ML20093L024
| ML20093L024 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/11/1984 |
| From: | Doyle J, Mary Walsh Citizens Association for Sound Energy |
| To: | |
| Shared Package | |
| ML20093K997 | List: |
| References | |
| OL, NUDOCS 8410180274 | |
| Download: ML20093L024 (98) | |
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E UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION- coeg(8u, usN BEFORE THE ATOMIC SAFETY AND ' LICENSING BOMD LTT'17
-In the Matter of- l-- 411 :4 5 i kl r:::= w ..
TEXAS UTILITIES GENERATING l- Doc ket . No2?a 50-44,5{.h ia - COMPANY, . et ~ al .- l and 50244Bil" - I
- (Comanche ' Peak Steam Electric Station i
. Station, Units:1 and~2)~ l CASE'S ANSWER.TO APPLICANTS' STATEMENT OF MATERIAL FACTS AS.TO WHICH THERE IS NO GENUINE ISSUE REGARDING STABILITY-0F PIPE SUPPORTS in the form of
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.1 AFFIDAVIT OF CASE WITNESSES MARK WALSH AND JACK D0YLE MESSRS. WALSH'AND DOYLE:
-It should be noted, first-o'f all, that instability of supports was discussed. extensively in CASE's 8/22/83' Proposed Findings of' Fact and
' Conclusions of Law (Walsh/Doyle Allegations),"Section III (see also.Section
.IV on cinched up U-bolts). -We'will not repeat everything which was stated therein, but urge that the Board review those Sections prior to reading the
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following. l-
'MR. WALSH:
- 1. : Applicants state:
'.' Instability of a particular pipe support, when viewed in isolation
- from the piping system, is of .little or no significance. The relevant Jconsideration is whether the entire piping system and associated supports are' stable when considered as a single system. (Finneran
. Affidavit at-5-7.)"
r- ! 8410180274'"841015' ' PDR ADOCK 05000445 G 1-PDR 93 O -
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F7T u e ( First, it should be noted that, as has happened before with Applicants' MotionsLfor! Summary Disposition,- the statements in-g Applicants' Statement of Material Facts do not correspond to the
. statements in the back-up Affidavit of Mr. Finneran (who is the sole sponsor of.the Affidavit). . (This is true in other instances throughout the Motion under discussion, but I will not address each and'every one of them.) But I believe that.-we must' treat the Statement of Material Facts as the Applicants' position; 1.e., that there is little or no significance to instability of a single pipe support, and I am Laddressing Applicants' Motion accordingly.
I do not. agree with-Applicants' first Statement of Material Facts. The ASME Code requires that each support be stable (see ASME Section NF, Appendix XVII, Section XVII-2221(a), which is quoted on page 2 of Applicants' Affidavit). The philosophy presented by the Applicants is mind-boggling. If an unstable support is of "little or no significance," then those
-supports are in essence not supporting the pipe and a pipe stress analysis would have to qualify the new stresses within the pipe and the additional loads now transmitted to the adjacent supports. The Applicants have not demonstrated that the unstable supports, when removed from all piping systems, would allow the piping systems to perform their function in a predictable manner.- Any analysis now
- provided by the Applicants to verify the adequacy of the piping system
'is irrelevant, because when one has two groups working (i.e., the pipe stress analysis group and the pipe support group), the procedure is 2
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that the pipe stress analyst will locate supports in such a manner _as Lto minimize'the number of' supports and still keep the pipe stresses within allowables.- The pipe. support design group takes the location
; dictated by'the pipe' stress' analysis _and provides a support in the
' indicated direction. The pipe support designer is not made aware of what the' stresses are in the pipe; therefore it is of the utmost
-importance for all the supports to perform their intended function.
nIf,'by chance, a support is not needed and is excluded from the rerun of the pipe stress analysis, then that support could be permanently removed. But to avoid all these reanalyses, it is standard industry practice for all pipe supports to withstand the intended loads and be stable:for those' loads. That is a basic assumption when performing such analyses. Applicants' position appears to be that when a support is in effect missing due to instability, it is of little or no significance. (This is contrary to testimony _of NRC Staff Witness Tapia, Tr. 8867/12-8868/2, that instability of even a single support could have an influence.) This is a very important concept, because'in CASE's
. previous Answers to other Motions for Summary Disposition, we have discussed' supports which are being overstressed for some reason, and these have been problems which are significant and generic (to Comanche Peak).. The' Applicants' present attitude toward these unstable supports ,
-(missing supports)1is that they don't care. This attitude calls into question.the true extent of their concern about all the other problems
' discussed-in.our.other Answers to Motions for Summary. Disposition, as well as other problems which may not have been identified by CASE but which may exist in other areas throughout the plant.
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'I y - '4 Also,[Applicantsdonotexplicitlyaddresstheoverallstability
' of'the piping systems together with their supports in design guidelines, as' stated by the NRC.Special Inspection Team (SIT) at.page
.28 of:the' SIT Report l(NRC Staff Exhibit-207):
"It islnot general industry. practice to explicitly address the
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Loverall stability of piping systems together with their supports 11n design' guidelines.~ Rather,iit is standard industry design practice to address only the structural integrity of. supports in
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. design ~ guidelines. The Applicant's practice corresponds to this industry practice.: Thus,.no explicit design guidelines addtess
.overall stability. . . " ( Emphasis added.) -
During.the May 1983 hearings, NRC Staff. Witness Dr. Chen testified c _ regarding the " disease" of instability, as.he referred to it. The. problem of' stability is discussed in'the Affidavit of CASE Witness ~ Jack _Doyle, attac'hed-to CASE's 10/6/84 First Motion for Summary Disposition
.Regarding Certain Aspects offthe Implementation of Applicants' Design
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Land QA/QC for Design (page 7, line'10, through page 15, line 23; page
-51~,=line 25, through page 52,.line 9; for example). I will not quote
- Mr. Doyle's~ entire sections on. instability,.but we adopt them and incorporate them herein by reference. Briefly, Dr. Chen dismissed the problem of instability, apparently because he did not find several nunstable. supports in a row.- But,.as discussed in Mr. Doyle's Affidavit t
(at page114, line 5, through page 15, line 10), there- were actually
'five unstable supports in a row which have now'been documented by CASE.
5(And there is no' reason-to assume'that CASE has been able to document
- all' cases which actually exist.)-
t The Applicants agree that there were three in a row on main steam
,' line MS-1-001,.and four in a row on main steam line MS-1-003. It is my 4
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c understanding-from' CASE President Juanita Ellis that on October 4, _1984, in' response to a request by'Mrs. Ellis, Applicants' counsel
-William Horin-provided'by telephone the following list of 13 unstable supports which Applicants maintain are the only unstable supports which had a U-bolt with a gap on the main steam line:
' 'MS-1-001-003-S72R MS-1-001-004-S72R MS-1-001-005-S72R MS-1-002-003-S72R MS-1-002-005-S72R MS-1-002-006-S72R MS-1-003-003-S72R
.. ~MS-1-003-004-S72R l? MS-1-003-005-S72R MS-1-003-006-S72R MS-1-004-003-S72R HS-1-004-005-S72R MS-1-004-006-S72R
_Considering that there are three principal directions for a support.(i.e., vertical, and two horizontal directions), one can see, regarding the four unstableLsupports on main steam line MS-1-003, that there were must have been at least two supports going in the same ,
. direction which were unstable.
-MR. DOYLE:
Q: Is there anything you would like to add or discuss regarding.,
. Applicants' Statement 17
- A: Yes,.there is. At page 6 of Applicants' Affidavit, Mr. Finneran states:
"Mr. Doyle also agrees that the important criterion by which stability should be assessed is system stability. Mr. Doyle 5
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testified as follows in September, 1982, with respect to a particular-support which he observed in performing the STRUDL
- analyses and which he- believed to be unstable (CASE Exhibit 669 at 210):
"'I wouldn't have done this. I would have used a clamp because, even though the structu:e below is apparently
-unstable, it takes so.little to make it stable that a support horizontally up and downstream is sufficient because the pipe won't see that much force to keep it stable.'
"Indeed, Mr. Doyle was referring to 'a clamp strut situation' similar to that' described above (see Figure 2), when he stated that a suport'up ro downstream could easily provide added stability (see CASE Proposed Findings at 111-9)."
I am getting tired of being cited as approving something which is not the case. . To put this problem to bed once and for all, let me state the following: (1) I never condoned in any way the use of U-bolts as a replacement or alternate for clamps (shell type) (see CASE Exhibt 669B, items 11YY and-11ZZ). (2) I have always stated that if U-bolts are cinched up, the stresses would fall the mechanism (stresses over
' manufacturer's allowable) (see CASE Exhibit 669B, item 11ZZ).
(3)- I have always maintained that-insufficient cinching would lead to lift-off problems when mechanical loads were applied (see Tr. 12,353-12,354). (4) I have always maintained that the use of U-bolts as clamps on coverd lines'with temperatures of 120 degrees F. to 450 degrees F. was not recommended (see MSS SP-69, 2.0 and Table 1). (5) As relates *.o instability problems for U-bolt double pinned columns or, for that matter box frames, is not recommended for support of pipes from below (see' MSS SP-69, 6.2 and 6.3).
'(6) I have always expressed a concern with the local stress problems on pipes with cinched-up U-bolts (see CASE Exhibit 669B,!1tems 11YY and 11ZZ).
Since I have always objected.to the use of U-bolts as clamps, how can I be cited ~as approving (even indirectly) the use of this unique deviation from standard practice. L 6 s
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, if SMR.1WALSH:
(( !2.._. Applicants < state:.
'"Th'e' stab'111ty of piping systems is not explicitly addressed in piping
. . analyses. ~ : However, it is not .necessary to' do so because through the -
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l normal design process the piping designers achieve a system which will
. stay within:specified deflection-limits and, thus,;will be incapable of
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the/ instabilities at issue here... (Finneran Affidavit at 7.)" 4'
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lITagree with Applicants' first sentence (see discussion under
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; answer'.1 preceding).
'Regardingqthe second sentence, I totally disagree. Applicants'
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' premise is.taken from page 7 of' Applicants' Affidavit and is illogical,.
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. ? irrational, and undocumented. To demonstrate this fact, consider the
, (following: Applicants' Witness Finneran is relying on the " normal-design process" and "specified deflection limits." Applicants' " normal
.~ design" process" created the problem with unstable supports and there' was'.no mechanism within the Applicants' system to identify, to correct, Lor to avoid unstable supports in the future, as will be demonstrated 4
- later. '"Specified* deflection limits" on which Mr. Finneran is relying
- are immaterial, since the supports will deflect out of the way of the
' pip'e:if they are unstable. The piping designers are incapable _of
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identifying an unstable-support (see Applicants' Witness Krishnan at-LTr.t4917,1where he conceded that unstable supports could have been input into the stress run as being stable, as pointed out in CASE's 8/22/83 Proposed Findings'of Fact and Conclusion of Law (Walsh/Doyle Allegations), at page III - 2). Further (as discussed on page Ill - 1
'_ of CASE's Proposed Findings), Mr. Krishnan, Applicants' Site Stress
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2 Analysis Group Supervisor. lacked any concept of what constitutes e-7 m
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..Linstabilityf(andthereisnoindicationthathehastakenstepstomake himself:more1 knowledgeable in this' regard);'he stated that he is not an
;expertion hanger ~ design and pipe hangerLaupports, and that'he was'not.
j cgivingEexpertl testimony in that regard.
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<3.- -Applicants' state: ,
"The~' support designer,is responsible for assuring the stability of each pipe support as part of the piping and support system, and may rely on
'the-presence of the pipe to (sic) a stabilizing effect. This
- . responsibility is delineated in ASME Code Section NF, Appendix XVII, Section KVII-2221(a), to which all support design organizations are
' committed. .(Finneran' Affidavit at 8.)"
> 11 will'not address.the legal requirements regarding Applicants' statements. 1But regardless of who is: responsible,_the important point here is that there were unstable supports constructed which were in violation of the ASME Code to which Applicants are committed.- And the Applicants did not-discourage field engineers from continuing to. create
- these unstable supports or ITT Grinnell from doing so.
(See also' discussion in answer 15 following.)
'4. LApplicants state:
" Applicants promptly identified and acted to correct potential
? instabilities of. pipe supports at Comanche Peak in the normal course of the design process. Potential instability of box frame rupports with
- single struts or snubbers-(which resulted from' modifications made in ,
.the field) were intitially identified by ITT engineers on site in May 4
1981 (prior to Mr. Doyle or Mr. Walsh working at Comanche Peak), at
. which time a hold was placed on approval of further designs of this
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- type of' support. There is no evidence that Mr. Doyle or Mr.'Walsh
- raised.the question of stability of these supports with their supervisors or other of' Applicants' personnel who were in a position to act on their concern. (Finneran' Affidavit at 9-11, 29.)"
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V 6: 9 MR. WALSH: I disagree with the first sentence. The Applicants have provided
, -inter-office correspondence by ITT Grinnell (Attachments A-1, A-2 and
'4.
- A-3 -to" Applicants' Affidavit).
Attachment A-l'is interoffice correspondence from Guc Abele; this fis-'the'bi-weekly report for Comanche Peak which provided the status of. the wo'rk baing done'by ITT Grinnell field engineers. On page 2, item 6, the potential. problem of instability of box structures is discussed, and it states that: " Technical Services will hold all supports using box structures as pipe attachments until written procedure or approval from Providence is received." -(Emphasis added.) There was no
-documentation provided by Applicants that such written procedure or approval from Providence was ever received.
This ' appears to be Grinnell's method of promptly identifying and correcting design deficiencies. This same correspondence is also used
-for such relatively'insigifnicant items as requesting pencils (bottom Lof page 2). There appears to be no special significance attached to the identified design deficiencies as opposed to the ordering of
- pencils,-for. example. Further, there appears to be no way which
' identified design deficiencies would have been trended from such a memorandum, so that the recurrence of the problems would have been avoided.
- The second memorandum (Attachment A 2) on which the Applicants rely to prove that they promptly identifed this " disease" of
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' instability was to the Manager'RD&E, Robert Mulcahey, from Gus Abele, ITT Grinnell Lead Site Engineer. This memorandum (which was some five inonths after the first' memorandum) is a request for information for ITT
.Grinnell field engineers to have some concrete guidelines for determining the.s'tability of box frames. There is no indication in either of'the two memoranda chat Applicants had identified that there
.was also a problem with instability in regards to supports with U-bolts.
The third memorandum (Attachment A-3 to Applicants' Affidavit), to Gus Abele from 'on Wisniewski, was' dated 4/2/82, almost six months after the second memorandum and almost one year after the problem was first identified. This answer from ITT Grinnell in regards to concrete guidelines for stability states that a " general answer cannot be generated" for a variety of reasons. It is obvious from this memorandum that the design organization (ITT Grinnell) did not even understand what the problem was or the extent of the problem -- almost a year after the problem was identified. There is no indication that any of the instability problems had been corrected or could be g; corrected. Further, there is no indication that anyone had identified that there was a problem with instability when utilizing a U-bolt (as on the main steam line, for example). This is not prompt i identification and_ correction of the problem.
.MR. D0YLE:
Q: Mr. Doyle, do you agree with Applicants' first sentence? 10 L
W W :-;. ; .: ; i A: L I do not.1 I discussed this:in my Affidavit attached to CASE's 10/6/84 First Motion for Summary Disposition Regarding Certain Aspects of the Implementation of Applicants' Design and QA/QC for Design (at page 8,
$line15,throughpage10,line13),andIwillnotrepeatitbere,but
, 'incorporete it.herein by reference.
