ML20071P255

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Motion to Reopen Record Re Steam Generator Upper Lateral Restraint.Util Should Be Ordered to Supply Citizens Assoc for Sound Energy W/Info Necessary to Determine If Problem Exists.Certificate of Svc Encl
ML20071P255
Person / Time
Site: Comanche Peak  
Issue date: 06/04/1983
From: Ellis J
Citizens Association for Sound Energy
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20071P210 List:
References
NUDOCS 8306070394
Download: ML20071P255 (8)


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6/4/83 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC' SAFETY AND LICENSING BOARD in the Matter of APPLICATION OF TEXAS UTILITIES I

Docket Nos. 50-445 I

GENERATING COMPANY, ET AL. FOR and 50-446 AN OPERATING LICENSE FOR I

J COMANCHE PEAK STEAM ELECTRIC I

STATION UNITS #1 AND #2 (CPSES) g CASE'S MOTION TO RE0 PEN RECORD REGARDING STEAM GENERATOR

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UPPER LATERAL RESTRAINT Pursuant to 10 CFR 2.730, CASE (Citizens Association for Sound Energy),

Intervenor herein, hereby files this, its Motion to Reopen Record Regarding i

Steam Generator Upper Lateral Restrairit.

B_ACKGROUND A

Duririg the May 16-20, 1983 operating license proceedings, there were issues raised regarding the steam generator upper lateral restraint.

(See especially tr. 6017-6092, 6173-6223, 6830-6858, 7037-7045.),

Following testimony by Applicants' witnesses and the introduction of Applicants Exhibit 157 (following tr. 6851), further concerns were briefly raised by CASE witness Jack Doyle (tr. 6857-6858). He was not allowed to thoroughly discuss those concerns at that time. However, the concerns which Mr. Doyle atter..pted to raise had to do with the new and potentially significant information contained in Applicants Exhibit 157 and the testimony regarding it by Applicants.

This document indicated that, although snubbers apparently 1

do exist,-they are not on the upper lateral support (as promised by Applicants 1

-- see tr. 6220/6-10); in actuality, they.are 90 degrees to the direction on the lateral restraint beam.

8306070394 830604 PDR ADOCK 05000445 C

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The new information that the snubbers are 90 degrees from where they had been assumed to be and indicated to be by Applicants raises another potentially significant pmblem which CASE had no way of knowing about until Applicants

. provided their Exhibit 157. The problem is detailed in the attached affidavit of Jack Doyle. Briefly, as indicated in Mr. Doyle's affidavit, the potential

. problem has to do with thermal contraction, rather than thermal expansion.

As indicated by Mr. Doyle, CASE at this point does not have sufficient information to ascertain whether or not a problem' exists in fact (although, based on the information we now have and Mr. Doyle's review of that information, there. does appear to be a p oblem).

CASE'S MOTION For the reasons set forth herein and in the attached affidavit of Jack Doyle, CASE moves that the Licensing Board:

(1) Reopen the record in this regard; (2) Order Applicants to supply CASE with the information necessary to determine whether or not a problem in fact exists and the extent of the problem if there is one -- the information which it appears is necessary to make this determination is:

(a) Drawings, including dimensions and locctions, of: the thme support struts of the steam recirculating pump between the cross-over and the cold leg; the three vertical columns for the preceding:

4 the four vertical columns (ali double-pin ended) on the steani generator. (See Jack Doyle affidavit, page 2, lines 9-12.)

(b) The center-to-center dimensions of the steam generator and the recirculating pump.

(See Jack Doyle affidavit, page 2, lines 13-14.)

(c) Details regarding the temperature and temperature differential when the steam generator is shut down.

(Sea Jack Doyle affidavit, page 1, lines.14-16, continued on page 2, lines 1-3.)

(d) Any known information regarding the decrease in the relative dimension between the centers of the steam generator and the recirculating pump.

(See Jack Doyle affidavit, page 1, line 16, continued on page 2, lines 1-3.)

(3) Should Mr. Doyle ascertain that a problem does in fact exist, allow further testimony in this regard by Mr. Doyle, the Applicants, the NRC Staff, and the State of Texas.

CASE realizes that this is an unusual potential problem; haiever, this Licensing Board has indicated a strong desire to arrive at the truth regarding

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whether or not Comanche Peak has been constructed such that it can operate without endangering the health and safety of the public. This apparent commitment on the part of the Board is well supported in NRC regulations (see especially 10 CFR, Part 2, Appendix A, V.(g)(1)). - CASE urges that this issue be explored to the extent indicated herein.

Respectfully submitted, i

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s.) Juanita Ellis, President ASE (Citizens Association for Sound Energy) i 1426 S. Polk l

Dallas, Texas 75224 214/946-9446 i

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11!!! Tf D S T AT ES OF AMERIC A NULLEAR R E GUL A T 0ld C0f4MI S S 10 U BEFORE TiiE ATOI11C SAFETY A!10 LICENSING C0ARD in the Matter of I

APPL I C ATION OF TEXAS t!T I L I T I E S Docket Nos. 50-445 I

GENERATitlG COMPANY, ET AL. FOR and 50-446 AN OPERATIllG LICEll';E FOR I

CDMAtlCilE PEAK STEAM ELLCTRIC I

SlATION UNITS #1 AND #2 (CPSES)

AFFIDAVIT OF JACK 00YLE 1

Q:

Mr. Doyle, is there additional infonnation which you believe is necessary y

to complete the record in these proceedings in regard to the steam gendrator 3

upper lateral restraint?

