ML20113E013

Case Supplemental Answer to Applicant Motion for Summary Disposition Re Local Displacements & Stresses.Affidavit of J Doyle Encl

ML20113E013
Person / Time
Site:	Comanche Peak
Issue date:	01/17/1985
From:	Ellis J Citizens Association for Sound Energy
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20113D985	List: ML20113D972 ML20113E013 ML20113E054
References
OL, NUDOCS 8501230284
Download: ML20113E013 (2)

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t/17/85 UNITED STATES OF AMERICA ^M.WJ3 NUCLEAR REGULATORY COMMISSION -

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g yu y pg g In'the Matter of i -

Docket Nos. 50-445 l and 50-446 -~

TEXAS UTILITIES ELECTRIC 1

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' COMPANY, et al. . I i (Application for an (Comanche Peak Steam Electric l Operating License)

Station, Units 1 and 2) {

CASE'S 1/17/85 SUPPLEMENT TO CASE'S ANSWER TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION REGARDING LOCAL DISPLACEMENTS AND STRESSES Pursuant to the Board's 10/31/84 Memorandum (Multiple Filings), CASE

.(Citizens Association for Sound Energy), Intervenor herein, files this, its

1/17/85. Supplement to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Local Displacements and Stresses.

This pleading was necessitated by new and significant information which supports. CASE's position - information which was not available until very recently. With regard to the four items which the Board has stated must be satisfie'd, we offer the following:

(1)~ Relevance: This~is relevant to, and gives further support to, CASE's 10/9/84 Answer to Applicants' Reply to GnSE's Answer to Applicants' Motion for, Summary Disposition Regarding Loca1' Displacements and Stresses (see Affidavit of CASE Witness Jack Doyle attached thereto, especially pages

-4~.through 11).

l(2) What new material in the last round filing is being responded tot i

LWe are supplementing CASE's response to point 2 of Applicants' 9/28/84 Reply to CASE's Answer to: Applicants' Motion for Summary Disposition Regarding

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Local Displacements and Stresses, at pages 5 through 9 (referencing Finneran

>Aff. davit at'pages 2 through 6)..

85012 4 850117 POR K-05000445 ^

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(3) Why the party was unable to anticipate this material in its last

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filing: iAs-mentiioned previously, this is new and significant information which was not available at that time (see SSINS No. 6835, IN 84-87, NRC Information Notice No. 84-87: PIPING THERMAL DEFLECTION INDUCED BY STRATIFIED FLOW, December 3, 1984, copy attached).

(4) The safety significance of the point that is being made: See full =

~ discussion in CASE's 11/15/84 Motion for Reconsideration of Board's 10/31/84 Memorandum (Multiple Filings). As part of that discussion, we stated that it is our understanding that these Motions for Summary Disposition were to

. have been one of the primary means by which Applicants hoped to convince the Board that- the entire plant had been-designed ~ properly. These specific items were chosen by the Applicants. In addition, the new and significant information discussed herein confirms and demonstrates graphically.one of JCASE's points. 'As stated by Mr. Doyle in his attached Affidavit: "

. . 15 minutes.after cool fluid was introduced into a hot pipe, the cool fluid caused a temperature differential between the top and bottom of'the pipe, resulting-in a displacement of the pipe which caused' severe damage to 1 1

several feedwater pipe hangers and snubbers." And the Information Notice states: "The difference in temperature between the . top and bottom of the pipe causes the pipe to bend and may pull hangers out of their supports."

(Emphasis added.)

CASE's Supplement is in'the form of the attached Affidavit offCASE Witness Jack Doyle.

Respectfully submitted.

02 NAN p s.) Juanita:Ellis, President flifi) u SE (Citizens Association for Sound Energy) 1426 S.' Polk', Dallas, Texas 75224

-214/946-9446 2~

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