-MESSRS.~WALSH'AND D0YLE:
In~ summary, Applicants'_ statement that they "promptly identified and acted'to correct potential instabilities" is misleading, since the lAp'plicants have'not provided any documentation to show that they had
. corrected.the problems of instability to box frames or that they had even identified another problem with instability on supports utilizing U-bolts.
MR. WALSH: Regarding Applicants' second sentence, the Applicants admit that ITT Grinnell engineers identified potential instability of box frame supports with single struts or snubbers,.but as discussed above, no
- corrective action was implemented, apparently in part.because ITT Grinnell's'home office did not understand the problem. In addition,-
LGus Abele (the same engineer who wrote the first two memoranda) discussed the potential instability using double struts (Attachment A-2, page'2). '(See answer 9 following.) i' Also, there is another important aspect discussed in Applicants' Affidavit but not included in their Statement of Material Facts. At 11 a L ..
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'page-10'of hisl Affidavit, Mr. Finneran~ states:
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!"The potential instability was identified by ITT engineers on site
--in_May-1981:(see memorandum CPG #36,' dated May. 22, 1981'
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Attachment:
A-1)). lAs can be seen from page 2 of this memorandum,
- 1) the.two supports! referenced as examples (CC-1-159-010-S43R and
. CC-1-028-039-S33R) are the same. supports listed by Mr. Doyle in
- CASE Exhibit'6698:(Items 4g-and.4h, 4o'and 4p),.and 2)'the supports were identified as potentially. unstable no later than May
. 22, 1981.- Mr. Walsh began. work ac Comanche Peak on June 15, 1981.
*1 EMr.'Walsh began work'at Comanche Peak on June 15, 1981. Mr. Doyle f ,
; began work on August ~ 17, 1981. .Neither of these individuals could
'have had any part in the identification of suports as potentially
- unstable."'
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'Apparently? Applicants did not realize that, by his statements quotedfabove, Mr. Finneran has proved one of our main points.
Applicants have now admitted that this problem-(even on the same two
? supports) was' identified' sixteen months before it was-again identifled,
- 'this-time by Mr. Doyle in his August.1982 deposition, that they didn't do.anything to correct the problem when it was first identified, and that41t wasn't until after I testified in July 1982 and after Mr.
.Doyle's August 1982-deposition that Applicants finally were forced, .
'because of.these operating. license hearings, into doing something about
..this problAm: - while at the same time offering this as some sort of
' proof that " Applicants discovered this problem themselves and promptly
-acted to address it."'.Mr.-Finneran's own scatements, in the same
. paragraph,' prove the contrary.
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'MR.'D0YLE: z :
Q: ~ 'Mr. Doyle, do'you agree with the third sentence of Applicants' Statement 4, or with the statements made by Mr. Finneran at page 11 of i. his Affidavit, where he states: i' IR y" 12 a
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"In fact, only Mr. Doyle alleges'that he spoke to anyone regarding
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.his concern.' Specifically, he. alleges that he had discussed this matter with Mr. Kerlin. : However, as Applicants indicated in their Motion for Reconsideration of the Board's Memorandum and Order (at
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20-21), Mr. Kerlin.was~a co worker of Mr. Doyle's and had no supervisory, responsibilities. Thus, Mr. Doyle took no action to
~ bring his concern to any.one whom he could have reasonably
- expected'.to.take any-action."
A:'. lI certainly do not. 'I testified during my August 1982 deposition (CASE-Exhibit 669A,1Doyle Deposition / Testimony, accepted into evidence at Tr.
'3630,;pages.21-23), regarding my unsuccessful attempt to explain instability to Mr. Kerlin. I stated at that time regarding Mr.
lKerlin's job:
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"0: Was a part of Terry Curlin's (sic) job to work with the pipe stress and pipe support people, the people who did this analysis;-
was he part of..the interface with others, as far as you know?
"A: What-I know is-that-he had something to do with ~'between the nuclear engineer, I can't think of his name -- between him and NPSI'and Grinnell on supports. I'niso know he was getting numbers from the Pipe Stress Group because he was running through them.
What his exact function is, I can't answer.'.' While it is true that.I did not necessarily mention specifically who I talked to about the instability problem other than Terry Kerlin, from my deposition (CASE Exhibit 669 and 669A, Deposition / Testimony of CASE. Witness Jack Doyle, admitted at Tr. 3630), it is obvious that I talked to everyone I thought was interested or might be willing to do something.about it relative to a vast number of problems. And among the number, instability (although it is unclear from my deposition) was discussed with Mark Walsh (who was, for some time, leader of my group), Gary Krishnan (Mark Walsh's immediate supervisor), and co-workers Pam-Stanford and Jerry Petty, and others. The discussion of problems on s 13
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'!many;occasiona^ willibe' noted' as follows, f rom my deposition (CASE.
[NI ._ [ ,_ -Exhibit: 669): E . !pages.14,' lines:3-6. U-bolts and LOCA problems,were discussed; - . m
.page-24,1 11nes'7-12,'LOCA was again a topic; and "
pagef 25, -lines .5-7, U-bolts lwere again brought up, as was the case
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at'page;30, lines 12-15. AsLfar as; general discussions, when qt.estioned by Applicants'
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- Witness Scheppele-(at.page 299, lines-22-23), I stated'that I felt it
,was serious and that's why I kept passing the information on.
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repeated'myself again at page:300 (lines-4 and 5), when Mr. Scheppele
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inquired as to whether I had ever told anybody tnat I had a specific
,, L concern !for the ' design of this facility; I stated that "I certainly Ji 'did, many timen_while;I was there." At.no earlier point, contrary to
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.Ll the~ openness for discussion with manageaent that Applicants'now try to y "
convey,-Mr. Scheppele.kept insisting.that-I worked within a-box (see pages 258-262).- At pages 261, line 25, through 262, line 2, Mr.
, ;Scheppela also stated that it was not my responsibility to change
, ' configurations _of supports.
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And beyond this,LApplicants' admission that one of their people
'had presented the instability problem in May of 1981 and received no.
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- y. : response until'Apri1 of 1982 (at which point.they sloughed the man off i
to another individual' for further discussion which was not documented)
'i s indicative of the lack of interest Applicants took in any complaints a< ;
"which were. brought forward.
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;The most significant point relative-to instability reporting is the-fact'that Applicants, by their;own admission,-received V
communication-from ITT Grinnell personnel on site that an instability
; problem existed. Over.a year later, 1 complained or the same problem fon the'same supports.-'Apparently nothing had occurred in the interim.
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'In April:of 1982, a year.after he had reported-it, Applicants passed this same ITT Grinnell employee of f to discuss the problem with someone else (that discussion is not documented). So what would have been the advantage of me (or.Mr.-Walsh) reporting the problem even if we had gone'to Mr. Spence himself? Nobody was interested anyway. As stated in-my deposition', I quit'(cr was fired, I'm not sure which) basically because of lack of interest by management at Comanche Peak in the problems that existed (my deposition, CASE Exhibit 669, at page 13, line 25, through page 15, line 1, and page 298, lines 2-13).
'MR. WALSH:'
0: 'Mr. Walsh, do you agree with the third sentence of Applicants' r fatatement 4,.where they state:
"There is no evidence that Mr. Doyle or Mr. Walsh raised the question of stability of these supports with their supervisors or other of Applicants' personnel who were in a position to act on their concern.' (Finneran Affidavit at 9-11, 29.)"
. . . or with the statements made by Mr. Finneran at page 11 of his Affidavit, where he states:
"In fact, only Mr. Doyle alleges that he spoke to anyone regarding his concern. . . Mr. Walsh has not alleged that he spoke to anyone, let alone a supervisor, regarding instability."
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Fu <ay . l f 'N i1 [,) g ,. (A: 'Ildisagree with Applicants' statements.- There M " evidence in the
; record that Mr. Doyle or'Mr. Walsh raised the question of stability of
. _ ._these' supports with'their supervisors or.other of Applicants' personnel-who wereLin a position'to act on their concern," as discussed by Mr.
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;Doyle in the prece'ing.
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d To the best of,myLrecollection, Dave Rencher_and Terry Kerlin cappeared to supervise the Technical Services Design Review Group
-(TSDRG),fincluding NPSI and ITT Grinnell engineers; Dave Rencher was c11sted as " Supervisor, Technical. Support Design Review . . . Contract- -
employee,. managed and. supervised by licensee" in the SIT Report (NRC-Staff Exhibit 207,-page 8 of Appendix). And it appears from documents "obtained since 1 testified in July 1982 that these TSDRG engineers were
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Eperforming vendor certification 1of pipe supports. The organizational Jatructure which involved _ Terry Kerlin and Dave Rencher appeared to be l as f6110ws: The ITT Grinnell and NPSI engineers did the calculations
-for supports that were given to them from Dave Rencher and Terry
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k' Ker11n. - Any changes to pipe supports or memoranda in regards to those supports were;through the office of: Dave Rencher and Terry Kerlin. The
' latest as-built $1oads went to Dave Rencher and Terry Kerlin, so that-the ITT Grinnell and NPSI engineers could evaluate the supports for the
'new loads.
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I' generally recall the day when Terry Kerlin and Jack Doyle had theirl discussion and Jack Doyle tried to explain to Terry.Kerlin about
~ - Einstability.. I was not directly involved in the discussion.but I 6
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. overheard parts of it. I don't remember all of the conversation, but i do recall'tha'tkJack Doyle pointed out the problem of instability to Mr.
' Kerlin'. ' 'Although _ the Applicants' may claim that Mr. Kerlin "was a co-tworker- of- Mr. Doyle's ~ and had no supervisory responsibilities," Mr.
'Kerlin,.in his position,:certainly appeared to be in a supervisory .
[ ' 1 position.: It should,be note'd that the Licensing Board, in its 2/8/84
, :iN MEMORANDUM AND ORDER (Reconsideration Concerning' Quality Assurance for IDe' sign),atpageL15, item 2,. stated:
Applicant relles on extra-record materials to rebut the' Board's ifinding that Mr. Kerlin had some supervisory responsibility.
g ",. 7 Although Applicant has not yet presented evidence on this point, we are confident that it will do so in order to establish its _ point."
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This isfcorrect, and there was never any need for me to discuss s~ this catter, because Mr. Doyle's testimony was unrebutted in the record-c
,op , anyway. :And the Applicants have still failed to provide evidence'to
. rebut the Baard's original finding. The only " evidence" which Applicants have provided is Mr.-Finneran's statement in his Affidavit
.(at.page 11)t; g y" "However, as Applicants indicated'in their Motion for.
- Reconsideration of . the Board's Memorandum and Order (at '20-21),
Mr. Kerlin:was a co-worker of Mr. Doyle's and had no supervisory responsibilities." (Emphasis in the original.) There is no indication that Mr. Finneran did any independent , research regarding this matter or that he is relying on anything other v than the extra-record'and unsupported statements in Applicants' Motion for Reconsideration. ~And there is no documentation to support any of
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,. Applicants' statements ~1n this regard; this includes the CMC which Mr.
Finneran stated had been written in March 1981 to improve stability (Tr. '4893/12-4895/3).
-And regarding Mr. Finneran's amazing statement that "Mr. Walsh has not alleged that he spoke to anyone,'let alone a supervisor, regarding instability," during my unrefuted cross-examination testimony in July of 1982, I stated (Tr. 3107/19-22):
"What happened was the engineer from Crinnell, I went over and
~
., informed him that 1t was unstable, and he told me that it was his responsibility."--(Emphases added.)
" Consequently, we sent.it back that way."
'It should be pointed out that this entire question as to whether
- or not Mr. Doyle or I had reported our concerns to anyone onsite is a
-relatively unimportant matter when compared to the many serious design and design QA/QC deficiencies at the plant.- It was Applicants who have made this into a big issue, and who have again by their own actions proved-(among other things) that they didn't listen when the problem was first brought up, or when it was brought up by Mr. Doyle and me, or apparently even.when I testified in July of 1982 in front of many of Applicants' witnesses and representatives (including, I believe but am not positive) Mr.' Finneran himself.
- 5. Applicants state:
" Applicants reviewed all supports in Unit 1 and common areas and identified 12 frames that fall in the category of box frames with single struts or snubbers. There are about 17,000-18,000 safety-related supports in Unit 1 and common areas at Comanche Peak.
18 e
y (Finneran Affidavit at 12-13.) Modifications made to these supports (all initiated priorfto February 23, 1983) will prevent rotation of the
' frame around the pipe and thus remove the mechanism through which the ,
potential rigid. body instability could occur." Regarding the first two sentences, it is not surprising to me that
^
Applicants could only find 12 frames out of the 17,000-18,000 safety-related supports in Unit-1 and common areas at Comanche Peak. The
-reason I.am not surprised is based on the memorandum which is Attachment A-3 to Applicants Affidavit._ It appears that the Applicants could not respond'to Gus Abele's request for guidelines for stability, as shown in Attachment A-3 and as stated earlier. As will be shown in answer 6, there is at least one more unstable box frame with single struts which Applicants have not identified as unstable.
In regards to Applicants' third and last sentence, I have two points to make. The Applicants claim that they initiated modifications to the 12 unstable supports with box frames prior to February 23, 1983. The Applicants have shown no proof or documentation that this is true. It is my understanding that this was to be Applicants' last oppotunity to prove their case and that it is the Applicants who must provide sufficient evidence and documentation to prove their point -- not always CASE who must request and provide documentation to the Board. The burden of proof should be on the Applicants -- not CASE or Mr. Doyle or me. It was because of this lack of proof or documentation by Applicants that I am now having to answer (and have answered in the past) Applicants' Motions for Summary Disposition. If the documentation does exist, the Applicants should have provided it with their Motion for Summary Disposition. CASE and I are at an inconvenience in answering these mot'.ons which the Applicants are 19 u
-=, i utilizing to attempt to'show that they have a proper design / design QA/QC program because many times we have had to request documents before we have really had time to thoroughly review the Applicants' Motions to begin with._ So we've just had to do the best we can with
~
-the documents we did ask for and receive.
The Applicanta have not demonstrated that the modifications which they have made to these 12 supports will, in fact, prevent rotation of the frame around the pipe and thus remove the mechanism through which the potential' rigid body instability could occur.
- 6. Applicants state:
" CASE incorrectly asserted that NCRs should have been issued against
-these supports. This potential deficiency was identified as part of
.the normal design review process. Applicants do not use NCRs to document deficiencies identified in that process. In addition, irrespective of this fact, the Component Modification Cards (CMCs) that were written which created the potential instability do not constitute an official design change until they have been reviewed and approved by the responsible design organization. In this' instance, the potential
- instability was identified prior to approval of the CMCs, and in fact s
as part of the review cycle. Thus, the question of whether further documentation of this potential deficiency should have been issued is not_ relevant. (Finneran Affidavit at 14.)" When Applicants state that " CASE incorrectly asserted that NCRs-should have been issued against these supports," it is apparent from Applicants' testimony in the September 1982 hearings, as compared to the Affidavit of Mr. Finneran attached to Applicants' Motion for-Summary Disposition, that Applicants are still committed to the same erroneous postion they initially took -- although the Board clearly 20 L -
% _ s
+ -
- i s.; :e 1
^ ,
Y
'S
[ stated _in its 12/28/83 Memorandum and Order (Quality Assurance for
- Design) that; Applicants (and NRC Staf f's) premise was incorrect and in
-violation _ of NRC-regulations (Order at page 2-7,-20-30, and 69-71, for.
_ example).
