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Category:AFFIDAVITS
MONTHYEARML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20086Q3931991-12-26026 December 1991 Affidavit of Case President J Ellis.* Affidavit of Case President J Ellis Re Motion for Leave to File Response to Portions of Motion of R Micky & Dow to Reopen Record. W/Certificate of Svc ML20154G7841988-09-0909 September 1988 Affidavit of Jj Macktal Re Oppressive Terms of Settlement Agreement for Addl Safety Concerns.Related Info Encl ML20207E6061988-08-12012 August 1988 Affidavit of B Brink.* Discusses Concern Re Operation of Plant.W/Supporting Documentation & Certificate of Svc ML20207E5941988-08-0505 August 1988 Affidavit of K Mccook.* Discusses Concerns Re Operations of Plant.Unexecuted Affidavit of P Reznikoff Encl ML19325D6431988-07-12012 July 1988 Affidavit of B Brink.* Expresses Concern That Operation of Plant Will Cause Loss of Health to Author & Family & Safety Problems at Plant Will Jeopardize Life & Property ML19325D6461988-07-12012 July 1988 Affidavit of L Burnam.* Expresses Concern That Operation of Plant Will Cause Loss of Health to Author & Family & Safety Problems at Plant Will Jeopardize Life & Property.W/ Certificate of Svc ML19325D6401988-07-12012 July 1988 Affidavit of P Reznikoff.* Expresses Concern Re Danger to Health & Safety Posed by Normal Operations of Plant & by Possible Accidents ML20197E3011988-05-23023 May 1988 Affidavit of JW Muffett.* Encl Review Issues Lists (Rils) on Pipe Stress & Pipe Supports Document That All Issues Closed by Cygna.Job Responsibilities of JW Muffett Stated. W/O Rils.W/Certificate of Svc ML20154E5391988-05-13013 May 1988 Affidavit of Ha Levin.* Related Documentation Encl ML20154E5281988-05-0606 May 1988 Affidavit of RP Klause.* Discusses Design Validation & for Large & Small Bore Piping Supports at Plant During Preparation of Project Status Repts.Author Statement of Training & Experience Encl ML20196B0751988-02-0101 February 1988 Affidavit of Rd Pollard Re Environ Qualification of RG-59 Coaxial Cable ML20236X2501987-12-0202 December 1987 Affidavit of Dn Chapman.* Discusses Mgt Analysis Co Audit Rept ML20236E0481987-10-23023 October 1987 Affidavit of Bp Garde in Support of Motion for Reconsideration.* ML20236E7501987-07-23023 July 1987 Affidavit of Jt Merritt.* Affidavit Discusses Mgt Analysis Co Audit Repts.Related Correspondence ML20236E7411987-07-22022 July 1987 Affidavit of JB George.* Affidavit Discusses Mgt Analysis Co Audit Repts.Related Correspondence ML20236E7551987-07-22022 July 1987 Affidavit of Eg Gibson.* Affidavit Discusses Mgt Analysis Co Audit Rept.Related Correspondence ML20211D0591987-02-11011 February 1987 Affidavit of Eh Johnson.* Responds to Statements in Case Motion Re Trend Analyses or Trend Repts.Trend Analyses & Repts Incorporated Into SALP Repts in 1980.Certificate of Svc Encl ML20212E8631986-12-26026 December 1986 Affidavit of Case Witness J Doyle Re Case 861230 Partial Response to Applicants 861201 Response to Board Concerns.* Certificate of Svc Encl ML20211J4721986-11-0101 November 1986 Affidavit of J Doyle Re Scope of Cygna Role.Supporting Documentation Encl ML20211J4141986-10-28028 October 1986 Affidavit of DC Garlington Re Irregularities in Plant Const or Operations Noticed During Site Visits.Emergency Lights Not Aimed & Locked & Trash in Diesel Room Noted in Monitoring Repts.W/Certificate of Svc ML20211J3551986-10-0303 October 1986 Affidavit of MD Nozette Re Events Concerning Participation as co-owner of Plant Between Nov 1984 & Feb 1985.Discusses Util Failure to Answer Questions Posed in Re Participation in Project ML20214L6911986-08-18018 August 1986 Affidavit of Tg Tyler Supporting Applicant Response to a Palmer Affidavit Re Case 860731 Response to Applicant 860716 Motion for Protective Order & Motion to Compel.W/ Certificate of Svc ML20214M4271986-08-0505 August 1986 Joint Affidavit of D Lurie & E Marinos Clarifying 860404 Joint Affidavit on Statistical Inferences from Comanche Peak Review Team Sampling ML20207F7741986-07-16016 July 1986 Affidavit of Le Powell Re Discovery in CP