ML20141C790

From kanterella
Jump to navigation Jump to search
Transcript of 840806 Telcon in Bethesda,Md Re Discussion on Motions for Summary Disposition Filed by Applicant. Pp 1-87
ML20141C790
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/06/1984
From:
NRC
To:
References
NUDOCS 8512310071
Download: ML20141C790 (96)


Text

1 ORIGINAL' 2 UNITED STATES OF AMERICA A A ON ,

3 4

5 6 In the Matter of:

1 S **

DISCUSSION ON MOTIONS FOR

SUMMARY

8 DISPOSITION FILED BY APPLICANT 9 COMANCHE PEAK h to 11 12 13 14 15 16 k'

17 18 19 20 Location: Bethesda, Maryland Pages: 1-87 21 Date: August 6, 1984 22 23 24 , f O C W/23 067 I oi MwrT .~20 aiaTE REPORTING INC.

Court Reporting e Depositions D.C. Aree 161-1901 e Bolt. & Annop.169-6136 i

l 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2

DISCUSSION ON MOTIONS FOR

SUMMARY

3 DISPOSITION FILED BY APPLICANT 4

5 Conference Call 7735 Old Georgetown Rd.

6 Bethesda, MD Room 10117 7

August 6, 1984 8

Meeting in the above-entitled matter convened at 9 8:00 p.m.

10 APPEARANCES:

ii On behalf of the Applicants:

12 DR. ROBERT IOTTI JOHN FINNERAN q 13 DAVID WADE (j WILLIAM A. HORIN, ESQ.

14 On behalf of the NRC Regulatory Staff:

15 GEARY S. MIZUNO, ESQ.

16 SPOT BURWELL HANK FLECK 17 DAVID TERAO JOHN BRAMMER 18 On behalf of the Intervenor Citizens Association 19 for Sound Energy:

20 JUANITA ELLIS, President 1426 South Polk Street 21 Dallas, Texas 75224 22 Mark Walsh 23 24 hkC-105 25

/s 1

L)

FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 169-6136

' 2 t'M 1

P g g g g 3 g I_ N_ Q g 2 MR. BURWELL: My name is Spot Burwell, I'm the 3 Comanche Peak Project Manager for the NRC. I have with 4 me here tonight, David Terao, and the court reporter. I 5 would recommend that we go through and introduce 6 ourselves one more time to give the court reporter one-7 more opportunity to hear your voice.

8 MR. MIZUNO: This is Ceary Mizuno, counsel to 9 the NRC staff.

10 MS. ELLIS: Juanita Ellis for the Intervener 11 CASE. With me is Mark Walsh. Mark, do you want to say 12 something for the reporter. Woops, I will go see if I 13 can find him.

14 MR. HORIN: Who are the consultants' for the 15 NRC staff one more time?

16 MR. FLECK: Yes. This is Hank Fleck. I am with 17 E-Tech, consultant for the NRC.

18 MR. BRAMMER: John Brammer with E-Tech, 19 consultant for the NRC.

20 MR. HORIN: John, how do you spell your name?

21 MR. BRAMMER: Brammer.

22 MS. ELLIS: Okay. Mark is on now. Do you want 23 to say something, so the reporter can hear your voice.

24 MR. WALSH: This is Mark Walsh.

25 MR. HORIN: This--is Bill Horin, counsel for BH p

v NRC-105 T-1 2

FREE STATE REPORTING INC.

Court Reporting . Depositions D.C. Area 161-1902 e Bolt. & Annop. 169 6136

.3

, ~y

' 1 Texas Utilities. We have three other individuals on the 2 line also, which I will go around in alphabetical 3 order.

4 MR.-IOTTI: This is Bob Iotti.

5 MS. ELLIS: :You just faded completely.

6 MR. IOTTI: I am a consultant to Telco.

7 MR. WADE: This is David Wade with Texas 8 Utilities , also.-

9 MR. BURWELL: Okay. Let's go ahead and try it.

10 As I understand it, the purpose of_this meeting is to 11 allow CASE to ask the Texas Utilities questions 12 concerning the, some of the motions for summary 13 disposition that have been filed by Texas Utilities.

(]

mj 14 Before we go into that, I would like to find out what 15 the agenda is this evening. In particular, I would like 16 to -establish early on that we are going to talk about 1.7 the items in which by consultants at E-Tech 18 participate, and if so, to take that up early in the 19 agenda. If not, to drop them off.

20 MS. ELLIS: Right. I think that is a good way.

21 After talking with you earlier today Spot, as we 22

-discussed, I haven' t discussed with the applicants yet, 23 I think that we can save a lot of time. Bill Horin had 24 asked that we try to limit this to a couple of hours. I 25 think that we can probably do that by doing a few BH

[') NRC- 105 T-1 3'

FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Aree 261 1901 e Bolt. & Annop. 169 6136

1 l

l 4

(~)

\~/ 1 things to begin with. I think the quality assurance for 2 design questions don't need necessarily to have 3 everybody, all of the technical people on the line.

4 What I propose to do, and what we discussed was to try 5 to do something in writing on that, and get that off if-6 not tonight, tomorrow for sure, so that the applicants 7 can have it-right away, and everyone can have it. Then, 8 get back with another, and informally try to take care 9 of those things. That will save us some time tonight.

10 Also, Mark has indicated, I don't believe we 11 really will have any questions on the upper lateral 12 restraint. We just would like to be sure that we get

(-)

%J 13 the same information that was given the staff on it.

14 Another thing, I know you had mentioned, Spot, that is some of your people might be interested in is about the 16 differential displacement. We don' t have any questions 17 on that. So, any of them that are involved with the 18 staf f , they don' t really need to stay on the line.

19 Other than that, the ones that we do want to 20 get into tonight are, first, cinched up U-bolts, axial 21 restraints, richman inserts, and stability. Knowing the 22 way things go, we figure that will probably take the 23 rest of the time that we have allotted. We are going to 24 try and go through just as quickly as possible.

25 MR. BURWELL: Excuse me, Ms. Ellis. What was BH

(')

\'

NRC-105 T-1 4 l FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 169-6136 ~

[5 s

('J

( i the third one? You had cinched up U-Bolts, actual 2 restraints, Richman inserts.

3 MS. ELLIS: Richman inserts.

4 MR. BURWELL: I believe there are two of those 5 on Richman inserts.

6 MS. ELLIS: Not that we have gotten.

7 MR. BURWELL: Okay.

g UNIDENTIFIED SPEAKER: Spot, there is just 9 one.

10 MR. BURWELL: Just one, alright.

ii MS. ELLIS: Stability was the fourth one.

12 Does that fit in with your people okay Spot? We could rearrange it if we need to.

g 13 34 MR. FLECK: Spot, this is Hank Fleck. If you is could do the U-bolt cinching actual restraint, I would 16 appreciate it. We are not on , well, we haven' t gone out 17 to dinner yet. If we could get that out, that would is help us here.

19 MS. ELLIS: Excuse me, I can' t hear whoever is 20 talking at all. I can tell there is talking, but I 21 can' t understand it at all. You will have to translate 22 whatevet they say.

23 MR. BURWELL: Okay. That was Hank Fleck. Mr.

24 Fleck. requested that we take up the cinch U-bolt first.

25 That dif ficulty is that they have to pull together some BH

,G NRC-105 U T-1 5

FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Aree 261-1902 e Bolt. is Annop. 169-6136

C n

i <

\ '# 1 things and look over some personal business before they 2 get on the plane early tomorrow morning to arrive here 3 to be at the meeting on Wednesday.

4 MS. ELLIS: Right. Are there any others that 5 we need to arrange?

6 MR. BRAMMER: Are you going to ask any 7 questions on local stress and displacement?

8 MS. ELLIS: I couldn' t hear that, Spot.

9 MR. BURWELL: Mr. Brammer, I believe, asked if to you were going to ask anything on local displacements 11 and stresses.

12 MS. ELLIS: I believe that, is that the 13 differential displacement?

(_'./e) 14 UNIDENTIFIED SPEAKER: No. We will not.

15 MR. BRAMMER: Thanks.

16 MR. HORIN: This is Bill.

17 MS. ELLIS: I can barely hear you, Bill.

l 18 '

MR. HORIN: Before we start, I want to clarify l

19 a couple of things. The first thing, to determine 20 whether or not there are, whether you plan to ask any 21 additional questions in this exercise with respect to 22 anything other than the cinch U-bolts, the actual 23 restraits, the Richman stability, and the design OA? Is 24 it my understanding that those last five you have 1 l

25 questions on?

BH

('i NRC-105

\> T-1 6

FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 1611901 e Bolt. & Annep. 149 6136

u 7

O O 1 MS. ELLIS: I believe that is right, isn' t it 2 Mark?

3 MR. WALSH: Yes.

4 MR. HORIN: As we discussed th , = morning , I'm 5 sure, Mark that Juanita passed it along to you. We 6 would anticipate that you would be able now, after 7 having these for a month to have focused questions. I a asked her to pursue those things that you really 9 believe are important in material. We want to provide 10 the information that is necessary to respond, but we 11 don' t want to exercise in dealing with the new shif t.

12 It is not important, and I'm sure you will be able to 13 disern what is important and what isn't. I think it O 14 will save everybody a lot of time.

15 MS. ELLIS: I think that's true. I think that 16 we can probably do it with a little less discussion 17 than we did before. Though the discussion was 18 interesting, I think it did take up quite a bit of time 19 back and forth.

20 MR. HORIN: What I would propose to do is that 21 we start, as we did before with a particular motion.

22 Mark, I don' t know how you organized it, but if you 23 have it organized again by the statement of material, 24 perhaps I should just start going into it right now.

25 MR. BURWELL: Mark, would you speak up loud so BH

""C- s C'>'

- T-1 7

FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Belt. & Annep. 169-6136

8 U 1 my people in California have some chance of hearing

.' you.

3 MR. WALSH: Now, the first one would be the 4 ascension of U-bolts. In the first guide, I'm shown 5 there, would like the documentation that the stress 6 ' relaxation stops after you reach a certain level. For 7 A36 steel, that it is approximately 1/2 of the yield 8 stress.

9 MR. IOTTI: This is Bob Iotti. Can you hear me ,

10 Mark?

11 MR. WALSH: Barely, but I can.

12 MR. IOTTI: I don't know the documentation you 13 would like to have, but some of the documentation is

O 14 already provided as part of the test results. You can is see what happens to the screen in the U-bolt as the 16 streses in the U-bolt exceed a certain level in where 17 the strain relaxation stops. In addition, I could refer 18 you to that reference, I believe it was quoted. Now, I f

19 have to go back to the affidavit.

20 MS. ELLIS: Okay, Bob. Just a moment, before 21 you continue. Look through the documents that you have 22 provided, so if it is in there, and that is all that 23 you can provide on it, you don't really need to go into 24 the detail of that. Just tell us what is provided is 25 it.

BH p/

t NRC-105 T-1 8

FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Aree 161-1902 e Belt. & Annop. 169 6236

9 g

V 1 MR. IOTTI: What is provided is already in the 2 document.

3 MR. HORIN: There is also a reference in the 4 document, Bob,.that Mark should look at?

5 MR. IOTTI: The results that are most 6 illustrative are in the test results of.. .give me one 7 second.

8 MS. ELLIS: I think you just faded out.

9 MR. IOTTI: I'm sorry.

10 MS. ELLIS: I'think you just faded out.

11 MR. IOTTI: I'm sorry, Mrs. Ellis. I will try 12 to speak louder, but I am already at the top of my 13 lungs.

V 14 MS. ELLIS: I know.

15 MR. IOTTI: If you go to attachment one, you 16 Will see a lot of the results already in attachment 1.

17 MR. WALSH: So, what you are saying is that 18 your whole conclusion is pretty much based on that 19 conclusion. and pretty much based on that tasking that 20 you have performed?

21 MR. IOTTI: No, that and that additional ASTM 22 document that I referenced in the affidavit. I am 23 trying to find the precise page where that is 24 different. Look at page 25 of the affidavit, reference 25 11. The title is Calculation of Stress and Relaxation BH f) NRC- 105 L' T-1 9

- FREE STATE REPORTING INC.

Court Reporting e Depositlens D.C. Aree 161-1901 e Belt. & Annep. 169 6236

10 tQ kJ 1 Engineering Alloys, ASP & Data Service Publications 2 GS-60. l 3 MR. WALSH: Can we get a copy of that?

4 MR. IOTTI: The whole document is really 5 irrelevant. I can send you a copy of (inaudible).

6 MR. WALSH: Can you repeat that last part?

7 MR. IOTTI: It is a thick document, most of 8 which is totally irrelevant, because it refers to 9 alloys which have nothing to do with carbon, maganese, 10 silicon steel, such as A36. I can send you the section 11 of the documents which are relevant.

12 MR. FINNERAN: This is Jack Finneran, Mark, n la Did you hear that? If not, I will translate.

U .

14 MR. WALSH: Not that well.

15 MR. FINNERAN: .He said that that document 16 would no be of any use to you becuase it concerns a lot 17 of other type materials than the ones that the U-bolts 18 were made out of. He will send you copies of the pages 19 that are pertinent to the U-bolts in question.

20 MR. WALSH: Alright.

21 MS. ELLIS: Was there anything else Bob, that 22 you need to say on this?

23 MR. IOTTI: No, Mrs. Ellis.

24 MS. ELLIS: Okay.

25 MR. WALSH: Okay. Number three.

BH O NRC- 105 d T-1 10 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Belt. & Annep. 169-6136 Y

]

l .l.l.

n 1 MR. IOTTI: Just a moment, Mr. Walsh. Let me 2 make a note.of what I need to send you.

