ML20116C918
| ML20116C918 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/25/1985 |
| From: | Horin W BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#285-720 OL, NUDOCS 8504290212 | |
| Download: ML20116C918 (29) | |
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UNITED STATES OF AMERICA N3pkgg NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD hfh;flI,ECRETAP 59 fy^['E?Vl(.i. v In the Matter of )
) Docket Nos. 50-445Gand TEXAS UTILITIES ELECTRIC ) 50-446cc COMPANY, ET AL. )
) (Application for (Comanche Peak Steam Electric ) Operating Licenses)
Station, Units 1 and 2) )
APPLICANTS' FIRST PARTIAL RESPONSE TO CASE'S FIFTH SET OF INTERROGATORIES AND REQUESTS TO PRODUCE "RE: CREDIBILITY" I. INTRODUCTION Pursuant to 10 C.F.R. 552.740b and 2.741, Applicants here-by respond to CASE's Fifth Set of Interrogatories and Requests to Produce Re: Credibility, filed March 4, 1985.1 Applicants' response is governed further by the Board's February 15, 1985, Memorandum (Motion for Protective Order),
whereat the Board granted, in part, Applicants' motions for protective orders by restricting Applicants' obligation to 1/ Applicants and CASE agreed to an extension of time to respond to these discovery requests. The Board accepted this agreement and requested that Applicants document its acquiescence in the first set of partial answers.
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respond to CASE's discovery requests regarding credibility "to discovery related to the validity or reliability of tests and samples" (Memorandum at 1). Accordingly, Applicants respond only to those requests which are within the scope of the authorized discovery.
The responses provided below concern primarily those requests which Applicants consider to be beyond the scope of authorized discovery. Applicants are in the process of pre-paring responses to the remaining requests.
II. APPLICANTS' RESPONSE TO CASE'S FIFTH SET OF INTERROGATORIES 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:
Ql. Affidavit at page 5, second paragraph:
- a. How many shipments of tube steel have been received at Comanche Peak?
- b. Provide a breakdown of the test data (which 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 something such as:
2/ These discovery requests were authorized by the Board in its December 18, 1984, Memorandum (Reopening Discovery; Misleading Statements).
the test data for 3 shipments of tube steel indicated an actual yield strength of 36 ksi the test data for 5 shipments of tube 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.
Response: Applicants object to this request, CASE seeks data regarding every shipment (there has been hundreds of such shipments) of A500 tube steel at Comanche Peak. It would be extremely burdensome to produce the requested information.
Applicants suggest that CASE select a reasonable number of the 182 supports in our sample (CASE has a list of all the supports) and Applicants will provide copies of the CMTR's we have for those supports.
Q2. 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 remained significantly below those allowables" (in-cluding, 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.)
Response: Applicants object to this request. The quoted statement is merely Applicants' conclusion drawn from examining the facts presented in Applicants' Affidavit.
Relevant documentation has already been produced with
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respect to specific requests concerning the actual sample. Applicants also note that there were no written instructions related to drawing the sample and doing the analysis. Those instructions were communicated verbally.
CASE should recall that Applicants previously explained, in response to earlier discovery requests on this subject, the process by which the sample was taken and the analysis performed.
Q3. Affidavit at page 6, second full paragraph, bottom of page continued on page 7:
- 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 fol-lowing:
In Unit 1 In common (those areas shared by both Unit 1 and Unit 2)
In Unit 2 (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:
i Unit l?
In common?
Unit 2?
- c. Provide the drawing and calculation package for each of the 182 supports utilized in the sample (as they existed at the time e 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 sup-ports contained an excellent mix of buildings, systems, classes and types of supports."
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- e. Applicants stated " Analysis of the above sample demonstrates that for over 95% of the sampled sup-ports the tube steel members seeing the maximum stress is stressed less than 50% of the reduced A500 allowable" (emphasis in the original).
(1) Provide any and all documentation of Applicants' statement.
(2) List each support which constituted the 5% of the sampled supports where the tube steel mem-bers 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.
- f. Applicants stated "In fact, the average percentage of the allowable stress seen by all such members is 16.4%."
Provide any and all documentation for Appli-cants' statement (including, but not limited to, the raw data for the listing on page 7 of the Affidavit).