Extension Proceeding.W/Certificate of Svc ML20207E3071986-07-16016 July 1986 Affidavit of Le Powell on 860716 Re Estimate of Time & Effort Required to Prepare Responses to Questions 4-7 of M Gregory Set One Discovery Requests.Related Correspondence ML20197C1301986-05-0606 May 1986 Affidavit of M Walsh,Advising That Statistical Sampling Being Performed & Proposed for Facility Inappropriate. Applicant Reliance on Statistical Sample Will Not Identify Problems W/Pipe Supports.Certificate of Svc Encl ML20197C1051986-04-26026 April 1986 Affidavit of J Doyle,Addressing Applicability of Statistical Sampling to Facility ML20155A6851986-04-0404 April 1986 Joint Affidavit of D Lurie & E Marinos Re Board Concerns on Statistical Inferences from Comanche Peak Review Team Sampling.Certificate of Svc Encl ML20138B1711986-03-13013 March 1986 Affidavit of SD Mckay Re Likelihood of Reactor Coolant Pump Restart Due to Operator Error W/No Occurrence of Inadequate Cooling Event.Prof Qualifications & Certificate of Svc Encl ML20138B1431986-03-12012 March 1986 Affidavit of B Mann Re Treatment of Operator Error in Licensing Process & Likelihood of Reactor Coolant Pump Restart During Inadequate Core Cooling Event.Prof Qualifications Encl ML20138B1071986-03-12012 March 1986 Affidavit of CE Mccracken Re Core Flow Blockage Due to Fine Paint Particles ML20215E7171986-01-27027 January 1986 Partially Withheld Affidavit Re Allegations Concerning Drug Use & Distribution ML20138P5551985-12-14014 December 1985 Affidavit of Jj Doyle in Response to Applicant Changes to 1984 Motions for Summary Disposition ML20137X1831985-12-0505 December 1985 Affidavit of R Mcgrane Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits Only Recent Awareness of Rept.Related Correspondence ML20137X0201985-12-0505 December 1985 Affidavit of Dh Wade Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge of Rept Prior to May or June 1985.Related Correspondence ML20137W9971985-12-0404 December 1985 Affidavit of Nh Williams Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge of Rept Prior to 850625.Related Correspondence ML20137X2101985-12-0303 December 1985 Affidavit of R Siever Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits Awareness of Audit & Rept Preparation Through General Onsite Conversation in 1985.Related Correspondence ML20137X1611985-12-0202 December 1985 Affidavit of P Chang Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge of Rept Prior to mid-1985.Related Correspondence ML20137X1291985-12-0202 December 1985 Affidavit of G Krishnan Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits General Awareness of Discovery Process Re 1980 Licensing Proceedings.Related Correspondence ML20137X0881985-12-0202 December 1985 Affidavit of Rc Iotti Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge Apart from News Publicity & ASLB Documents in mid-1985.Related Correspondence ML20137X0601985-12-0202 December 1985 Affidavit of Jc Finneran Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge Apart from News Publicity & General Onsite Conversations Earlier in 1985.Related Correspondence ML20205H4071985-11-12012 November 1985 Affidavit of Rc Iotti & Jc Finneran Re Corrections & Clarifications to Affidavits Supporting Motions for Summary Disposition of Pipe Support Design Allegations. Supporting Documentation Encl.Related Correspondence ML20205H3501985-11-12012 November 1985 Affidavit of Rc Iotti & Jc Finneran in Response to ASLB Request for Info Re Variation of Field Configurations of Pipe Supports Utilizing clinched-down U-bolts.Related Correspondence ML20133F8161985-09-0909 September 1985 Affidavit of CE Mccracken Providing Further Explanation of Background of Sser 9,App L,Per ASLB 850918 Memorandum ML20133F8221985-09-0909 September 1985 Affidavit of Aw Serkiz Providing Explanation Re Sser 9, App L,Per ASLB 850918 Memorandum.Certificate of Svc Encl 1994-09-19
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
[Table view] |
Text
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., o DogtiEe gIgocogRESM T5 NQ/13 A9:55 November 12, 1985 0FFICE "r SECRfita -
~
UNITED STAfsshOfR% RfC .