~
Also, until Applicants changed their FSAR (Applicants' Exhibit 3) on July 11. 1983, they were in noncompliance with their own FSAR in this regard.' (See Attachments'A and B hereto: FSAR page 17.1-39, May. 31,-1979;;and.FSAR pages 17.1-39, July 11, 1983, respectively. See
~
also Attachments C and D hereto: FSAR page 17.1-40, May 31, 1979; and
'FSAR page 17.1-41, August 7,'1981, respectively. See also discussion in CASE's _8/22/83 Proposed Findings of Fact and Conelissions of Law (Walsh/Doyle Allegations), pages XXIX - 19 through -23.)
In his Affidavit at page.14, Mr. Finneran states:-
" . ' . . the Component Modification Cards (CMCs) that were
. written.which. created the potential instability do not constitute an official design change until them have been reviewed and approved by the-responsible design organization.
As I' previous testified, all CMCs creating design changes are subject to review by-the responsible design organizations. (Tr. 4870-71.)"
'In their Motion-for Summary Disposition, Applicants do not discuss what method, they do utilize to identify and correct design deficiencies.
or potential design deficiencies. They rule out the use_of NCR's and it is obvious that they cannot use CMC's because, as Applicants claim, it.was CMC's which were written which created the potential *
'ibstability. It appears that Applicants' statement that they do not use NCR's to document deficiencies is correct, but,it does not go far s
4 21 m.
enough -- it appears that= Applicants do not use anything to document
~
'such~ deficiencies, based on the small amount of " documentation" they have provided.
The Applicants further claim that the potential instability was identified' prior to approval of the CMC's. In CASE Exhibit 669B (Attachment to Deposition / Testimony of CASE Witness Jack Doyle,
' admitted at Tr. 3630), Item 4E represents one of the unstable supports
-as it existed at Comanche Peak. Item 4E is written on a CMC and it will be noted that_it is approved. Applicants may claim that this does not mean that it was approved for design, but C. M. Chamberlain, the latest approver, is from PSE Engineering; therefore, this is (by implication) engineering approval. In addition, in CASE Exhibit 669B, Item 4C, a copy of the CMC, Rev. 13, is shown for this same support.
~
This CMC was-approved by Dave Rencher (who is listed in the SIT ~ Report as Supervisor, Technical Support Design Review, contract employee, managed and supervised by licensee). It should be noted that Technical Support Design Review (TSDR) does the vendor certification. Although the reason that the support in CASE Exhibit 669B, Items
-4C and 4E, is unstable may have been discussed elsewhere, I will
-quickly reiterate the reason. Without a sufficient clamping force, this box frame will rotate about the axis of the pipe and will slide down the axis of the pipe. The Applican,ts do not have an established procedure that would be adequate for engineering ~to verify that a proper clamping force exists. In addition, as will be discussed in 22 u- .
W ;f X f-e ,74 1- ' . s 1: > 1*{
' answer 9 herein,-- it is highly probable that a gap exists between the
. pipe and"the frame.
' Attachment E, Attachment F1, and Exhibits F1 and F2, attached
- . hereto, are part of the " insignificant" material which Applicants were to; provide to the Staff on instability.(CASE'is using the same designation for Attachment F1 and Exhibits F1 and F2 which Applicants
- +
Lhad already assigned to them, since this fell in line with our LAttachment. numbering sequence). This support is also shown in CASE e LExhibit 6698,= Item 11JJ through 11NN. During the 8/23/84 meeting
+
3, onsite between the NRC Staff and Applicants, Applicants promised to 7 _ . provide this material to the Staff by 8/30/84, but it was not provided
'to-the Staff until 9/24/84', and CASE received it on 9/25/84. Support CC-1-028-034-S33R (which is described in CASE Exhibit 669B, items 4C
' and 4E), has a similar configuration.as that shown in Exhibits F-1 and F-2 for supports CT-1-008-007-S22K and CT-1-008-008-S22K. These last two supports presently exist at Comanche Peak, as discussed in Attachment E hereto at page 1 of Answer F(a), and Exhibit F1, respectively, wherein Applicants attempt to explain why they
-(erroneously) believe that the support is stable.
One difference between Exhibits F-1 and F-2 and CASE Exhibit 669B, items.4C and 4E, is-that the Applicants' Exhibits have lugs welded only
.to.the pipe, whereas items 4C and 4E do nor have the lugs welded.co the pipe.- In CASE Exhibit 6698, items 4C and 4E, the pipe is running horizontally, and is being supported vertically from below and has one t
horizontal direction of restraint; in Exhibits F-1 and F-2, the pipe is vertical and has horizontal restraints in the East / West and North / South 23
p n a . :- _ t f 1 p
directions. In' Exhibits F-1 and F-2, the Applicants support the deadload of the supports by welding lugs to the pipe. As will be shown below,-these lugs'do not_ improve the stability of these supports.
, Therefore, both Exhibits F-1 and F-2 and CASE Exhibit 669B, items 4C
.and'4E, are similar.in.that they are box frames which have a strut or
. snubber-and-are intended to provide support for the pipe.
m In Applicants' Attachment F-1 from ITT Grinnell, Grinnell attempts to qualify these existing supports. In Grinnell's response regarding f'p the stability of these supports, they attempt to show that the supports v
, ~ are' stable. On pages 2, :3, and the top of page 4, Grinnell determines
[ ' displacements and rotations to come up with the additional load (which
- is meaningless) for the support configuration. As stated in'their
^
reply on page 4, they consider the increase in stress'due to a kick load. Since the previous stresses were below the allowables, Grinnell erroneously assumes that " sufficient design margins exist to account for worst case considerations." Grinnell apparently has no concept, to this date, of what constitutes a support's being stable or unstable, since they are still considering the stresses within the member, and not the rigid body
- , rotation which is exhib'ited in this type of support. The numbers provided en'pages 2, 3, and 4 of Attachment F-1 are irrelevant, illogical, and immaterial, since they do not address the stability problem as a rigid body. These supports are unstable because if a load is in the North / South direction and is minutely offcenter from the 24 6
4 , y, ,-, . i
~
fNorth/ South.direc'tional support, and has a load in the East / West
~
' direction minutely offcenter from the' East / West direction, and if both
~
1oads would tend to put' compression in the supporting snubbers, this
-frame will rotate out of'the way,.and~this'will be as if there is no
- support at this' location.
JGrinnell's error in the calculation also did not consider the [ dynamic effects and the reason a postiive clamping force is required. When the Applicants tested the cinched-down U-bolt with a preload on
'the U-bolt, they discovered thac the support assembly will rotate about
- the pipe when dynamically : loaded. These frames under discussion
-(single struts or snubbers on box frames) have no positive clamping
. force and are therefore unstable.
The Applicants prc.vided CASE, on discovery drawings for some unstable supports. The-drawings included 'he t drawing that made the w : support unstable _and the drawing that made it stable. Attachments G
-and H hereto include the drawings which made the supports unstable.
.And in both cases, these are on CMC's and both are from engineering-
'(CPPE, which is' Comanche Peak Project Engineering). As a matter of
-fact,'in Attachment G, which is for' Support CC-1-048-007-A33R, Rev. 1, the originator was G. Abele (Lead Site Engineer, according to Attachment A-2 to Applicants' Affidavit, and according to the SlT Report. NRC Staff Exhibit-207, page 8 of Appendix, Supervisor, Sit i
Engineering, contract employee, managed and supervised by licensee),
^
who was~the one who wrote Attachments A-1, and A-2, and who was the
=sddresseei 'n Attachment A-3, to Applicants' Affidavit. It would appear that the approval'as shown on the CMC's would also be from an engineer
-or from engineering. This assumption is supported by the testimony of
~
25
}
i - ,
; q: ' j. ;
e , Q _
,= ,' t .Mr. Finneran:1n~the September 1982 hearings at Tr. 5184/1-6:
h
- "BY WITNESS FINNERAN:
"A. The' pipe support field engineer interfaces directly with the
- l craft.1 -When interference or a problem is encountered, he will
_0- resolve the problem, document the resolution on a CMC, and forward the CMC to the proper design organizatica for review and approval." (Emphases added.)
-It was during'the testimony as to how the problem with unstable D_ pipe supports came about in the first. place that Mr. Finneran made his
~
now-famous statement that the problem was caused by field engineers who were.not responsible-for the design of the support (Tr. 4955-4962), and _thatfthese were "somewhat knowledgeable" engineers (Tr. 4962-4965, emphasis added). Then NRC Senior Resident Inspector - Construction
. Robert Taylor testified, regarding deficiencies in design, that the source c0 these' design deficiencies is "a'somewhat' inexperienced engineering staff." (Tr. 6403/4-6404/3, emphasis added.) He further D s confirmed that these somewhat inexperienced engineers are still involved in design work at Comanche Peak (Tr. 6406/1-11). (See y discussion at page III - 4 of CASE's 8/22/83 Proposed Findings of Fact land Conclusions of Law (Walsh/Doyle Allegations).
I'do not want to [ belabor the point here, but want to call the Board's attention especially to the single-spaced transcript citettons in the middle of
.the;page regarding the credibility of Mr. Finneran's testimony.)
In. summary, the Applicants have not shown that they have a program
;c Lwhich will comply with'the requirements of 10 CFR Part 50, Appendix B,
~ Criteria II, XV and XVI. "Somewhat knowledgeable" engineers (including
< 26 e _2 . - _ -
p= g,
+ p. ..
1 g- ge , n.( isupervisory personnel) apparently. created the unstable supports.
"Somewhat' knowledgeable" engineers (including supervisory personnel) apparent 4y: approved the unstable supports. "Somewhat knowledgeable" n
engineers-(including supervisory personnel) apparently are part of the
- original design organisations or vendor certification process. The L , Applicants have not demonstrated whether or how they have, or plan to, c educate these individuals to avoid this problem in the future.
I 7.- Applicants state:
'Nith respect (sic) the question of the stability of the main steam supports, ongoing discussions were in progress in September 1982 as to whether there was a need for corrective action on this type of support.
Thesel discussions revolved around the impact of various effects on the supports' stability. Because'the design practice for U-bolts used as clamps on single strut supports is to have the U-bolts cinched down
-(as is done with a clamp) there was no need to impose any restrictions
.on design practices pending ultimate resolution of these questions.
Applicants decided.'in late 1982 to modify these supports to improve
.their stability because the modifications were relatively simple and readily accomplished. '(Finneran Affidavit at 15-18.)"
To begin with, Applicants did not provide any documentation with their Motion for Summary Disposition to support their allegation that they were having the " ongoing discussions" in September 1982 as to whether there was a need for corrective action on possible instability of the main steam supports. . It should be noted that Mr. Finneran does not provide any transcript citation to support his statement that there had been.such " ongoing discussiuns" -- because he did not state that i during his testimony in the September 1982 hearings when he discussed this matter. In fact, from his testimony during the September 27 L_ '
-w ---
hearings, it appears that Mr. Finneran was relying only on thermal expansion of the pipe to make the support stable; Mr. Finneran concluded that he felt the support might be unstable with the loads shown without this thermal expansion (Tr. 4943). In addition, it should be noted that Mr. Finneran does not provide any citation to the SIT Report to support his statement that there had been such " ongoing discussions" - because there is none to cite. It appears to me that the only " ongoing discussions" were the testimony and cross' examination of Mr. Finneran (and other Applicants' witnesses) There has certainly been no discussion in the transcript, or statements in the SlT Report, g documentation supplied by Applicants to support the idea that they had any such " ongoing discussions" or had even identified the problem prior to Mr. Doyle's deposition on August 19 and 20, 1982. And there is nothing to prove that Applicants would have ever dealt with this problem or attempted to correct the problem if it had not been brought out by Mr. Doyle in these hearings and under the eye of the Licensing Board. In the third sentence of Applicants' alleged Material Facts, the Applicants are referring to U-bolts which are cinched down. This is. Irrelevant to the unstable main steam supports because they had a 1/8" gap and were not cinened down. But to clarify the record, the Applicants, even in September of 1982, could not rely upon any clamping
- force due to the cinched down U-bolts because the craft were not requested or required to pretorque these bolts. This is demonstrated 28
7, - 4 . Jin the SIT' Report (NRC Staff Exhibit 207) on page 32, under the discussion of-item g. Use of U-Bolts in Pipe Support Design, where it states (emphasis added):
"Regarding the preloading stresses in item 3(a) of Mr. Doyle's concern, the Special Inspection Team determined that the Brown &
Root Design Change Notice.(DCN) Number 1, dated 10/8/82, to
' Construction Procedure'No. 35-1195-CPM 9.10 Rev. 8 provides additional requiremen'ts to paragraph 3.3.2, ' Threaded Items,' for U-bolts. It' states:
"'When U-bolts are specified on the design document as not having any clearances, the U-bolt shall be snug tight so that the U-bolt cannot be moved by hand....
"' Snug tight is defined as the tightness attained by a few impacts on an impact wrench or the full effort of a man using an ordinary spud wrench.'"
Another reason they could not rely upon a frictional clamping force as 1s used for a clamp is because a U-bolt is not a clamp; a U-bolt does not go all the way around the pipe as would a clamp. This was recognized by the SlT Team at page 33 of the SIT Report:
"Further, the U-bolt is normally provided.with a 1/16 inch diametrical gap on the pipe to facilitate its installation. Even after cinching down, there is not full circumferential contact between the.U-bolt and the pipe." .(Emphasis added.)
In addition, as has been pointed out by CASE Witness Jack Doyle (see CASE's Answer to Applicants' Statement of Material Facts As To Which There Is.No Genuine Issue'Regarding Consideration of Cinching Down of U-Bolts in the form of Affidavit of Case Witness Jack Doyle, at page'4): *
"The Applicants have proved by random sampling that there is no effective torque rate for the plant." (Emphasis added.)
29
- , -,--.-.,,,---,-r-,, - - , , . , , , . , . . , . - , - - - , ~ -. -
. . . . . . , _ - _ . . ~- _ . . . . . . , . . . .
As discussed in the preceding, Applicants did not have procedures to support Applicants' third alleged Material Fact (referencing Mr. Finneran's Affidavit at page 16).of the design practice being to have the U-bolts cinched down. But whether.or not there had been such procedures, I do not agree with Applicants statement that "there was no need to impose any restrictions on design practices pending ultimate resolution of these questions." Applicants have boxed themselves into a corner. After the' stability problem with these supports was j identified by Mr. Doyle, they decided to go along and cinch up the U-bolts, without any consideration of the consequences and without proper analyses to support their improper fix. At that time, according to their own FSAR commitments, they should have written an NCR, placed a hold tag on all affected supports, and made the proper analyses of this design change (which would have indicated that this was an improper fix) -- and they should have done all this before they actually went into the field and cinched down any U-bolts to improve stability. What Applicants did is clearly improper and contrary to their own FSAR commitments, ANSI N45.2.11, and NRC regulations (specifically 10 CFR Part 50, Appendix B, Criteria III, XV, XVI, for example). On pages 16 and 17 of his Affidavit, Mr. Finneran discusses the specific questions and observations which allegedly were under review in September of 1982. On page 17, under item 1, Mr. Finneran states that "during the compressive load cycle for this support, the crosspiece cannot slide around the pipe" because " sufficient friction 30
r. force will be developed to resist the sliding." But when the . Applicants performed a vibration test on U-bolts under a cyclic loading condition, they determined that " insufficient assembly preload will
=
permit the assembly to rotate about the pipe and also ualk axially along the pipe axis in either direction with respect to the location of the strut." (See Applicants' Motion for Summary Disposition Regarding Cinched-Down U-Bolts, Affidavit of Robert C. Iotti and John C. a Finneran, Jr. Regarding Cinching Down of U-Bolts, at page 27.) These supports which are on the main steam line contained a 1/8" gap between the pipe and the U-bolt. Obviously, these were not cinched down and the U-bolts did not have a preload. Therefore, based on the ., Applicants' testing, these assemblies would rotate about the pipe and walk axially down the pipe and are therefore unstable (i.e., unable to take the load in the intended direction). The comments made by Mr. Finneran in item 2 on page 17 are also without merit due to the testing performed for cinched down U-bolts. I believe that Mr. Finneran should have informed the Board in his Affidavit that the U-bolts would not have acted in the intended ) direction. He did not do this, although there is a clear contradiction in his statements in the two Affidavits. As the NRC Special Inspection Team has reported to this Board in the SIT Report, as stated before above, the Applicants had no pretorque : requirements for U-bolts prior to 10/8/82 (which occurred after Mr. Doyle's testimony had been given in the September hearings). In 31
O- O-addition, the SlT reported that a 1/16" diametrical gap is normally L provided to facilitate-installation. The Applicants have 380 supports
- which consist of the 'same configuration under discussion for the main
-steam supports (i.e., U-bolt and strut or snubber) which had no
~
pretorque requirements prior to October 1982 which the Applicants considered stable. These supports are now being modified by increasing the U-bolt preload (i.e., cinching the U-bolt down). Without this cinched down U-bolt to a minimum pretorque requirement, all these supports would be unstable, as the Applicants have demonstrated by their own tests. It should be noted that the preceding statements regarding testing are based on the assumption that Applicants' tests were correct and were. correctly done. However, 1 do not agree that this was the case, and I refer the Board to CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue Regarding Consideration of Cinching Down of U-Bolts in the form of Affidavit of Case Witness Jack Doyle for further details in this regard. Regarding Applicants' last sentence in Statement-7, it would appear that the Applicants were (and are) reluctant to admit that these supports were unstable. The Applicants apparently would like to have the Board believe that the only reason that they corrected this problem is to " improve their stability" and because the cinching up of a U-bolt : was "relatively simple and readily accomplished." They did not admit
. .that the reason they decided to cinch up the U-bolts was because the support was unstable.
