ML20205H322

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Forwards Affidavits of Jc Finneran & Rc Iotti Re Representativeness of U-bolt Support Configurations Employed in Applicant Tests & Corrections & Clarifications Re Motions for Summary Disposition on Piping.Related Correspondence
ML20205H322
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 11/12/1985
From: Reynolds N
BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To: Bloch P, Jordan W, Mccollom K
Atomic Safety and Licensing Board Panel
Shared Package
ML20205H327 List:
References
CON-#485-168 OL, NUDOCS 8511150104
Download: ML20205H322 (2)


Text

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gELATED CORRESPOrlDEM I

COLKETEP law orrects or USNRC l

CISHO P, LIB ER M AN, COO K, PU RC ELL & REYN OLDS IN NEW v0Ra 1200 SEVENTEENTH STREET, N.W.

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WASHINGTON, D.C 2OO36 el5 HOP, L18ERMAN & COON (2O2)857-9800 liSS AVENUC Or THE AMER 8CAS OFFICi 0F SEcht fu. aca voaa.acw voaa icose 00CKETING 4 SEi<Mi (am ro. oioo TELEX 440574 INTLAW Ut BRANCH Tcuen asarer WRif tse'S DIRECT OlAL (2o 2)

November 12, 1985 Peter B. Bloch, Esquire Dr. Kenneth A. McCollom l

Chairman, Atomic Safety Administrative Judge and Licensing Board Dean, Division of Engineering, U.S. Nuclear Regulatory Architecture and Technology Commission Oklahoma State University Washington, D.C.

Stillwater, oklahoma 74074 Dr. Walter H. Jordan Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory 881 W. Outer Drive P.O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Oak Ridge, Tennessee 37830 Subj:

Texas Utilities Electric Company, et al.

(Comanche Peak Steam Electric Station, Units 1 & 2);

Docket Nos. 50-445, 50-4460L

Dear Administrative Judges:

Enclosed are the affidavits of John C. Finneran, Jr., and Robert C.

Iotti.

These affidavits concern two topics:

(1) the representativeness of U-bolt support configurations employed in Applicants' tests and (2) corrections and clarifications to Applicants' affidavits supporting the motions for summary disposition regarding piping and motions for support design.

This material was requested by the Board to assist it in ruling on " Applicants' Motion for Rdconsideration of Licensing Board's Memorandum (Reopening Discovery; Misleading Statement)."

In preparing the affidavit concerning corrections and clarifications, Applicants have been mindful of the Board's instruction to disclose fully material which may be incorrect or incomplete or which would tend to mislead.

The corrections and clarifications presented in this affidavit represent a fair and frank arpessment of Applicants' technical affidavits.

(The Board

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. should note that many of these corrections and clarifications have been provided previously in the normal course of discussions regarding Applicants' motions.)

We trust that this material is responsive to the Board's request.

Sincerely,

,D.

i Nicholas S. Reynolds Counsel for Applicants cc:

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