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
) Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC ) 50-446 COMPANY, ET AL. )
) (Application for (Comanche Peak Steam Electric ) Operating Licenses)
Station, Units 1 and 2) )
AFFIDAVIT OF ROBERT C. IOTTI AND JOHN C. FINNERAN, JR., IN RESPONSE TO BOARD REQUEST FOR INFORMATION ON VARIATION OF FIELD CONFIGURATIONS OF SUPPORTS UTILIZING CINCliED-DOWN U-BOLTS We, Robert C. Iotti and John C. Finneran, Jr., being first duly sworn, hereby_ depose and state as follows:
(Iotti) I am Vice President of Advanced Technology for Ebasco Services, Inc. I was retained by Texas Utilities Electric Company to oversee the assessment of allegations concerning the design of piping and supports at Comanche Peak Steam Electric Station in accordance with Applicants' February 3, 1984, Plan to Respond to Memorandum and Order (Quality Assurance for Design)".
A statement of my educational and professional qualifications was l
transmitted with Applicants' letter of May 16, 1984, to the Licensing Board in this proceeding.
(Finneran) I am Project Discipline Supervisor-Pipe Support Engineering at Comanche Peak Steam Electric Station. In this position, I oversee the design work of all pipe support design l 8511150112 851112 i
hDN ADOCK 05000445 PDR
_________-______-_-_a
t i'
i organizations for Comanche Peak. A statement of my educational and professional qualifications was received into evidence as Applicants' Exhibit 142B.
The purpose of this Affidavit is to provide information requested by the Board as described in Attachment A,1 hereto.
Therein the Board expressed a concern regarding the extent to which the tests that were done on U-bolts could be generalized to the actual configurations found in the plant. That concern includes a question regarding the effect of variatio'ns in l
dimensions of pipes'and support components and configurations.
As discussed below, Applicants' program of tests and analyses assured that results of both the tests and finite element analyses, described:in Applicants' Affidavit supporting their motion for summary disposition of cinched U-bolts,2 may be applied to supports in the field. Variations in actual suoport configurations and dimensions are accounted for in Applicants' program.
1/ Statement By Chairman Peter Bloch, Atomic Safety and Licensing Board (January 9, 1985).
2/ Affidavit of Robert C. Iotti and John C. Finneran, Jr., Regarding Cinching Down of U-bolts (June 29, 1984) (" Affidavit").
_e i
3'-
APPLICANTS' EVALUATION METHOD It-is important to understand that Applicants' approach-in utilizing U-bolt tests was not a simple empirical one of .
- performing selected tests and employing the test results directly for evaluating field conditions. Rather, the tests were utilised for the purpose of deriving, then confirming, a general theoretical model for predicting the torsional moment necessary-to overcome the' frictional restraint of the U-bolt / cross-piece assemblies employed in the plant, as well as local pipe stresses, U;-bolt stresses, and crosspiece stresses. After verification with the test results, the general theoretical method is employed to predict the stability of actual pipe supports (i.e., predict torque requirements), and the acceptability of pipe, U-bolt and l cross-piece stresses, accounting for variations in dimensions of support components (Affidavit at 4.).
In addition to verifying the theoretical method with the tests,,it was also verified against results obtained by computer analyses using the finite element method (which provided
. additional information not directly available from the tests, e.g., stresses in the pipe immediately below the cross-piece).
The finite element models' ability to provide a realistic representation of the actual behavior of the components was also verified against the tests.