32
n.- On page 18 of Mr. Finneran's Affidavit, he states that the
. cinching'up of the U-bolts was to " improve their stability." He could not then, and cannot now, quantify the degree of stability then or the amount of' stability achieved by cinching up the U-bolt based on the new
-Brown & Root procedure for torquing of the U-bolt which was discussed in the preceding.
Further, the NRC Staff's understanding (and the Board's and other parties' understanding because of the testimony in the proceedings) was
~
that Applicants were gcing to assure that each and every unstable support was made stable, as indicate'd in testimony by NRC Staff Witness Dr. Chen (Tr. 6719/7-6720/11, emphases added):
" JUDGE McCOLLOM: Now, the Applicant is said to be committed to looking at these unstable supports as a system, to see if they are indeed stable; is that correct?
" WITNESS CHEN: Their actions, I'think, will ensure that. In fact, what they are doing is they are looking at each pipe support now, and making sure that in and of themselves they will be stable --
" JUDGE McCOLLOM: 'Each' individual pipe support?
" WITNESS CHEN: The box type, yes, nonrigid box type supports.
. Those are the only ones outstanding that I'm aware of for this problem.
"With regard'to the U-bolts, there was no rotation, and hence no loss of function, if you wish, that kind of support. The box frame kind of supports, though, could have this problem, and they are committed now to remedying those.
"That action, I think, will be sufficient to ensure that the entire piping system will be stable.
" JUDGE McCOLLOM: Will all individual pipe supports also be stable?-
33 m
c..
. , -- 7.-
" WITNESS CHEN: That is correct.
" JUDGE McCOLLOM: ;And was the iterative procedure that the Applicant was using, would it have caught these even if we had not been notified of this, if you wish, by Mr. Doyle?
" WITNESS CHEN: Yes, I believe so.
"JGDGE McCOLLOM: You now believe that there is in place a system to remove all these instabilities?
" WITNESS CHEN: Yes, that is correct."
Certainly it was the Board's understanding that Applicants were going to' assure that each and every unstable support was made stable, as reiterated by Judge Bloch in the October 1983 hearings (Tr. 8880/17-20):
". . . at the last hearing 1 thought we understood the Applicants had undertaken to eliminate any instability that might exist in an individual support -- not only system basis, but on an individual support. . ."
~
There is another important aspect of this of which the Board should be aware regarding the lack of documentation supplied by Applicants with their Motion for Summary Disposition. NRC Staff Witness Dr. Chen testified at Tr. 6720/18-6721/14:
" JUDGE McCOLLOM: There was some earlier testimony from Mr. Taylor about his reason for believing that the iterative process would
. pick up all the problems.
"Dr. Chen, as I remember, Mr.'-Taylor was particularly impressed by
.the quality of the people who would be participating in the last
~
review.
"What are the factors that led you to believe that -- do you believe all of these mistakes would be picked up, or just that this group would do a very good job of it?
" WITNESS CHEN: I believe that all -- most of them would be picked
.up.
i 34 11 o
,o a I
" JUDGE-BLOCH: As a scientist and engineer, you have difficulty in even getting the word 'all' out of your mouth, don't you?
" WITNESS CHEN: -That,is correct.
~
" Based on two things, if I may. Our review of the hundred vendor certified supports did not indicate that there were any problems
~
there.- And secondly, l'have seen, I believe, Notes coming back
'from Gibbs & Hill to the designer saying that-there are unstable supports which need to be fixed." (Emphasis added.)
The~ notes-to which Dr. Chen referred were not attached to
-Applicants' Motion for Summary Disposition. In fact, there is no
. documentation which has been'provided by Applicants where they actually
~ admit that there definitely,-positively, really are supports which are unstable. If such. documentation actually exists (as indicated by Dr.
Chen),. Applicants should have provided it.
- 8. Applicants' state:
" Applicants identified 15 of.these types of' supports in Unit 1 and common areas.- Thirteen of these supports are mainsteam supports.
Three of the mainsteam supports were actually modified during initial installation in such a way that the potential instability was removed. These modifications occurred prior.to September, 1982. The remaining
. ten mainsteam supports were_ modified between January, 1983 and June, 1983. The two non-mainsteam supports were modified in October and December,-1982. The modifications consisted of snugging the U-bolts or adding supplementary structural steel that would prevent-the-rotatf.r,
~of the U-bolt ~ clamp assembly.- (Finneran Affidavit at 18.)"
As. Applicants have stated,Jthey only identified 15' supports in Unit 1 and common areas; they did not mention how many supports in Unit , 2 were identified or even that they had looked at Unit 2.
.Regarding Applicants'-first and second sentences, they are
' assuming'that only those supports which indicated a gap between the U-35
~ - _
F ]
- . . 1 s.
bolt.and the pipe were unstable. As mentioned in answer 7 preceding,
'all'of the supports utilizing a U-bolt were unstable becauce of a 1/16" jdiametrical gap which-was uced to facilitate construction. Therefore,
?the Applicants' identification' process was in error.
Regarding' Applicants' third and fourth sentences, there is no documentation attached to Applicants' Motion to support these i< istatements.- In addition, Mr. Finneran, in his Affidavit, does not cite any transcript reference where he stated this during his September 1982 testimony (and it would be assumed, he would have done so), nor does he
; cite any-reference'in the SIT Report which so indicates. It appears that,'at the time he testified in September 1982, these supports had not been. identified by Applicants as being unstable, and that if they were modified so that the potential. instability was removed, it was by accident.
If these modifications that occurred prior to-September 1982 were by removing the 1/8" gap between the U-bolt and the pipe which is needed=for radial expansion of the pipe, I would assume that the construction was'not in compliance with the drawing or that the field
. engineers were ma'ing k modifications to the support and not considering the effects of cinching down a U-bolt.
Another possibility which may be the. reason the Applicants are
. claiming the support is stable is by assuming that the strut or snubber :
binds up at the base plate, as:was discussed during the May 1983 hearings by NRC Staff Witness Dr. Chen (Tr. 6730/15-6734/18), regarding CASE Exhibit 819, pag'es 2 and 3 (bound in following Tr. 6723). I do 36 =- _.
. o not agree with this assumption, based on two points. As indicated in the cited transcript pages, the binding plates are not symmetrical because there was a S/8" gap; one of the plates was 5/8" further from the centerline of the strut than was the other plate.
~
In addition, this binding action would induce additional stresses within the strut - due to bending which had not been accounted for the in the original design, and struts are not qualified for bending, only for an axial load. In sentence 5 and the last sentence, Applicants state that the
" remaining ten mainsteam supports were modified between January, 1983 and June, 1983" and that the " modifications consisted of snugging the -_
U-bolts or adding supplementary structural steel that would prevent the rotation of the U-bolt clamp assembly." (The supplementary structural steel is also referred to as a " bumper.") Apparently four of these ten relied upon bumpers for stability, as indicated in the Cygna Phase 3 Report, Observation No. PS-02, Sheet 1 of 1: -
"The stability of four Main Steam supports is maintained by =
providing horizontal ' bumper' frame members to limit the support horizontal movement to approximately 1/8". There was no derivation of design load for these ' bumper' frame members, nor were there any design calculations. The remainder of the support was designed properly." Under "4.0 Potential Design Impact" (same page), the Cygna Report ._ states: -
" Failure of the ' bumper' frame members may prevent the support from performing its intended function."
37
?,? is k ,
' And on~ Atta' c hment A of Observation PS-02, Sheet 1 of 1, "1.0 Probable'Cause,"-Cygna states:
-" Project personnel' (refe cence' 3.5) directed designers not to T
perform calculations for the bumper' frames." (Emphasis added.) See Attachment I hereto,_-which is a main steam support with a
' bumper frame.-
.There are several pointe I want to make regarding this. First, if
~
^
the U-bolts are"cinche'd up,-the bumpers will act as a horizontal restraint, and this was not considered by the Applicants-for this.fix. The second comment I would like to make is that because there is a
.1/8" gap between thefeross piece member and the bumper, the bumper does-not provide a sufficient mechanism for rotational ~ restraint such that the support would be considered stable for the vertical' load condition,
- which it was intended-to do. My position was also concurred in by the NRC Staff's Mr.ITerao in his discussion with the Applicants during the 8/9/84 meeting withL the Applicants and NRC Staff-in Bethesda, excerpted
~
.from Tr. 6 through 11:
MR.' TERA 0: LWell,- I think my position.is still- my-position still, on this restraint is, because of the gap in there, going back'to my criteria so to speak on whether or not that clamp is functional, if we can't-rely on the clamping function around the pipe then 1 am not going to allow credit as a seismic restraint even in the vertical direction. But, what I am saying, because
~
your analysis show that you don't even need this restraint for a seismic then-1 have no problems with you using this restraint for a weight tender. But, I would.not approve the restraint for a seismic restraint in the vertical-direction. :
". . ..It's not clamping.. There is no positive clamping force
~ developed between the pipe and the support.
" . _ . . My problem is still that analytically-it is very difficult
,._ to show what will happen to that pipe during a seismic event
- without some type of testing or without some type of nonlinear analysis-to conclusively show what will happen.
38
~
J
". . . the problem is that it is not a controlled mechanism for assuring the stability of that,- of the clamp around the pipe."
"MR. IOTTI: . . . We only have two of these?
"MR. FINNERAN: Two that don't have a cinched U bolt."
"MR. TERAO: . . . My disagreement is whether or not you can analytically prove it and whether or not this restraint will then negate your linear analysis that you run in your typing (sic) analysis.
". . . The disagreement is whether or not you can analytically show it and whether or not your analysis is valid. Whether you can rely on your present analysis to show that this restraint is going to conform to that analysis."
One reason this is significant is due to the procedures utilized by the Applicants. The pipe support designer is required by the ASME Code to provide a stable support, as discussed in answer 1 preceding. The designer did not fulfill this obligation, and now the Applicants are attempting to demonstrate that, although the pipe supports are not needed, the piping stresses are still within allowables (as will be shown later, this is an incorrect premise and they are needed). The pipe support designers do not qualify the piping systems; their job is to provide a support in the intended load direction. The Applicants, regarding this particular matter, are looking only at 50' of straight main steam line. If the Applicants had previously known that they did not need any pipe supports for this portion of the main steam line, it is not reasonable to believe that they would have gone to the trouble and expense of installing them to begin with; this is not logical, and it is certainly not sound engineering. 39 y 1.
7r ilt is also significant because the Applicants have informed the NRC~ Staff, as well as the Licensing Board, that the stresses within the pipe were below Code allowables. But that pipe stress analysis did not consider the mass participation factors, and as Cygna stated in the resolution of this item (Cygna Phase 3 Report, Observation PS-02, Attachment A, Sheet 1 of 1):
"Cygna has not reviewed these calculations as yet, since these piping' systems will be affected by the results of the Gibbs and Hill mass participation study (see Potential Finding Report PFR-
'01). Cygna will review the_new results for these four lines when they are available."
Of additional significance is the fact that, as indicated in the
-preceding from Attachment A of Observation PS-02, Sheet 1 of 1, "1.0
-Probable Cause," of the Cygna Phase 3 Report: " Project personnel L(reference 3.5) directed designers.not to perform calculations f'or the
' bumper' frames." _( Emphasis added.) Without these calculations having been performed (as discussed by Mr. Terao of the NRC Staff in the portion quoted earlier), Applicants cannot analytichily show whether or not their analysis is valid, and they cannot rely on their present
. analysis _ to show that the restraint is ' going to conform' to that analysis.
Applicants' repair for the majority of these supports has been
~c inching down of the U-bolts. This now creates a problem for the pipe stress analyst, if he realizes that it was cinched down; he needs to know to what amount, so that he can add the additional stresses to the pipe stress already calculated, if he cares to address it. The cinched down U-bolt will increase the stresses within the pipe, which has not been adequately addressed by the Applicants.
40 F
7 v 45 . 4
.9-'
It should~be noted that Cygna did not consider the erroneous use of burpers to provide stability to be a problem (much less a Definite
^V , Je Potential: Finding-Report) and considered this closed (as indicated in the Cygna; Phase 3 Report; Observation PS-02, Attachment A, Sheet 1 of
~1,' .
under-2'.0' Resolution).-
~
'Astindicated in the preceding, two o# these supports were not
, originally cinched down and two of them were cinched down later, and
.all four of them relied upon the bumpers to provide stability -- an improper fix. Since the 8/23/84 meeting between the Applicants and the Staff, the Applicants have again modified these four main steam g, supp' orts. As stated in Attachment E hereto (Applicants' answers to' the'S'taff on stability), page 53, item (f):
. Question: '?( f) Describe any proposed modifications to the main
-steam line supports which have limiting bumpers."
. Answer: "These supports, of which there is one per main steam
..line,.will.be modified:by assuring that the U-bolts are cinched
, and enlarging the; gap between the bumpers and the supoprt proper so that contact with the-bumpers cannot take place. This gap
. enlargement will be accomplished via~ removal of the bumpers.or cutting of a portion of it, whichever can be most expeditiously-1 accomplished."
This now means_that.the. statement'in the Cygna Phase 3 Report y f(Observation No. PS-02, Sheet 1 of 1, as quoted above) that "The stability of.four: Main Steam supports is maintained by providing Lhorizontal ' bumper' frame members.to;11mit the support horizontal
- movement to,approximately 1/8"" is no. longer valid.
t
- + -.
41 4 :7 : .. __)
54 _ ,
,,L
{e: , m
+
ThusitApplicants utilized;an improper fix (the use of bumpers) to 4
= .2
' correct-instability.-- then turned around and utilized another-improper fixl(cinching'down'offthe.U-bolts) to correct _that original improper fix - .all without having ' performed proper and necessary: calculations and. analyses lin a: timely manner as required.by;NRC regulations and Code fand 6ther: requirements.