Response: The response to requests 3.a. and 3.b. will be provided later.
With respect to request 3.c., Applicants object to this request as being unduly broad, burdensome and in part duplicative. As stated in Applicants' Response to CASE's Fourth Set of Interrogatories and Requests to Produce "Re: Credibility" (at 6), Applicants have already provided the requested information for the 23 supports which, using CASE's own criteria, were the worst case Further, the issue involved is narrow, i.e.,
supports.
whether A500 tube steel members in supports are adequate-ly designed if one assumes the applicability of revised yield values published in an ASME code case revision.
CASE's request is unduly broad in that it seeks material
not relevant to the adequacy of the tube steel members (e.g., all calculations for the supports).
Therefore, if discovery is to be had at all it should be limited to the portions of the design calculations regarding A500 tube steel members.
Regarding request 3.d., the quoted statement is Applicants' opinion and CASE already has the information by which it may assess the validity of that opinion.
Specifically, CASE has a copy of Specification 2323-MS-46A. In Section 3.5 of that Specification, an explana-tion of the meaning of the support numbering scheme is presented; building, system, class and type are indi-cated. CASE also has a list, by support number, of all the supports in the sample. CASE can thus readily ascer-tain the validity of Applicants' statement.
With respect to request 3.e.(1), CASE was already provided with the " documentation of Applicants' state-ment" in the data presented in the Affidavit (see Affidavit at 7).
Regarding 3.e.(2), Applicants previously provided this information with respect to the 23 worst case supports (including the 20 most highly stressed) by CASE's own criteria, plus all large bore supports, in their letter of September 6, 1984. With respect to the
" maximum stress" (we assume CASE refers to the maximum stress in the tube steel members) for these supports,
CASE may readily-determine the maximum controlling stress, i.e., combined (axial plus bending)'or shear, from the interaction values previously provided for those supports and the reduced allowable.
Finally, with regard to request 3.f., CASE can readily calculate this figure from the information presented in the Affidavit (at 7). As for the actual calculations ("rav data) performed to determine the
! revised interaction values (which include consideration of revised allowables), as was explained to CASE in our September 6, 1984, letter, these simple calculations were not part of the design calculations and have not been retaineu, Documentation to demonstrate the manner in which the calculations were performed was provided to CASE in that letter for, using CASE's own criteria, the 23 worst case supports. Also in that same letter, Appli-
' cants provided the revised interaction values for all large bore supports, as requested by CASE. Applicants object to providing further information as being unduly burdensome in view of the information already provided CASE.
Regarding Axial Restraints:
Where an affidavit is referenced, it is the Affidavit of Robert C. Iotti and John C. Finneran, Jr. Regarding Considera-tion 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.
i Q7. Affidavit at page 15, middle of page:
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- a. What is the basis for the statement that "These minimal [ plastic] strains are of no consequence to the integrity of the pipe or the lug"?
- b. Has any analysis been performed to verify the state-ment referenced in a. preceding?
If the answer is yes, provide any and all documentation of such analysis,
- c. Has any test 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: Applicants object to this request as seeking information beyond the authorized scope of discovery.
Requests 7.a., 7.b., 7.d. and 7.e. concern analyses performed by Applicants, not tests or samples. Request 7.c. does not concern any test or sample relied on in Applicants' motion for summary disposition. In any event, the answer to request 7.c.
is "No".
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 Condi-tions, 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.
Q8. 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.
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- b. Have any tests been performed to support your answer to a. preceding?
- c. Provide any an all documentation for your answers to
- a. and b. preceding.
Response: Applicants object to this request. CASE's questions relate neither to sampling nor testing performed in connection with Applicants' motions for summary disposition. The quoted statement is merely a statement of fact regarding piping analysts' normal prac-tice. The answer to b. is, in any event, that no tests have been performed.
Regarding Differential Displacement (Wall-to-Wall / Floor-to-Ceiling):
Where an Affidavit is referenced, it is the 6/22/84 Affi-davit of R.C. Iotti and J.C. Finneran, Jr. Regarding Differen-tial Displacement of Large Frame Pipe Supports, which was Attachment 1 to Applicants' 6/22/84 Motion for Summary Dis-position of CASE Allegations Regarding Differential Displace-ment of Large-Framed, Wall-to-Wall and Floor-to-Ceiling Pipe Supports.