In summary, Applicants' method for evaluating the behavior of support configurations is ultimately based upon the use of a theoretical method. This method was verified by a series of
't u
tests on a cross-section of the relevant support configurations in the plant 3
and by comparison to results of analyses using advanced computer methods. The theoretical method enables a determination of the torque required for stability, as well as pipe, U-bolt and cross-piece stresses, for each individual support configurat'on oncountered in the field.4 RELEVANT PIPING / SUPPORT PARAMETERS With regard to the Board's specific questions concerning the representativeness of test supports to field configurations,5 we 1
discuss below how the support configuration parameters were l
accommodated by Applicants' program of tests and analyses.
A. Representativeness of Pipe Size in Test Specimens The piping in the plant on which supports with U-bolt / single strut or snubber configurations are located varies from 1/2" to 32" diameter. The tests were conducted on piping of 4, 10 and 32 inch diameters. (Affidavit at 12.) The 32" pipe is the largest 3/ Support configurations discussed herein, and at issue in the Affidavit, are those consisting of cinched U-bolts on single struts or snubbers.
-4/ Applicants committed (Affidavit at 34-35, 74) to inspect 100 percent of the torques on cinched U-bolts on single strut or snubber supports in the field and to establish torcue values for sizes dif ferent f rom those testec. and analyzed. The status of this review is discussed hereinafter.
5/ See note 3.
I t
pipe relevant to the issue.6 Also, the issue of stability is progressively less significant for smaller and smaller size pipes, in that the externally applied load that could cause the .
instability is progressively smaller and the lever arm through which the load acts is also smaller, resulting in very low torque requirements. Thus, the 4-inch ~ pipe represents a good upper bound for the small pipe sizes. It is subject to comparable, but generally larger external loads, and its support configurations also have comparable or larger lever arms than those on 3-inch and small bore pipes. The 10-inch diameter pipe was chosen as representing the mid-size range of pipes primarily because the support configurations at issue here are more numerous on this size pipe than on 12, 14, 16, 18 and 24 inch sizes.
In summary, the chosen pipe sizes suitably represent small and intermediate size pipes and bound the large size pipes.
These sizes span the range of actual pipe sizes.
B. Representativeness of Support Configurations in Test Specimens There are 392 ASME safety-related pipe support configurations in Unit 1 and common piping utilizing U-bolts on single struts or snubbers (60 on small bore). There are an additional 94 (1 on a small bore pipe) in Unit 2 piping contained within the Unit 1 secure area boundary. 0f this number, 139 are either 4" (79),
10" (49), or 32" (11) in diameter.
6/ There is a support on a 42" line, but the U-bolts are attached to smaller diameter (24") trunnions welded to the line.
These pipe support configurations do have a degree of variability in specific comoonent dimensions such as U-bolt diameter and piping wall thickness. The specific range of some of the principal parameters, compared to the test parameters, is shown graphically in Attachment B. It may be seen that the test configuration parameters are within the range of values existing in the plant. This figure illustrates the representativeness of the test configurations. We reemphasize, however, that the evaluation method used by Applicants to apply test and analytical results to the field configurations accounts for variability in support configurations.7 STATUS OF SUPPORT EVALUATION Applicants completed their initial evaluation of the supports on Unit 1 and common piping. That initial evaluation indicated that of the 392 supports at issue, less than 15 are likely to require some modification to assure that stresses remain within acceptable limits at torques necessary to assure stability.
Applicants originally intended to submit this evaluation with this affidavit. However, we have requested that Stone and Webster also review this evaluation as part of its program to requalify piping and supports. Consequently, the ultimate determination as to the adequacy of those designs has not been
~/
7 As indicated below, because Stone & Webster will review the specific formulas used for these purposes Applicants will submit the formulas in the context of that review.
T
made. Accordingly, Applicants will present the details of those analysis in the context of the Stone & Webster program.
SUMMARY
We have explained in this affidavit the method by which test results'and computer analyses concerning cinched U-bolts have been applied to U-bolt configurations in the plant. In short, the results of those efforts were employed to verify a general theoretical method which, in turn, was used to evaluate individual supports in the field taking into account variations in dimensions. We have also shown that, although they would otherwise be accounted for by the analytical approach derived by Applicants, the dimensions of support configurations employed in
, the tests fall within the variations in dimensions of actual
, support configurations.
L- _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _
o -
{
State of Texas County of Somervell P
'Rober't'd. Iotti Subscribed and sworn to before me this 12th day of November, 1985.