In addition,-at1the time Applicants wrotd their Motion for Summary-n
~
- Disposition,.they were not aware'that they had made an improper fix in.
regarding1to the use of bumpers.' After the Applicants-became aware of
;this improperLconfiguration, they'did not inform'the Licensing. Board
'and.have~not changed their' Affidavit or th'eir Motion.
^
RIt is also~myLunderstanding that Applicants-have claimed to the 1 IBoardLand parties thatlthis was:an " insignificant" change, and that- .
.this was part of thejinformation to which Mrs. Ellis~ called the Board's
' attention;(because Applicants h'ad told the. Board-that there was nothing
!significant'in the information-they would be providing to'the-Staff as-
'a result of the;8/23/84'onsite meeting b'etween Applicants and NRC.
. e Staff). 'This " insignificant" change amounts to 40%=of the supports under discussion beingtimproperly fixed. -Four out of the. ten supports
, r.
- had to be ' modified. :-(This is not to say that their latest fix is
; iproper, and it in~ fact is alsofimproper.) ,
'P
'In' Applicants' next-to-last sentence they state that the "two non-mainsteam supports were modified in October and December, 1982." One s
c ' , 42 L - - -
m e of the.two supports which'the Applicants claim was modified is Support
-SB-1-101-001-A55R. .There are two'significant items which are evident from the documents Applicants provided CASE on discovery (see I
Attachment;H hereto). CASE requested from the Applicants the drawing which made the support unstable and the drawing which corrected the instability. .For this support, the instability was created in August of 1982. This'was one month after I had testified to the Licensing
. Board-that there was a problem with instability of pipe supports at Comanche Peak. The Applicants claim that the support was modified in October or December, 1982. The drawing which Applicants provided CASE , as being the one which corrected the instability is dated 2/22/84 (see Attachment H hereto)..
The other support is CC-1-048-007-A33R (see Attachment G hereto), and' Applicants also claim that this support was modified in October or December, 1982. This support was made unstable in June of 1980. But the drawing which Applicants provided CASE as being the one which corrected the instability is dated February 10, 1983 (see Attachment G hereto). It appears that one of three things must have occurred: (1) The statement in Mr. Finneran's sworn affidavit is incorrect; (2) the
~ documents provided to CASE on discovery were incorrect; .or (3)
Applicants made this fix without documenting the change on their component modification cards or drawings (or whatever other way they might have documented it). 43 O --
3 ., -.- l
. (9. ' Applicants' state: -
, - " CASE has ral' sed allegations'concerning the stability of two other categories.of supports, namely, double. strutted frames and single struts or snubbers with snug U-bolts. Applicants' review of the double
' strutted frames shows that the friction forces associated with these frames are sufficient to prevent the frame from sliding down.the pipe and,-thus,;to maintain stability. Applicants' extensive tests and (analyses of_the single struts or snubbers with snug U-bolts demonstrate thatlthese. supports will. function as pipe clamps and prevent rotation of'the clamp assembly around the. pipe. Thus, this category of supports
'is also' stable. (Finneran' Affidavit at 19-21.)"
I disagree with Applicants' statements. Regarding double strutted
' frames, the Applicants are relying on a friction force and have s sm provided in_the their Affidavit an erroneous calculation (page 19 of Affidavit). This calculation and its results are all based on a static
- loading _ condition; the' actual loadings are dynamic in nature. For example, if one were to' drive a car down a gravel road, the car can sit still and the rear end will not move sideways. But as the car begins to move at a higher rate of' speed, the rear _endlof'the car will begin to swerve to one side or the other of the crown of the road. A similar situation occurs.when. driving on snow or ice. As long as the car is-sitting'still,'it will not move sideways. But as it begins to move, t the rear end will try to' slide off the road. The Applicants' testing regarding the cinched down U-bolts verifles this phenomenum. As the
-Applicants demonstrated-in their cinched down U-bolt testing, under a dynamic' load even under preloading on the holding item so that there is ,
a positive: clamping force, the support walked down the axis of the pipe. (See Affidavit of CASE Witness Jack Doyle, attached to CASE's
- 1:
44-4
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+
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110/8/84. Answer to-Applicants' Motion for-Summary Disposition Regarding
.m + -
'F'
'ConsiderationoflCinchingDownofU-Bolts,fincluding;especiallypages _
03, 4,[101and 11'; see also Applicants' Motion for Summary Disposition
~
J
,, ~
Regarding Cinched-Down U-Bcits, Affidavit of Robert C.'Iotti and John
~
- O -o 4
.C. Finneran,-Jr. Regarding Cinching Down of U-Bolts, at page 27; and
'see'also~discussioniin answer 7 preceding.)
-For th'ese double-strutted or. snubber-support configurations, the instabilityfoccurs from the. time a dynamic load is applied; the support will" slide along the pipe and-will not be able to resist the piping-s load 11n the intended direction.
1The stability of the double strutted snubber supports was also a
, ;;. concern of-G.-Abele in 1981, as shown in' Attachment A-2 to Applicants' fAffidavit. 10n pa'ge 24 the' bottom drawingLis of a double strutted.
1 support.1;This; unstable 1 support' configuration was a concern-to G. Abele.
, -~1n 1981,4 b ut.the Applicants did not address his concern until September
, -1982 b'ef, orethe Licensing Board. -
(In a related matter, the' Applicants in-the past have relied on no gap 1betwee'n the pipe and the; box frame-to provide stability (see Tr.
, .4943/24-4946/7).- At thisLportion of the transcript; the discussion was
.regarding CASE' Exhibit 669B, item 4-0.-
As shown on that exhibit, there'
.is a zero-inch gap between the pipe and box frame. As part of
_ Applicants' answers toithe-NRC--Staff's questions, Applicants provided L'rawings d for double strutted frames. .Of particular concern is drawing J SW-1-012-009-A33R, as shown in the attached portion from Applicants'
, 45
' ~ ~
[ : L*/ :e' .. ! m- , l a he , Attachment'F-10. . This is'the same support which was attached to
- +
- -
- , . Applicants' MotionLfor Summary Disposition.Regarding Consideration of
, ~ sFriction Forces in=the Design of Pipe Supports with Small Thermal r t [ Movements, Attachment A. 'As the. Board isz aware, this support was not capable ~of? resisting the_ friction load...Thisl support was already ill?
. due to problems with friction, then'the' Applicants:gave it the disease
, of instabilitys -In my' Affidavit. attached to CASE's Answer to Applicants' Motion;for Summary Disposition on~ friction,-in regard to
- the dimensionishown on'the~ drawing, I questioned whether a 1/16" gap existed as'shown on the drawing (see my Affidavit' attached to CASE's Answer, pages 11 and 12). In reply _to my' questioning of the Applicants' drawing,'Mr. Finneran stated in a sworn affidavit:
~
f, .
"The tube. steel is installed with a 1/16" clearance as indicated on th'e drawing." (Emphasis in the original.) -
- j
{ .
; The drawing to.which Mr. Finneran-was referring is Rev.-1 of the ITT (Grinnell drawing. The current drawing, which indicates a zero inch gap I (although Mr.' Finneran claims'there is actually a_1/16" gap) is Rev. 4-
'of the Brown &' Root drawing.-
This discrepancy leads to two significant-problems. One of these
, , yis that the-Licensing Board'cannot rely on the sworn affidavit of Mr.
Finneran if in. fact no gap exists. The other significant problem woeid be that,1f a.1/16" gap'does exist, the drawings on which the engineers . rely'are no good. The present drawing = indicates a zero inch gap, but
-there is'no way of knowing whether or not this has actually been v -
verified in-the field by'OC inspection or other properly proceduralized k
-46 e
, .-l--
~
;r. .:
4 methods.a me still do.not know whether or not there actually.is a 1/16" J gap.: LThi$ ~is the only. support which the . Applicants have implied that
.they actually went out and checked the actual support configuration in the, field,-and.this'did not correspond to the latest revision of the drawiag.
-The preceding takes on even more significance when considered in
- conjuction with the following portions of the transcript of the 8/23/84 onsite. meeting between the Applicants and the PHu: Staff (which would, Laccording to Applicants' counsel, generate no significant changes
~
, : applicable to' Applicants' Motions for Summary Disposition). This discussion; concerns the results of the inspection by the NRC Staff's
_Mr. Fair.regarding U-bolts acting as two-way restraints. Excerpted' from Tr. 56-61.(emphases adde'):d "MR. IPPOLITO: John was in the procss of completing his evaluation, and what he wanted to do is to apparently go look at what were identified as maybe eight or so of the most significant
< of:these U-bolts and just confirm that, yes, in-fact the plant is built as you have indicated.in your design and in your drawing.
He sent this morning with your people, and'the thermal agra-(sic),
+
whatever was-over-it, was' removed in front with John present. John made some measurements. And I would like to have John tell you_what he discovered while he was there. Did.you see all eight?
"MR. FAIR: Yes..
MR. 'IOTTI: John, are these the same eight that we have identified as the --
"MR. FAIR: -Yes. . .'These are the cases where you use U bolts for one-way restraints with the presumption'that they provided no
- lateral restraints to the piping system. There were the limited number which you identified in the affidavit.- The argument in the affidavit, the steps of the argument, went this way: there was a sixteenth of an inch gap' designed in'these U bolts. You identified eight of them where the total movement exceeded that 47 x2 L__
i ' . ,
,x
~.< *-
t- t n &
~
- one sixteenth of-an inch total seismic plus thermal. You did some
, ' ' sample re-analysis' seismic.re-analysis, assuming no gap present for-two'of'tho U bolts that had the largest total displacement, , - found no problem.with the piping analysis. Tested a couple of p ,
s sizes (of U: bolts,+ determine ~that they could take substantial lateral. deflections, and;then concluded that there was no safety iconcern with these seventy U bolts.- I have no problems with your technical:argumentsithat you-put forth. The only thing I wanted
'toldo,was to go out to theJfield and take these eight U bolt's and
~ confirm the" existence and nonexistencefof-these gaps. As_it turns
;out, when I:took the measurements this morning, the sixteenth of-
~
- antinch gap existed in the direction cf restraint and not in the
. lateral-direction. As a matter of fact, six out of the eight-supports I checked had-lateral: gaps less than one sixteenth of an-J ' inch, and only two of them had a sixteenth of an inch gap or
'better in the-lateral direction. ...
. "ER. IOTTI: 'I'm not sure I follow. What do you consider directional restraints? Directional restraint is up?
"MR. FAIR: : That's' correct.--
"MR. 10TTI: -Can'you resummarize it again? You said six out of
'eight had no gap laterally? _
"MR.-FAIR: 'Had lateral gaps less than'one sixteenth-of an inch, this is total lateral gap on'both-sides.
"MR. 10TTI: Right.That's the way it's stated here.
There.was'one that had'practially zero-gap in the-
~ ~
")m.~ FAIR:
lateral ~ direction.
"MR. 10TTI: That's total?
"MR. FAIR: Total. both sides. Therefore, I was unable to confirm
, that the sixteenth of an inch gapiexists on these U bolts. 1 . - I also: looked at the drawings as I was. reviewing these supports,'and the sixteenth-of an inch gap that.is.specified on t
- the drawing is in the direction of the restraint and not the-clateral-direction..
. 1 s
"MR. 10TTI: Which systems were they on? Do you recall? * -
"MR. FAIR: : Majority of them were componentLtooling (sic -- should.
be' cooling). . .
~~
l' . 48
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- n' v se q' Tp-9+-e e vwW^r4---*1-' t'$ ce *7 e *P-4 T----te-T-$-T--trwNW49 -er' m 'ta
~- - h - t.'
"MR. ,IPPOLITO': I think that's what John said was he had no problems w'.th your analysis, but'the plant apparently does not conform to your analysis.
"MR.' FAIR: LWell, I'm not sure that that's the case. ..
-. .. . Let me say I have two problems. One problem is that the summary disposition motion with it states chat there is a sixteenth of an inch gap, that leads me to the conclusion that the sixteenth ol'an inch gap was in a lateral. direction, and therefore, we were only concerned with eight total supports. We took a sample of the worst two and showed no problem, and I thought it was a pretty good sample. The second is in the basic assumption of. ignoring the lateral restraints. Now, if you do have a gap in there and it did exceed the movement, I have no problem with making that assumption. However, if the gap does not exist.there, 1 consider that a bad assumption even if it does not turn out to be a safety problem. I think that was a poor engineering practice. . .
. . . Let me state I only looked at those supports, those eight, which the movements were greater than one-sixteenth."
Regarding the 380 supports with single struts or snubbers.with snug U-bolts, see discussion in answer 7 (pages 28, 29, 31, and 32) preceding; see also discussion in CASE's Answer to Applicants' Motion
-for. Summary Disposition Regarding Consideration of Cinching Down of U-Bolts, Affidavit--of CASE Witness Jack Doyle. To briefly summarize, these 380 supports were unstable and could'not have been verified to be
. stable because there was no pretorque requirement, and even after
~
torquing there was a 1/16" diametrical gap. These supports which the Applicants have and still consider to be stable, have had their U-bolts all cinched down and reinspected -- still an inappropriate fix.
. 10. Applicants state:
"Almost all Unit 1-and common pipe supports (17,000-18,000) have been vendor. certified to date. A total of 27 supports for all of Unit 1 and common area safety-related supports were potentially unstable. f1/
(Finneran Affidavit at 22.) 49
uw-.---.c.----m--------.w-s.=
"f1/ This figure is consistent with Mr. Finneran's representation to the Bo.rd in an affidavit filed June 3, 1983, that only 21 of 13,681 supports certified at that time had been identified as potentially unstable."
The 27 supports referenced by Applicants does not include the box frame supports which were Exhibits F-1 and F-2 attached hereto (see discussion in answer 6 preceding). Further, the Applicants have neglected to consider the number of unstable supports in Unit 2. And they have not considered the 380 supports with cinched down U-bolts or the double-strutted frames, both of which were discussed in answer 9 preceding.
- 11. Applicants state:
"None of the potentially unstable supports identified by CASE present a safety concern. As explained above, two of the four categories of allegedly unstable supports were, in fact, stable. (Finneran Affidavit at 19-21.) As for the other two categories; the potential instabilities were detected in the normal course of the design process, and appropriate measures were implemented to address the condition.
Because these conditions were detected in the normal design process, no concern is raised for the adequacy of that process. (Finneran Affidavit at 9-18.) In addition, even if the mainstream (sic) supports were. considered to be unstable and uncapable (sic) of carrying seismic loads, there are no adverse safety implications. (Finneran Affidavit at 27-28.)" I disagree with Applicants' statements. With regard to Applicants' second sentence, I do not agree; see answer 9 preceding. In fact, all four categories of supports were unstable. With regard to Applicants' third and fourth sentences, I do not agree; see answers 4 through 8 preceding. The Applicants are relying 50
gv ,
. V t'
- on their " normal design process" _ to detect these unstable supports.
'They apparently are including, in the normal design process,
. allegations made to the Licensing Board which brought these problems to
.their attention, since their normal. design process at Comanche Peak had not' identified which supports'were unstable, how many supports were unstable, and they had not (in my-opinion) corrected any of the unstable supports prior to the testimony of CASE's witnesses in these
-proceedings.
As discussed in previous answers, Applicants did not take steps to
~ correct- the problems of . instability promptly. The instability problems at Comanche Peak were~ not detected.in the normal design process, because had the normal design process been working effectively, it would'not have allowed the problems of instability'to continue unidentified and uncorrected as long as they did. Clearly the " normal
._ design process" as implemented at Comanche Peak and on which Applicants are relying is inadequate. The normal design process which is normal.
to the industry does not allow field changes by "somewhat knowledgeable" engineers, and does not allow the support to be built
~and actually' existing in the field, and then have the original design organization perform calculations. analyses, and tests after-the-fact to try to make it appear that what exists in the field meets design requirements.
