F45S calculations with as-built load showing missing weld is 0.K.

27. WD-07, iten #4C:

(1) DCA-17147 (2)' Reasoning (with tests or calculations) showing a 3" or less hori-zontal separation is acceptable.

(3) Item #5, DCA-17,397.

(4) Reasoning (with tests or calculations) showing missing grip is acceptable.

CASE'SfREQUEST FOR DOCUMENTS - Page 4

28. PS-05, latest drawing and calc'ulations for RH-l=010-003-S22R.

29. PS-07, latest drawing and calculations for SI-1-038-013-S22A'

' 30. PS-10, latest drawing and calculations for RH-1-064-010-S22R. .

31. PS-12, latest drawing and calculations for RH-1-062-002-S22R.

32. PS-16, latest drawing and calculations for SI-075-001-S22R.

33. PS-23,16 test drawing and calculations for RM-1-010-004-S22K and RH-1-010-002-S22S.

34. PS-28, latest drawing and calculations for RH-1-024-Oll-522A'.

35. PS-30, latest drawing and calculations for SI-1-030-003-S32A.

36. The generic study perfonned by Texas Utilities in regards to self-weight excitation, referenced. in Note 1 of Checklist No. PS-Ol'.

37. CYGNA's response to TUSI memorandum CPPA21550 referenced in PS-16 in item 10. Also CYGNA's review of bolt separation versus depth.

38. TUSI memorandum CPPA 21550.

Respectfully submitted, MU ps.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 l 214/946-9446 1

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8 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of I i

APPLICATION OF TEXAS UTILITIES Q GENERATING COMPANY, ET AL. FOR Q Docket Nos. 50-445 AN OPERATING LICENSE FOR Q and 50-446 COMANCHE PEAK STEAM ELECTRIC Q STATION UNITS #1 AND #2 (CPSES) Q CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE'S SIXTEENTH SET OF INTERROGATORIE'S AND REQUESTS TO PRODUCE TO APPLICANTS.

have been sent to the names listed below this 2nd day of February , 198 4_,

by: Express Mail where indicated by

• and First Class Mail elsewhere.

Administrative Judge Peter B. Block Alan S. Rosenthal, Esq. , Chairman U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Board Atomic Safety and Licensing Board Fanel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Dr. Kenneth A. McCollom, Dean Dr. W. Reed Johnson, Member Division of Engineering, Atomic Safety and Licensing Appeal Board Architecture and Technology U. S. Nuclear Regulatory Comntission Oklahoma State University Washington, D. C. 20555

. Stillwater, Oklahoma 74074 l Thomas S. Moore, Esq., Member l Dr. Walter H. Jordan Atomic Safety and Licensing Appeal Board 881 W. Outer Drive U. S. Nuclear Regulatory Comission Oak Ridge, Tennessee 37830 Washington, D. C. 20555 l

0 Nicholas S. Reynolds , Esq.

l Atomic Safety and Licensing Appeal Panel Debevoise & Liberman U. S. Nuclear Regulatory Commission 1200 - 17th St. , N. W. Washington, D. C. 20555 Washington, D. C. 20036 Docketing and Service Section Geary S. Mizu'no, Esq.; Office of the Secretary Office of Executive Legal Director U. S. Nuclear Regulatory Comission U. S. Nuclear Regulatory Comission Washington, D. C. 20555 Washington, D. C. 20555 .

Atomic Safety and Licensing Board '

Panel U. S. Nuclear Regulatory Comission Washington, D. C. 20555

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

Ctrtificate of S:rvice ,

Page 2 David J. Preister, Esq.

Assistant Attorney General Environmental Protection Division P. 0. Box 12548, Capitol Station Au.stin, Texas 78711 .

John Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Cormission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Mr. R. J. Gary (Hand delivered to'TU offices 2/2/84)

Executive Vice President and '

General Manager Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Lanny Alan Sinkin 114 W. 7th.. Suite.220 Austin,cTexas 78701 Dr. David H.' Boltz 2012 S. Polk Dallas, Texas 75224' A ls

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r Juanita Ellis, President CASE (Citizens Association for Scund Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 e

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