3 MS. ELLIS: I didn' t understand that.

4 UNIDENTIFIED SPEAKER: Mr. Iotti said that he 5 wanted to make a not on what to send you.

6 MR. IOTTI: Go ahead.

7 MR. WALSH: The next item is number three.

8 UNIDENTIFIED SPEAKER: This is the statement 9 effect?

10 MS. ELLIS: Yes. All of these will be, unless 11 we tell you otherwise.

12 MR. WALSH: Okay. It is about a sample that 13 you looked at. We would like to know what criteria was O 14 used to select the particular supports, how many of 15 these supports have the U-bolts cinch down after the 16 ground and root procedure before this cinching of 17 U-bolts came into effect, were in that sample. How the 18 random sample was selected, and how that random sample 19 is representative with the bolts, all the U-bolts in 20 the plant.

21 MR. IOTTI: This is Bob Iotti again. John, you 22 may have to help me out on that.

23 MR. FINNERAN: Mark, could you hear Bob?

24 MR. WALSH: Yeah. Bob, just keep speaking up.

25 MR. IOTTI: First of all, you have correctly BH

(']

v NRc-105 T-1 11 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1902 e Belt. & Annep. 249-4236 s

.} .9 V 1 stated the sample was random in the sense that we did 2 not choose any particular type of U-bolt.

s We chose 3 reasonably,.with a criterion that said we should 4 C-bolt, not U-bolt in different sizes, in random areas

~5 of the plant. In the affidavit, cable tubes, you will 6 have total' number of U-bolts. It is broken down in the 7 number of U-bolts, and these bolts identified by size.

8 That is Table 2.

9 MR. WALSH: How many of these have been 10 inspected by QC for the torque values?

11 MR. IOTTI: John.

12 MR. FINNERAN: Bob, can you hear me?

o 13 MR. IOTTI: Yes.

b 14 MR. FINNERAN: Bob Iotti, can you hear me?

15 MR. IOTTI: Yes.

10 MR. FINNERAN: Okay. I'm at a little bit of a 17 loss here, because I can't find my statement of 18 material facts. So, tell me which sample we are talking 19 about. l 20 MR. IOTTI: We are talking about sample of the 21 torque that are present in the cinched narrow U-bolt, 22 which were taken randomly in the...

23 MR. FINNERAN: In the field?

24 MR. IOTTI: February. His question is how many l I

25 of those U-bolts have been inspected through the BH NRC-105

' T-1 )

12 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Belt. & Anney. 169 6136

' 1$

em 1 Brownley Rhodes Procedure?

2 MR. .FINNERAN: To the best of my knowledge, 3 all the U-bolts have been inspected.

4 UNIDENTIFIED SPEAKER: Mark, would you repeat 5 your question again for John?

6 MR. WALSH: My question was how many of the j 7 U-bolts have been ' inspected for the torques that came 8 out in the brown root procedure, and were inspected by 9 QC?

10 MR. FINNERAN: Mark.

11 MR. WALSH: Yes.

12 MR. FINNERAN: This is John Finneran again.

13 MR. WALSH: Okay.

x) 14 MR. FINNERAN: As I said before, to the best 15 of my knowledge, all of U-bolts that these samples were 16 taken on had been completed in construction, had been 17 bought off by OC.

18 MR. WALSH: Of the sample that you look at, 19 was there any type of reliability analysis performed 20 that one could extract the confidence level that the 21 supports would be stable with the ascension down 22 values, the torque values and cinching them down?

23 MR. IOTTI: Bob Iotti. I am not sure I 24 understand your question.

25 MR. BURWELL: Bob, Dr. Iotti. Spot Burwell BH

/] NRC-105 V T-1 13 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Belt. & Annep. 149 6136

1'I

/

1- here. May I make a suggestion. Would you talk very 2 carefully into your phone. It sounds like you are 3 turning your head away from the speaker very often.

4 MR. IOTTI: . Well, unless you.want me-to take 5 the speaker out of my mouth. . .

6 MR. BURWELL: Thank you for your patience.

7 MR. IOTTI: Okay. I'm getting a sore throat a very quickly. Mark, let me see if I can answer your 9 question, because I am not sure I totally understand. I to think what you are driving at is have we established 11 every one of the supports that we sample. Is there a 12 sufficient torque applied to assure stablility?

m 13 MR. WALSH: In a numerical sense.

U 14 MR. IOTTI: In a numerical sense?

15 MR. WALSH: Yes. You didn't test every one of 16 them. You only tested a sample.

17 MR. IOTTI: I understand. As a matter of fact, 18 we are telling you in the report that there may be some 19 the lowest range of torque of which may be below the 20 value in which stability in the sense that the support 21 won't move.

22 MR. WALSH: Okay.

23 MR. IOTTI: Might not be assured. That doesn't 24 mean in our minds the support is unstable in the sense 25 that it performs its functions. But, if you interpret l BH  !

(V9 NRC-105 T-1 14 FREE STATE REPORTING INC.

Court Reporting . Depositions D.C. Area 1411901 e Belt. & Annep. 149-4134

15 A

_V 1 stability as being support, it will not move. There 2 already are some in the range we have sampled which 3 will be below that level. That is why we have committed 4 to go back and inspect all_of the stationery U-bolts to 5 make sure that the minimum value of torque exists. When 6 I say all, I mean all the stationery U-bolts.

7 MR. WALSH: Okay.

8 MR. IOTTI: That is in the affidavit.

3 MR. WALSH: Right. I remember. Now, the next i to one is item number four.

11 MR. IOTTI: Does that answer your question?

12 MS. ELLIS: What?

,o 13 MR. IOTTI: I was just wondering if my answer U 14 satisfies Mr. Walsh on his question on three?

is MR. WALSH: Yes.

16 MR. FINNERAN: Let's make it clear too, that 17 there is nothing that the applicant is to provide in 18 addition to what we just discussed. Is that correct? We 19 owe you no documents?

20 MR. WALSil: That's correct. Alright. The next 21 item is number four. This is relating sort of, to what 22 Dr. Iotti was just talking about. The second sentence 23 is therefore unlikely. How will one know from a 24 reinspection, that there.has been an overtorqued 25 condition, and how does one come up to a percentile Bli T NRC-105 (d T-1 15 FREE STATE REPORTING INC.

Court Reporting e Depositlens D.C. Area 2411901 e Belt. & Annep. 149-4136

' .! C O'd 1 that saying, well, maybe only one percent will be 2 overtorqued.

3 MR. IOTTI: Okay, Mr. Walsh, if you will look 4 at table 2 on the affidavit, you will note that none, 5 zero, of the supports that were sampled were, in fact, 6 overtorqued. That is, whether they might have been 7 overtorqued to begin with or not, we don' t think they 8 were. At the space when they were inspected, none of 9 them showed overtorquing. Now, I don't remember how to many total U-bolts we inspected, do you remember John?

11 MR. FINNERAN: No. I don' t remember of f hand ,

12 Bob.

f-) 13 MR. IOTTI: I think, if I can find table 2. I

(/

14 would say, roughly, 150 supports. Now, when you find 15 none of them overtorqued out of 150, you already have a 16 certain confidence that you have a high probability 17 that none of the others will be overtorqued.

18 MS. ELLIS: You just faded again.

19 MR. WALSH: I got it Juanita.

20 MS. ELLIS: I think that we understood your 21 answer, though.

22 MR. WALSH: Yeah.

23 MR. IOTTI: Is that sufficient, Mark?

24 MR. WALSH: Yeah. That is sufficient. The next 25 item will be number 5, item B. That is on Page 3, and BH NRC-105 f) T-1 16 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 141-1901 e Belt. & Annep. 149-4134

.17

(~)

\- t it is in regards to the friction test.

i 2 MR. IOTTI: Yes.

3 MR. WALSH: Did this friction test include  !

4 cyclic thermal results. If not, I would like to see the 5 effects of cycline thermal results.

6 MR. IOTTI: The friction test did use the l

7 electric load. The cyclic results, because one of these l

l 1

8 specimens.

9 MS. ELLIS: I'm sorry. I can't hear you.

to MR. BURWELL: This is Spot Burwell again. Bob, 11 may I suggest that I contact my operator again, and see 12 if, we can try to get a clear circuit on you.

fw 13 MR. IOTTI: Let me relay my answer to John 14 Finneran, who also knows the answer. Maybe he can make is himself understood better.

16 MS. ELLIS: If you could do it in phrases, 17 sort of, that would probably work.

l 18 MR. FINNERAN: Well, that is going to take j 19 twice as much time. Spot, if you can just to and use 20 another phone and call, and we will keep going.

21 MR. BURWELL: Let me see what I can work out 22 here.

23 MS. ELLIS: Spot. It seems like sometimes we i

24 are hearing him alright and sometimes it fades.

l 25 MR. BURWELL: Yes. I am having the same BH

(~)

k/

NRC-105 T-1 17 FREE STATE REPORTING INC.

Court Reporting e Depositlens D.C. Area 141-1901

  • Belt. & Annep. 149 4134

'- l. b 3

(V 1 trouble.

2 MR. IOTTI: Let me try again. Can you hear me 3 now?

i 4

MS. ELLIS: Sounds good now.

5 MR. IOTTI: We'11 take advantage of the proper 6 airwave. There were on the ten inch scheduled for the 7

stainless steel pipe. Two tests were run. In one 8 instance, the friction test was the same U-bolt, the 9 same type. Eventually, the U-bolt is led by the to difference.to cycling test, because the friction test 11 was repeated.

12 To compare the results of cycling effects on 13 friction, versus what we are going to expect the v

14 friction to be on verging the pipe material and the 15 U-bolt material in different U-bolts placed on a l 16 different section of that pipe or fuse. In fact, we did 17 see some difference in the friction.

18 MR. WALSH: Well, my statement, or my request 19 is to see documentaticn of a U-bolt on the friction 20 test that has exhibited, or excuse me, has experienced 21 the cyclic thermal action that a pipe support will see 22 at Comanche Peak, a direct correlation.

23 MR. IOTTI: Well, there is no.

24 MR. BURWELL Dr. Iotti. This is Spot Durwell.

25 I have talked with my operator. If you will hang up, BH NRC-105 T-1 18 FREE STATE REPORTING INC.

Court Reporting e Depositlens D.C. Aree 141-1901 e Belt. & Annep. 149 4236

I .9 o

V 1 she will try ringing you back.

2 MR. IOTTI: Alright. Will do.

3 MR. BURWELL: Would you try that please.

4 (Brief recess.)

5 MR. IOTTI: Let me rephrase these questions.

6 We would like to have the test results for direct 7 correlation that shows friction between the U-bolt and 8 I formally cyclic thermal tests on the U-bolts. That 9 tests were not right. Ilo w e v e r , that chance was then to (inaudible) by a combination of tests that were 11 conducted on friction varying as the difference about 12 the free load posed on the U-bolt. The thermal driving 13 test shows how much free load is posed on the U-bolt O 14 after it has been cycled. The last effect is to show 15 how much variability there is in friction due to l 16 pollinate the effect. The population of those three 17 tests is what would enable us to determine, for J

18 instance, in the final analysis, how much stress is 19 developed between the pipe and the U-bolt when the 20 torque is applied to the free load.

21 MR. WALSH: Why was it decided not to do a 22 te 9t vith friction and thermal cycling of loads?

23 MR. IOTTI: Simply, time consideration. You 24 have selected the number of tests that would encompass 25 a maximum contination of all of the parameters that you 1

Bli O

'd NRC-105 T-1 19 PREE STATE REPORTING INC.

Court Reporting e Depeeltions D.C. Aree 161-1901 e Belt. & Annep. 169 6134

i 20 O

's 1

wanted to take in a reasonable time.

2 MS. ELLIS: Anything further on that one, 3 Mark?

4 MR. WALSH: No. Item B on page 4.

5 MR. IOTTI: Go ahead.

6 MR. WALSH: Item B on page 4 is the next item.

7 MR. IOTTI: I got it, go ahead.

8 MR. WALSH: In the last sentence of the second 9 paragraph he says the decision to retain an adequate to clamping for it. What is raeant by sufficient? And, how

'11 do you know that it is sufficient?

12 MR. IOTTIt The results of the finite element la analysis and both the results of the tests where we ran 14 the seismic tests as well as the long term vibration 15 test with the minimum clamp supports.

16 MR. WALSH: But, that didn' t include the 17 thermal tests, correct?

18 MR. IOTTI: What dif ference does that make. We 19 ran it at the minimum value of the clamping force.

20 MR. WALSH: Well, if the piping expanded, and 21 the clamps were relaxed, would there still be ,

22 sufficient clamping force?

23 MR. IOTTI: That has been determined. The 24 minimum clamping force that I am talking about, Mark, 25 after the, pipe has done all of that it would be the Bil NRC-105

{J. T-1 20 ,

FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Belt. & Annep. 169 4136

.- 9,. I O

V i clamping force that you are talking about. We 2 determined that from the kind of element analysis.

3 MR. WALSil: On page 6.

4 MR. FINNERAN: Does that mean you don't have 5 any more questions on that, Mark?

l 6 MR. liALSH : Correct. On page 6, item 6, it 7 references a manstran program. Is this the same program j s that Dr. Bjorkman (phonetic) was talking about in the 9 last hearing? -

10 MR. IOTTI: Quite possibly, Mark. There are ti many versions of the program, and they are all called 12 manstran. This happens to be a particular version that 13 has certain capabilities. Now, as I recall, Dr.

O 14 Bjorkamn had not utilized a manstran for his analogies is either. lie utilized (inaudible) .

t r, MR. WALSil The is not the same analysis that 11 Dr. Bjorkamn was discussing then, correct.

