ML20100B288

Affidavit of Rc Iotti & Jc Finneran Re ASLB Inquiry Concerning Hot Functional Test Results

ML20100B288
Person / Time
Site:	Comanche Peak
Issue date:	12/03/1984
From:	Finneran J, Iotti R EBASCO SERVICES, INC., TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20100B282	List: ML20100B281 ML20100B288 ML20100B293
References
OL, NUDOCS 8412040275
Download: ML20100B288 (5)

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UNITED STATES OF-AMERICA j- NUCLEAR REGULATORY COMMISSION i

P BEFORE THE ATOMIC SAFETY AND LICENSING BOARD t

In the Matter of )

) Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC ) 50-446 COMPANY, ET-AL. )

) (Application for (Comanche Peak Steam Electric *

) Operating Licenses)

Station, Units 1 and 2) )

AFFIDAVIT OF ROBERT C. IOTTI AND JOHN C. FINNERAN, JR., REGARDING BOARD 1

INQUIRY CONCERNING HOT FUNCTIONAL TEST RESULTS l

y I, Robert C. Iotti, being first duly sworn hereby depose and '

state as follows:

I am Vice President of Advanced Technology for Ebasco Services, Inc.

A state:aent of my educational and professional l 1

qual i fica.tions ws: trousmitted*with Applicants' letter of May 16, 1984, to the Licensing Board in this proceeding.

I, John C. Finneran, Jr., hereby depose and state, as follows:

I am employed by Texas Utilities Generating Company as Project Pipe Support Engineer for Comanche Peak Steam Electric Station. A statement of my' educational and professional qualifications is in evidence as Applicants' Exhibit 142B.

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's s We address in this affidavit the questions' posed by the Board in.its November 9, 1984, Memorandum (Official Notice Concerning Pipe Supports), as clarified by'the-Board at Tr.

19431-32. The B'oard has invited Applicants to' correct portions of the transcript of an October'23, 1984 meeting between Applicants and the NRC Technical Review Team.

The portion of the transcript cited by the Board concerns statements.Inr Mr. Richard E. Camp, the Manager, CPSES Startup, regardina " deficient

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supports found during hot functional testing and the need to conduct retests. associated with thermal expansion."

As explained by Mr. Camp in his affidavit there is no need to correct the cited transcript. '

i The Board also noted that it believed the comments by Mr'.

Camp "appea'r to be relevant to the adequacy of the design of pipe supports, i.o the adequacy of quality assurance for . design and to Applicants' testimony that there is a safety f actor' of 40 'in -the design of this plant" (Memorandum at 1). The Board subsequently clarified its concerns to be (1) "whether any of the deficiencies corroborate allegations of the I'ntervenors with respect to improper design of pipe supports", (2) "the extent to which any

- of the results from the hot functional testing corroborate

Intervenor's allegations that thermal expansion-has not been properly considered by the Applicants in the design of pipe support [s)," and (-3) "whether [the test results] might corroborate [the allegations]-with respect to local stresses on pipes" (Tr. 19431-32). We address each of these concerns below.

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Relevance to-Design Quality-Assurance The testzdeficiencies identified during hot functional

? testing 1have few' implications for' support design. Those deficiencies simply reflect routine deviations from predi ted' conditions which are expected during HFT. The overwhelming majority of these conditions have no. implications for the piping andTsupport design.- Our review ~of the test results indicates ,

that there are some isolated deficienciesLwhich me.y be. considered r 6 to concern design. These virtually always concern .tdun initial' selection of snubber setting, spring can size, or-drafting i

inconsistencies. Identification of such conditions is not, however, unexpected during an HFT. Indeed, the isolated nature of such conditions demonstrates the adequacy of the. design i- quality assurance process.

Safety Factor The safety factor of 40 which was addressed in Applicants' May 20, 1984, motion for summary disposition on that topic refers specifically to the overall seismic design margin, and not to a safety factor which is generally applicable-to individual aspects of support ~ design.1 A significant portion of this margin can-

- never be' tested because it arises from the conservatisms inherent 1

= The ' Board should note that Applicants claimed a factor of safety of' 40 only for seismic loads.- Applicants clearly stated-(Affidavit at.4), that for static ' loads the margin of.

safety equals the product of Items C1 and C2 of Table:2, or.

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_4-in.the definition of the design. basis seismic input or other analytical ~ inputs' not. susceptable to confirmation by test -(see Table 2 of Applicants' Affidavit on Safety Factors, Items A, B1, B2 and B6). Further, although certain factors noted in Appli-cants' motion could be tested by other means, HFT does not test for those factors (see Items B3-5 and B7-9, and Items C1 and C3).

The only safety factor-which could be affected by results of the HFT.is'that given as Item C2, i.e., " Static Reserve Strength (Code Margin).." This factor of safety (which is the same as that quoted by NUREG/CR-2137 for the nominal margins) could only be affected if the loads experienced during HFT exceeded those allowed by Code.

However, because conditions observed during HFT which may indicate such effects would be rectified and because original designo generally limit loads to levels below (rather than at) allowables, reduction of this safety factor is highly unlikely.

In summary, because allowable values to which supports are designed. consider combinations of many loads, including seismic, and HFT only produces certain loads, i.e., deadweight plus thermal, it is not possible to determine precisely how HFT may have affected real safety margins. It is clear, however, that the HFT results do not indicate that 1e safety margins addressed in Applicants' motion are incorrect. Those margins exist irrespective.of the HFT results and may be considered in conjunction with the appropriate contributors to the loading combinations.

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Relammas to CME A11==*fq_

'Ib e to the questiczia the Board posed in the Novenbar 15, 1984, o:mfenmce call (Tr. 19431-32), we zwiewed all Test Deficiency Deports fran the HET related to pipe supports. 'Jhe test deficiencies do not = Arate any of CME's allegations related to the design of pipe apports, including CME's allegaticma rayardjng consideraticn of themal expansicm effects m the design of pipe supports and local stresses cn pipes.

Po5ert C. Iotta. ~ /

W FA L C. Pmneran, Jr.

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STNat T 'IEDS CCINIY T SOERVEL Subscribed and swm to before me this 3rd day of We, 1984.

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my cemma sse ew erpise s &C" *h '4 73 This is a'telecopy facsimile. The original will be sent under sepsrate cover.

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