4 A:

Yes.

5 Q: Why do you believe it is necessary to reopen the record in regard to 6

' this matter?

' 7 A:

From the information we had previously, we didn't know about this 8

potential problem. We were locking at thermal expansion and now we're concerned

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9 with thennal contraction. We were working in one direction on a potential problem, 10 and now it appears that the potential problem is actually in the opposite direction.

11 The steam Generator is now locked in place in the hot position relative 12 particularly to'its own radial expansion and its interdependence on the recir-13 culating pump. From the infonnation we have, the recirculating pump is locked 14 in place relative to the steam generator. When they shut the generator down, 15 it returns to 1200 in about six hours or so (we don't have the exact information 0

16 on this). The temperature differential would be about 500, so the relative

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I dimension between. the centers of the steam generator and the recirculating 2

pump will decrease by sane discrete dimension which we currently don't know.

3 (I't would probably be 3/4" to 1".)

4 With diat upper lateral restraint as a rigid support, it will cLuse 5

moment at the cross-over leg. So there could be a oroblem both wi.th the cross-over 6

' leg and with the upper lateral restraint due to constraint of contraction.

7 Q: What specific inforr..ation w;uld you require to be able to make an analysis 8

of tnis potential problem?

9 A:

The support struts of the steam recirculating pump between the cross-10 over and the cold leg.

ihere are three struts at 1200 and there are also three 11 vertical columns. And on the steam generator, there are four vertical columns, 12 double-pin ended ca all four columns. We need the drawings for all of those.

13' And we also need the center-to-center dinensions of the steam generator and 14 the recirculating pump.

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19 20 21 l

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I have read the foregoing two-page affidavit, which was prepared under ray. personal direction, and the thoughts and words expressed therein are my own thoughts and words.

It is true and correct to the best of my knowledge and belief. Where questions were posed, they were posed by CASE.

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Jack Doyle l

DATE:

COUNTY OF-STATE OF MASSACHUSETTS On this, the day of June,1982, personally appeared Jack Doyle, known to me to be the person whose name is subscribed to the foregoing instrument, and acknowledged to me that he execuwd the same for the purposes therein expressed.

Subscribed and sworn bef ore me on the,, ____ dey of June,1983.

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Notary Public in and for the County of,

Massachusetts My Comnission Expires:

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UtilTED STATES OF AMERICA flVCLEAR REGULATORY C0FMISS10fl c

BEFORE Ti;E ATOMIC SAFETY AND LICENSIrlG BOARD In the Matter of l

l APDLICATION OF TEXAS UTILITIES Q

GENERATIrlG COMPAilY, ET AL. FOR Q

Docket Nos. 50-445 Aff OPERATli1G LICENSE FOR Q

and 50-446 COMAtlCHE PEAK STEAM ELECTRIC Q

STATION UNITS #1 AND #2 (CPSES) l CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE'S MOTI0ft TO RE0 PEN RECORD REGARDING STEAM GENERATOR UPPER LATERAL RESTRAINT have been sent to the names listed below this 4TH day of June 3

, 198 _,

by: Express Mail where indicated oy

  • and First Class Mail elsewhere.
  • Administrative Judge Peter B. Bloch Alan S. Rosenthal, Esq., Chairman U. S. fluclear Regulatory Commission Atomic Safety and Licensing Appeal Board 4350 Eas t/ West Highway, 4th Floor U. S. Nuclear Regulatory Commission Bethesda, Maryland 20014 Washington, D. C.

20555 Dr. Kenneth A. McCollom,- Dean Dr. W. Reed Johnson, Member j

Division of Engineering, Atomic Safety and Licensing Appeal Board Architecture and Technology

-U. S. fluclear Regulatory Cunnission Oklahoma State University Washington, D. C.

20555 Stillwater, Oklahoma 74074 Thomas S. Moore, Esq., Member

  • Dr. Walter H. Jordan Atomic Safety and Licensing Apt

, Board 881 W. Outer Drive.

U. S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D. C.

23555

  • flicholas S. Reynolds, Esq.

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 (3)

  • Marjorie Ulman Rothschild, Esq.

Office of the Secretary Office of Executive Legal Director, USNRC U. S. Nuclear Regulatory Commission Maryland Plational Bank Building Washington, D. C.

20555 7735 Old Georgetown Road - Room 10105 Bethesda, Maryland 20814

  • Ms. Lucinda Minton, Law Clerk Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board 4350 East / West Highway,- 4th Floor Panel Bethesda, Maryland 20014 U. S. Nuclear Regulatory Commission Washington, D. C.

20555

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Certificate of Service Page 2 David J. Preister, Esq.

Assistant Attorney General Environmental Protection Division Supreme Court Build.ing Austin. Texas 78711 John Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Mr. R. J. Gcry Executive Vice President and General Mondger Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Lanny Alan Sinkin 838 East Magnolia Avenue San Antonio, Texas 78212 i

hed 4Mrs.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 t

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