18 MR.,IOTTI: This was not the same analysis. We 19 are discussing here, afforded in attachment 3 is the 20 totally independent analysis that CYGNA had done.

21 MR. WALSil: Alright. On page 7.

22 MR. FINNERAN: So, we are all clear on that 23 one, Mark?

24 MR. WALSil On page seven, item two.

25 MR. IOTTI: I don't have an item...oh, sorry, BH NRC-105 Os T-1 21 FREE STATE REPORTING INC.

Court Reporting e Depositlens D.C. Aree 161-1901

  • Salt. 46 Annep. 249 4234

22 i go ahead.

2 MR. WALSH: It states maximum stress in the 3 U-bolts are the results of the worst case load 4 combination evaluatsd compared favorably with test 5 results demonstrated that stress in the U-bolts will 6 not cause any adverse impact. Did these stresses exceed 7 code allowables?

8 MR. IOTTI: I have to go back now and turn to 9 the affidavit. Give me a second. The stresses to calculated in the U-bolt are given on page 48 of the

~

11 affidavit, Table C. I don' t have them, John, what is 12 the code allowable for those U-bolts. Do you remember?

13 MR. FINNERAN: No, Bob. Not of f the top of my 14 head I don't.

is MR. IOTTI: That's my problem right now. I 16 don' t remember right of f the bat whether we could have 17 at least the instance of the floor range 160 has 18 exceeded the code allowables. You understand, of 19 course, that is with a maximum free load that we don' t 20 expect to have. It is a maximum that we chose to 21 analyze with.

1 22 MR. FINNERAN: Isn' t that something that Mark 23 could check on as easy as us, now that he knows where 24 the particular stress level.

BH 25 MR. IOTTI: I think he could check it himself.

' s] NRC-105 -

T-1 '

22 FREE STATE REPORTING INC.

Court Reporting e Depositions

D.C. Aree 161-1901 e Belt. & Annep. 169 4136

23

~%

(V 1 MR. WALSH: Okay. Alright, my next questions 2 was the stresses within the pipe, which is item 3. How 3 does one know that that won't have an adverse impact 4 on the piping system?

5 MR. IOTTI: We have analyzed the stresses in 6 the pipe. We have looked at two different manners in 7 assessing whether the stresses could cause the problem.

8 In either case, we will re' view that the stresses were 9 acceptable, or are acceptable at maximum free load i 10 level. You understand'the-tool gives you no direct n guidance of this.

12 MR. WALSH: 'Wouldn't these stresses be added 13 to the pipe stresses?

14 MR. IOTTI: They were added. The stresses is already present in the pipe were added to the stresses 16 produced by the clamping action on the U-bolt.

17 MR. WALSH: In all cases?

18 MR. IOTTI: In all of the four cases examined.

19 MR. WALSH: No, I'm discussing the piping 20 systems at Comanche Peak that are in place.

21 MR. IOTTI: We added the largest values of the 22 stresses whether they occur at the same point of U-bolt 23 or not. We were conservative for, of course the pipe 24 sizes, that were available.

25 MR. WALSH: And, they will be using these BH A NRC-105 U T-1 23 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 141-1901 e Belt. & Annep. 169-4136

1 f r

?A n

U 1 values, these additional stresses when they perform the 2 stress analysis?

3 MR. IOTTI: The values were added absolutely.

4 So, you can calculate it independently. Previous 5 analysis of piping systems were examined to determine 6 what were, what could be the maximum value of the 7 stresses, regardless of where they occur, though they a had to occur in the piping because that is where we a .have ri-hni t ct , Nnw..ynn take the maximum value for the 10 particular pipe size, and then added that value to 11 whatever stresses were being calcualted by, and I 12 shouldn't talk in stressing densities here, not o 13 stresses. They were added to the stresses calculated by L) 14 the finite element analysis.

15 MR. WALSH: Okay. Will these stresses be added 16 when Gibbs and Hill do their stress analysis 17 evaluation?

18 MR. IOTTI: No. They have been added now.

19 Gibbs and Hill have already done their analysis. We 1

20 have no intention to go back and add these stresses on  !

21 top of Gibbs and Hill. What we did was added Gibbs and 22 Hill on top of these. The two results are the same.

23 MR. FINNERAN: I think to make it clear, the 24 purpose of the analysis and testing that we did was to 25 demonstrate the adequacy of what had been done. There BH NRC-105 (V] T-1 l

24 FREE STATE REPORTING INC.

Court Reporting e Depositions a D.C. Area 161-1901 e Bolt. 6t Annop. 269-6136

2ij f'\

V 1 is no intention to backfit all the stress analysis to 2 add stresses in that we don' t ever agree that was 3 required to be considered. It was clearly to 4 demonstrate the acceptability that we had.

5 MR. IOTTI: Dave. Bob Iotti. Even if we were 6 to do it the other way, as Mark suggests, for us to 7 take the stresses and give them to Gibbs and Hill for 8 them to add, they would come to the same conclusions.

9 They would add it just as we did, and then they would to be faced with the task of determing what the code 11 allows. They would go through the same type of 12 exercise. So, we just went the other way. We took Gibbs fs 13 and Hill stresses and added them to ours, and made the U 14 same determination.

15 MR. WALSH: Okay. I think that clarifles it.

16 MS. ELLIS: Okay, anything further on that 17 one?

18 MR. FINNERAN: No.

19 MR. WALSH: Alright. On page 9, item 13, the 20 first sentence. We would like to see some documentation 21 for the criteria that why these original support 22 designs were intentionally cynched down, the U-bolts.

23 MR. IOTTI: John'Finneran.

24 MR. FINNERAN: Yes.

25 MR. IOTTI: Can you provide that?

BH

(] NRC-105 x_/ T-1 25 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 269-6136

U 2 fl 1 MR. FINNERAN: Tell me what the first sentence 2 says, someone.

3 MR. WALSH: A significant number of U-bolt 4

supgorts at CPSES were ultimately contended to be 5 cynched down.

6 MR. FINNERAN: Well, the documentation for 7 that Mark, would be all the drawings when they were 8 initially released showing zero clearance between the 9 U-bolts and the pipe. i 10 MR. WALSH: I would like to see calculations ii showing that this needed to be performed in the 12 original design calculations.

13 MR. FINNERAN: These U-bolts were always 14 intended to act as clamps. .They were assumed to be the is same as pipe clamps attaching to the pipe. You won't 16 find any calculations in a support documentation about 17 these clamping for pipe supports, either.

18 MR. IOTTI: Well, let's not be too hasty. You 19 will probably find the criteria or...

20 MG. ELLIS: I'm sorry. We can' t hear . you at 21 all now.

22 MR. WALSH: I'm sorry. We are losing that 23 completely now.

24 MR. IOTTI: I would just like to expand on 25 John Fintieran's answer. John, wouldn' t you find on BH

(~) NRC-105

\ T-1 26 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 26f.1901 e Bolt. & Annop. 269-6136

R ~i 7-~.,

k.) i

~

those supports which were always intended to be cynched 2 down, the (inaudible) in the old calculations would 3 assume that there is no free expansion actually in that 4 direction, or sufficient thermal expansion to be given 5 in any other direction.

6 MS. ELLIS: John, if you can hear him can you 7 tell us what he said. We couldn' t hear it.

8 MR. FINNERAN: I will have to apologize, 9 because I lost it too, Bob. Try one more time.

10 MR. IOTTI: John. Where you have the cynched 11 down U-bolts, always intended to be cynched down, 12 wouldn't you expect no axial thermal movement?

g-) 13 MR. FINNERAN: Okay. Bob said that where I had G

14 these, where we had these U-bolts always cynched down, is would we expect no axial thermal movement.

16 Bob, can you hear me?

17 MR. IOTTI: Yes.

18 MR. FINNERAN: These particular U-bolts, Bob, 19 are used on single strutts and snubbers.

20 MR. IOTTI: Okay. You can't exceed more than 21 the movements of...that the snuffer or the strutt 22 permits'you, right?

23 MR. FINNERAN: _That's correct.

24 MR. IOTTI: Forget my question.

25 MR. FINNERAN: I guess I am having trouble BH

) NRC-105

('J k T-1 27 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Aree 261-1901 e Bolt. & Annop. 169-6136

. ,) n ca

\

(/

\- 1 connecting that up with Mark's question, Bob.

2 MR. IOTTI: Well, he was asking what criterion 3 would you use to select when you would cynch them down 4 from A-1 versus, you know, not cynching them down.

5 MR. FINNERAti: Yes. I think he asked me if 6 there were any calculations in the original design of 7 these reports related to the cynching down of these a U-bolts. Is that correct, Mark?

9 MR. WALSH: Yes. There is none, correct?

10 MR. FINFJERAN: I would say that there is none.

11 These were to be assumed to be pipe support clamps, and 12 there would be none for clamps either.

13 MS. ELLIS: Anything further on that?

14 MR. liALSH: Yeah. There is an end of item 15 number 13, there is a reference to go back to the is affidavit at 5. And, at page 5, the last paragraph, 17 table 1 is a partial list of supports. We would like to 18 have the complete list.

19 HR. HORIN: What is this.a list of?

20 MR. WALSH: It is a listing of the reports 21 that are cynched down at CPSES.  !

22 MR. HORIN: Mark, to get back to my point 1

23 earlier, is a list of particular material to anything l

24 that needs to be responded to. Is there some technical 25 information that can be drawn from a list that would be BH NRC-105 b'~l

/ T-1 28 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1902 e Bolt. & Annop. 269-6236

' 2,9 m

( )

1

' helpful in responding? Okay, just a moment Darrel.

2 MR. WALSH:. We would like to have the ones 3 that were excluded for the larger pipe sizes, which 4 have less intense sub supports. In other words, what I 5 am asking for is those ten.

6 MR. IOTTI: Well, this list was compiled as 7 follows. John.

8 MR. FINNERAN: I'm listening.

9 MR. IOTTI: Okay. If there were more than 10 10 supports for that piping size, 10 supports. Then, we 11 listed the ten most heavily loaded.

12 MR. FINNERAN: That's correct.

13 MR. IOTTI: Okay. Where you do not see 10,

(-]x w

14 there aren't ten. What-you see is what you have.

15 MR. HORIN: Okay. John, repeat that for Mark.

16 Could you hear that, Mark?

17 MR. WALSH: Very little.

18 MR. FINNERAN: What' Bob said is the list you 19 have for a particular pipe size is a listing of the 20 highest loaded supports for that size. If there are l l

21 less than 10, then that is all that there is on that 22 pipe size.

23 MS. ELLIS: Oh. Are you saying that even 24 though that there is less than 10, that those 9 or 25 however many there are are still listed?

~

BH

/ , NRC-105 V T-1 29 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 269-6136 '

L .30

\-J 1 In other words, they are included in the 2 table? Is that correct?

3 MR. FINNERAN: What we are saying is that for 4 each pipe size, this list was to list the 10 highest 5 loaded supports for each pipe size. If on this list 6 there are less than 10 supports listed, then that is 7 all the supports of that size for cynched U-bolts.

8 MS.. ELLIS: Right. The way this was worded, it 9 sounded as though these larger pipe sizes which have 10 less than 10 were excluded in some way. That is not it what you are saying?

12 MR. FINNERAN: No.

13 MS. ELLIS: They are still on the list, there 14 is just not ten of them, right?

15 MR. FINNERAN: Yeah. For instance, 514. There

~

16 are only two. We didn' t delete any. There are only two 17 on 14 inch piping.

18 MS. ELLIS: Okay. That is what...that is 19 alright.

20 MR. FINNERAN: Adequate for you, Mark?

21 MR. WALSH: That finishes up cynched up 22 U-bolts.

23 MS. ELLIS: Okay, next will be the axial 24 restraints.

25 BH O NRC-105

\J T-1 30 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1902 e Bolt. & Annop. 269-6236

i- 31 U 1 MR. WALSH: Item one. I would like in item 2 one.

3 MR. IOTTI: Hold it. I have got to get my 4 file.

5 MS. ELLIS: We will take a second for 6 everybody to get their documents together.

7 MR. IOTTI: Can I take one minute for a drink?

8 MR. WALSH: Good idea. The material facts of 9 the actual restraints, we request documentation on the io applicants procedure on modeling trunyans (phonetic).

11 MR. IOTTI: You were right, John.

12 MR. FINNERAN: I'm sorry. I just got back in

, 13 the room.

(v,)

14 MR. IOTTI: Mark is asking for documentation is of the procedures that here utilizes the model, the 16 trunyan. >It is on' item one of the material facts.

17 MR. FINNERAN: Alright, let me look at it.

18 We'11'just have to look into it.

19 MR. IOTTI: Mr. Walsh, I guess we will have to

~

20 provide it to you in narrative form, or the procedure, 21 if an' actual procedure in an actual environment.

22 MR. WALSH: Item number four, page two.

23 .. MR. FINNERAN: Let me clarify that last one.

24 Are ou~looking for a copy of the procedure, is that 25 correct?

BH (3 .NRC-105

'O' T-2 31 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161 1901 e Bolt. (a Annop. 269-6136

s. ') t) i l t, l'~

v 1 MR. WALSH: Yeah. In which describes how they 2 are modeling the trunyans.

3 MR. FINNERAN: This is the Gibbs and Hill 4 procedre?

5 MR. WALSH: Gibbs and Hill and Westinghouse.

6 Both of them. If they are the same, it is either one.

7 MR. IOTTI: Okay. We will get back to you on 8 that.

9 MR. WALSH: Item four. We would like to see 10 the drawing which demonstrates the largest difference 11 when one considers the rotational effects on the 12 support compared to when there is no rotation effects es 13 considered.

b 14 MR. IOTTI: Now, here you say drawings?