One reason this type of design process is unacceptable is that this puts the engineers to the task of qualifying substandard L 51 m - __ __
a . configurations. For example, Mr. Finneran is attempting to qualify the-double-strutted supports by use of static friction methods. The
- supports are already in existence in the field, and if the calculations were-performed prior.to the construction of the supports, the original designer:might have detected the instability problem (though whether they would have'or-not is questionable also).
' MESSRS. WALSH AND D0YT.E:
~
Q: Do you agreeLwith Applicants' assertions in the first and-last sentences,,that none of the potentially unstable supports identified by CASE present a safety concern, and that, even if the mainstream (sic) supports were considered to be unstable and incapable of carrying seismic loads, there are no adverse safety implications?
~ MR. D0YLE:
A: I certainly do~not agree. The facts are-that instability problems represent a gross concern for the design of Comanche Peak and are in violation of the codes and laws to which Applicants are committed. MR. WALSH: A: TI totally disagree with Applicants' statements. For-example, when Applicants omitted the main steam supports-from the piping analysis, the supports for the connecting 8" line exceeded allowables (see pages'27-28 of Applicants' Affidavit). The analysis which the: Applicants used.did not consider mass participation factors as was noted in the Phase 3 Cygna Report, Potential Finding Report PI-52
y ., r 100-05. Cygna's' Observation PS-02, Observation Record Review, Attachment'A, Sheet l of 1-(see discussion in answer 8 preceding), also E
. states:
". . . As stated'in the TUGC0 letter to Cygna dated July 12, 1984,
- TUGC0 has reanalyzed these four systems (AB-1-23A, B, C, D)
'"'...w'ith these supports. completely removed from the analysis. This evaluation results in no overstressed piping or supports.'
"Cygna has not reviewed these calculations as yet, since these piping systems will be affected by the results of the Gibbs and
-Hill mass participation stu'dy (see Potential Fiuding Report PFR-01).. Cygna~will review the new results for these four lines when they.are available.
" Based on the above TUGC0 response, and contingent on the favorable outcome of the mass participation study, this
; observation has no . impact on the design and safety of CPSES and is considered' closed."
Cygna closed _this item'because TUGCO's response indicated "no
-overstressed piping or supports"'(emphasis added). It is apparent that
- l. _ Cygna was not given the true effects of the analysis of the main steam system without the supports, and therefore their conclusions are based
;on false information. The mass participation factors, which were not included in'the analysis of the main steam line without supports, will 11ncrease the strcsses within the pipe and increase the loads on the adjoining supports.
I have not seen the calculations which the Applicants should have provided to support their position that the stresses were within
~
m -allowables for the containment penetration and moraent restraint; but the Applicants have, in:the past, have utilized improper design and 4 53 L __
5 .
, c.
-m
;p- _ ',1 -
",; ( > , e r
;; calculational methods to qualify supports (as' discussed in CASE's-n
~
U;- [
'l Answersito Applicants' Mot 1ons for Summary Disposition on AWS/ASME (De' sign);/A500' Steel;; damping - OBE'/SSE;1 friction; generic stiffnesses; g.
-l-Richmond inserts; local displacements; and axial restraints). The
'Boafd cannot rely on Applicants' answers 1without supporting
. documentation (with the opportunity for review by CASE).
~
F
'12.: Applicantsjstate:
~s p ~
_ ', ;" Forces and moments, including static and dynamic loads, provided by
,, 'the: pipe design' organizations at the. node' points of these supports were-considered by the pipe-support design groups. (Finneran. Affidavit at
_22-24.)" b4 .This statement was in response to the first two Board questions' posed byLthe-Board in its 2/8/84 Memorandum and Order (Reconsideration
~
Concerning Quality Assurance for Design):
-(1) "[W]hether,the forces and_ moments indicated by the initial
_ -pipe ' run analysis were met by the pipe design groups at the node points to which these supports were attached." (2)L [W]'hether all' required static and dynamic forces were-
, , ' considered."
The 13 main: steam' supports referenced by Applicants did not consider'th'e forces which'would induce instability; i.e., a compression i force. -All; field modifications-to the remaining-14 unstable' supports % referenced by Applicants should never have been allowed to become
?
I _ . unstable. If the Applicants had.followed ANSI N45.2.11 and.10 CFR Part l
'50, Appendix B,-Criterion III, these supports would have been-commensurate with the original design and would not have been allowed to become' unstable.-
A
-54
~
= .
ii. __
m- , E In regards to' the dynamic forces, the Applicants are still neglecting the dynamic nature when it pertains to the box frames and
. double-strutted frames, as discussed in answers 6 and 9, respectively.
- 13. Applicants-state:
'"The conditions which could cause instability of the supports in . question.are unlikely to occur. (Finneran Affidavit at 24.)"
I totally disagree with this statement. This statement was apparently an effort to respond to the Board's third question in its 2/8/84 Memorandum and Order:
~
(3)- "[T]he nature of the instability, including the conditions under which it would exist and the likelihood of those conditions occurring."
.As discussed previously herein, Applicants are still refusing to even admit that any stability existed or exists at Comanche Peak. It
-is apparent that Applicants did not and do not understand the nature of instability, including the conditions under which it would exist (or how to correct it) (see, for example, discussion at page 24, answer 6 preceding). -And-if they do not understand these basic considerations,
.they cannot know the likelihood of the conditions occurring.
I 'Obviously, Applicants' statement cannot be true, since such conditions have occurred and in some instances still exist at Comanche Peak that we know about -- and there is no reason to believe that we
-have been able to identify ALL such instances where the problem currently exists but has not been identified by Applicants, the NRC Staff, or Cygna. (Also see previous answers herein.)
55
E _ . = N
- 14. Applicants state:
"Gibbs & Hill was provided as-built drawings of each pipe support along with as-built survey information that was marked on the drawings. It was not Gibbs & Hill's responsibility, as piping analyst, to review these supports for stability. (Finneran Affidavit at 25.)"
= These statements were apparently in response to the Board's fourth question in its 2/8/84 Memorandum and Order: = =
- (4) "[T]he extent to which Gibbs & Hill was provided with all the information about the performance of the support that they needed for the purpose of doing a revised pipe run analysis and a local pipe stress analysis."
1 disagree with Applicants' entire premise. First of all, it g appears that this is an effort to remove responsibility from Gibbs & E Hill and from Applicants for allowing these unstable supports to = develop, go undetected, and go uncorrected. And there was no documentation provided with Applicants', Motion for Summary Disposition y- to support their statements.
- 15. Applicants state:
"In that the support designer is required to maintain support stability by the ASME Code, there is no need for separate design guidelines regarding stability.
(Finneran Affidavit at 28-29.)" E This appears to be an attempt by Applicants to answer only the ~ first of two Board questions in its 12/28/83 Memorandum and Order i (Quality Assurance for Design) s' tu e 21: a
"(1) why design guidelcr. , t . cning stability were not r necessary."
5 1 do not agree with Applicants' statement. It is apparent that, E' since there was a problem and it was a historical problem at Comanche s F W Er 56 L
' '~
CE';~4 7, %' 3;f - [:g
- kL - :
a Phak, the. Code:Nad.to.be supplemented by Applicants through some kind
- of' guidelines. -These' guidelines would have brought to the designer's
~
~ and~ field ~ engineers' attention that stability of the individual members and the support: configurations is a vital'requirenent and more 3 attention needed to be place'd on it.- (Both-the original designer and-
~
s the; field. engineers should1have used the same guidelines, since.under JANSI N45.2.11 and~10 CFR Part 50, Appendix B,, Criterion III, design J f changes should,be commensurate with-the, original design.)
~
(In addition, guidelines are.whatJG. Abele was requesting in May o s 1981: and October 1982, 'not whethers the support was, stable or not; he
'apparently had already realized-that.the supports were obviously
. . unstable and;was asking for assistance in the form of guidelines.
-g t
h e It should be'noted that Applicants have: included'important statements in their Affidavit, wherein they. attempt to answer b _.;4 Jadditional' Board questions, which were not. included in their Statement Jof: Material Facts (see pages 26, 27, and 28 including the second of the Board's questions on'page 21 of its 2/8/84-Memorandum and Order). Regarding Board question.(5) cited on page 26 of Applicants'
" Affidavit:
'(5) -"[T]he reason that these supports were unstable." 5
. . . Applicants are stilll refusing to admit that any supports
.it
-vere, and are, in' fact unstable. Applicants' response to the Board's
- question is. inadequate. See previousidiscussions herein regarding our
~
answers to the discussions referenced by Applicants. 57 q
)
w W
Regarding Board question (6): (6) "[H]ow Applicant identified these instabilities and the process by which it resolved (or is resolving) them, including the paper trail of that process."
. . . Applicants (as stated above) still do not admit that there are any unstable supports. See also previous answers herein, especially answer 6 regarding the paper trail.
Regarding Board question (7): (7) "[T]he potential safety significance of these deficiencies."
. . . Applicants' answer that the unstable supports were detected through their design review process is a bunch of baloney. It is quite apparent that it was detected after Mr. Doyle and I brought these allegations to the Licensing Board. See previous answers herein, especially answers 7 and 8.
Another important comment is in regard to the main steam supports where Applicants state " Applicants and their design organizations believed that realistically these supports would function in a stable manner." (Emphasis added.) These main steam supports would not be able to support the intended load, as discussed in answer 8 herein, and as admitted by NRC Staff Witness Dr. Chen (Tr. 6725/20-26). It is unfortunate that the Applicants relied only on their " belief," rather than upon calculations, analyses, and/or properly performed testing. . It is unfortunate that the Applicants, instead of utilizing proper engineering techniques, were wishing their problems away. 1 believe that is how Applicants designed the entire plant, i.e., by wishing their problems away and pretending that they do not exist. 58
. v At the top of page 27, Applicants make the statement that "by
~
mutual agreement between TUSI and ITT, the supports were modified to i improve their stability." This statement proves my point discussed in answer 15 preceding that Applicants' guidelines and procedures for { dealing with the problems of instability were (and undoubtedly still _- are) inadequate and should have been supplemented. Further, from A Applicants' discussion at the bottom of page 26 and continued on page
; 27, it is obvious that -- even now -- Applicants would not have ever addressed this problem and would never have taken any corrective action f had the problem of instability not been brought up by Mr. Doyle and me, and had the Licensing Board not been concerned about it.
Regarding the second of the Board's two questions in its 12/28/83 [; Memorandum and Order (Quality Assurance for Design) at page 21:
~
. "(2) whether design deficiencies are corrected promptly."
gJ . . . it is obvious that the answer aust be an emphatic NO. See
': discussions in previous answers herein.
i- ?" With regards to Applicants' further statements on pages 27 and 28, see previous answers preceding. M= i I believe we have already addressed Applicants' statements in our preceding answers. It is my understanding that we are only required to
- Pe
} respond to the matters specifically stated in the Statement of Material I Facts. If, however, the Board decidcs to rule based on these O-
) statements by Applicants even though they are not included in their IT
_~ k sE 59 C;
e - r -y
-e . 5 l
+
-Material Facts, I would_like the opportunity to'further address any statements to which we have not specifically responded.
? ATTACHMENTS:
' Attachment A. 'FSAR Page 17.1-39, May 31, 1979 -- in effect prior to 7/11/83
-- see page 21 of this pleading
' Attachment B FSAR Page 17.1-39, Amendment 41, July 11, 1983 -- see page 21
'of 'this pleading
_ Attachment C FSAR Page 17.1-40, May 31, 1979 -- in effect through at least
'8/22/83 -- see page 21 of this pleading Attachment D FSAR Page-17.1-41, August 7, 1981 -- in effect through at least 8/22/83 -- see page 21 of this pleading Attachment E Pages 43-54, F. Stability section of information provided to Staff by: Applicants -- see page 23 of this pleading
.Attachaent-F1 . Attachment provided with Attachment E above -- see page 23 of this pleading Exhibit F1 Exhibit provided with Attachment E above -- see page 23 of this pleading Exhibit-F2 Exhibit provided with Attachment E above -- see page 23 of.
this pleading Attachment F10 Support SW-1-012-009-A33R, 2 page drawing, Rev. 4 -- see page 38 of this pleading
' Attachment G- ^ Support CC-1-048-007-A33R, 2 page drawing, Rev. 6, ar ,
Component Modification Card (CMC) No. 37607, R. 1, Sh.et 1 of ~ 2 -- see page 25 of this pleading
-Attachment H Support.SB-1-101-001-A55R, 1 page drawing, Rev. 5, and 1 page Component Modification Card (CMC) No. 77263, Rev. 1 --
see page 25 of this pleading Attachment I. Support. MS-1-004-003-S72R, 3 page drawing, Rev. 4, f rom Phase 3 Cygna Report, shows a main steam support with a bumper frame -- see page 38 of this pleading 60 L _
ww
; ', l; f 7 g L .~ .
f s The preceding CASE's Answer to Applicants' Statement of Material Facts j .- As To Which There Is No Genuine Issue was prepared jointly under the T personal direction of-the undersigned, CASE Witnesses Jack Doyle and Mark Walsh.- We ean be' contacted through CASE President, Mrs. Juanita Ellis, 1426 ' L 7 S. Polk, Dallas, Texas 75224, 214 946-9446. f
~
.Our qualifications and background are.already a part of the record in these. proceedings. .(See CASE Exhibit 842, Revision to' Resume of Jack Doyle,
. accepted into ev'idence'at Tr. 7042, and CASE Exhibit 841, Revision to Resume
.of Markt.Walsh, accepted into evidence-at Tr. 7278; see also Board's 12/28/83 Memorand'um and Order (Quality Assurance for Design), pages 14-16.)
.Wa- have read the statements therein, and they are true and correct to the best of our' knowledge and belief. 'We do not consider that Applicants
-have, in.their-Motion for Summary Disposition,. adequately responded to the issues raised by.us; however, we have attempted to comply with the Licensing Board's' directive to answer only the specif ' statements made by Applicants.
}
Cdd (Sigr#d) Jack Doyle .[ Date: $ $ _ STATE OF.
' COUNTY OF.
On this, the \\h day of , 1984, personally
~
appeared Jack J. Doyle, 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 the purposes therein expressed. -
Subscribed and-sworn before me on the \ b day of ~ __, 1984. b. c~ve A of
-My Conlaission Expires:
'Whf toMMISSION EXPIRES 3ANUARY 9,1987
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' ? -~ ,
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The preceding CASE's Answer tol Applicants' Statement _of Material Facts
- As To.Which There Is No Genuine Issue was prepared jointly under the personal direction of the undersigned, CASE Witnesses Jack Doyle and Mark Walsh. We can be.contacte'd through CASE President, Mrs.:Juanita Ellis, 1426 S.IPolk, DalL:c. . Texas' 75224, 214/946-9446.
Ourigt:::11fications and background are already.a part of the record in
- these proceedings. -(See CASE. Exhibit 842, Revision to Resume of Jack Doyle, accepted into evidence ~at Tr. 7042, and CASE. Exhibit 841, Revision to Resume
- of-Mark Walsh,Jaccepted into evidence at Tr. 7278; see also Board's 12/28/83-
- Memorandum and Order (Quality Assurance for Design), pages 14-16.)
i We have read the statements therein, and they are true and correct.to
- the best of our. knowledge and belief.- We do'not consider that Applicants
~
have,-in-their Motion for Suamary Disposition, adequately responded to the
. - issues raised by.us; however, we have attempted-to comply with the Licensing Bo'ard's directive.to answer only the specific. statements made b'y Applicants.
