ML20098F432

Affidavit of Jc Finneran in Support of Applicant 841001 Reply to Case Answer to Applicant Motion for Summary Disposition Re Differential Displacement of large-framed Pipe Supports.Certificate of Svc Encl

ML20098F432
Person / Time
Site:	Comanche Peak
Issue date:	09/28/1984
From:	Finneran J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20098F430	List: ML20098F429 ML20098F432
References
OL, NUDOCS 8410020731
Download: ML20098F432 (6)

Text

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.k OCT ~2 pg;;;3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00dI(7[,[jk'h!'W:O 3R f

. BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

-In the Matter of )

) Docket Nos. 50-445~and f} (,

TEXAS UTILITIES ELECTRIC ) 50-446 COMPANY, et

~ ~ ~ ~

al. )

) ~(Application "or (Comanche Peak Steam Electric ) Operating Licenses)

Statidn, Units 1 and 2) )

AFFIDAVIT OF JOHN C. FINNERAN, JR. IN SUPPORT OF APPLICANTS' REPLY TO CASE'S ANSWER TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION REGARDING DIFFERENTIAL DISPLACEMENT OF LARGE-FRAMED,.

WALL-TO-WALL AND FLOOR-TO-CEILING PIPE SUPPORTS I, John C. Finneran, Jr., being first duly sworn hereby depose and state, as follows: I am the Project Pipe Support Engineer for the Comanche Peak Steam Electric Station. In this position I oversee the design work of all pipe support design organizations for Comanche Peak. A statement of my educational 4

and professional qualifications was received into evidence as Applicants' Exhibit 142B.

Q. What is the purpose of this affidavit?

A. This affidavit provides information in support of Appli-cants' Reply to CASE's Answer to Applicants' Motion for 1 Summary Disposition Regarding Differential Displacement of Large-Y'ramed, Wall-to-Wall and Floor-to-Ceiling Pipe Supports.

1 8410020731 841001 PDR ADOCK 05000445 O PDR

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. O. In-his Affidavit, Mr. Walsh alleges that in 1982, Applicants J

informed the Special~ Investigation Team that there were no large-framed, wall-to-wall or floor-to-ceiling pipe suports designed by ITT or NPSI. Is this correct?

A. No. I was present during discussions with and made state-ments to the NRC Staff regarding this issue. It's obvious that we could not have made this statement to the SIT team, when I had already testified (Applicants' Exhibit 142 at 25) that there were Service Water support frames in a fuel building tunnel which also span from floor to ceiling.

These frames are items 17 through 24 on Attachmeat 1 to Applicants' Affidavit attached to Applicants' motion for.

summary disposition regarding this issue. These frames were designed by 1TTs When asked this question by the SIT, we actually replied that we were not aware of other of these type supports other than what had been previously discussed or testified to. We made no statement that there were not any more. The only,way to know for sure would have been to review all designs.

Q. In his Affidavit, Mr. Walsh alleges that no PSE guidelines i

existed on design of large-framed wall-to-wall and floor-to-ceiling pipe supports prior to late 1981. Is this correct?

A. No .' Attached to this Affidavit is documentation signed by a

hanger engineer on 1-6-81, that he had added cer'ain pages of Revision 1 to Section II of the Engineering Guidelines-

.: o Pipe Support Designs.* Page 2-6 is also attached.

Paragraph 3.13.1 of page 2-6 concerns design of large frames. The above noted documentation demonstrates that Applicants not only had guidelines' prior to late 1981, but

.also that those guidelines contained information related to large framed wall-to-wall or floor-to-ceiling supports.

t Prior to the reorganization of CPSES in late 1981 that lead to the formation of PSE, the pipe support design group on l site was called PSDG (Pipe Support Design Group). The 1 attachment to this Affidavit is from the design manual for that group.

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$f John C. Finneran, h' ^ ,

.fre m o c rer ,

co v~ r y oe s .n w .c ~

[ r, Subscribed and sworn to before me this 21 d day of September, 1984.

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Notarf Public v v my cemn,ss,.a uriae s maca ag, i,n -

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DOCKETEL U$hRC 14 00T -2 M1 :13 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OfflCE : SEcnt 4

BEFORE THE ATOMIC SAFETY AND LICENSING BOAR 60CKETING & SEh r BRANCH In the Matter of )

)

TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445 and () (__

COMPANY, _et _al. ) 50-446

)

(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)

CERTIFICATE OF SERVICE

, 'I hereby certify that copies of " Applicants' Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Differential Displacement of Large-Framed, Wall-to-Wall and Floor-to-Ceiling Pipe Supports," in the above-captioned matter was served upon the following persons by express delivery (*), or deposit in the United States mail, first class, postage prepaid, this 1st day of October, 1984, or by hand delivery (**) on the 2nd day of October, 1984.

• • Peter B. Bloch, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. William L. Clements

• Dr. Walter H. Jordan Docketing & Service Branch 881 West Outer Drive U.S. Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C. 20555

• Dr. Kenneth A. McCollom Dean, Division of Engineering Architecture and Technology **Stuart A. Treby, Esq.

Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Legal Director U.S. Nuclear Regulatory Mr. John Collins Commission Regional Administrator, Washington, D.C. 20555 Region IV .

U.S. Nuclear Regulatory Chairman, Atomic Safety and Commission Licensing Board Panel 611 Ryan Plaza Drive U.S. Nuclear Regulatory Suite 1000 Commission Arlington, Texas 76011 Washington, D.C. 20555

-I Renea Hicks, Esq. *Mrs. Juanita Ellis Assistant Attorney General President, CASE Environmental Protection 1426 South Polk Street Division Dallas, Texas 75224 P.O. Box 12548 Capitol Station Ellen Ginsberg, Esquire Austin, Texas 78711 Atomic Safety and Licensing Board Panel Lanny A. Sinkin U.S. Nuclear Regulatory 114 W. 7th Street Commission Suite 220 Washi~gton, n D.C. 20555 Austin," Texas 78701 2  : .

Malcolm H. Philiprf Jr.

cc: John W. Beck Robert Wooldridge, Esq.

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