15 MR. WALSH: Pardon?

16 MR. IOTTI: Did I hear you say drawings?

17 MR. WALSH: Yes, drawing and calculations.

18 MR. IOTTI: I guess what I am a little 19 confused about is what do you mean by the largest.

20 MR. WALSH: Well, in the last sentence it says 21 that these loads did not exceed applicable allowables.

22 MR. IOTTI: Okay.

23 MR. WALSH: Therefore, a comparison had to be 24 made on all the supports.

25 MR. IOTTI: That is correct.

BH O

'd NRC-105 T-2 32 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 269-6136

.33 g

v 1 MR. WALSH: We would like to see where the 2 largest comparison occured. We would like to see that 3 drawing and the calculation.

4~

MR. -IOTTI : Okay. It will take us just a while 5 to go through and identify-the particular ones that had 6 the largest change, and select that particular support 7 and provide you with a drawing. Is there any problem 8 with that, John?

9 MR. FINNERAN:. None, except that we are flying 10 out tomorrow for a meeting with the NRC. So, we will 11 try and get to it as quickly as possible.

12 MR. IOTTI: When I say quickly, Mr. Walsh. It s 13 is assumed that you will understand that it will 14 probably be no earlier than Monday of next week, is because we will be in Washington the remainder of this 16 week.

17 MR. WALSH: Right. Well, try to do the best 18 you can'. ,

19 MR. FINNERAN: We'll try and get something l I

20 moving on it tomorrow. l 1

21 MS._ELLIS: Okay.

22 MR. WALSH: Okay. Item Number 5. We would like 23 to see the calculations to support CT-1-013-023.

24 MS.'ELLIS: Slow down, do that again, slowly.

25 MR. WALSH: We would like to see the BH p

'l NRC-105 T-2 33 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 1611901 e Bolt. & Annop. 169-6136

~

31 V' 1 calculations on CT-1-013-023-S42K.

2 MR. FINNERAN: Let me play it back to you, 3 Mark. CT-1-013-023-S42K.

4 MR. WALSH: Yeah.

5 MS. ELLIS: Do you want the calculation of 6 drawings?

7 MR. WALSH: Yes, showing that they have taken a into account the double trunyan effect.

9 MR. IOTTI: Okay. i 10 MR. WALSH: And, if it is shown on the 11 drawing.

12 MR. FINNERAN: That what is shown on the 13 drawing?

14 MR. WALSH: The load due to the double trunyan 15 effect.

16 MR. IOTTI: The answer is no. It will not be 17 shown on the drawing.

18 MR. FINNERAN: Did you hear that, Mark?

19 MR. WALSH: No sir.

20 MR. FINNERAN: The load on the drawing will 21 not be the load that reflects the double trunyan 22 effect.

23 MR. WALSH: Why is that?

24 MR. IOTTI: Because we don' t believe that is 25 the best way of modeling the double trunyan. We have BH p

V NRC-105 T-2 34 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 269-6136

t 3 .I)

,m

( )

w/ 1 told you how both Gibbs and Hill and Westinghouse have 2 modeled the double trunyan. What we have then done with 3 the affidavit is attempt to prove to you even had we 4 modeled this, -the way that you would like us to, the 5 load has been computed for each leg of the trunyan 6 would still be within the scope.

l 7 MR. WADE: I think this again is the case  !

l 8 where we have provided additional information to back 9 up the judgements engineering has done previously. We to feel that it is justified and we have no intention of n updating all of the record calculations and drawings in 12 the field. We did this entire effort simply because the es 13 assurance of what we had done was a good judgement _in (s_-)

14 engineering practice.

15 MR. WALSH: Okay. Alright. I'll leave it at 16 that.

17 MR. WADE: Do we still agree to supply those 18 cales?

19 MR. WALSH: Yes. I would still like to see 20 those calculations for that particular support.

21 MR. FINNERAN: You understand that this was 22 only a special calculation for this' particular case.

23 MR. WALSH: Yeah.

24 MR.-FINNERAN: It's not the calculation of 25 record for this support.  ;

BH

(' NRC-105

\/')

T-2 l 35 l FREE STATE REPORTING INC.

Court Reporting e Depositions  !

D.C. Area 261-1902 e Bolt. & Annap. 269-6136

' 3b V 1 MR. WADE: Nor, will it be.

2 MR. FINNERAN: Nor will it be.

3 MR. IOTTI: We will label it as such.

4 MR. FINNERAN: Do you understand that, Mark?

5 MR. WALSH: Alright. We would like the latest, 6 as well as the ones, the effects when it was modeled as 7 a double trunyan.

8 MR. FINNERAN: 'I didn' t understand that.

9 MR. WALSH: Well, didn't Gibbs and Hill 10 reanalyze this, let's say the CG line. Has this support 11 been a double trunyan?

12 MR. WADE: Mark. We have given you a special n

\.J 13 analysis that we did especially for this effort. It is 14 not the calculation of record, nor do we intend for it 15 to be. We are simply doing this to demonstrate that 16 what our initial engineering practice was, was 17 justified. -This is a special calculation done only for 18 purposes of these discussions.

19 MR. WALSH: Well, did Gibbs and Hill reanalyze 20 that line as a double trunyan?

21 MR. - IOTTI : The answer, Mr. Walsh, either one 22 or two.

23 MR. WALSH: Speak up, please.

24 MR. IOTTI: I don't. remember that specific 25 support in that particular line. It may be that that BH

' V() NRC-105 T-2 36 FREE STATE REPORTING INC.

Court Reporting Depositions D.C. Area 161-1901

  • Bolt. da Annop. 169-6136

3/ i i

V 1 support is a support on one of the lines that Gibbs and 2 Hill reanalyze as part of the substantial reanalysis 3 for the purpose of this affidavit. Or, the support was 4 reanalyzed by itself by using a manual method to 5 compute the increase in load through trunyon effect in 6 a conservative manner. So, in either case in analysis 7 or reanalysis of the report was perfected. I just don' t >

8 remember which one of the two this particular support 9 would fall into. But, in either case, we can provide 10 the special calculation.

11 ~ MR. FINNERAN: Did you understand that, Mark.

12 MR. WALSH: I believe so, I have another n 13 question. So, the applicants did not reevaluate the U 14 supports using pipe stress analysis loads, but another is method, correct?

16 MR. FINNERAN: Some supports were evaluated in 17 this special study using the output of analyses that 18 did have these modeled in as double trunyans. Some, 19 conservative loads were generated manually to analyze 20 them. They were not the result of' any additional piping 21 analysis that was done.

22 MR. IOTTI: Bear in mind that the manual 23 method is' guaranteed to produce conservative results.

24 MS. ELLIS: Okay. Did you want anything about 25 the drawings and calculations on'this particular BH

/N NRC-105 T-2 37 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. 66 Annop. 269-6136

- 3S

'~ I support, still, Mark?

2 MR. WALSH: Yeah. Please.

3 MR. HORIN: Mark, let me repeat what I 4 understand you are asking for here. That is, simply 5 whatever recalculation might have been done for our 6 affidavit, with respect to the support, whether it 7 might have been a reanalysis as part of the piping 8 stress, or whether it was a manual method that Dr.

9 Iotti is describing.

10 MS. ELLIS: And you will indicate which, 11 alright?

12 MR. HORIN: It would be obvious.

f- s 13 MR. WALSH: Alright. Let's move on to item

(

v

)

14 number seven. We would like to see some documentation is showing that the applicants are in compliance with the 16 ASME code when it comes to these logs and the stresses 17 that it induces into the piping system. This is the 18 localized stresses if they are wstill within the 19 allowables.

i 20 MR. IOTTI: I thought the documentation had '

21 been provided as part of the examples of finite element 22 analysis that we had given you as attachment one to the 23 affidavits.

24 MR. WALSH: Okay. That is sufficient. That is 25 all I have.on the axial restraints.

BH NRC-105 (V3 T-2 38 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 169-6136

30

(')

'- 1 MR. FLECK: Spot, this is Hank Fleck here.

2 MR. BURWELL: Yes.

3 MR. FLECK: It sounds like the two items that 4 I am involved -in have been covered, so I en going to 5 hang up here.

6 MR. BURWELL: Okay, fine. I take it John 7 Brammer dropped off earlier.

8 MR. BRAMMER: No. I'm still here, but I'm 9 dropping off now.

10 MR. BURWELL: Good night, gentlemen. We will 11 see you Wednesday.

12 MR. FLECK: Right. Bye.

m 13 MR. BRAMMER: Thank you.

(d 14 MR. IOTTI: As a point of information, Spot.

15 MR. BURWELL: Yes.

16 MR. IOTTI: What time is the meeting on 17 Wednesday?

18 MR. BURWELL Nine o' clock.

19 MR. IOTTI: I also ask where?

20 MR. BURWELL: Oh, certainly, I think it is in 21 room 1713 Maryland National Bank Building.

22 MR. IOTTI: Okay. Thank you.

23 MR. FINNERAN: Okay. Do we take up Richmond 24 inserts next?

25 MR. WALSH: Yeah.

~

BH

-NRC-105 (d'\

T-2 39 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 261-1901 e Bolt. & Annop. 169-6136

' 40

\~J 1 MR. IOTTI: Let's hear it, I've got to get the 2 Richmond insert document. Don't fire yet... Fire away.

3 MR. WALSH: Okay. This relates to items 4 and 4 5 on page 2 of the material facts. We would like to see 5 documentation showing that Richmond Screw Anchor 6 company has a quality assurance program, that the 7 inserts used in EPSCS are a reflection of the tests 8 that were performed in 1957.

9 MR. IOTTI: Excuce me, Mr. Wa'sh. l I don' t seem to to be able to find this material.

11 MS. ELLIS: Can' t hear at all.

12 MR. FINNERAN: Dr. Iotti is saying he cannot p 13 find his material facts, and I can' t either. Bob Iotti.

U 14 MR. IOTTI: Yes.

15 MR. FINNERAN: I believe in my stack, it was 16 the very last document, even after all of the 17 attachments.

18 MR. WADE: Motion affidavit even after the 19 statement of fact.

20 MR. IOTTI: Mine doesn't have it so, John. Do 21 you have it?

22 MR. FINNERAN: I believe so.

23 MR. IOTTI:

Well, would you fall along, and I 24 will.try and come in as best as I can.

25 MR. FINNERAN: Okay.

BH

(')

V NRC-105 T-2 40 _

FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 261-1901 e Bolt. 46 Annop.169-6236

v 41 V 1 MR. WALSH: Should I restate the question?

2 MR. FINNERAN: Yes.

3 MR. WALSH: We would like to see documentation 4 showing the Richmond Screw Anchor Company has a quality 5 assurance program, such that the inserts used at CPSES 6 are a reflection of the tests performed back in 1957.

7 MR. FINNERAN: Let me write that down.

8 MR. WADE: John, is that something that we 9 have or something that we have to obtain?

10 MR. FINNERAN: That would probably be 11 something we have to obtain. The only connection that I 12 can see in the current documentation that we have, the em 13 facts, the same type of insert is referenced, the EC

(_) '

14 type.

15 MR. WADE: Are we making a material statement 16 here that this is a fact?

17 MR. FINNERAN: No.

18 MR. HORIN: What do 4 and 5 of the statement 19 of material facts say?

20 MR. FINNERAN: It doesn' t say anything about 21 that. It says, really, it is a listing of the 22 allegations of CASE, that they raised allegations 23 related to number one, the factor of safety use for 24 Richmond inserts, number two the testing of Richmor.d 25 inserts, Number 3, the ability of Richmond inserts to BH

/m NRC-105 d T-2 41 FREE STATE REP'JRTING INC.

Court Reporting , Depositions D.C. Area 261-1902 e ben. & Annop. 169-6136

d2

' I resist actual torsion. Number 4, the methods used to 2 analyze connections.

3 MS. ELLIS: We are talking about items 4 and 5 4

on page two.

5 MR. FINNERAN: Oh. I'm sorry. I thought you 6 were talking about items 4 and 5, and Item 1.

7 Okay.

MS. ELLIS:

.8 MR. FINNERAN: Alright. Well, the 9 documentation there would be the recommended allowable 10 loads in the Richmond Screw Anchor catalog for the type 11 of inserts we are talking about.

12 MR. WALSH: Yeah. But, we are requesting rw

() 13 14 documentation showing that the Rich, that the anchors that they are producing now, is still a reflection of 15 the test back in 1957.

16 MR. HORIN: John. Does the additional testing 17 that ew performed demonstrate that the anchors were at 18 least as strong if not stronger.

19 MS. ELLIS: You lost me on the last part 20 there.

21 MR. FINNERAN: I think Bill Horin is saying 22 that the additional testing we have done shown that the 23 anchors are at least as strong or stronger than the 24 previou 1957 test.

25 MR. HORIN: So, my question is how is the BH NRC-105 l

(] -

T-2 42 FREE STATE REPORTING INC.

Court Reporting e Depositions

- D.C. Area 161-1902 e Bolt. & Annop. 269-6236

.. tj ,' }

V) t 1 request you are making, Mark, really material to the 2 ultimate issue?

3 MR. WADE: Well I think that that is the 4 thing, Bill. But, it is also true that Richmond 5 represents in their most recent catalog the same data.

6 That, in itself states it there behind the test data 7 produced in 1957.

8 MR. WALSH: So, Richmond does not test these 9 anchors when it makes them. It just sends them out and 10 just assumes that they are as good as some time ago.

11 MR. WADE: We didn' t say that they didn' t have 12 a destructive test periodically. That is something that n 13 would have to be confirmed. But we know from our test U 14 data that the numbers good.