> ~(Signed) Mark Walsh
. STATE'0F' TEXAS
- :On this, the: / dayofl[ , 1984, personally appeared Mark Walsh,:k'nown to me to be the person whose 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 ne on the /Y day of , i
~ 1984..-
Nf Notary Public h and for the hh SAMUEL W. NESMe of Texas
- f. [-[~ **C' j Ex Commission Exp. ires
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My} Commission'Expirest '14145 ,
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- y .or rm.,. ym,,r.,., ,w._,.,%. ,,..,,,-# w%, , , . -..,.,wm,,,, .,_,,...re,. ,p.,% r,,,pg.,pw,,.,y_,r., ,n -.-,, -w.m.,,,,,p ,-+-
E - u Pr - CPSES/FSAR ATTACINENT A A nonconforma_nce report 'is utilized .for the identification, ,
' documentation, dispositioning, and verification of deficiencies in J
char.acteristics,; documentation, or procedures which render the quality of an item unacceptable or indeterminate. iAll' nonconfonning items are tagge'd and segregated as defined in section 17.1.14,:"Inspe:.:en and Test Status" and Section 17.1.13, " Handling,
. Storage, and Shipping." ~
Following identification _and dispositior.ing of nonconformances, specified reviews and approvals are procedurally required for 1) "use as is" and '" repair," and 2) rewo rk . " Upon completion of action: required for disposition, repaired or
. reworked . items are reinspected to verify that specified action and
- requirements are complied with.
! A Jeficiency report is utilized for the identification, documentation,
- resolution, and re-evaluat' ion of procedural violations /programatic deficiencies which are not directly related to-the physical charactristics of an item. Procedures provide measures which, when
- initi~ated, assure tnat' activities adverse to quality are suspended
.pending identification, documentation, and resolution. Proposed resolutions-are then reviewed and approved, prior to implementation, to assure that specified requi~rements are complied with. Impl emented .
resolutions.are re-evaluated to assure that the resolution has provided compliance with specified requirements.
- Procedures require " trending" of nonconformance and deficiency reports -
to identify' trends. adverse to quality. Procedures require the initiation of a-corrective action request for significant nonconformances/ deficiencies and chronically repetitive nonconformances/ deficiencies as defined in Section 17.1.16. p 17.1-39 MAY 31, 1979
, : ~ ~ ~ ~ ~ ~
~
CPSES/FSAR ~ ATTAC! MENT B Procedures define the actip,ns necessary to identify, resolve, and closeout deficiencies in characteristics, documentation, or procedures which render the quality.of an item unacceptable or indeteminate, t When required by specific procedures / instructions, items identified as
~
unsatisfactory or 1.ncomplete and which can be corrected within a reasonable period of time may be identified on an inspection report and/or. deficiency report. A nonconfcmance report is used to document 41 deficiencies unless another method is prescribed by a specific procedure /i nstruction. Items identified on a nonconfomance report are tagged and segregated where practical as defined in section 17.1.14, " Inspection and Test Status" and Section 17.1.13, " Handling, Storage, and Shipping." Following disposition of nonconformance reports, specified reviews and approvals are procedurally required for 1) "use as is" and " repair," and2) " rework." Upon completion of action required for disposition, repaired or reworked items are reinspected to verify that specified action and . requirements are complied with. l Procedures require " trending" of deficiencies identified on 4g I nonconfomance reports, deficiency reports, and inspection reports to identify trends adverse to quality. Procedures require the initiation of a corrective action request for significant or chronically repetitive nonconformances as defined in Section 17.1.16. 17.1-39 AMENDMENT 41 JULY 11, 1983
r CPSES/FSAR ATTACINENT C 17.1.16 , CORRECTIVE ACTION 2 TUGC0/TUSI requires that measures be established to assure that condi-tions adverse to quality are promptly identified, reported, and
. corrected. Responsibility for performing corrective action is assigned to' contractors, applicable subcontractors, and vendors so that each is alert to those conditions adverse to quality within his own area of activity. In the case of significant conditions adverse to quality, which are reportable to NRC under the provisions of 10 CFR Part 50.55 (e), measures are taken to assure'that the cause of the condition is determined and corrective action is implenented to preclude repetition.
Corrective action pro'c'edures placed in effect require thorough investi-gation and documentation of significant conditions adverse to quality.
- The cause and corrective action is reported in writing to the appropri-ate levels of management and to the purchaser. This corrective action applied is subject to review by TUGC0 and the prime contractor responsible for the original purchase specification.
For CPSES, the Quality Assurance Plan requires that procedures and practices be established and documented which provide assurance that conditions adverse to quality, such as failures, malfunctions, deficien-cies, deviations, defective material and equipment, and nonconformances, are promptly identified, do;umented, and corrected as soon as practicable, and that appropriate action be taken to correct the cause of the cordition. Corrective action documentation and request forms or formal letters are used to document the corrective action-related requests, responses, and follow up. The plan requires that measures be established by the prime contractors to assure that th.e acceptability of rework or repairs is verified by reinspecting the item as origina'lly inspected and that the reinspection is documented. These measures are verified by review and approval of the prime contractors' QA Program and by the subsequent audit for conformance to the approved program. Significant conditions adverse to quality are identified (such as those which, if they had remained undetected, would a MAY 31, 1979
I ! CPSES/FSAR l ATTACINENT D have adversely affected safety-related functions), the cause of the condition is detemined, and corrective action is taken to preclude
. repetition. Such significant conditions, their causes, and the corrective action taken are documented and reported to appropriat'e levels of management through established communication systems.
Corrective action followup and close-out procedures provide that corrective action commitments are implemented in a systematic and timely manner and are effective. t The occurrence and magnitude of deficiencies and nonconfomances requir-ing corrective action are evaluated by the purchaser's inspectors during surveillance and at hold point inspection and witnessing. Addi-tionally, these areas are identified for audit purposes. The effectiveness of the vendor's corrective action program is assessed during audits by the vendor, the prime contractor, subcontractor, and by TUGCO. Stop work authorit.y is exercised as required. 17.1.17 QUALITY ASSURANCE RECORDS The TUGC0/TUSI Quality Assurance program establishes procedures and practices to assure that TUGC0/TUSI and its contractors have a quality records system which provides documentary evidence of the perfomance of activities affecting quality. Procedures assure or shall require:
- 1. That records that are required to be maintained show evidence of performance of activities affecting quality. Typical records maintained include quality assurance programs and plans, design --
data and studies, design review reports, specifications, procurement documents, procedures, inspection and test reports, material certifications, personnel certification and test reports, audit reports, reports of nonconfomances and corrective actions, as-built, drawings, operating logs, calibration records, maintenance data, and failure and incident reports. 17.1-41 AUGUST 7, 1981
m - ATTACHMENT E F. Stability a) Provide the drawing for the one support having indexed lugs. Provide a detailed description of the reason why Applicants have determined that the specific indexed lug support cannot behave in an unstable manner. The drawings that show the details of the index lug support are attached as Exhibit F1 and F2. A discussion as to why this support is considered stable is provided in Attachment F1. b) Provide drawings for the strutted supports which are multiple frames, which are mentioned on page 19 of the Affidavit. There are four such supports in Unit 1 and common areas. Drawings for these supports are attached as Exhibit F3, F4, F5 and F6. c) Perform analyses which demonstrate that the triple strutted, multiple support frames will behave in a nanner not incommensurate with the assumptions made in the analysis of the supported piping and the design of the support proper. The pertinent support drawings for three of these four frames are attached as Exhibits F3, F4 and FS. Two of the frames are suspended from the ceiling at elevation 871'-7" of the auxiliary building with the third strut going laterally to a wall. The other two frames are in the electrical building and are suspended from the ceiling at elevation 871'-5", with the third strut also going to a wall, only the complex frame is shown (see drawing of support CC-1-144-701-E63R). The fourth I mums -mmimi
F W frame is extremely simple and any analytical effort on this frame would be clearly encompassed by the analyces of the first three frames. To determine that each of these supports would behave under a seismic-event in such a way as to not invalidate any of the
- analyses performed for the piping or supports Applicants have performed bounding analyses for each of the three supports.
These analyses assumed - the following: (1) During the earthquake the complete frame would move horizontally as if there were no piping supported within. Furthermore, no credit is taken for the third strut guiding action. This means that the frame moves as a pendulum. This assumption leads to the maximum possible horizontal displacement of the frame. In reality, the intsraction of the pipes with the frame, as well as the third strut effect, will 12.mit the horizontal deflection of the frame to a value which is less. (2) The possible axial movement is less than the " free" movement because of the presence of piping. This movement which occurs from simultaneous horizontal and vertical earthquake is assessed from a force balance where the instantaneous horizontal force created by superposition of maximum motion due to the horizontal earthquake and the horizontal component due to the E
7 y . -- vertical earthquake is resisted by the reacting force of the' pipe, and the corresponding vertical force is reacted by the pipe.and the struts. (3) The horizontal deflection-of the frame results in a vertical -(upward) deflection which would not have been
. considered in-the original analysis of the pipe. This vertical deflection can produce additional stresses in the pipes, which can be conservatively computed by
-assuming _that the vertical upward deflection occurs simultaneously with the maximum vertical seismic force computed for the pipes.
(4) The validity of the pipe analysis is assured (other
.than any additional contribution to pipe stresses from-(3) above) if the displacement is'within the tolerance limits assumed -in the original analysis or sufficiently
~
close to them so that the pipe analyst need not repeat the analysis. The three frames are modelled as simple-pendulums. The maximum horizontal displacement that the frames can have (in the absence of the supported pipes) is determined by computing the lowest frequency'at which the frame will respond, which would be that of a simple pendulum, and then determining the corresponding displacement from the tripartite charts provided for the floors of interest. For instance, the responses (displacement, velocity acceleration,) at Elevation 873.5 (the floor from which the frames are suspended) are provided for the SSE as Exhibit F7 'the L -
..-c o-worst of the two horizontal earthquakes at the low frequencies are shown). Obviously the _ presence of pipes will significantly affect-the calculated frequency and result in lower displacements.-
.The calculations and these results are. summarized hereinafterffor th three multiple support frames.
(i) Frame # 1. This, frame contains supports CC-1-041-710-A63R, CC-1-139-E - 706-A63R, CC-1-138-710-A63R and CC-1-144-707-A63R. All frames except that of CC-1-138-710-A63R have a 1/16" clearance at the top of the 4" pipes. The CC-1-138-710-A63R fran.s has no clearance, i.e. there is 0" gap on top and bottom.
!!odelling this frame as a pendulum of length 3.88 ft., the frequency of the pendulum is computed to be 0.458 Hz. From the tripartite charts the horizontal " free" displacement (free
.because it assumes that the pipes are not -present) is only available for 2% damping and is . equal to 7 inches. To compute the free displacement at the very low damping that a pendulum would have, which is here assumed to be 0.5 percent, the displacement at 2% damping is multiplyed by the ratio of displacements at 0.5% and 2% damping at a frequency of 0.25 Hz, which is available from Regulatory Guide 1.60. This ratio is 1.28.
- Similarly one can obtain the horizontal force of the pendulum from the product of its mass, which is approximately 400 lbs., and the acceleration at 0.458 Hz, which is 0.14g at 2%
b . j' damping, and is converted to the acceleration at 0.5% damping, by multiplication of the acceleration factor at 0.25 Hz obtained from R.G. 1.60 which is 1.4. The horizontal force is then 400 x 0.196g = 78.4 lb. 12He maximum " free" displacement would be about 9 inches. such horizontal displacement encompasses a rotation'of the pendulum.through 10.94 and this rotation would result in a vertical lift of_ the frame: equal to 0.846 inches. This vertical
' lift is- not possible because of the presence of the pipes, even when one assumes that the pipes are moving vertically under the influence'of she vertical earthquake component for a distance equalitoLthe.1/16" clearance, plus the vertical seismic motion at the support calculated by the stress analysis, which is small (4 .003"), plus the vertical motion of the mode shape away from the L node point which is assumed to facilitate frame horizontal motion-(rotation). The combination of these three vertical
' motions would only result in about 0.1" vertical pipe deflection.
Thus, the angle at which the frame makes initial-contact with the pipes (any pipe) as it . attempts to rotate is no larger than
.3.75 .
It is to be noted that to obtain that angle we have assumed that all frames have 1/16" clearance vertically. In reality _one of them has no clearance, hence the frame could not
.swir.g freely, or in other words the fundamental frequency of the frame would be much higher.
1To compute the maximum angle which the frame can rotate, four. occurrences have been examined. They are the following:
F
. l '. Pipe (s) impart a vertical ug force on the support (s) equal to the maximum ' computed by stress analysis;
- 2. LPipe(s)' impart tdue same force but downwards;
- 3. The support (s) impart a vertical. force upward (pull) on the pipe (s)- equal to f the maximum force of the stress analysis; and
- 4. The support (s) impart a vertical downward force (push) on the
' pipe (s) of magnitude as above. .
~ of.the four scenarios (1) and (4) are. essentially the same, and are bounding.
The angle of rotation that could be achieved by the frame if there were no hinge between the struts and the frame proper is
. computed by equating the vertical component of the total force (resulting.from the vertical earthquake and the rotation of the frame-caused by the' horizontal earthquake) which is carried by the pipes.to their bending resistance. The remainder of the force is carried by the struts.
The bending resistance is determined by modelling the pipes asfsimply' supported beams with a. total span length of 25'-6 1/4" loaded 10 '-9" from one of the ends. - The total vertical stiffness of'the four. pipes is thus computed to be 1498.4 lb/in. The angle computed in this fashion is 3.97 . To compute the resulting pipe stresses a single' pipe and a shorter span (20') is used. The stress thus computed is 1735 psi, which is acceptable. Under the assumption made that all frames have 1/16" clearances (which led to the angle of 3.97 to begin with), this rotation angle may not be the maximum that is possible. This is
y . g _ ~ y ,.g-- -
' y; [ because-the1 simultaneity of the vertical and horizontal motions (can;cause the frame to seize on its far bottom edge when the pipe
^
pushes downward ~and by} leverage on this -edge move its top in the same direction as the_ motion of-the overall frame. This'is permitted .by the. hinge between the struts and the frame. Next as
- the pipe' pushes.up (or the. support pulls) the contact can be
^
established;at the. opposite top edge while the bottom of the
. frame' swings in.the_same direction of motion as a result of 1 horizontal acceleration.
These alternating pivoting actions can result in a " walking" of - the fra.no -along the _ pipe. The extra horizontal' distance travelled in' this fashion can be estimated from the following:
- a. The distance per cycle is determined by geometrical considerations-(a 3" x 3". Tube steel: frame' supporting'4" pipes-with 1/16" vertical clearance),and is equal to 0.18. inches
- b. The total distance is the product of- the- distance per' cycle ~ times the number of cycles.
a
- c. The pertinent' number of cycles is that of the
. horizontal cycles which impart the force _necessary to move the
. bottom' portion of the frame away from the vertical. The vertical cycles would move the frame closer to vertical as shosn in the
. U-bolt cinching tests when frames aren' t allowed to rotate aroun.i the pipe. The total number of cycles is 0.458 Hz times the 30
^ second duration of the earthquake.
i-i I O _ _ _ _ _ . _ _ _ _ _ . _ _ . _ _ _ _ m-- - - - - - - - -
Thus, the extra distance is 2.60 inches, which when added to the horizontal distance corresponding to the angle of 3.94 (3.25 inches) gives a total horizontal distance of 5.85 inches, and an.
!overall angle of rotation of 7.16 .