Q9. Affidavit at page 8, last paragraph continuing on page 9:
- 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 calcula-tions) for the three supports as they exist at this time.
Response: Applicants object to this request. The request does not relate to the validity or reliability of Applicants' tests or samples. Applicants do note, how-ever, that no modification to these supports resulted
from any analysis done in support of Applicants' motion for summary disposition.
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.
Q10. 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 o my engineers review support drawings at random to identify these supports."
9 Were any of the individuals identified in your answer to f. preceding field engineers?
- h. If the answer to g. preceding is yes, were any of them the "somewhat knowledgeable" field engineers to whom Mr. Finneran referred during the operating license hearings?
If the answer is yes, identify by name which of the engineers fall into this category.
Provide the resume, qualifications and creden-tials of each engineer identified in your answer to
- f. preceding.
Response: Applicants object to these questions as not being relevant to the validity or reliability of Appli-cants' sample. Who selected the supports is not relevant Further, to the question of whether the sample is valid.
1 Applicants object to CASE's continued misapplication of
( Applicants' testimony regarding field engineer qualifica .
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tions. Applicants will not repeat here the facts which we have often stated but which CASE continues to ignore.
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.
Qll. Affidavit at page 2, A3., continuing on page 3, regarding Applicants' discussion of the survey conduced 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 he 16 nuclear projects. Also identify the Engineering firm involved in each plant's design / construction. In i
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 pr'ojects 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?
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- e. Identify the En
' the "only one (gineering firm which is stated to bewhich] gave s 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 auxiliary steel only."
- g. Identify the remaining firms.
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- 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 con-servative. Provide specific details.
- i. Provide any and all documentation for your answers to
- a. through h. preceding.
Response: Applicants will provide answers for the majority of these requests. However, Applicants object to the following requests:
With respect to 11.b. the status of each of the 16 nuclear projects is not relevant to the sampling.
Regarding II.c., the requested information is not relevant to the subject sample, would be unduly burden-some and would require Applicants to perform additional research and conduct new studies.
As for ll.h, this request is irrelevant to the sub-ject sampling concerning the use of " generic" stiffnesses at different projects by different A/E's, but rather seeks to determine whether other A/E's methods are con-servative. Such information was not within the scope of
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the original sample and, would be unduly burdensome for Applicants to ascertain, requiring Applicants to conduct additional research and perform new studies.
Q14. Affidavit at page 5, A7., continuing on page 6:
- a. What was the rationale for reanalyzing only three piping systems initially?
l b. What criteria wee utilized to determine which three i
piping systems were reanalyzed?
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/ vill 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: Applicants are preparing replies for parts a.
and b., and will provide the documentation requested in part f related to parts a. and b. With respect to parts c., d. and e., Applicants point out that regardless of whether the effects of including mass participation are beneficial, adverse or negligible, mass participation has of itself no bearing on the studies conducted to verify the effect of employing actual instead of generic stiffnesses. For such studies the only relevant parameter is stiffness.
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 1 to Appli-Application to Support Design, which is Attachment cants' Motion for Summary Disposition Regarding Design of Richmond Inserts and Their Application to Support Design.
Q15. Affidavit at page 9, last paragraph, continued on page 10:
- a. How many supports are there in Unit 1 and common areas which employ Richmond inserts?
How many in Unit 2? ,
- b. Provide the rationale or reviewing only 912 supports in Unit 1 and common areas.
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- c. Provide the rationale for reviewing the specific 912 supports which were reviewed.
- d. What was the reason for the review (i.e., what was the stated purpose, what triggered the review, etc.)?
- e. Provide any and all documentation for your answers to
- a. through d. preceding.
Response: Applicants object to this request. The referenced supports were not a sample. They were identified in a drawing review of each support in Unit 1 and common areas. Thus, CASE's request is beyond the scope of authorized discovery.
Q18. Affidavit at page 16, last paragraph on page, continuing on page 17:
- a. (1) Isn't it a fact that in some instances rein-forcing steel was left out of concrete pours at Comanche Peak?
