ML20107H876

Affidavit of J Doyle Constituting Case Answer to Applicant Response to Board Request Re Cinching Down U-bolts. Certificate of Svc Encl.Related Correspondence

ML20107H876
Person / Time
Site:	Comanche Peak
Issue date:	11/05/1984
From:	Doyle J Citizens Association for Sound Energy
To:
Shared Package
ML20107H825	List: ML20107H822 ML20107H853 ML20107H876
References
OL, NUDOCS 8411090299
Download: ML20107H876 (7)

Text

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l REtf,TED Cenn;5fc.10itiCE

. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION n.g g ,

.: l BEFORE THE' ATOMIC SAFETY AND LICENSING BOARD I l

.In the Matter cf l Docket N[Sl 5@446'Ok:11 l and 50-446 o L TEXAS UTILITIES ELECTRIC 1 ,

-COMPANY,.et al. l . v.

(Application 'fsr a'n

(Comanche Peak S+.eam Electric Operating License)

Station, Units 1 and 2) l CASE'S ANSWER TO APPLICANTS' RESPONSE TO BOARD REQUEST l FOR INFORMATION REGARDING CINCHING DOWN U-BOLTS in the form of l

l AFFIDAVIT OF CASE WITNESS JACK D0YLE 0: Do you find it necessary to alter any of your statements in your Affidavit attached to CASE's 10/8/84 Answer to Applicants' Motion for l l

Summary Disposition Regarding Consideration of Cinching Down of U- l Bolts, in light of Applicants' 10/23/84 Response to Board Request for Information Regarding Cinching Down U-Bolts?

As Yes. Even though this is not the raw data requested by the Board, it i does affect my previous response. In my original response, the last l

answer beginning on page 3 contains (at the top of page 4) the statement "All that Applicants have proved is that within their limited sample (and this in all probability is a very limited sample) . . . "

l I now must qualify my position, since this latest information indicates  !

l that my remark was in fact an understatement. )

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Q:- 'What do'you mean by that?

A In'my original sta ement, I assumed thet the selectivity utilized by Applicants would be limited ' to specific U-bolts corrected to. comply with their.0ctober 1982 criteria n/ which was instituted in response to allegations contained in my deposition / testimony and attachments

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It never dawned on me that while the majority of the allegations in reference to pipe support discrepancies involved Unit 1 and common areas, Applicants" random" sample would be limited to Unit 2.

I find it incredible that Applicants would'take a sample of 160 items exclusively in Unit 2.to prepare criteria for tests to answer allegations which were almost exclusively limited to Unit 1.

Applicants, for their part, have never expanded the allegations beyond Unit 1; see, for example, Applicants' Witness Mr. Finneran, who states 13/: 3 "We have identified 15 of these types of supports (modified to improve their stability) in Unit 1 and common areas."'

Mr. Finneran at no time in these hearings stated that similar supports exist'in Unit 2. The problem is therefore twofold: (1) The instability problems identified in Unit 1 exist in Unit 2 to the same Lif. See Affidavit of Robert C. Iotti and John C. Finneran, Jr. Regarding Cinching Down of U-Bolts, page.9; see also SIT Report (NRC Staff

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Exh! bit 207, bound in following Tr. 6289, received into evidence at Tr.

6402), page 32, citing Brown & Root Design Change Notice (DCN) Number 1, dated 10/8/82, to Construction Procedure No. 35-1195-CPM 9.10 Rev.

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2 CASE Exhibits 669 and 669A, Deposition / Testimony of CASE Witness Jack

'Doyle, and CASE Exhibit 6695, Attachments to Deposition / Testimony of CASE Witness Jack Doyle, all admitted at Tr. 3630.

f3/ See 6/17/84 Affidavit of John C. Finneran, Jr., Regarding Stability of Pipe Supports and Piping Systems, attached to Applicants' Motion for Summary Disposition Regarding Stability of Pipe Supports and Piping Systems, at page 18.

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i degree Las was noted in Unit 1, . in which case Applicants. have been less s than' candid with~the Board as relates to inst' ability; and (2) in which-

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icase utilizing the-torque vr ues resulting from a change in criteria'

.(10/8/82) prior to the major construction effort for pipe supports in

. Unit 2 isLalso. deceptive.

'1 must.also add that.the manner in which I answer these.U-bolt Auestions;does not indicate.that I' agree with Applicants' numbers (15

. 'to'tal U-bolt. instability! problems with enly 2 of this number on non-main steam'run pipes), since I identified more than two U-bolt instability problems-on non-main steam lines in my Exhibit 669B.

(As a matter of fact,.I find it difficult to agree with much that 7  : Applicants'haveito say in reference to stability; for example, JApplicants avoid the term:" instability" like the plague and prefer to

. use the term repaired to improve stability" (see,- for example, Tr.-

'4895). :For these supports cutlined under box frames and U-bolts with--

gaps,.the phrase "to improve stability" (emphasis added)'is like the doctor; telling'your wife not to worry because she is only a little-bit pregnant.)

Q: '

Do you have any;further statements in regard to this new information?