The. horizontal distance of 5.85 inches would not invalidate the-Gibbs & Hill stress analysis. The moment and shear stresses which would occur as the frame locks about the pipe through an angle of 1.05 (during the walking) are also acceptable since they are 1544 psi and 430 psi, respectively. Since several conservative assumptions have been made in these bounding analyses, namely (1) gap of 1/16" in a frame where there is none, (2) no frictional resistance opposing
. axial motion of the frame, (3) motion of the frame computed as if it were a very low frequency frame (pendulum), whereas the pipes will influence its frequency response, and (4) the third strut has been neglected, the horizontal displacement and rotations that could occur during an earthquake will be smaller. Since stresses in the pipes are acceptable and even at the conservatively estimated horizontal distances from the previously analyzed points, Gibbs & Hill states that the stress analyses would not be affected, it is concluded that the support would fulfill the function required by the stress analysts.
(ii) Frame 2 This frame contains supports CC-1-041-711-A63R, CC-1-138-711-A63R, CC-139-707-A63R, and CC-1-144-708-A63R. All frames have a 1/16" clearance vertically.
m . j 1 .. The analyses for this frame make the same assumptions as for
.the prior frame.. Results.are somewhat different because of the differences in geometry. 1The " free" frame frequency is 0.53 Hz (this stems .from a pendulum length .of 2.94'), which results in a
~
maximum " free" horizontal displacement of 7.17"'and a " free" angle of rotation of 11.49 . Again, the' presence of pipes prevent this angle and displacement from being achieved. The resistance of'the pipes, computed as before, result in a rotation angle Lof 4'.'4 which would be the maximum if no " walking"
. motion occurredLalong the pipe because.of the clearance in the frame _ and the hinges between the struts and the frame. This clearance and the hinge permit a motion of 0.15" to occur 'per cycle ~(the horizontal motion of 0.15". differs from the 0.18" motion obtained for the previous problem because the frames are composed of 4" x'4" tube steel'instead of 3" x 3" tube steel).
Thus, .a. total horizontal' m'otion of 5.08" resulting in an angle of 7.19 could'he: achieved. For this support, -however, this will not happen.- Because of the location of the supports, the vertical stiffness of the pipes in this case is considerably
. higher:than in the previous case. For.this case the pipes have
'been modelled as simply supported beams 11'9" in length loaded l'-0" from the end. 4 The vertical stiffness is this 5.73 x 10 lb/in. With this stiffness, the vertical resistance of the pipes alone is'oufficient to arrest all further horizontal motion at an angle of'6.38 which corr.esponds to a horizontal distance of 3.95
-inches.
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Pipe stresses are acceptable and the variation in horizontal _ location of :the support does not affect previous stress analyses. tHonce,:it.is concluded that this-frame behaves as required by the
. stress analyst.
(iii);Framef#3. This1 frame contains supports CC-1-144-701-E63R, CC-2-144-L702-E63R and CC-2-139-701-E63R. All have 1/16" clearance vertically with the pipes. The analyses of this' frame are in all respects equal 1 to those conducted for frame 1. For purposes of computing pipe' stiffness.the pipes have been modelled as simply supported beams 20'-3 1/2" long, while to compute stresses the
~
span lengths reduce to 16'-311/4". The " free" ' frequency,
-horizontal displacement, vertical displacement rotation, and force are 0.442.Hz,,8.85 inches, 0.79 inches, 10.2 and 25 lbs, respectively.
The maximum rotation permitted by the pipes excluding
'" walking" of the frame is 3.75 , and when " walking" is included, that rotation is increased to 6 . The total horizontal distance is 5.26 inches. Conclusions for this frame are the same as for
- the previous two frames.
, Calculations that show'how the values given above have been
.obtained are attached as Exhibit F8.
(d)- Provide drawing package for the piping segment containing: support CC-1-234-Ol7-C53R. 17ue drawing package requested is enclosed as Exhibit F9.
(Y - (e) Provide drawings for each-rigid frame support on double struts or snubbers. . Provide a description of why the.zero gap 3- between the frame and the pipe. assures the stable behavior of the supports.
; .The explanation as to why.these supports are considered stable is provided in Attachment Fl. The drawings of these supports are enclosed as Exhibit F10.
( f) Describe any proposed modifications to the main steam line supports which have limiting bumpers. These supports, of which there is one per main steam line, will be modified by assuring that the U-bolts are cinched and enlarging the gap between the bumpers and the support proper so that contact with the bumpers cannot take place. This gap enlargement will be accomplished via removal of the bumpers or cutting of a portion of it, whichever can be most expeditiously-accomplished. (g) Describe-any support which does not fall into any other categories described in the Affidavit, but which may be susceptable to " instability" as defined during the meeting of
- 8/23 at the CPSES site.
- Applicants had already identified some mainsteam supports which were trapeze type supports carrying vertical load which have as U-bolt pipe attachment that has a clearance. Although , Applicants had judged these supports to be stable, the decision o
has been made to snug these U-bolts up during the U-bolt torquing
4 .i . .
.c.-
A . 1' < program _whic[ Applicants-committed-:to in their' Affidavit on cinched U-bolts. This' would eliminate. any concern for stability
- under the. current-definition.
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t Attachment F1 I y' l "T 1T 1
. ITTGrinnellCorporation
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, M WestExdengeStreet Movidena,MafeIdand0301 R[peHangerDivision Hall 91-All? September 14, 1984 .' Texas Utilities Services, Inc. P.O. Box 1002 Glen Rose, Texas 76043
~ '
Attn: J.C. Finneran
- h
Subject:
Texas Utilities Gen. Co. Comanche Peak Stm. Elec. Sta. Units 1 & 2 .. P.O. No. CP-0046-A
- ICN - 2104 Gentlemen:
As a result of your meeting on August 23, 1984 at the CPSES site with the NRC we wish to provide the following information relative to the stability concerns. For clearity first let us reitterate the definition of stability as it pertains to pipe supports. The lengthly definition is the following: Improper functionability (" instability") is the ability of the
, support to move to an unqualified position in the absence of positive controls. Dnqualified position is any position which violates the assumptions made in the piping analyses, and alternatively is a position which by reason of unquantifiable uacertainities becomes unanalyzable. Positive controls denote appurentances by which the support is prevented from undesired motion by intentional design of the appurentances as well as physical limitations in recognition of which the support designer need not design appurentances to prevent motion since the geometrical configuration itself assures the support cannot move in an undesired manner.
q' A e
, 9-14-84 Page 2 e
,- To:- J. C. Finneran - TUSI A. The supports to which the NRC refers are CT-1-008-007-S22K and 4 CT-1-008-008-S22K (see Att. A).
!* For subject' support to ' behave in an unstable manner, it must move to an unqualifiable position. Let's assume, for sake of argument, -
that maximum thermal and seismic displacements and rotations occur simultaneously causing the support to become out of plumb to its maximum possible position. This condition will then be analyzed to determine if it is, or could lead to, an unqualifiabic position. Fully unrestrained, maximum displacements and rotations are as follows (data provided by Gibbs & Hill). X = +.239" RX = .0035 rad Y = +.2504" RY = .0012 rad Z = .336" RZ = .0045 rad Note: X, Z,. & RY due to maximum thermal, only Y,RX, & RZ due to maximum thermal, SSE, and - seismic. . . , anchor motion (sum abshlutes). , First, a check is made Eo determine if the cumulative effect of vertical displacement and h.orizontal rotations could cause contact with the ceiling. The following calculation, verifies that the support frame cannot impact the ceiling. , An examination of a plan view of the support indicates that the southeast corner of the frame will displace in an upward direction due to the directions of rotations above. Maximum vertical displacement may be calculated by: Y = .2504 + (.0035)(12.5) + (.0045)(11.375) =9* Y = 0.345" 6 1.0" Acheckisalsomadetoseeifthetopofitem4kwhichisonly 1/2" from ceiling) could possibly impact the ceiling. Conservatively assume that RX = +.0035 rad., rather than minus thus, Y = .2504 + (.0035)(20.8125) + (.0045)(2.75) =7 Y = 0.336" 6 0.5" In conclusion the support frame cannot impact the ceiling.
- r. . ,
l' * ' \ l 9-14-84 page 3 To: J. C. Finneran - TUSI
^!
The following calculations are now made to find the maximum out of plumb configuration that the support can assume. I) CT-1-008-007-S22K, displacement calculated at southern rear bracket... X = +0.239" hY Y = +.2504" + (.0045)(14.25) =7 Y = +0.315" Z = .336 - (.0012)(14.25) => Z = -0.353" Installed condition, C-C begin = 32.25"
- i. C-C end = l(30.25 .239)2 + (.315)2 + ( .353)2]l/2 .a C-C end = 32.0145"
{ T = [(.239)2 + (.31512 + (.353)2jl/2 =7 0.530"
- e. ,
, By the law of cosines, y e+
COS 4 = (30.0145)2 = (32.23)2 - (.530)2 2(30.0145)(32.25) "4, . 6=0.8470 (Maximum Misa1ignment) . .C c Q" " 4,gg . II) CT-1-008-008-S22K, displicement calculated at eastern rear bracket... X = +.239 + (.0012)(20.8125) = > X = +.264" Y = + .2504 + (.0035)(20.8125) = 7 Y = +.323" Z = .336" Installed condition, C-C begin = 21.8125" C-C end = [(21.8125 .338)2 + (.264)2 + (.323)2jl/2 7 C-C end = 21.481" T = ((.264)2 + (.323)2 + (.336)2jl/2 = T = .536" p By the law of cosines, d COS $ = (21.8125)2 + (21.481)2 - (.536)2 pY 2(21.8125)(21.481)
'h=*1.9880 (Maximum Misalignment)
T 4 b
- l :.
9-14-84 l page 4 To: J.:C. Finneran - TUSI - For CT-1-008-007-S22K, this value is 0.8470, for CT-1-008-008-S22K it is 1.9880 Assuming a 20 skew on '
' CT-1-008-008-S22K, .aus additional 248f of force could be introduced
, into the piping / support system. The Y-component of this force must be taken up by the frame and pipe; the horizontal component willibe shared with CT-1-008-008-S22K.
For conservatism, assume a 5% increase in stresses for both supports due to the " kick load". Review of the support calculations show the three maximum stressed areas to be reviewed: Steel (item 10)... 75.7% Weld at baseplate... 69.3% Hiltis (by FUB)... 51.0% Hence, as expected sufficient design margins exist to account for worst case considerations. 7 Cibbs and Hill ha's informed us that pipe stress at the support location based on unrefined response' spectra are as follows: Eqn.'8:f= 678 psi <? 15,000 psi
-Eqn. 9(Upset):: = 2779 psi Egn. 9(Emerg): = 3683_ psi.c 18,000 psi Eqn. 10: = 1553 psi e. 21,000 psi Eqn. 11: = 2233 psiic 36,000 psi Additionally, consideration has been given to the local stresses induced by the lugs. These stresses are negligable.
In conclusion, based on a thorough review of all factors, adequate , positive controls exist to assure that the support cannot move to an unqualifiable position, and therefore is considered stable for all loading conditions. B..The mechanism for improper functionability (instability) for rigid frame supports with double struts is an out of plumb alignment of the frame down the axis of the pipe. For this to happen, the frame must " walk" down the axis of the pipe a sufficient amounc such'that the support assumes'aut unqualifiable position. i l s L. _ :. _ - _--___: . _ - _ . _ _ - _ . - _ _ _ - -
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9-14-84 1
- Page 5 -
To: J. C. Finneran - TUSI F i With zero gap existing on the frames, the frame cannot displace ' axially relative to the pipe unless two events occur , simultaneously: , (1) The frame slides down the pipe (since the pipe is assumed to have sufficient axial restraint), and
.(2) The pipe displaces-towards the building structure in the t
. restrained direction an appropriate distance te accomodate ,
all of the pendulum action of the struts. For event (1) to occur, a sufficient axial force must exist in the frame lto overcome-the friction between_the pipe and frame. Any actual force applied to the-frame thru the struts will also exert a rotation or binding force to the frame which significantly decreases any tendancy for it to slide down the pipe In order for event (1) to occur event (2) must also occur because
.the struts are a fixed length and must swing the frame on an arc.
If the pipe could displace in this manor, it will exert a restoring force on the frame (due to the restraining effect of other supports up and down stream), which would add to the fictional effect of the pipe to the frame 9 ThisinformatioEwehopewillclearupanyconcernstheNRCstaffmay-have on this issue. iIf we can be of any-further assistance please do not hesitate to call , on us. Very truly yours, ITT RINNELL C . h D. E. PO'4ERS Engineering DEP/ng-cet 3. Hill - ITT Fld. Rep. K. Thornton - B&R-D.C. Frankum - B&R r J.W. Hare - Prov. R.'Heitsen - Houston S. Perreault - Prov. 2084c l-
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j-i SHEET 3 OF 3 REV. 4 { ' l CODE class -
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e x UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In'the-Matter of }{
}{
TEXAS UTILITIES-ELECTRIC }{ Docket Nos. 50-445-1 COMPANY, et al. }{ and 50-446-1 l(Comanche Peak Steam Electric. }{ Station, Unit's 1.and 2) }{ CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of
. CASE's Motions and Answer to Applicants' Motion for Summary Disposition
- Regarding Stability 'of -Pipe Supports
.have been sent to'the names listed below this 15th day .of . October - ,198jI, _
;by: Express Mail .where indicated by
- and First Class Mail elsewhere.
s
- Administrative Judge Peter B. Bloch *-Nicholas S. Reynolds, Esq.
U. . S. Nuclear Regulatory Commission . Bishop, Liberman, Cook, Purcell 4350: East /Wes't Highway, 4th Floor & Reynolds Bethesda, Maryland 20814- '1200 - 17th St., N. W.
- Ms. llen Ginsberg,-L jawleff~
'U. .
S. ear Regulatory Commission
- Geary S. Mizuno, Esq.
4350 East /We ighway, 4th Floor Office of Executive Legal
--Bithesda, Marylan '
814 Director U. S. Nuclear . Regulatory
- Dr. Kenneth A.'McCollom, Dean Commission Division of Engineering,- Maryland National Bank Bldg.
Architecture and Technology - Room 10105'
'. Oklahoma State University 7735 Old Georgetown Road LStillwater, Oklahoma 74074 Bethesda, Maryland 20814 4
- Dr.' Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel Oak-Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission
~
- Judge Elizabeth B. Johnson .
. Oak Ridge National Laboratory P. O. t Box X, Building 3500
-Oak Ridge, Tennessee 37830 1
4
j, . -v;: 4; '
;Ch' airman . .
Renea Hicks, Esq.
' Atomic Safety and Licensing Appeal Assistant Attorney General
- , ; A Board Panel' Environmental Protection Division f;U. S. Nuclear Regulatory Commission: Supreme' Court Building
-Washington', D.' C.. -20555' ' Austin, Texas. 78711
' John' Collins Regional-Administrator,. Region IV
, U. S. Nuclear; Regulatory Commission.
'611 Ryan Plaza Dr., Suite 1000 '
- Arlington, Texas - 76011 -
Lanny;A. Sinkin: c 114 W.;7th, Suite 220
' Austin,'. Texas 78701 Dr. David H. Boltz 2012 S. Polk Dallas,' Texas 75224 Michael:D.-Spence, President
~ Texas' Utilities Generating Company Skyway Tower. ..
.400 North Olive St., L.B. 81 Dallas,-Texas 75201.
Docketing and Service Section , . c(3 copies).s-10ffice of the Secretary-U. S.' Nuclear Regulatory Commission
. Washington, D.~ C. 20555 1
sj i wb AJ '
%)d'.J-JuanitaEllis, President CKSE (Citizens Association for Sound Energy) 1426 S. Polk
-Dallas, Texas 75224 214/946-9446 2-
- -.}}