15 MR. HORIN: My point is Mark, that 16 irrespective of what Richmond does, the purpose of our 17 affidavit was to demonstrate the capacities of the 18 Richmond in various loading combinations, and we did 19 our own independent tests. That is really what we are 20 relying on in our affidavit.

21 MR.'WALSH: Alright.

22 MR. HORIN: Bob, correct me if I am wrong.

23 MR. IOTTI: I think you are right.

24 MS. ELLIS: Really in effect, you are saying 25 that what you are saying in items 4 and 5, you are not BH

[] NRC-105 v T-2 43 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. Et Annop. 269-6136

u .} .]

1 relying on?

2 MR. HORIN: Well, I'm not saying that either.

3 I am saying whether I am questioning Mark's request is 4 really important to the ultimate question given what 5 our tests have shown.

6 MS. ELLIS: I think is only important as far 7 as the fact that you have put it in your af fidavit 8 here, and in your material facts. It is something that 9 we have to address. If you are relying on it fine. If to you are not relying on it, we will forget it.

11 MR. IOTTI: Bill or John, would you read me 12 statement 4 and 5 of material facts?

g) 13 MR. FINNERAN: Okay, Bob. Statement 4 says V

14 the current allowable recommended load for the inserts 15 by the Richman Screw Anchor Company are based on tests 16 conducted at the Polytechnic Institute in Brooklyn in 17 1957.

18 MR. IOTTI: That is correct.

19 MR. HORIN: Yes, Mark. Your question has no 20 bearing as to whether that statement is true or 21 correct. We stand on that statement irrespective of 22 your question. Number 5, John.

23 MR. FINNERAN: Number five says, data from the 24 manufacturer's test reflect a failure in all sheer BH 25 tests and the 1-1/2 inch tension test of card due to O NRC-105 T-2 44 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. 46 Annop.169-6136

t 4 ,']

U 1 failure of the anchor stud bolts, not failure of the 2 inserts. Failure in the 1" tension test occurred due to 3 the failure of the inserts by concrete cone pullout.

4 MR..IOTTI: That is correct. That statement 5 that shows that can be made available.

6 MS. ELLIS: I couldn' t hear the last part of 7 what he said.

8 MR. FINNERAN: He said that that statement of 9 material fact is correct, and has added to substantiate 10 that can be given to you. I think you may already have 11 it. It is in the record.

12 MS. ELLIS: If it as the same that is attached 13 to 142, do you have 142?

d 14 MR. FINNERAN: Part of it. I am not sure if 15 142 has the 1-1/2 inch and the 1" . Part of it does.

16 Part of it is in 142.

17 MR. WALSH: Okay..Let's go on.

18 MR. HORIN: You don't need anything else then, 19 Mark.

20 MR. WALSH: No. Item 7 on page 3. We would 21 like to see documentation showing the applicants, 22 structure designers and/or engineers to check the 23 capacity of the threaded rod. Also, verification of 24 threaded rod capacity as judged, for example, in 25 support number MS-1-02-003-C72S from NPSI. We would BH NRC-105 (V^h T-2 45 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 169-6136

dC g

\J 1 like to see the original calculations with the original 2 drawings that would verify that the AGE seven bolts is 3 checked or the bolt that is utilized there is checked.

4 We would like to see an example from the PSG group 5 original design prior to 1982, or June of 1982.

6 One ITT Grinnel original calculation as it 9

7 was sent out showing that they checked the bolt 8 capacity as well as the moment limiting restraints that 9 was discussed in the hearing. The calculation is to performed by Gibbs and Hill. We would like to see the 11 original calculations showing that the Richmond inserts 12 that were utilized that review was checked.

-w 13 MR. HORIN: John.

_]

14 MR. FINNERAN: I'm trying to write all of this is down.

16 MS. ELLIS: Do you need for us to go through 17 it a little slower?

18 MR. IOTTI: I think what he is reallj saying 19 is please do the calculations and indicate what 20 consideration was given to the allowables.

21 MR. WADE: Dr. Bob, we can' t hear you at all.

22 MR. IOTTI: Did I hear you say no?

23 MR. FINNERAN: Yeah. Now we can hear you.

24 MR. WADE: We couldn' t hear you at all.

25 MR. IOTTI: I said that I think that what he BH

(~S NRC-105 k- T-2 46 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 261-1902 e Bolt. 66 Annop. 269-6136

e tj 7 n's./ 1 is asking is in an abbreviated way for us to produce 2 calculations for each of the designers, VSE, ITr, and 3 NTSI, that shows that they have considered the minimum 4 of either the insert or the bolt, whichever is left in i

5 terms of designing the support.

6 MR. WALSH: In the original designs prior to 7' 1982.

8 MR. FINNERAN: Okay.

9 MR. WADE: John, we are agreeing to provide 10 that?

11 , MR. FINNERAN: Well, I don't. I think we 12 already have in the record the allowables f rom SS30. I

,3 13 assume he asking for some kind of backup calculation on 14 those.

15 MR. WADE: Looking for examples from each 16 organization, Gibbs and Hill, ITT, VSE and MPSI that 17 they in fact did check the accuracy of the threaded 18 rods in the original design counts. Is that correct, 19 Mark?

20 MR. WALSH: As well as pipe support labeled 21 MS-1-02-003-C72S. I believe that is an NTSI support, 22 but I am not sure. And, the calculations on limiting 23 restraint that is done by Gibbs and Hill that was used 24 in these hearings.

25 MR. WADE: I'm not sure which specific moment BH

/3 NRC-105 V T-2 47 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 169-5136

AS

,a i 4 kJ 1 restraint we are referring to. I know we have discussed 2 moment restraints in the hearings. Do you have one 3 particular one in mind that you can identify?

4 MR. WALSd: I believe we only looked at one in 5 the hearing.

6 MR. FINNERAN: Can you give us some additional 7 guidance as to what context it was, something to 8 identify.

9 MR, WALSH: It utilized alec, Richmond 10 inserts.

11 MR. WADE: I recall one such case where we 12 discussed it. I believe there were numerous cases that 13 were brought up at the same time. Do you have a drawing 14 number or anything?

15 MR. WALSH: It is incorporated in Jack 16 Doyle's exhibit, or CASE's exhibit tract oil drawings.

17 MS. ELLIS: Okay. Why don' t we try to ' find 18 that drawing number and let him know what it is.

19 MR. WALSH: Okay.

20 MR. FINNERAN: I think I know which one it is.

21 MS. ELLIS: You know which one it is, John?

22 MR. FINNERAN: Yes.

23 MS. ELLIS: Okay.

24 MR. WALSH: That'will finish the Richman.

25 MS. ELLIS: Next will be stability, I guess.

BH NRC-105 T-2 48 FREE STATE REPORTING INC.

Court Reporting e Depositbns D.C. Area 161-1901 e Bolt. & Annop. 169-6136

'! .9 1 MR. FINNERAN: Do you have your file, Bob?

l 2 MR. IOTTI: Just a second, I am reasonably l

3 organized.

l 4 MR. FINNERAN: I say more than reasonably 1

5 organized.

6 MR. IOTTI: I sure would like to know what 7 happened to the material package to Richmond. Bring an a . extra copy, will you?

9 10. WADE: John's unstapled the mat.

10 MR. BURWELL: Gentlemen?

11 MR. FINNERAN: Yes.

12 MR. BURWELL: I believe we have identified fm 13 that moment restraint you were talking about a minute U 14 ago.

15 MS. ELLIS: Okay.

16 MR. BURWELL: It is 699B Doyle deposition, 90 17 MS. ELLIS: 907 18 MR. BURWELL: 90. It continues on 9R.

19 MR. MIZUNO: It was more than one page.

20 MR. BURWELL: It is bound in the transcript of 21 May 17, 1983. I believe it is bound in following page 22 6224.

23 MR. WADE: That will help.

24 MR. WALSH: Okay. Alright, on stability, I'm 25 going to material facts again. Item number 3. We would BH O, NRC-105' V T-2 49 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1902 e Salt. is Annop. 269-6136

50

(~

\- 1 request documentation to an explanation for the reason 2 there were unstable supports to begin with.

3 MR. FINNERAN: We haven't said there were any 4 unstable supports.

5 MR. WALSH: In item 4, it states a hold was 6 placed on a further design to this type of support.

7 MR. FINNERAN: Potential instability.

8 MR. WALSH: To accept whether or not they 9 were. So, we would like an explanation, then why would 10 a support designer issue a support that was potentially 11 unstable in the first place.

12 MR. FINNERAN: I think we explained here that

<s 13 these potentially unstable back frame supports were not N.]

14 designed by the original designer. They were field is modifications made by the field engineers.

16 MR. HORIN: We provided the documentation with 17 the motion and affidavit placing the hold on further 18 designs of that type by the field engineer, following 19 through on the assessment of whether they made...

20- MR. WALSH: Alright. I will go right on to 21 item number 4.

22 Were there any classes or sessions or 23 instructions provided to the engineers to show them 24 what an unstable support was? The field engineers.

25 MR. FINNERAN: The field engineers, is that BH

NRC-105 T-2 50 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 261-1902 e Bolt. & Annop. 269-6136

I5}

( )

v 1 what you said?

2 MR. WALSH: Yes.

3 MR. WALSH: John.

4 MR. FINNCRAN: Just a second. I don't know of 5 any formal classes or instructions that were given to 6 the field engineers as a result of identification of 7 these box frames. The potential problems with these box 8 frames were communicated verbally amongst the field

[ engineers.

10 MR. WALSH: So, what is meant by a hold was 11 placed on approval? What is meant by a hold. Is that a-12 CNC NCR?

f-w 13 MR. FINNERAN: A hold means that none of the G) 14 supports would be approved by the original designer is until the potential has to build the issue has to be 16 resolved.

17 MR. WALSH: How does one know that the support 18 was stable or not. How did Comanche Peak put a hold on 19 the_ supports.-Did they already know which ones were and 20 which ones weren' t and they immediately put a hold on 21 every one of them?

22 MR. FINNERAN: I think Mr. Abeley's (phonetic) 23 -letter says that supports of this type, of the box 24 frame type, as he indicated in his memo would be put on-25 hold.

SH O NRC-105 V T-2 51 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 261-1901 e Bolt. & Annep. 169 6136

I 1

s s .' t ;

i) <

(' 1 MS. ELLIS: What their hold tag applied?

2 MR. HORIN: No. Juanita, this is simply a hold 3 in the approval process. The memorandum that we 4 provided with the motion shows the written direction 5 that this hold be placed on the approval, on this 6- particular type of support. There is no need to do 7 anything in the field. It is in the approval process 8 back in the office. This memorandum gets in that 9 direction, and all parties that were required to be 10 aware of that were made aware of that. The 11 determination as to whether these supports may, in fact 12 be unstable was then conducted separately.

,fq 11 MR. WALSH: Was this hold method, or method of V

14 holding a method of trending?

15 MR. WADE: I think we are getting a feel for 16 the subject here, aren' t we Bill.

17 MR. FINNERAN: No. We simply listen to the ITT 18 engineers until the issues were involved with these 19 supports. None of-these supports were to be-approved.

20 MR. WALSH: Did TSE have any of these 21 problems?

22 . MR. FINNERAN: _All of the supports were ITT 23 supports.

24 MS. ELLIS: I'm not sure I understand you. Did 25 you say that all of the supports were ITT?

BH

(] NRC-105 T-2 a

52 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 269-6136

b3 o

k' 1 MR..HORIN: They were all on ITT design, John 2 believes.

3 MR WALSH: NTSI had no unstable supports? Is 4 that correct, John? Ia that what you are saying?

5 MR. FINNERAN: We haven' t said that anybody 6 had any unstable supports there, Mark.

7 MR. WALSH: Well. We are talking about this 8 hold. Now, did this hold apply to, also to the NTSI 9 supports?

10 MR. FINNERAN: This hold that we are talking 11 about here is a hold that was placed on by Gus Aveley 12 of ITT. It was a hold against the box frame pipe gm 13 supports. All of those were on ITT design.

\

14 MR. WALSH: Did that include NTSI supports?

15 MR. FINNERAN: No. That hold was not.on any 16 design by NTSI. Mr. Aveley was with ITT.

17 MR. WADE: I think what John said is that 18 there were no NTSI supports that fell in that category, 19 nor was there any TSE supports that fell in that 20 category.

21 MS. ELLIS: That's what we were asking him.

22 MR. WALSH: So, the only documentation to this 23 is this letter? Is 'this letter attached to the motion?

24 MS. ELLIS: For the affidavit.

25 MR. HORIN: I believe there were two BH

^'

/ NRC-105

\ ') T-2 53 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901

  • Solt. & Annop. 169-6136

$.j

(~'s kJ 1 memorandums with the affidavit.

2 MR. WALSH: Which one is that?

3 MR. FINNERAN: Attachment A-1 to the 4 affidavit.

5 MS. ELLIS: To the affidavit.

6 MR. WALSH: Just a moment. I can't find that.

7 A-l?

8 MR. FINNERAN: Second page.

9 MR. WALSH: This is the bi-weekly report?

10 MR. IOTTI: Yes.

11 MR .- FINNERAN: That's it. Number CG36.

12 MS. ELLIS: Okay.

MR. WALSH:

(q) 13 This is the item where he orders 14 his pens and pencils, right.

15 MR. FINNERAN: I don' t know what you are 16 talking about. The statement that we are talking about 17 is page 2, item 6, the last sentence.

18 MR. WALSH: And it is dated May 22?

19 MR. FINNERAN: No. Yes, dated May 22. Right, -

1 l

20 1981... '

21 MR. WALSH: Now, dated, on attachment 3, and 22 it is dated 4-2-82. ,

l 23 MR. FINNERAN: Right.