(2) If the answer is yes, provide a summary of each such instance. Identify each as to where the instance occurred (for instance, Unit 1 contain-ment, Unit 2 containment, etc.) and provide all other relevant details (such as elevation, how and why the omission occurred, who was responsible for the omission's having occurred, whether or not the area is safety-related, etc.).
(3) If the answer is yes, provide any and all documentation regarding each such instance.
Response: Request 18a. is itself not relevant to the validity or reliability of the testing of Richmond inserts. The possibility that some Richmonds may be in an area where the rebar could have been left out is relevant (Request 18.b.) and will be responded to.
Q19. Affidavit at page 21, answer, middle of page:
- a. How many supports were reviewed?
- b. Provide any and all documentation that the finite element analyses provided results which are '
representative of the actual conditions at CPSES.
- c. (1) Did the analyses consider the variability of the tube steel material properties, length end con-ditions; i.e., welded plates, angularity of the rod and insert?
(2) Isn't it true that the effect of the top of the tube would resist the load first, and then the bottom would resist, as demonstrated in the drawing below:
(drawing not reproduced]
(3) Provide any(and all (2) documentation of your answers to 1) and above.
Response: Applicants object to this question. The request related to an analysis performed to respond to an issue concerning the coupling of the torsional moment.
The request does not relate to a test or sample and is, therefore, beyond the scope of authorized discovery.
Q20. Affidavit at page 23, last paragraph, continuing on page 24:
- c. What criteria is there which would require the inclined bolt or offset bolt to be shown on the drawing?
Response: Applicants object to this question. It is not related to any test or sampling relied on in Applicants' motion and, therefore, is beyond the scope of authorized discovery.
Q21. Affidavit at page 24, continuing on page 25:
- a. Provide the screening criterion and any and all documentation regarding it or its results.
- b. How does this criterion relate to bolt holes that are offset?
- c. Why wasn't the gap between the bolt and hole considered?
- d. How do Applicants account for the offset in designs less than 1.75?
- e. Isn't it true that it is standard industry practice to use a factor of 1.0, rather than the 1.75 used by Applicants?
- f. What is Applicants' rationale for using a factor of i 1.75 rather than following standard industry !
practice?
- g. Based on the test data, what confidence level is there that the connection will behave as intended with relation to the 1.75 factor proposed by Applicants and the 1.0 factor that is used in all designs except for Richmonds?
- h. Provide any and all documentation for your answers to
- a. through g. preceding.
Response: The portion of Applicants' Affidavit cited by CASE refers neither to sampling nor testing.
Accordingly, Applicants object to this question as being beyond the scope of authorized discovery.
Q22. Affidavit at page 34:
- a. Has a study been performed for lengths greater than 20 inches?
- b. If the answer to a. preceding is no, why not?
- c. If the answer to a. preceding is yes, what are the results of such study (or studies) and how does this correspond to what has been stated in the Affidavit?
- d. What were the effects when the concrete strengths varied?
- e. What were the results when the concrete varied?
- f. What were the stresses imposed on the concrete due to the bending in this analysis?
- g. Provide any and all documentation for your answers to
- a. through f. preceding.
Response: The referenced portion of the Affidavit at (p.
- 34) refers to a parametric, analytical study performed to .
validate a modelling technique. Neither sampling nor test data was involved as part of the study. According-ly, Applicants object to this request as being beyond the authorized scope of discovery.
Q23. Affidavit at page 38, last paragraph:
- a. What assurance is there and/or what criteria required the NPSI designer to check for sufficient elongation?
- b. What sampling program was used to assure that 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.
- e. Provide the drawings and calculations for each sup-port which was included in this analysis.
- f. Provide any and all documentation for your answers to
- a. through d. preceding.
Response: Neither sampling nor test was used to support this portion of the Affidavit. Accordingly, Applicants
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object to'this request as being beyond the scope of i
authorized discovery.
i Regarding Gaps:
Q25. a. Have Applicants or their employees performed any tests or analyses regarding the effects of gaps which l
were not discussed in Applicants' Motion for Summary j
l Disposition regarding gaps?
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- 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: Applicants performed no tests within the scope of the question. Applicants object to that portion of the request concerning analyses. Analyses are not within the scope of discovery permitted by the Board. With respect to tests not discussed in Applicants' motion, such request also is beyond the scope of authorized dis -
covery in that, even if such tests had been performed (none were performed) they were not relied on in Appli-cants' motion.
