ML20100B293

Affidavit of Re Camp Re ASLB Inquiry Concerning Hot Functional Test Results.Certificate of Svc Encl

ML20100B293
Person / Time
Site:	Comanche Peak
Issue date:	12/03/1984
From:	Camp R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20100B282	List: ML20100B281 ML20100B288 ML20100B293
References
OL, NUDOCS 8412040278
Download: ML20100B293 (7)

Text

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UNITED STATES OF AMERICA NUCLEAR ~ REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matte'r of )

) cket 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 RICHARD E. CAMP REGARDING BOARD INQUIRY CONCERNING HOT FUNCTIONAL TEST RESULTS I, Richard E. Camp, being first duly sworn hereby depose and state, as follows: -

I am employed by Impell Corporation under contract to Texas Utilities Generating Company as Manager, CPSES Startup. In this position my responsibilites include. oversight of the conduct of preoperational testing, which includes hot functional testing.

The purpose of this affidavit is to address certain questions posed by the Atomic Safety and Licensing Board in its November 9, 1984, Memorandum (Official Notice Concerning Pipe Supports).

In its Memorandum the Board quoted portions.of a transcript of an October 23, 1984, meeting between Applicants and the NRC Staff Technical Review Team. Those portions of'the. transcript i

involve my discussion of activities to be completed during the l next plant heat up. Specifically,'the Board quoted, as follows:

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-- : l Included in that next [ hot-functional testing] heat up will be the thermal expansion test of the deficiencies found the last time. The current' status is that we

[are] . . . in preparation.for ambient measurements for the-deficient supports found during hot functional testing.

At the current time,- we plan on finishing these incomplete preoperational tests prior to' fuel load, in which case they will .las reviewed and approved prior to fuel load. Any kind of technical specification deviations that may be associated with thermal expansion, we don't know the scope or extent of those at this time, and we won't know until we with' thermal finish the re-tests associated expansion.

The Board indicated in a recent conference call that its concern focusses on the language "the deficient supports found during hot functional testing" and "re-tests associated with thermal expansion" (Tr. 19,431-32).

The Board believes these statements appear to be relevant to pipe support design and invited the parties "to correct these portions of the transcript" if they wished. (Memorandum at 1.)

There is no need to correct either portion of the transcript cited by the Board. The term " deficient support" refers to supports for which a test deficiency exists. It was not used to l refer to supports which were incorrectly designed.

Further, because it is extremely difficult to predict the b

exact thermal movement of the piping system one-of the purposes of the HFT is to measure the actual movement of piping, compare-it-to the predicted movement and reconcile the differences that I

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.are#outside )the . acceptance criteria.:. These differences are

documented on.TDR's as deficiencies.- Accordingly,'duringlthe first, hot l functional' test (HFT), pipe supports (constant. and -

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. variable springLsupports as well asisnubbers) which had~not been-

. installed or did . not meet . the acceptance. criteria ' for expected thermal movement asL specified : in L the thermal expansion test .

procedure,-were identified.for. retest. . There:is no need tx) correct my statements regarding thermal expansion retests.

In order to illustrate ~the nature of test deficiencies for the-Board I provide-the following information. Documentation of

deficiencies on Test Deficiency Reports assures that-the supports will be retested. Test Deficiency ' Reports contain the problem description, corrective action and ratest requirements. The i reports are used by the Startup organization to report' deficiencies in system or component operating characteristics, test documentation or startup procedure compliance. Examples of-the deficiencies concerning pipe supports documented ~in these reports are, as follows

1 1)' If the design requirements of a-support-(for example, a -

L spring setting) are revised by engineering after.the.first L

1HFT due-to'as, built piping analysis,1 each such support-is ~

documented on a~ Test Deficiency Report to assure subsequent retesting. '

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2) If during the test the piping did notl move exactly ass predicted'by'the. analysis such that spring or snubber-settings'are outside.the acceptable ranges or there is 1 binding in the support . components, 'the af fected supports .are

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listed on Test Deficiency-Reports.-

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.The' HFT was conducted prior to completion of all.as-built l'

~p iping analysis work.-

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3) If-it is. decided during. review of the~ test data'.that the

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data may be suspect, inaccurate, or insufficient, the affected

.For' supports are listed on a Test' Deficiency Report'.

example, the reading for a spring during initial. ambient was.too far from the. reading during final ambient.

4) Hardware problems (e.g., malfunction of a snubber or spring) are documented on Test. Deficiency' Reports.

5) A snubber may have been temporarily removed to allow constructionfaccess. The test.results with respect to'such-supports would, therefore, be indeterminate.- These supports would'be listed on Test Deficiency Reports. ,

In summary, my quoted' statements during the October 23, 1984, meeting are accurate.

There is no need to correct:the cited portions of 'the transcript. The " deficient supports" I referred to involve supports which exhibited conditions requiring documentation as test deficiencies. These " deficiencies" are not, however, intended to refer to supports which were inadequately designed. In fact, the type of conditions which were observed during hot functional testing are the type expected and routinely encountered in such testing and one of the principal purposes of the testing is to identify and correct those anticipated " deficiencies".

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-Richard R. Camp

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d day of Deeceber, L984.

. Subscribed and sworn to before me this

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He L Mocary kblic This is a telecopy facsimile. The original will be sent under separate cover.

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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 and

-COMPANY, et al.

) 50-446

)

) ( Application . for

'(Comanche Peak Steam Electric ) Operating Licenses) d Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereb'y certify that copies of " Applicants'

~

Response to Board Memorandum (Official Notice Concerning 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 3kd day of December, 1984, or by hand delivery (**) on the 4th day of December, 1984.

• • Peter B. Bloch, Esq.

Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Board Licensing ~ Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 washington,RD.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 **Stuart A. Treby, Esq.

Architecture and Technology Office of the Executive

-Oklahoma State University Legal Director Stillwater, Oklahoma 74074 U.S. Nuclear Regulatory Commission Chairman, Atomic Safety 7735 Old Georgetown Road and Licensing Board Panel Room 10117 U.S. Nuclear Regulatory Bethesda, Maryland 20814 Commission i Washington, D.C. 20555  ;

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Robert _D. Martin * . Elizabeth B. Johnson Regional Administrator, Oak Ridge National Laboratory

-Region IV Post Office Box X U.S. Nuclear Recttlatory Ruilding 3500 ,

Commission' Oak Ridge, Tennessee .37830 611 Ryan Plaza Drive.

Suite 1000 *-

Mrs. Juanita Ellis Arlington, Texas 76011 President, CASE 1426 South Polk Street-Renea Hicks, Esq. Dallas,-Texas 75224 Assistant Attorney General Environmental Protection Lanny A. Sinkin Division 114 W.'7th Street P.O. Box 12548 Suite 220 Capitol Station Austin, Texas 78701 Austin, Texas 78711

( 1 0if i Ll1 bf 6 William A. Horin '

cct John W. Beck Robert Wooldridge, Esq.

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