ML20197H256
| ML20197H256 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/17/1984 |
| From: | Horin W BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20197H236 | List: |
| References | |
| NUDOCS 8406180380 | |
| Download: ML20197H256 (10) | |
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June 17, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC
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50-446 COMPANY, et al.
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(Application for (Comanche Peak Steam Electric
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Operating Licenses)
Station, Units 1 and 2)
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APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION REGARDING STABILITY OF PIPE SUPPORTS Pursuant to 10 C.F.R.
I 2.749, Texas Utilities Electric Company (" Applicants") hereby move the Atomic Safety and Licensing Board for summary disposition of the citizens Association for Sound Energy's (" CASE") allegations regarding the stability of pipe supports.
As demonstrated in the accompanying affidavit and statement of material facts, there is no genuine issue of fact to be heard regarding these issues.
Applicants urge the Board to so find, to conclude that Applicants are entitled to a favorable decision as a matter of law, and to dismiss this issue from the proceeding.
I.
BACKGROUND CASE has raised allegations concerning the stability of certain types of pipe supports.
The substance of the various allegations is set out in Section III of CASE's Proposed Findings
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4 of Fact and Conclusions of Law, filed August 22, 1983.
CASE allegod that Applicants have not acted promptly to identify and resolve stabi'ity problems (see CASE Proposed Findings at III-9).
CASE also alleged that there are specific technical problems.with certain categories of pipe supports, such as supports described r
t as three-bar linkages, which would be unstable if the box frame or U-bolt clamp asaembly was able to rotate around the piping l
(Id. at III-7 to 8).
l The allegations relating to stability were discussed in i
l Applicants' Proposed Findings of Fact, filed August 8, 1983, at 44-47, in Applicants' Reply to CASE's Proposed Findings, filed September 6, 1983 (at 12-17), and in Applicants' Motion for l
Reconsideration of Memorandum and Order'(Quality Assurance for
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Design), filed January 17, 1984, at 19-26.
i
.t In its Memorandum and Order (Quality Assurance for Design),
l dated December 28, 1983, at 22-29, the Board concluded that the l
4 record was insufficient to support a finding that specific l
technical problems with support stability have been corrected.
As the Board stated in its Memorandum and order (Reconsideration Concerning Quality Assurance for Design), dated February 8, 1984 l
(at 16):-
"the. entire matter of instability has been handled in an incomplete manner in our record", and therefore posed a series of questions to be addressed by the Applicants in further testimony (these questions are discussed in the accompanying Affidavit of John C.
Finneran, Jr.).
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o we e In response to the Board's Memorandum and Order, the Applicants agreed that they would
[p]rovide a detailed description of the evolution of the instability issue, from the design process through the resolution of the issue.
Documentation will be provided on the identification of the instability as an issue and of the engineering process leading to its resolution.1 This information is provided in the accompanying Affidavit of John C.
Finneran, Jr.
II.
APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION A.
General Applicants have previously discussed the legal requirements applicable to motions for summary disposition in their " Motion for Summary Disposition of Certain CASE Allegations Regarding AWS and ASME Code Provisions Related to Welding," filed April 15, 1984 (at 5-8).
Accordingly, we incorporate that discussion herein by reference.
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Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for - Design), filed Feburary 3, 1984, at 5, Item 2.
9,
B.
CASE's Allegations Regarding Pipe Support Stability Should Be Summarily Dismissed 1.
The Nature of " Instability" The first principle to be noted is that the instability of a particular pipe support, when viewed in isolation from the piping system, is of little or no significance.
This principle is explained fully in the accompanying Affidavit of Mr. Finneran at 2-7.
The point is simple:
a support on a piping system may seem to be unstable because it can swing in one direction, but in actuality any movement in that direction is restrained by other supports on the piping system.
The important consideration, therefore, is whether the entire piping system and associated supports are stable when considered as a single system.
Both CASE and the NRC Staff have recognized this principle.
(Finneran Affidavit at 6-7).
4 2.
Applicants' Assessment of the Stability Question The Board has questioned v/hether Applicants acted promptly in identifying and addressing stability problems.
The allegations in this regard take two forms:
(1) that Mr.- Doyle was the one who first brought the problems with stability to the attention of Applicants (see CASE Proposed Findings at III-9), and (2) that, once the problems were identified, Applicants did not act promptly to resolve them-(see the December 28, 1983, Memorandum-and Order at 15-16).
Both of these allegations-are invalid.
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. As to the first allegation, it is clear that the potential instability of box-frame supports at Comanche Peak was identified in the normal design review process.
As Mr. Finneran explains, the potential instability of box frames with single struts or snubbers was identified by ITT engineers at the site in a memorandum dated May 22, 1981 (attached to the Finneran Affidavit), nearly a month before Mr. Walsh began work at the site and three months before Mr. Doyle began work (Finneran Affidavit at 10).
Further, there is no documented evidence that either Mr. Doyle or Mr. Walsh ever reported concerns about stability to a supervisor or a member of management (Id. at 10-11; see also Applicants' Proposed Findings at 20).
Thus there is no basis for CASE's statement that stability was a problem which "Mr. Doyle fought to bring to [ Applicants'] attention for months without success (CASE Proposed Findings at III-9)..
As to the second allegation, the evidence presented in Mr.
