ML20087B478

Affidavit of J Doyle,Correcting 840222 Testimony During cross-examination of Cygna.Certificate of Svc Encl

ML20087B478
Person / Time
Site:	Comanche Peak
Issue date:	03/03/1984
From:	Doyle J Citizens Association for Sound Energy
To:
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ML20087B470	List: ML20087B462 ML20087B478
References
NUDOCS 8403090108
Download: ML20087B478 (7)

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AFFIDAVIT OF JACK 00YLE In. reviewing my testimony which occurred Wednesday, February 22, 1984, during my cross-examination of Cygna, I noted several minor corrections and possibly a moderate correction which should be noted for the record.

On page 9884, line 8, "HATEL" should be "HEDL" (that's Hanford Engineer-ing and Development Laboratories). On line 19, " smart ice" should be " smart eyes." On page _9893, line 15, " box spring" should be " box frame." On page 9904, line 7, " box spring" should be " box ' frame." On page 9896, lines 9 and 17,

" link" should be "line." On page 9904,-line 4, I believe " thicknesses" should be "stiffnesses." Line 7, " box spring" should be " box frames." Line 8,

" equivalence" should be " equivalent".

In addition, I noted several points where my answer was more precise than reason allows, particulary after a lapse of many years, and I must, as a con-sequence, request to modify the answers since they may be s'mewhat misleading, o

to the Board.

1.

Page 9886, line 8, reads:

"I did not see any of this type of appli-

. cation.

Had I have..." etc.

I would like to change this to:

"To the best of.my recollecti

.7, I did not see any of this type of application. Had I have..." etc.

2.

Page 9887, line 16, reads:

"I have never seen that configuration..."

etc.

I would. like to change that to read "To the best of my recollection, I have never seen that configuration."

3.

Page 9887, line 21, reads:

"I did not see those at any of the plants on which I worked."

I would like to change this to read "To the best of my recollection, I did not see those at any of the plants on which I worked."

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i I may have made an error in t'e testimony in answer to a question by Judge Bloch..This may-have resulted from two factors, both pressure-related.

First

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was the pressure associated with being both the interrogator ard simultaneously the interrogated. ~ Second, I detected a certain, vein ii1 the cross-examination

- by Mr.' Reynolds which I felt.had been more carefully 'desisned than was apparent

.on;the. surface. And I was -still trying.to fathom < the intent' of Mr. Reynolds'

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line when I inadve tently paid less than close attention to what Chairman Bloch had asked. The incident occurs at page 9885 in an'swer to Chairman Bloch's

. question at lines 17 through 21, which-L answered lat lines 22 and 23 and which read'as follows:

"It's not exactly analogous:

No~, it's not arialogous to,-thN application we have-been discussing."

At lines 24 and 25, Judge Bloch asks:

"50 the request I just made may prove fruitless and a waste of time?"

To which I answered at page 9886,,' lines 1 and 2:

"It probably would be because it was.more of an anchorage problem."

The result was that on line 3, Judge Bloch ordered the NRC:

" Cancel that request."

The prob'.em I am having with the above exchange-is that, while it may be-legally and gramatically correct, it does not Nddress the question which may be broader than that which. involves U-bolts, dnd that is, the problem of clamp rotat' ion regardless of what co'nstitutes the clamp.

In this regard, if the Chairman's question was lim' ted to the stability i

question which would result from rotation of the U-bolts or box beam and the associated problems due to cinching up of the U-bolt, then my answer was responsive.

- However, if the Chainnan's query was in reference to instability including that

-which can occur even in clamps that 'have an estabiiched friction plane, -then

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my answer may be inaccurate.

A brief history of-the FFTF problems, investigatidn, and actions may clarify this point.

I cited several major generic problems with the pipe supports and piping systems at t..e FFTF in late 1977 and early 1978, which was followed by the contracting of an independent consultant to evaluate at least some of

'my allegations..The consultant concurred with enough of what I alleged to cause a reconsideration of the Westinghouse position as relates to their perception of the status of the plant piping and supporting systems. The result was a complete critique of the existing plant analysis (civil, piping, supports, etc.)

followed by a corrective action program.

It was during this period of review and corrective action that an investigation was conducted by the Department of Energy.at the FFTFP0 (Fast Flux Test Facility Project Office), area 300, Hedl, This investigation was conducted by R. D. McCutcheon Richland, Washington.

of the Inspector General's Office, Department of Energy, on about June 7,1978.

I filed about a four-page statement which included, among other points, a concern with iristat,ility for the supports on the HTS (Heat Transport System),,

which is the co'. ling system (equivalent to the hot and cold legs at CPSES) l for the FFTF reactor (these unstable supports were removed and replaced with stable units which are rigid structures and therefore comply with industry f

i standards). This may be found, I believe, on the second page of my statement which wc-taken by and signed by R. D. McCutcheon, witness.

i And now to the point:

It was, I bleieve, at about the time of the DOE t

investigation that a major concern was raised (I do not recall whether I raised

. the issue or if it was a natural outgrowth of the instability issue with the reactor cooling system).