{

24 MR. WALSH: How would this letter reflect that l

25 hold? '

BH

(~'T NRC-105 k/ T-2 54 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 169-6136 e

s~ .~

i);)

v 1 MR. FINNERAN: Attachment A, that's one. It 2 saysthat technical services of all supports using box 3 structures as attachments until written procedure or 4 approval from provident is received.

5 MR. WALSH: Yeah.

6 MR. FINNERAN: In attachment A-2 reiterates to 7 the ITT home office that they are requesting 8 as'essment s to the situation of ITT home office, 9 assessment A-3 is a request from ITT home office for to more information to allow them to proceed with that 11 assessment.

12 MR. . WALSH: Who is Ron Wiesinski (pnonetic)?

q 13 MR. FINNERAN: He was in the home office.

V 14 MR. WALSH: So, this was from the home office is to us.

16 MR. FINNERAN: Attachment A3, correct.

17 MR. WALSH: Alright. This came from the home 18 office to the site. The home office, item 2, it is 19 saying to the site people define stability? I would 20 like to know how the Attachment A3 solved the problem?

21 MR. FINNERAN: .We didn' t say that attachment 22 A3 solved the problem? I 23 MS. ELLIS: Was there an answer to Attachment 24 A3?

25 MR. FINNERAN: I don' t recall.

BH'

-~) NRC-105 V T-2 55 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 169-6236

?b VJ

' )

1 MR. IOTTI: John.

2 MR. FINNERAN: Yeah, Bob.

3 MR. IOTTI: My recollection is that eventually

'8 TSE got so fed up with the inability of ITT to resolve 5 these issues, that...

6 MS. ELLIS: I'm sorry. I can't hear him at 7 all.

8 MR. FINNERAN: Well, all you have to do is to 9 go to.our affidavit to see what occurred here. 1 10 Eventually, as we said in our affidavit, and I want to 11 find you the place.

12 Okay, it is on page 11 of the affidavit. We p 13 say, the very last sentence on the page, when question L) 14 had not been resolved by ITT by September of 1982. He is directed that the support be modified to improve 16 stability. -

17 MS. ELLIS: Okay. I think that what we would 18 like to have is any answer that was made, any backup 19 notes, any handwritten notes having anything to do with 20 this particular matter in answer to attachment A3, and 21 any subsequent information that went back and forth 22 regarding this' matter. l 23 MR. HORIN: Juanita. '

24 - MS . ELLIS: Yes.

25 MR. HORIN: How is'that, I don't even know if BH

^

NRC-105

'[V T

T-2 56 FREE STATE REPORTING INC.

Cotert Reporting e Depositions D.C. Aree li -001 e Bolt. & Annop. 169-6136

i 5 'l V 1 there is any material that would fall into the scope of 2 that request. How is that material to the disposition 3 of this issue. We have already established in or 4 affidavit how it was ultimately resolved. We stated 5 that it had not been resolved.

6 MS. ELLIS: You are fading there at the last.

7 How what?

8 MR. HORIN: We stated in the affidavit that it 9 had not been resolved by September 1982. They usually 10 took it upon themself to be directly resolved. I simply 11 don' t see how additional documentation along those 12 lines that you are requesting is material to the position of the issue.

(qs 13 I think given the lateness of 14 the hour and this exercise, I think that one falls on is the side of matters that are not really important to 16 this issue.

17 MR. WALSH: I object to that one. The method 18 the applicants utilized in addressing this topic. It

~

19 would appear that they knew it in 1981', and didn't make 20 a modification until late of 1982.

21 MR. HORIN: Those are the facts, and we set 22 out the facts. Alright. We have given you the 23 communication that went back and forth, and we have 24 given you the matter in which was ultimately resolved.

25 -MS. ELLIS: I think, Bill _, if you look at BH p) NRC-105 i' T-2 57 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Belt. & Annop. 269-6236

4 l

l

(~h.

'N> 1 material facts number four, that answers your question. I 2 I think it totally ties in to that.

3 MR. HORIN: Read it to me.- I don' t have a copy 4 of it.

5 MS. ELLIS: Applicants promptly identified and 6 acted to correct potential instabilities of piping 7 supports at Comanche Peak over the course of the design 8 process.

9 MR. HORIN: We did promptly identify them, and 10 proceeded to resolve the issue.

11 MS. ELLIS: And acted to correct. We want to 12 know what you did, in fact, to correct it, including 13 the documents that we have asked for.

v 14 MR. HORIN: We have given you the complete 15 list of what we did.

16 MS. ELLIS: I think we made pretty clear the 17 documents that we would like to have.

18 MR. HORIN:'I realize you made that clear, but 19 .what I am saying is that we have provided the 20 information which sets out the steps that were taken in 21 this exercise. When it was initially identified, the 22 additional communication transpired how it was 23 ultimately resolved. I_think the material facts that 24 have been presented and the documentation that has been 25 presented for material facts has been provided.

BH

/'T NRC-105

(_) T-2 58-FREE STATE REPORTING INC.

Court Reporting

  • Depositions D.C. Artm 261-1901 e Bolt. & Annop. 169-6236

30

(~')

V 1 MS. ELLIS: Okay. Are you saying that there 2 was no answer ir writing to attachment A3 or any 3 subsequent inforamtion in writing either informally or 4 in the form of phone calls with, perhaps, documented 5 discussions, and so forth.

6 MR. HORIN: I am not aware of whether there 7 was or whether there was not. All I am saying is that 8 given the memorandum, the three memcranda which we have 9 provided to_you, I believe John, what is A3 dated? Is to that in April of 1982?

11 MS. ELLIS: Yes.. It is April 2, 1982.

12 MR. HORIN: Okay. As we stated, it was still 13 being kicked about with ITT and whether or not ITT was f-)

C/

14 doing something internally, we are not sure. But, when 15 it came to September of 1982, we decided that we were 16 going to take it upon ourself to do something. I don' t 17 see how it is material whether ITT is doing more 18 internally or not. There has not been a final 19 resolution as of September 1982. That is the material 20 ' fact.  ;

l 21 MS. ELLIS: Okay. I think in this particular l

l 22 instance, we will probably be following up with the i 1

23 board on this. I think it is within the realm of what.

24 should be provided. I think it is very relevant to item l 25 4. I think you understand our' position.

BH O

NRC-105 b T-2 l

59 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 169-6136

60 (m,

'N ') 1 MR. HORIN: I understand your position. I say 2 that you should sit back and look at it and step back a 3 step, and see what is really material.

4 MR. WALSH: Okay. Something you just sai.d, 5 Bill.

6 We would like to see some documentation that 7 indicates two chiefs knew there was a problem. They 8 acted on it, prior to July of 1982.

9 MR. HORIN: John, correct me if I am wrong, 10 but I think we were just generally aware of the 11 question. I don' t know if -there is any separate 12 documentation on it.

fm 13 MR. FINNERAN: That is correct.

(.) 14 MR. WALSH: How~were you aware?

15 MR. HORIN: John.

16 MR. FINNERAN: How were we aware?

17 ~MR. WALSH: Yes.

18 MR. FINNERAN: As I said, there was verbal 19 communication concerning these box frames on the job 20 site, and the fact that there were these questions of 21 potential stability that just Aveley raise. l 22 MR. WALSH: Was information that got the belly 23 raised, sent to Texas Utilities?

24 .MR. FINNERAN: I don' t think they got the copy 25 of Texas _ Utilities on this particular memo that he BH

(~') NRC-105

' T-2 60 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 2611902 e Bolt. & Annop. 269 6236 I

m

b }.

o O 1 sent. But, he was in the field group at the time. He 2 certainly had discussions with other field engineers.

3 He'obviously passed this information along to the 4 service engineers. All of those people have contact 5 with TUSI (phonetic) 6 MR. HORIN: Technical Services Engineers are 7 not organizations in specific, are they John?

8 MR. FINNERAN: I didn't hear that.

9 MR. H.OhIN: I said the Technical Services to Engineers are not specific to any one design 11 organization?

12 MR. FINNERAN: Well, they are representatives 13 of, at this' time they were representatives of ITT and

-14 NSSI in the technical services group.

15 MR..HORIN: But, they were all working 16 together.

17 MR. FINNERAN: That's correct.

18 MR. WALSH: So, there is no documenation. What 19 documentation does TUSI have to avoid a reoccurance of 20 this problem from the field engineers.

21 -MR. WADE: Again, we have never said it is a 22 problem.

23 MR. WALSH: So, you did not recognize it as a 24 potential problem, is that correct?

25 MR. FINNERAN: No. That is not correct. We

~BH O NRC-105 k T-2 61 FREE STATE REPORTING INC.

Court Reporting e Depot.itions D.C. Area 2611901 e Bolt. 46 Ar.nop. 269-6136

1 l

l

' oil V 1 obviously recognize it as a potential problem, and that 2 is why we wrote the memo.

3 MR. WALSH: Which memo is this?

4 MR. FINNERAN: Dr. Aveley's memo.

5 MR. WALSH: But, that is not TUSI. I said 6 TUSI, not ITT Grinnell.

7 MR. WADE: ITT is the one that is ultimately 8 responsible for the design,.not Texas Utilities. This 9 is an oversite function. When we did identify or 10 understand what the issue was, we did take an action.

11 W' en we saw that the issue didn' t get resolved in a 12 prompt manner, if we~would have expected it took our 13 only week to get it resolved.

14 MR. WALSH: Yeah, but I believe Mr., I don't 15 believe. . . John just stated that it wasn' t on that list 16 to see that letter. So, how would he know about this?

17 MR. WADE: Because it was discussed openly on 18 the site, and was well known by the people on the site.

19 MR. WALSH: So, it was a commonly known '

1 20 problem that the supports were unstable? ,

1 21 MR. WADE: It was a commonly known problem 22 that the supports were unstable. We don't agree that 23 they are unstable. We agreed it was understood that the 24 issue had been raised and was being discussed, and that 25 action was being taken. We knew that action was being BH tO NRC-105 V T-2 62 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901

  • Belt. 66 Annep.169-6136

< G3

,m

(- 1 taken on the part of ITT Grinnell. So, we gave them 2 what we felt was an appropriate amount of time to 3 respond. When it was not resolved, we took our own 4 action to resolve it.

5 MR. WALSH: Is modifications that occurred 6 after the 1981 memo still ended up on the stable 7 supports.

8 MR. WADE: We don' t agree with that.

9 MR. WALSH: Well, then there is no other 10 unstable supports created.by the field engineers after 11 May of 1981?

12 MR. FINNERAN: We will take issue with your 13 characterization of them as unstable supports.

v 14 MR. WALSH: Yeah. Other than that, that letter is from Grinnell, or Gus Able from his home office, was it 16 correct, the unstable supports being generated by the 17 field?

18 MR. FINNERAN: His letter doesn' t have 19 anything to do with what the field engineers might do.

20 His letter is saying that technical services the ITT 21 review engineers are not to approve any of these 22~ supports until the issue gets involved. Those fellows 23 do not write the C&C's, the ITT engineers.

24 MR. WALSH: Mr. Able, or Abeley. Is he part of 25 Tech Services or field engineering?

BH O, NRC-105 V T-2 63 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 169 6136

bd 1 MR. FINNERAN: At this point and time he was a 2 member of field engineering. He was also the lead ITT 3 engieer on site. That is why he was the one writing the 4 memo back to the home office. So, he was representing 5 Tech Services in this regard...

6 MS. ELLISh Has it now been lifted?

7 MR. FINNERAN: I think that we state that 8 since that he directed the supports, all of these 9 bi-frame supports, be modified to improve their lo stability. If you want to assume that is a lif ting of 11 the hold. The supports were approved by ITT, but only 12 af ter modifice.tions to the facility then.

MR. WALSH: Alright. Just, I think, a couple (p) 13 14 of more items here. I think John jsut stated that a is hold was put on for Tech Services to approve those type 16 of supports. What was done to stop the field engineers 17 from Creating those type of supports?

18 MR. FINNERAN: That was by word of mouth by 19 Mr. Aveley, because he was a member of the field 20 engineers at that time.

21 MR. WALSH: And this word of mouth is the only 22 documentation that we have had?

23 MR. FINNERAN: That's correct.

24 MS. ELLIS: Just to be sure, there was no 25 NCR's? or IR's, no BMC, no DCA or anything like that O BH

\~ ' ' -NRC-105 N

FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. 46 Annep.169-6136 L

b[j

- I written up, correct?

2 MR. FINNERAN: No.

3 MS. ELLIS: Thank you.

4 MR. HORIN: John.

5 MR. FINNERAN: Yeah.

6 MR. HORIN: Were any of this type of support 7 created by the field engineers following, you know, a 8 short period of time after the 1981 memo?

9 MR. FINNERAN: Bill, I don' t know that. We 10 didn't look into that.

11 MR. WADE: John, weren' t there some specific 12 C&C's issue that were issued with the specific intent

<g 13 of -improving this facility?

O 14 MS. ELLIS: I'm sorry, I can' t hear you David.

15 MR. WADE: I said , wasn' t there some C&C's 16 that were issued specifically, including that they were 17 being issued to improve the stability.

18 MR. FINNERAN: That's correct.

19 MR. WADE: Would that be in relationship to l

20 this memo? l 21 MR. FINNERAN: It could have been, David. It 22 could have been in reaction or relation to the verbal 23 discussion of these supports in the field at that time.

24 MR. WALSH: Could we have a copy of that C&C 25 then?

T BH NRC-105 T-3 65 FREE STATE REPORTING INC.

Court Reporting Depositions D.C. Area 261-1901 e Bolt. & Annep. 269-6136

[$ f}

(3 kJ 1 MS. ELLIS: Or of all of them, if there is 2 more than one?