Regarding Cinched 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.
Q27. Regarding the raw data underlying Table 2 contained in Applicants' Motion for Summary Disposition on cinched-down U-bolts:
- b. Regarding the 10/8/82 Brown & Root procedure for torquing U-bolts:
(iv) How many of the supports in Unit 1 had their U-bolts cinched down:
(a) before the 10/8/82 Brown & Root procedure went into effect?
(b) after the 10/8/82 Brown & Root procedure went into effect?
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(vi) How many of the supports in Unit 1 were inspected for torquing: ,
I (a) before the procedure went into effect? j (b) after the procedure went into effect?
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- e. Was there any type of reliability analysis performed so that one could extract the confidence level as to whether the supports would be stable utilizing the cinched-down torque values (e.g., as to whether there is sufficient torque applied to assure stability)?
(1) Provide any and all documentation for your answer.
Response: With respect to b.(iv) and (vi), Applicants object to these questions as being unduly broad and burdensome. There are hundreds of supports utilizing cinched U-bolts. The information sought by CASE would require Applicants to review several different documents for each support. Applicants note, however, that we did develop information relating to this issue for presentation to the NRC Staff in a meeting held on April 22, 1984. (CASE had a representative at that meeting.)
Accordingly, CASE should also refer to that information.
With regard to part e., the answer is "no".
Q28. Refer to the attached IE Information Notice No. 85-15:
NONCONFORMING STRUCTURAL STEEL FOR SAFETY-RELATED USE:
- a. Have Applicants performed any tests to ascertain whether or not the actual physical properties (yield and tensile strength) of the A-36 plate material used at Comanche Peak are the same as, or greater than, that required by the A-36 material specification?
- b. If the answer is no, do Applicants anticipate under-taking any such tests?
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- c. If the answer is yes, provide a summary of such test and its results?
- d. If the answer is yes, provide any and all documentation regarding each such test and its results. .
Response: Applicants object to this question as not relating to tests or samples relied on in Applicants' Affidavit. It is, therefore, beyond the scope of authorized discovery. Further, the referenced document is not applicable to Comanche Peak in the first instance (see Attachment 1 to the Notice).
Other:
Q29. Isn't it true that mass pr.rticipation was not considered in any of Applicants' Motions for Summary Disposition?
- a. If the answer is no, provide any and all documenta-tion for your answer.
- b. Is [ sic] the answer is yes, why wasn't it considered?
Provide specific details?
Response: Applicants object to this question as not being relevant to sampling or testing relied on in Appli-cants' motions. (see also Response to Question 14, above and Questions 30 and 31, below.)
030. Which of the following was considered in sampling, analy-ses, 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 j
AWS/ASME (design)
Friction forces l
Section property values i
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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: Applicants object to this request. Sampling or testing conducted to support specific Motions for Summary Dispositions have been devised solely with the intent of addressing the issue covered by the Motion. As such, consideration of items related to other Motions did not enter into the sampling or testing conducted for a t specific motion, e.g., no consideration of generic stiff-ness impact entered the plan for testing cinched-down U-bolts. On the other hand results of sampling and/or tests from those motions may have been used directly or indirectly in drawing conclusions regarding analyses done for other motions or in reply to NRC questions, e.g.,
actual stiffness results obtained from testing of U-bolts were used to show that the assumed stiffness values in the actual v. generic stiffness study are consistent with the tested values. However, the use and application is outside the scope of discovery. The validity and reliability of individual samples or tests is established in the context of the particular Motion for which it was devised and utilized. CASE's inquiry concerns the con-
clusions which may be drawn from tests or samples and not the validity of the tests or samples themselves.
Q31. Have Applicants utilized any samples or performed any analyses or tests considering the cumulative effects of the following:
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 documentation for your answer.
Response: Applicants object to this question as being beyond the scope of authorized discovery. Discovery is permitted only with respect to the samples or tests relied on in Applicants' motions.
Q34. Provide any and all documentation that the A36 and A307 steel which Applicants tested is representative of the steels actually employed at Comanche Peak.
Response: Applicants object to this request. Applicants already provided information responsive to this question.
(See Applicants' response to Board Memorandum (Information on Composition of A36 and A307 Steel), dated December 5, 1984).