Finneran's Affidavit demonstrates that Applicants acted promptly to address the stability question regarding these supports and to identify analogous problems elsewhere in the plant. -As indicated therein, Applicants became aware of the stability problem with box-frame supports in May 1981 (Finneran Affidavit at 10).
Applicants then' took immediate action to suspend approval of any such supports until'ITT could resolve the problem-(Id. at 11-12).2 Concerns with'these frames were communicated to'all. field 2
For a description.of the process of resolving-this stability (footnote continued) 1
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.t engineers in May 1981 (Id. at 12).
Thereafter, ITT engineers at the site continued to pursue a resolution of the problem (Id.).
-A t.otal of 12 frames'were ultimately considered to require modifications to improve their stability.
All these
-modifications were initiated by February 1983 (ld. at 12-13).
With respect to the stability questions associated with'the main steam supports (Category II in the Finneran Affidavit at 15-18), the evidence shows that discussions on this matter were in progress in September, 1982 between the responsible design organizations.
(ld. at 15-16, 17).
These discussions centered i
on whether certain mechanisms could reasonably be expected to 7
provide stability.
In particular, these supports are located on a straight run of pipe, approximately 50 feet long, anchored at one end by a penetration and at the other by a moment restraint.
4 Therefore, the vertical struts which are essentially plumb will remain that way.
-In any event, even assuming an' offset would exist, the load conditions for these supports will result in friction forces that will resist sliding and rotation of the support, thereby providing a-stabilizing mechanism.
In addition,.
the seismic load on these supports is of very short= duration,-
before reversing-direction.
It is-extremely'unlikely that a mechanism thatiwould-create an unstable condition could be (footnote contin ~ued froml previous-page) question, see the discussion at pages 14-16 of Mr. Finneran's:
As is evident.from that discussion,~.there were close technical ~ questions presented'regarding-the stability of these supports which were not susceptible to immediate1 resolution.
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. established in this time frame.
(Id. at 16-17 and 25).
Nevertheless, because the modifications necessary to improve stability could be easily accomplished it was decided in late 1982 that these supports should be modified (Id. at 17-18).
A total of 15 supports of this type were modified, with all
. modifications completed by June 1983 (Id. at 18).
In sum, Applicants' design review process identified concerns regarding the stability of these pipe supports during the normal course of the-design process.
Applicants initiated corrective action, including discussions regarding the need for modifications and the suspension, where necessary, of the approval of support designs similar to those considered to be potentially unstable.
Applicants ultimately adopted a cautious resolution of these questions by determining to modify the j
supports despite the existence of viable mechanisms.to assure stability.
i 3.
CASE's Remaining Allegations Relating to Specific. Supports I
CASE has raised concerns relating to four different categories of supports..Mr.~Finneran describes Applicants' review of these supports at pages 9-22 of his Affidavit.
The resolution of the potential problems associated with the first..
two categories of supports--(box frames _and main steam) were described in the previous section of this motion.
Applicants' resolved any potential. instabilities through modifications.to the supports-(Finneran Affidavit _at 9-18).
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- With respect to the third category of supports (double strutted frames), CASE has alleged that these frames will experience out of plane movement of about 1/8 inch and will therefore be unstable.
Hovever, Mr. Finneran has shown that the friction forces associated with these frames are sufficient to prevent the frame frcm sliding along the pipe and thus to maintain stability (Id. at 19-21).
As for the fourth type of support (single struts or snubbers with snug U-bolts), CASE has alleged that this type of support is unstable because the snug
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U-bolt cannot provide sufficient friction to prevent rotation around the pipe.
Applicants have performed extensive tests and analyses to determine the capabilities of this type of support to-resist rotation of the pipe (see the Affidavit of Iotti and Finneran Regarding Cinching Down of U-Bolts, to be filed i
j shortly).
The results of these tests and analyses demonstrate that these assemblies will function as pipe clamps and prevent rotation of the pipe, thus assuring stability of the supports.
1 (Finneran_ Affidavit at 21-22).
In' sum, _the pipe supports in-Categories III and IV which CASE contended were unstable are, in fact, stable.
Thus, no safety concern exists with respect to the stability of these supports.3 3
As Mr. Finneran explains (id. at 22), the total number of-.
j safety-related supports whTch'are potentially unstable is 27 for all Unit 1 and-common areas._ There are 17,000-18,000
-safety-related supports in Unit 1 and common area at.
Comanche ~ Peak.
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Response to Board Questions Applicants' responses to the questions of the Board are presented at pages 22-28 of Mr. Finneran's Affidavit.
As indicated therein, Applicants' pipe support design process functioned properly in identifying and resolving questions regarding the stability of supports.
Each organization correctly performed their assigned functions, consistent with their responsibilities in the pipe support design process.
In addition, the potential instabilities did not raise a safety 3
concern.
As explained above, two of the four categories of i
allegedly unstable supports were, in fact, determined to be stable.
As for the remaining two categories, the potential unstable conditions presented no safety concern.
(Id. at 26-27.)
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III.
CONCLUSION
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For the foregoing reasons, Applicants' motion for summary disposition of the allegations relating to pipe support stability should be granted.
Respectfully submitted, f
Nicholas S.
Reynolds William A.
Horin l
BISHOP, LIBERMAN, COOK, j
PURCELL ti REYNOLDS 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 (202)857-9817 Counsel for Applicants
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June 17, 1984 i
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