A: Yes. In their random sample of specific supports, Applicants also inclu'edd 35 Class 5 supports, 16 supports listed as Class 6 (balance of

.' plant, non-safety related), and at least 1 Class 4 support. As far as testing ASME pipe supports, the inclusion of th'e condition for 52 of-s 160 supports which are'not specifically ASME controlled is only 3

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utilized as a means of creating an appearance of a large sample. The same is true for the 20 small bore and 16 3" diameter line U-bolts included in Applicants' " random" sample, which have nothing to do with the tests for 4", 10", and 32" lines. In fact, only 45 of the 160 U-bolts in the " random" sample are relevant. This is particularly

'misleadihg when' Unit I has a large number of'U-bolts cinched up that could have been used for the sample.

Finally, I must note that, vhile the new direction instituted by Applicants' 10/8/82 procedure gave-the. appearance of solving a problem by. offering guidance for cinching as a means of obtaining stability, it obviously fell short. This fact may be noted in at least two areas relating to the effect of the torque spread, noted by Applicants in Table 2, on the mechanisms for problems:

(1) For at.least some in all sizes over 3" diameter to 30"

. diameter, lif t-of f would be a major problem, as was the case for stiff clamps, as noted in the Administrative Board Order on this subject.

(2) The spread between minimum and maximum torque for this selective sample does not speak well for the procedure established by Applicants (10/8/82), nor does it address the probabilicy for torques above or below the current scatter.

.0: Do you have anything further to state on this subject?

=A: No, I do not. I believe the above will suffice to qualify and quantity my original " understatement" which resulted due to a lack of knowledge of Applicants' meaning of " random sample," which translates to

" controlled sample."

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I have read the foregoing affidavit, which was prepared under my personal direction, and it is true and correct to the-best of my knowledge and belief.

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Date: Zh /

STATE OF NA COUNTY OF W

'On this, the UDday of Orth , 1981, personally appeared 0, M. Otto - MkA. y

, known to me to be the person whose name is-subscribed to the foregoing instrument, and acknowledged to me .

that he/she executed the same for the purposes therein expressed.

Subscribed and sworn before me on the 2 C D day of Orw ,

1983.-

IRVIN L LERNER NOTARY PUBUC. State ef t;ew yort hD Notary Fublic in and for the State of tio. 52 2315660 Qg Quahtied L1 Suttolk Ccunty h OU*esadasch 30,19F I My Commission Expires:

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_ __ UNITED STATES OF AMERICA NUCLEAR REGULATORY C0milSSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'In the' Matter of }{

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g . TEXAS UTILITIES-ELECTRIC }{ . Docket Nos. 50-445-1 COMPANY, et al. }{. and 50-446-1

-(Conanche. Peak Steam Electric }{

5tation, Units 1 and 2) }{.

CERTIFICATE OF SERVICE ley my signature below, I hereby certify ~that true and correct copies af

- C SE's Motions and CASE's Answer to Applicants'. Response to Board Request

for Information Regarding Cinching Down U-Bolts have been sent to.the names listed below this 5th day of November ,1984 ,

.by: ' Express Mail where indicated by

• and First Class Mail.elsewhere.

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• Administrative Judge Peter B. Bloch

• Nicholas S. Reynolds, Esq.

U.1S. Nuclear. Regulatory Commission

.Eishop, Liberman, Cook, Purcell O 4350 East / West. Highway, 4th Floor & Reynolds Bethesda, Maryland 20814 1200'- 17th St., N. W.

Washington, D.C.. 20036 1*' Judge Elizabeth lB. Johnson-Oak Ridge National Laboratory

• Ceary S. Mizuno, Esq.

P. O. ' Box X, Building 3500 Office of: Executive Legal Soak Ridge,; Tennessee 37830 Director U. S. Nuclear Regulatory

• ' Dr. Kenneth A.- McCollom, Dean Commission

Division of Engineering,. Shryland National Bank Bldg.

' Architecture and-Technology - Room 10105

. Oklahoma State University 7735 Old Georgetown Road

.Stillwater, Oklahoma 74074 Bethesda, Maryland 20814

• Dr.' Walter M. Jordan ' Chairman, Atomic Safety and Licensing 881 v. Odcer Drive 3oard Panel Oak Ridge, Tennessee 37330 U. S. Nuclear Regulatory Commission i Washington, D. C. 20555 1

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, . Chairman '- . .

'tenea Hicks, Esq.

. . _ Atomic Safety and LicensingfAppeal' Assistant-Attorney General

-Board Paneli Environmental: Protection Division

, , . iU.-:S.-Nuclear. Regulatory: Commission . Supreme Court Building.

~ :Washingtonf:D.'C.i ~.20555' l Austin', Texas 78711

' John Coll' ins-r:~  : Regional: Administrator, Region IV 1

U.-S. Nuclear Regulatory Commission 611.Ryan Plaza Dr., Suite 1000i Arlington,i. Texas 76011

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.Lanny.A."Sinkin:

114.W. 7th, Suite'220 ,

Ausein,' Texas. 78701

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Dr; David 3.LBolt:

'2012JS.-?olk?

. Dallas , - . Texas ' 75224 9  ? Michael 3.4 Spence,VPresident.-

• TexasLUtilities Generating;Co=pany

-; Skyway; Tower; 400f North ; 0 live St. , - L.B. 81-Dallas,2 Texas; 75201--

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_ Docketing.and: Service Section -

-. .  ;(3Lcopies)'- -

(Office of..the Secretary U.;S. Nuclear Regulatory Commission

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': Washington,:D.' C. -

20555 s-(

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. prs.)JuanitaEllis,-President -

f CASE (Citizens Association for Sound Energy)

W 1426 S. Polk Dallas, Texas 75224

'214/946-9446 i

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