Q35. If not already provided, supply CASE with copies of all answers to requests for information and all documents which Applicants have provided or will provide to the NRC Staff (including the TRT, Contention 5 Panel, Region IV, and all other panels, committees, individuals, etc., with h
the NRC) in response to the Staff's questions or requests for documents. These should include (but not be limited to) all documents requested during the meetings between the Staff and Applicants on February 26, 27 and 28, 1985, and March 5, 6 and 7, 1985.
Regarding the documents not already provided, please supply CASE with copies at the same time you supply them to the Staff.
Response: This request is not directed at sampling or testing relied on in Applicants' motions. Accordingly, Applicants object to this request as being beyond the scope of authorized discovery.
Q35. If not already provided, supply CASE with copies of all answers to requests for information and all documents which Applicants have provided or will provide to Cygna in response to Cygna's questions or requests for docu-ments.
Regarding the documents not already provided, please supply CASE with copies at the same time you supply them to Cygna, Response: See response to the first Question 35.
Q37. Will Applicants' academic expert be reviewing and analyzing samples and testing as part of his duties? If so, provide any and all documentation regarding his qualifications regarding sampling and testing.
Response: Applicants previously transmitted to the Board and parties a copy of Dr. Boresi's resume, attached to Applicants' Report Regarding Academic Expert, filed November 9, 1984. As an experienced engineer and teaching professor, Dr. Boresi has extensive experience and expertise in the conduct of tests and has employed appropriate sampling methodologies in his work. Further, as CASE is aware, Dr. Boresi was asked to review the h
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basic engineering principles of the work performed in connection with Applicants' Plan. To the extent Dr.
Boresi considered it necessary to analyze samples and testing to conduct his review he was free to do so.
Q38. Have Applicants hired consulting firm (s) or consultants who are, or will be, doing the statistical sampling, analyses, and/or setting the parameters for testing, sampling, etc. (including but not necessarily limited to Applicants' evaluation and response to the TRT's and the NRC's Walsh/Doyle Allegation Panel's questions and con- I cerns) as " independent" outside consultants who will review the design / design QA issues as well as the problems identified by the NRC's Technical Review Team?
- a. If the answer is no, provide correct information in this regard.
- b. Will these consultants actually be doing the statistical sampling, analyses, and/or setting the
' parameters for testing, sampling, etc.? Will they also be reviewing the overseeing sampling and testing as part of their duties? If not, who (names, titles, organizations) will be performing each of these functions?
Supply specific details information regarding the duties of these consultants and/or others who will be performing each of these function.
- c. Provide full and complete details (including any and all resumes, background, qualifications, and training, contracts, letters of understanding, letters or intend, statement of protocol, statement of scope, and all other documentation as defined on l page 2, item 3, of this pleading) regarding these consultants and/or others and their duties.
Include specifically any and all documentation regarding the qualifications of each individual regarding sampling and testing.
l l
l Also include specifically full and complete l details and a discussion of each irdividual's ties I and past associations with Applicants' John Beck and l
with one another.
f d. Provide CASE with copies of all answers to requests
' for information and all documents which Applicants
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have provided or will provide to these individuals in response to their questions or requests for documents.
Regarding the documents not already provided, please supply CASE with copies at the same time you supply them to the individuals.
Response: Applicants object to this request as being beyond the scope of authorized discovery. The discovery permitted by the Board concerns the tests and samples in Applicants' motions. This request only seeks information regarding test and samples performed (or to be performed) in other contexts.
Q39. a. Identify (name, title, organization, and brief job description) each of the individuals who constitute any review team which is reviewing and/or addressing the TRT findings and/or the Walsh/Doyle design / design QA issues. Include details regarding John Beck, James Wells, Phillip Halstead, David McAfee, and Jack Redding.
Include in your answer what part each will play in doing the statistical sampling, analyses, and/or setting he parameters for testing, sampling, etc.
(including but not necessarily limited to Applicants' evaluation and response to the TRT's and the NRC's Walsh/Doyle Allegation Panel's questions and con-cerns).
- b. Will these individuals actually be doing the statistical sampling, analyses, and/or setting Will the they parameters for testing, sampling, etc.?
also be reviewing and overseeing sampling and testing as part of their duties? how will each of these individual interface with those individuals who will be performing each of these functions.