3 MR. FINNERAN: Which C&C?

4 MR. WALSH: The.one that you just said that 5 may have been issued to improve its stability.

6 MR. HORIN:- I think that has already been 7 provided months and months and months ago in the 8 hearing.

9 MR. WALSH: That would be the one that you are io referencing right now?

11 MR. HORIN: That is the one that I was 12 referring'to and it was discussed in the hearings.

n 13 MS. ELLIS: Okay. Just the onc, 1 understood t, )

14 you to say that there was Sub'C&C's. Was I wrong about is that?

16 MR. FINNERAN: I was just remembering myself, 17 the one that we talked about in the hearing.

18 MR. HORIN: Whatever is 'in the hearing record 19 is the only thing we are referring to. That is the only 20 thing that I have any knowledge of.

21 MS. ELLIS: Okay.

MR. WALSH:

~

22 Alright, on page 4, item 8 of the 23 material fact. We would like to see the 15 supports as 24 they were and as they are now. We would like to see 25 the calculations that made them stable, I guess it is.

O V

BH NRC-105 T-3 66 FREE STATE REPORTING INC.

Court Reporting Depositions D.C. Area 161-1901

  • Bolt. & Annop. 169-6136

G7

/m

- 1 MS. ELLIS: Okay. You want to see the drawings 2 and calculations as they were then and as they are now?

3 MR. WALSH: Yes, and one other item.

4 MS. ELLIS: Wait just a second. Let me write 5 that down.

6 MR. IOTTI: Which category is this?

7 MR. FINNERAN: You don't have a statement of 8 material facts?

9 MR. IOTTI: No.

10 MR. FINNERAN: This is when we talk about, let e v *.

11 me go back just a second.

12 MR. IOTTI: We are talking, basically, about a 73 13 main steam report.

U 14 MR. FINNERAN: We are talking about the main 15 steam support, and item number 8 in the material facts 16 refers to page 18 of the affidavit. Okay, we are 17 talking about 15 supports, 13 of which remain steam 18 supports. These were supports which in the original 19 design main steam supports had the eighth inch gap in 20 the. design. I believe CASE already has some of these 21 drawings and has entered them into the hearing.

22 MR. WALSH: We want to make sure we are 23 talking about...

24 MR. FINNERAN: Most of the other drawings will 25 essentially be the same. They will show that there is

/~Ni BH

\/ NRC-105

T-3 U

FREE STATE REPORTING INC.

Court Reporting e Depositions i D.C. Area 161-1901 e Bolt. & Annop. 169-6136 i  !

GS n

U 1 no value to the eigth in gap.

2 MR. WALSH: We want to make sure tat we are 3 talking about the same 15. I don't think we have ever 4 seen all 15 and correlated them.

5 MR. HORIN: I'm having trouble seeing why we 6 have to go into all 15 of them.

7 MS. ELLIS: I don' t think that 15 is an a unreasonable number for this _particular one. The 9 (inaudible) is one of the important things that, I 10 think we are interested in.

11 MR. FINNERAN: I don' t see what this is going 12 to show you beyond what you already have. We have some drawings which show an eigth inch gap between the Q 13 14 U-bolt mechanism, the U-bolt plant mechanism and the 15 pipe. What is a drawing showing the same thing going to 16 give you?

17 MS. ELLIS: The problem is that we don' t have 18 them identified in the af fidavit or in the material' 19 facts. If you could tell us which ones they are and 20 point them to us, that would be fine if we got them. If 21 we don' t have them, we would like to have it.

22 MR. WADE: John. I think on page 15 of the 23 affidavit we talk about these potentially unstable 24 supports. . We talk about U-bolting strutts and solid 25 gap. For example, we say it is exhibit 669B40. So, all O BH V NRC-105 T-3 68 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Belt. & Annop. 169-6136 l

C .9 (d~') 1 of them.will essentially look like this. They will hae 2 an eigth inch gap in them.

3 MR. WALSH: Well, John, I think it would be 4 just best if you were to give us the 15 support 5 drawings and the calculations before and after, so that 6 when we run across it, we won't say, well, this is a 7 support that was not noticed already or something like 8 that. For example, during the CYGNA hearings, we found 9 another unstable support that was modified. We don' t to know if that was part of 15. So, if we were to give you 11 those (inaudible), if we should add to it, or if...

12 MR. HORIN: Mark. We have already identified O 13 the type of support. We can justi give a list.

(

14 MR. FINNERAN: Yeah. I will give you a list of 15 the main steam supports. That will allow you to 16 identify them.

17 MR. WALSH: Well, we would also like to see 18 which organization originally designed them, and which 19 organization is responsible for the. final design, ECD.

20 MR. FINNERAN: The main steam supports, ITT 21 was responsible for all the designs.

22 MR. WALSH: And, the other cens?

23 MR. FINNERAN: Which other ones?

24 MR. WALSH: Well, there is 15, and there is 25 only 13 main steam supports.

O C'

BH NRC-105 T-3 69 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 o Belt. & Annep. 269-6136

?l)

O

'w/ 1 MR. FINNERAN: I think the other two are ITT 2 also. I can confirm that.

3 MR. WALSH: Alright. So, one of them is the 4 residual heat system.

5 MR. WADE: That was definitely ITT.

6 MR. WALSH: I don' t know what the other one 7 was.

8 MR. WADE: We can discuss that against a list 9 of all (inaudible).

10 MR. WALSH: Alright. If you provide us with 11 the numbers, and who was doing the other two while a 12 list of the organizations that would be sufficient.

13 MS. ELLIS: Okay. We may want to ask, are you 14 going to answer some more, maybe some of the is calculations when we see them, Mark? Are you going to 16 want those later?

17 MR. WALSH: Yeah. I would like to see the 18 final, the before and after drawings.

19 MR. FINNERAN: The other container, ITT also 20 designed.

21 MR. WALSH: Okay.

22 MS. ELLIS: So, all_of them are ITT?

23 MR. FINNERAN: That's correct.

24 MR. WALSH: We would like to see the original 25 drawing that was issued, the drawing that was made BH

> kd/3 NRC-105 T-3 70 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Belt. 46 Annep. 269-6136

i 7{

,n, 1

'/

'- 1 stable, and the drawing as it is tu let it, that it was 2 made stable by.

3 MR. HORIN: Aren' t these all the same 4 condition, John?

5 MR. FINNERAN: Couldn' t hear you Bill.

6 MR. HORIN: Aren' t these all under the same 7 condition. All the drawings simply show the same thing.

8 MR. FINNERAN: It is the same condition every

(

, 9 time.

10 MR. WALSH: So, they were originally designed 11 that way, on every one of them?

l l 12 MR. FINNERAN: On the two, off the main steam, i

p 13 let me check that, just a second.

w' 14 Okay, on the two non mainsteam supports, I l

15 don' t believe the additional designs show a gap, but l 16 they were modified in the field. The field l

17 modifications that were made actually wound up with a 18 gap and this was identified and corrected.

19 MR WALSH: When was this identified?...in the 20 drawing. We would like the specifics.

21 MR. FINNERAN: I don' t know when they were 22 identified, as we stated in our af fidavit on page 18, 23 the two non mainsteam supports were modified in October 24 and December of 1982 to address the gap.

25 MR. WALSH: Well, we would like to see when

( BH

' NRC-105 T-3 71 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 169-6136 I

72 (3

\_/ 1 this thing became unstable. When the steel modification 2 came about.

3 MR. FINNERAN: When the modification was made 4 that had a gap in the U-bolt?

5 MR. WALSH: And the calculations to bcck the 6 support up.

7 MR. HORIN: Mark, on the calculations that is

~

8 a separate question. 1 think that when we are talking 9 about stability, we are not talking about separate to calculations that relate to stable or unstable it conditions itself. You are not going to have separate 12 cales to determine what is stable or unstable. That is 13 something that the designer simply looks at the loads b

14 and assesses whether or not the support is stable in is those directions. It is not some calculation that he

! 16 does to see if it is unstable.

17 MR. WALSH: Okay. Well, we would like to see 18 the field modification, the date of it, and the j 19 . calculation if he did calculate for it.

20 MR. HORIN: Can we get the date of when the 21 modification might have been?

22 MR. WALSH: We would like to see the drawings l 23 and the support numbers , you know, like in a little l

l 24 package. Yes, all 15 of these. This would be a lot 1

25 easier, instead of doing one at a time. l G BH O NRC-105 l T-3 l l

2 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 261-1901 e Bolt. 46 Annop.169-6136 l

73 n

1 MS. ELLIS: I think the problem Bil2, that I 2 have got with not getting a list and getting them and 3 coming back ind saying that we want this one and this d one. It is going to be lengthy.

5 MR. HORIN: But Juanita, what I was saying was 6 not that there was going to be any delay. I was just 7 saying that for the purpose that Mark said he wanted 8 these for, there was no need to provide drawings.

9 MR. WALSH: Yes. I believe it is very to important for the drawings. That is one of the most 11 important parts.

12 MR. FINNERAN: How does it relate to the 13 material facts? We don' t see that.

14 MR. WALSH: Well, first I can see if the thing is is stable or not. Then, I can look at it and I can 16 determine if the thing is now stable, or is it 17 unstable. I haven' t seen this stuff. Maybe the thing is 18 still unstable. It went by before by a lot of people's 19 desks, and the thing went- out and was constructed and 20 it was unstable. I don' t know if it is stable or not.

21 MS. ELLIS: I think this all goes back to item 22 8 on'page 4. I think that it is very clear, the wording 23 there.

24 MR. HORIN: What does item 8 say?

25 MS. ELLIS: Item 8 states, applicants p'

BH NRC-105 T-3 73 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 269 6136

t 7.j n

U 1 identified 15 of these types of supports in Unit 1 and 2 common areas. Thirteen of these supports are main steam 3 supports. Three of the main steam supports were 4 actually modif-ied for the initial installation in such 5 a way that initial instability was removed. These 6 modifications occurred prior to September, 1982. The 7 remaining 10 mainsteam supporters were modified between 8 January 1983, and June 1983. The two non-maintenance 9 Steam supports were modified in October and December io 1982. The modifications consisted of cutting the 11 -U-bolts or adding supplementary structural steel that 12 would present the_ rotation of the U-bolt clamp 13 offender. It refers back to the affidavit on page 8.

14 MR. FINNERAN: Okay. All you are going to see is here is that the majority of those drawings that the 16 U-bolts have been snugged out.

17 MR. WALSH: Alright. Well, we would like to 18 see that.

19 MS. ELLIS: Okay. Can we take a break for just 20 a moment.,

21 MR. WALSH: Yeah. Fine with me.

22 MS. ELLIS: I want to talk about this for a 23 second. Maybe we can cut it down some.

24 MR. BURWELL: Off the record.

25 (Off the record discussion.)

O kJ BH NRC-105 T-3 74 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Belt. & Annep. 1694136

75 t )

v 1 MR. FINNERAN: We can' t see the connection 2 between the material facts and what CASE has asked for 3 here. So, we don' t see the need for them to have these 4 drawings. We have shown you exactly what we have got, 5 and the drawings will show you that we have done that.

6 MR. WALSH: We would like to see what the 7 applicants identify, because that is stated right there a in the beginning.

9 MR. FINNERAN: Yeah. You already have a io drawing that shows that in your own cz.se exhibits.

11 MR. WALSH: We want to see all of them that 12 the applicants identified, not what CASE identified.

p MS. ELLIS: CASE isn' t asking for an operating

() 13 14 licence.

is MR. WALSH: But, it states applicants 16 identified, not CASE. We want to see the 15 that the 17 applicants identified.

18 MR. HORIN: Do you just want those drawings?

19 MS. ELLIS: Okay. I think what we would like 20 to have is a listing of all 15. We want the two that 21 were not mainsteam supports. We want the complete 22 packages on those, the parts. When I say complete 23 packages, what we want is...run through that once 24 again, Mark.

25 MR. WALSH: The orginal drawing as it was BH t]

v NRC-105 T-3 '

75 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Aree 1411901 e Belt. & Annep. 169 6136

70 O

V' 1 issued, revision zero. We want the drawing that- was 2 made, that was made unstable, that shows a support 3 being potentially unstable.

4 MR. FINNERAN: Well, maybe that is the 5 original drawing, Mark.

6 MR. WALSH: Well, if that is the case, that is 7 what we want to see. And, the third' item is the drawing 8 that made it stable.

9 MR. FINNERAN: Okay.

10 MS. ELLIS: And any calculations to go with 11 that.

12 MR. WALSH: And any C&C's on those supports 13 that were issued by the field that when the field 14 engineer generated the C&C, he made it not stable, if is that exists.

16 MR. WADE: Are you talking about the two non 17 mainsteam?

18 MR. WALSH: Whatever supports. We don' t know.

19 We haven' t seen them. As soon as we see the drawings, 20 we can tell you.

21 MS. ELLIS: Okay. So far we have asked for a 22 list. We have asked for packages on the two that are 23 not main steam point. Okay, from the list, we want to 24 come back and ask for, say three, packages on the 25 mainsteam support.

3 (V

BH NRC-105 T-3 D

FREE STATE REPORTING INC.

Ceant Reporting e Depositlens D.C. Area 141-1901 e Belt. & Annep. 149-4134

77 t

MR. HADE: When you are saying packages, are

. 1 2 you saying the same thing that you mean by packages 3 with respect to two.

4 MS. ELLIS: Right.

5 MR. WALSH: The packages would be the original 6 design or the original drawings, the drawing that made 7 it unstable, and then the drawing that made it stable.