This concern involved the clamps used to support the piping at FFTF which consisted of two steel half shells (quite similar to star.dard-type clamps) with a machined layer of solid marrimet insulation between the shells and the pipe. The clamp unit was secured by pretorquing the bolts

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• which joined the half shells, to a predetermined load which was controlled by Belville washer stacks.

In this way, a clamping force was developed and an allowance remained in the Belville stack to accommodate radial thermal growth of-the pipe,to the extent predictable.

It was found, however, that the friction plane was not sufficient to resist clamp rotation under all conditions (basically the friction force is only relied on to maintata the clamp location relative to the rode point on the pipe) and the result would be instability.

Therefore, a major program was instituted to develop a po'sitive lock (in addition to the friction plane) beyond the movement required for thermal displacement, to prevent clamp rotation and the resulting instability.

I saw several of the devices which were developed.

However, which method was finally utilized as a generic fix, I don't recall.

I did, however, see some installation drawings with a device incorporated that limited the rotational capability of the clamp.

Beyond this, I do recall, however, that this particular problem received extensive consideration.

I am not sure, as noted from the above, if I misled the Board by this inadvertent omission.

In short, instability and clamp rotation were addressed

.cxtensively at FFTF,.but I still do not recall if U-bolt rotation was ever a i

i problem because I still do not recall the CPSES configuration at FFTF. And if it were present, it would have come under the Clamp Rotation Task Force Action Plan.

I have read the foregoing affidavit, which was prepared under my personal -

direction, and it is true and correct to the best of ray knowledge and belief.

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r STATE OF d#cA42r rer COUNTY OF ) A 4 W e-On this, the T*/ day of /// # /

,198h personally appeared

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, known to me to be the person whose name is subscribed to the foregoing instrument, and acknowledged to me that he executed the same for th'e purposes therein expressed.

Subscribed and sworn before me on the 7A / dayof)'awd 1982 i

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NotaryPub41cinandjfrth State of,,pa.. a.a fiay $e l

t W#5 D '3 IC My Comission Expires:

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UNITED STATES OF AMERICA NUCLEAR-REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l

1 TEXAS UTI'.ITIES GENERATING i

Docket Nos. 50-445 and l

COMPA!H, et al.

l 50-446 l

(Comanche Peak Steam Electric Station l

Station, Units 1 and 2) l C'tTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE'S ANSWER TO APPLICANTS' PLAN TO RESPOND TO MEMORANDUM AND ORDER (QUALITY ASSURANCE FOR DESIGN); AND AFFIDAVIT OF JACK 00YLE CLARIFYING. TESTIMONY have been sent to the names listed below this 5th day of March

, 198 4,

by:

Express Mail where indicated by

• and First Class Mali elsewnere.

(Attachments sent only to Parties, Board, and Docketing and Service)

Administrative Judge Peter B. Bloch Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Panel 4350 East / West Highway, 4th Floor U. S. Nuclear Regulatory Commission Bethesda, Maryland 20814 Washington, D. C.

20555 Dr. Kenneth A. McCollom, Dean Alan S. Rosenthal, Esq., Chairman Division of Engineering, Atomic Safety and Lscensing Appeal Architecture and Technology Board Oklahoma State University U. S. Nuclear Regulatory Commission Stillwater, Oklahoma 74074 Washington, D. C.

20555 Dr. Walter H. Jordan Dr. W. Reed Johnson, Member 881 W. Dater Drive Atomic Safety and Licensing Appeal Oak Ridge, Tennessee 37830 Board U. S. Nuclear Regulatory Commission Nicholas S. Reynolds, Esq.

Washington, D. C.

20555 Bishop, Liberman, Cook, Purcell

& Reynolds Thomas S. Moore, Esq., Member 1200 - 17th St., N. W.

Atomic Safety and Licensing Appeal Washington, D. C.

20036 Board U. S. Nuclear Regulatory Commission Geary S. Mizuno, Esq.

Washington, D. C.

20555 Office of Executive Legal Director U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Maryland National Bank Building Panel 7735 Old Georgetown Road - Room 10105 U. S. Nuclear Regulatory Commission Bethesda, Maryland 20814 Washington, D. C.

20555

g-s 2-r Docketing and Service Section j

,(3 copies)

Office of the Secretary

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

20555

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^?i Renea Hicks, Esq.

U Assistant Attorney General Environmental Protection Division Supreme Court Building

. Austin,_ Texas 78711 John Collins Regional Administratorf Region IV U. S. Nuclear' Regulatory Commission

'611 Ryan Plaza Dr., Suite 1000 Arlingtcn, Texas 76011 Dr. David H. Boltz i

2012 S. Polk-Dallas, Texas 75224 Lanny A. Sinkin 114 W. 7th, Suite 220 Austin, Texas 78701

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R. J.- Gary, Executive Vice President 1 Texas Utilities Generating Co.-

. 2001 Bryan Tower Dallas.. Texas-75201 i

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f)A L ys.) Juanita Ellis, Pr6sident CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 t

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