Supply specific details information regarding the duties of these individuals,
- c. Provide full and complete details (including any and all resumes, background, qualifications, and training, contracts, letters of understanding, letters of intent, statement of protocol, statement of scope, and all other documentation as defined on
page 2, item 3, of this pleading) regarding each of these individuals and their duties.
Include specifically any and all documentation regarding the qualifications of each individual regarding sampling and testing.
Also include specifically full and complete details and a discussion of each individual's ties and past association with Applicants' John Beck, with one another, and/or with anyone else associated with Applicants (see page 2, item 2, of this pleading).
- d. Provide CASE with copies of all answers to requests for information and all documents which Applicants have provided or will provide to these individuals in response to their questions or requests for documents.
Regarding the documents not already provided, please supply CASE with copies at the same time you supply them to the individuals.
Response: See response to Request 38.
Respectfully submitted,
(
l Nichclis S. Refholds a
William A. Horin BISHOP, LIBERMAN, COOK, I
l PURCELL & REYNOLDS I
1200 Seventeenth Street, N.W.
Washington, D.C. 20036 (202) 857-9817 Counsel for Applicants April 25, 1985 l
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State of Maryland County of Montgomery John C. Finneran, Jr., being first duly sworn deposes and says:
That he is the Pipe Support Engineer, Pipe Support Engineerii a Group for Comanche Peak Steam Electric Station and knows the contents of the foregoing Applicants' First Partial Response to CASE's Fifth Set of Interrogatories and Requests to Produce "Re:
Credibility"; that the same is true of his own knowledge except as to matters therein stated on information and belief, and as to that he believes them to be true, vost ,
John C. Finneran, Jr. [/
Robert C. Iotti, being first duly sworn deposes and says:
That he is Vice President of Advanced Technologies for Ebasco Services, Inc. and knows the contents of the foregoing Applicants' First Partial Response to CASE's Fifth Set of Interrogatories and Requests to Produce "Re: Credibility"; that the same is true of his own knowledge.- except as to matters therein stated on information and belief, and as to that he believes the, to be true.
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Robert C. Iotti State of Maryland County of Montgomery Subscribed and sworn to before me this 25th day of April,1935.
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Notary Pub'lic My commin:en :7:ua: Izy 1. :.:
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gamocoPRESF0fMEi DOCKETEC USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 15 APR 26 A9:14 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFIC[r OF DOCK TING & SECRETAR SERVIci*
BRANCH 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' First Partial Response to CASE's Fifth Set of Interrogatories and Requests to Produce "Re: Credibility", in the above-captioned matter was served upon the following persons by express mail (*) or deposit in the United States mail, first class, postage prepaid, this 25th day of April, or by hand delivery (**) on the 26th day of April, 1985.
- Peter B. Bloch, Esquire Chairman, Atomic Safety Chairman, Atomic Safety and and Licensing Appeal Licensing Board Panel U.S. Nuclear Regulatory U.S.. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555
- Dr. Walte r H. Jordan Mr. William L. Clements 881 West Outer Drive Docketing and Service Oak Ridge, Tennessee 37830 Branch U.S. Nuclear Regulatory
- Dr. Kenneth A. McCollom Commission Dean, Division of Washington, D.C. 20555 Engineering, Architecture and Technology **Stuart A. Treby, Esquire Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 h
s.
. Chairman, Atomic Safety
- Elizabeth B. Johnson and Licensing Board Oak Ridge National
, Panel Laboratory U.S. Nuclear Regulatory Post Office Box X Commission Building 3500 Washington, D.C. 20555 Oak Ridge, Tennessee 37830 Robert D. Martin Renea Hicks, Esquire Regional Administrator, Assistant Attorney General Region IV Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548 611 Ryan Plaza Drive Capitol Station Suita 1000 Austin, Texas 78711 Arlington, Texas 76011 Mrs. Juanita Ellis Lanny A. Sinkin President, CASE 3022 Porter Street 1426 South Polk Street Suite 304 Dallas, Texas 75224 Washington, D.C. 20008 Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 1000 San Francisco, CA 94111
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William A. H'orin cc: John W. Beck Robert A. Wooldridge, Esq.
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