8 MR. WADE: . Mark, I think you may be 9 oversimplifying what you are looking for. There were to design changes in that system, just as the normal 11 design progressed, which there may be no comparison to 12 the original supports and the support that was out 13 *here now for many other reasons other than the one 14 that you are pursuing.

15 MR. WALSH: Okey. But, if any of those design is changes created an unstable condition, we would like to 17 now those also.

18 MS. ELLIS: We are trying not to ask for the 19 whole package for the whole thing, okay.

20 MR. WADE: That is what you are asking for, 21 though. What you are going to get is a ton of paperwork 22 that you are not going to know what to do with.

23 MR. HORIN: David. I think what he means by 24 packages is simply the drawings, the red zero 25 drawing with the gap. Then, in the instances where BH Ox NRC-105 T-3 77 FREE STATE REPORTING INC.

Court Reporting e Deposittens D.C. Aree 161 1901 e Belt.& Annep. 149-4134

' 78

(\

V 1 there were no field modifications that created the 2 potential instability, the drawings in which the change 3 was made to eliminate instabilities.

4 MR. WADE: Now, I hear that Bill, but it is

~

5 not that simple, I think. Because, progressicr of the 6 design on that system, in some cases, we may have found 7 a way to optimize design and completely ~ changed the 1

l 8 functions of all the supports. The original designs l

l 9 will bear no resemblance to the design that is there 10 now,or even this question.

ii MR. .HORIN: I think we know that that is the l case in at least-two incidents that we have seen.

12 MR. FINNERAN: Yeah. We have said that.

O 13 l 14 MR. WALSH: We're looking for a history. That l

15 is what most we have made...

16 MR. WADE: But, the subject is stability, not 17 the entire history of this line and its designed 18 progression.

19 MS. ELLIS: That is why we asked him for 20 everything.

21 MR. WADE: You did ask for red zero and 22 everything in between, so, you are asking for 23 everything.

24 MR. WALSH: No. We are asking for red zero, 25 and a revision to the drawing that made it unstable.

f BH b] NRC-105

~

18 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 1611901 e Belt. & Annep. 169 6136

79

(~l

'- 1 MS. ELLIS: Not if there were 15 others in 2 between. We don' t want those.

3 MR. WADE: That is what I am saying. You are 4 comparing apples and oranges. The original drawing that 5 may have existed on that line years and years ago, may 6 not even be of any similar configuration which you 7 could have made unstable.

8 MR. WALSH: We are interested in the one that 9 was issued to the field.

10 'bGt. WADE: You don't understand what I am 11 saying, do you?

12 MR. WALSH: Before the field engineers get 13 ahold of it.

p%J 14 MR. WADE: You don' t understand what I am is saying, you are not listening.

16 MS. ELLIS: Wait a minute. I think I 17 understand what you are saying. Okay, rather than 18 necessarily asking for the original drawing, maybe we 19 should ask for the drawing that made it potentially 20 unstable, and the drawing immediately preceeding that.

21 MR. WADE: There you are getting closer.

22 MS. ELLIS: Is that more what you are talking 23 about?

24 MR. WADE: Yeah. What I am saying is they may 25 have done a completely different design configuration BH

,]\- NRC-105 T-3 79 FREE STATE REPORTING INC.

Court Iteporting e Depositions D.C. Aree 161-1901 e Belt. & Annop. 149 6136

bi) g V 1 than existed years ago. Because of optimization or 2 changes to the system, it may have occurred, we may i' 3 have completely changed the design of that supporting 4 system. So, there is no resemblance at all. Therefore, 5 the original design that was put out there might never 6 have been unstable or could have been unstable.

7 What you are concerned with is the support 8 which may have proceeded Lack up the way maybe two or S 9 three revisions.

10 MS. ELLIS: Right.

11 MR. WADE: But, not the original. You go back 12 to the original, and you are going to get a pile of fm 13 paperwork you won't know what to do with.

U 14 MS. ELLIS: Okay. We don' t want all the stuff 15 in between, but I see what you are saying, I think. So, 16 what we want, what we basically want is the history.

17 MR. FINNERAN: I think you want the history of 18 the unstable aspects, the history of what exists there 1

19 today. I think it was prior to that time.

20 MS. ELLIS: Right. What it looked like right 21 before it was made potentially unstable.

22 MR. WADE: I understand what you are looking 23 for.

24 MS. ELLIS: Right. And then, up through now.

25 MR. WADE: We understand, but don' t ask for

/

S BH l '

NRC-105 T-3 80 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1902 e Bolt. & Annop. 169-6136

Ol l 1

'/

- 1 rev. zero, because you are going to get more than you 2 want. Let us determine, we know what you are looking 3 for, let us supply that information.

4 MR. FINNERAN: In probably 13 of these .

5 supports, he is going to get reg. zero.

6 MR. WALSH: Well, that is what I was under the 7 impression. So, that is why I said, Reg. zero.

8 MR. WADE: I know the history that has been 9 main steam and of the design progressions. I am to concerned that there could be somewhere that you would 11 not get Reg zero's.

12 MS. ELLIS: Okay. As long as we understand n 13 where we are coming from and what we are really after.

U 14 MR. WADE: That is the key, that we understand 15 what the contest is.

16 MR. HORIN: You said that you wanted a list of 17 the 15 and then a sample of the three of the packages.

18 You said that you would ask for that later.

19 MS. ELLIS: Right.

20 MR. HORIN: We will just go ahead and do that 21 sample right now and save time.

22 MS. ELLIS: Well. We would like to take the 23 sample. You can go ahead, if you want to, it may be 24 alright, but there may be some particular support in 25 there that either we have a drawing of, whether we have O BH NRC-105 T-3 81 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Aree 261-1902 e Bolt. & Annop. 269-6136

S2 Is -) 1 something like that we may want to pursue.

2 MR. HORIN: So. Maybe we will just give you 3 the list so we don' t duplicate the ef fort.

d MR. FINNERAN: We could go ahead and pick l

5 three of those that you don't already have. We know the 6 ones in the Dall exhibit.

1 7 MS. ELLIS: I think you know, pretty well, the j 8 ones that we have.

9 MR. FINNERAN: Yeah. You want three that you to don' t have.

11 MS. ELLIS: Is that basically it, Mark?

12 MR. WALSH: Either way, I don' t care.

~

s 13 MR. FINNERAN: We'll do that, d 14 MS. ELLIS: Okay. That's the main thing. In 15 the two that are not maintained, we will not bother 16 wi th t'.!a t on e .

17 MR. FINNERAN: Okay.

18 MS. ELLIS: One more thing. If there are any 19 calculations, we would like to have them too, that are 20 applicable to what we are talking about. If there is 21 not, well, fine.

22 MR. WALSH: Alright. The last thing is on page ,

23 27 of the affidavit, discussing a portion of the main 24 steam piping. We would like to see the drawings of the 25 supports that were involved with this pipe run.

{ BH NRC-105 T-3 82 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 269-6136

b.3 G

'Y

- 1 MR. HORIN: What do you mean by involved?

2 MR. WALSH: Pardon?

3 MR. HORIN: What do you mean by involved?

E MR. WALSH: Well, they analyze 50 feet of 5 pipe. I would like to see all the supports that are 6 involved to this pipe run, that are attached to to 7 pipe.

8 MR. FINNERAN: You want a copy of the drawing?

9 MR. WALSH: Yes.

10 MR. FINNERAN: That's not problem.

11 MR. IOTTI: Excuse me, this is Bob Iotti.

12 Mark, do you understand that for the purpose of this 13 analysis, all of those supports were assumed to not be 14 acting?

15 MR. WALSH: Yes. I would like to see those 16 supports. Could you also get me the piping isometric 17 that went along with it so I can identify where they 18 are located?

19 MR. HORIN: Would it be one iso, John?

20 MR. IOTTI: No. I think it is two.

21 MR. FINNERAN: We can provide that.

22 MR. WALSH: Alright. That is all.

23 MS. ELLIS: Okay.

24 MR. HORIN: Juanita, you.said you were going 25 to send something on design QA?

]v BH NRC-105 T-3 83 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 269-6136

84 3

(d i MS. ELLIS: What?

2 MR. HORIN: You said you would be sending 3 something on design QA?

4 MS. ELLIS: Right. Just as I suspected, this 5 went a little over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and I certainly didn' t want 6 everybody, all the technical people to have to go 7 through that.

8 MR. WADE: Bill, I have noted here several ,

9 items which we.have now agreed to provide, and I think to it would be nice so that there are no misunderstandings si that we go over those briefly and make sure everybody 12 agrees what those seven items are. If my count is

m. 13 . wrong, then let's correct it, (d 14 MS. ELLIS: Okay.

15 MR. HORIN: Would you all like for me to

-16 start?

17 MS. ELLIS: Yeah. Why don't you go ahead.

18 MR. HORIN: The first item had to do with 19 ascension of U-bolts. We agreed that we would provide 20 you the pertinent parts of an ASTE document that is 21 referenced in the affidavit.

22 MS. ELLIS: Right.

23 MR. HORIN: The second item, dealt with the 24 axial restraint. It was documentation on the procedure 25 that we used for modeling trunyon for Gibbs and Hill BH p

V NRC-105 T-3 84 FREE STATE REPORTING INC.

Co. art Reporting Depositions D.C. Area 161-1901 e Bolt. & Annop. 169-6136

b[i

(~'s O 1 'and Westinghouse.

2 MS. ELLIS: Right.

3 MR. HORIN: The third thing I have was a 4 drawing or something that demonstrated the largest 5 difference when we were~considering rotation, also the 6 calculations to back that up.

7 MS. ELLIS: Right. We have already prepared 8 them with that.

9 MR. HORIN: Okay. Is that agreed?

10 MS. ELLIS: Yes. I 11 MR. HORIN: Okay. The next item was 12 calculations supporting a particular support n 13 CT101323S42K, and the drawings showing that trunon k,.)

14 effects were taken into account. I think on that one we is clarified that the loads would not be on the drawings.

16 MR. WALSH: Right.

17 MR. HORIN: The next item has to do with 18 Richmond inserts. It was documentation that showed 19 where we instructed engineering to verify the adequacy 20 of threaded rods.

21 MR. WALSH: In the original design.

22 MR. HORIN: The original design counts by all 23 organizations, Gibbs and Hill, ETT, NPSI, all prior to 24 1982. You wanted to include support MSl-02003C72S, and 25 also from exhibit 669 90, which was the moment BH

('] NRC-105 v T-3 85 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1901 e Bolt. & Annop. 269-6136

l

=

8G g

V 1 restraint at Gibbs and Hill.

2 MS. ELLIS: I think he said 9-R also. It is a part of the same thing.

4 MR. HORIN: And then, I believe you requested 5 teh original of the 15 supports which we are going to 6 provide you three in the main steam system, and you 7 wanted both the samples that were not in the main steam a system on unstable pipe supporting.

9 MS. ELLIS: Okay.

10 MR. HORIN: Then, the last item, the one we n just discussed, which was on the drawing of the main 12 steam analysis and the stress isopes. That is 7 ., 13 everything that I show that we agreed to provide.

Q,)

14 MS. ELLIS: Right. I guess we will be going to is the board, Bill with the one that we discussed earlier is under item 4 under stability.-

17 MR. HORIN: That was the additional 18 documenation with NITT regarding the box frame 19 stability support subsequent to 1982.

20 MS. ELLIS: I can' t hear you too well, but I 21 think you are saying the same thing. This_is attachment 22 A3.

23 MR. HORIN: Right. Documentation subsequent to 24 that, IITT.

25 MS. ELLIS: Well, by anyone who.had anything BH

(~) NRC-105

'J T-3 86 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 261-1901 e Bolt. & Annop. 269-6136

87 NJ 1 to do with it. If SUZI had anything back and forth with 2 ITT or anybody that had anything to do with it.

3 MR. HORIN: Okay.

4 MS..ELLIS: I'm sorry, I can' t hear you .

5 MR. HORIN: Ask Mark to read over the material 6 facts if he really thinks that is material.

7 MS. ELLIS: I think we agree very definitely 8 that we do.

9 MR. WALSH: Yeah.

10 MR. HORIN: Okay, so we all stand.

ii MS. ELLIS: We disagree, right?

12 MR. HORIN: Yes. Well, alright, I am gone. I f, 13 will catch you all later.

14 MS. ELLIS: I guess that is it.

15 MR. BURWELL: -Okay, if that is it, anyone 16 else. Does that complete it?

17 MS. ELLIS: It will probably take me, I have 18 got some other stuff that I am committed to do 19 tomorrow. Hopefully by either tomorrow night or 20 Wednesday, I will be able to get something of f ' on this 21 QA for design.

22 MR. BURWELL: Okay, very fine. With that, 23 then, the meeting is closed, and the record is closed.

24

( Meeting closed at 10:50 p.m. )

25 BH

% NRC -105

(~J

\~ T-3 87 FREE STATE REPORTING INC.

Court Reporting e Depositions D.C. Area 161-1902 e Bolt. & Annop. 269 6236

i.

1 CERTIFICATE OF PROCEEDINGS 3

This is to certify that the attached proceedings before 4 the NRC.

5 In the matter of: COMANCHE PEAK 6

7 Date of Proceeding: 8/6/84 8 Place of Proceeding:

BETHESDA, MD.

9 were held as herein appears, and that this is the original 3 transcript for the file of the Commission.

9 11 12 13

-q

' .Tnn MpwMnN _

Official Reporter - Typed 15 16 Y

h Official m //pf Reporter - Signature 19 l;)g

~' ~

20 TRANSCkIBER 21 22 23 24 25 t

FREE STATE REPORTING INC.

Court Rerotting e Depositions D.C. Aree 261-1901 e Bolt. & Annop. 269-6136 l

, . . . _