$A ik.s-n
' Bill Hddges "
My commission expires March 28, 1988.
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1
@R21629.0 DRT/ajg I UNITED STATES OF AMERICA 2 WJCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: :
5 :
TEXAS UTILITIES GENERATING COMPANY, : Docket No. 50-445-OL 6 et al. : 50-446-OL 7 (Comanche Peak Steam Electric :
Station, Units 1 and 2) :
8 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _;
9 Nuclear Regulatory Commission Fifth Floor Hearing Room 10 4350 East-West Highway Bethesda, Maryland 11 Wednesday, January 9, 1985 12 A Statement by Chai,rman Bloch was made for the
- ~
I3 record in the above-entitled matter at 12:45 p.m.
14
^
BEFORE:
15 JUDGE PETER BLOCH, Chairman 16 Atomic Safety and Licensing Board JUDGE WALTER H. JORDAN, Member II Atomic Safety and Licensing Board 18 JUDGE HERBERT GROSSMAN, Member Atomic Safety and Licensing Board 19 20 APPEARANCES:
On behalf of Applicants:
McNEILL WATKINS, ESQ.
22 NICHOLAS S. REYNOLDS, ESQ.
Bishop, Liberman, Cook,
23 Purcell & Reynolds 1200 Seventeenth Street, N.W.
Washington, D. C. 20036 24
>F es er.: n porters. inc.
25 -- continued --
2 ,
1 APPEARANCES (Continued):
2 dn behalf of Nuclear Regulatory 3 Commission Staff:
4 STUART A TREBY, ESQ.
Office of Executive Legal. Director 5
U. S. Nuclear Regulatory Commission Washington, D. C.
6 On behalf of Citizens Association ,
7 for Sound Energy: ,
8 ANTHONY Z. ROISMAN, ESQ.
BILLIE GARDE, ESQ. '
Trial Lawyers for Public Justice 9
2000 P Street, N.W.
Suite 611 10 Washington, D. C. 20036 11 On behalf of Oliver B. Cannon & Sons, 12 Joseph Lipinski, and John J. Norris:
- JOSEPH GALLO, ESQ.
13 PETER THORNTON, ESQ.
Isham, Lincoln & Beale
' Id 1120 Connecticut Avenue, N.W.
Washington, D. C.
~
16 17 ,
18 19 20 .
21 22 23 24
- c. Fed:r:: Reporters. Inc.
25
3
.21424 0 4~1 0 1 ^
BRT t
1 PROCEEDINGS 2 JUDGE BLOCH: The purpose of this statemen.t is 3 to issue a request for information and to temporarily stay 4 the obligation, or the opportunity of the parties to 5 respond to Applicants' motion for reconsideration of l'984, and 6 Licensing Board's memorandum dated January 7, the accompanying affidavit of Robert C. Iotti and John C.
7 8 Finneran, Jr. t 9 On this particular matter I would like to make it clear 10 that there's no indication that the Applicants have done 11 anything intentionally wrong, but the matter is a matter of lack of communication.
12 the
~~
13 We had mentioned that we were concerned about 14 extent to which the tests thht were done on U bolts could 2, 15 be generalized to the actual configurations found in the-16 plant. What we are concerned with there, for example, is 17 with variations that might occur in the dimensions of the .
18 pipes, the configurati'ons of the pipes, or the size of the 19 base plate or the spacing of the holes'. And, as I read 20 the answer, the Applicants just having addressed the 21 possible problem, the answer appears to state that the U 22 bolts themselves are somewhat standardized items and that 23 the dimensions of the supports were taken from support 24 drawings, and, thus, "were typical of field configurations."
25 That appears on page 12 of the affidavit. ,
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1 The concern is that unless we know what the variation 2 in field configurations were,'then all we know is that 3 these configurations existed in the field, but we don't 4 know that they were typical or representative of the range 5 of conditions under which the U' bolts have to perform.
6- There's no response _necessary at this time.
~
7 MR..TREBY: Can I just clarify just what it was What is the impact 8 that you said at the very beginning?
9 of this notice?
JUDGE BLOCH: Until the Applicants file a 10 11_ supplementary statement or a statement.that they don't think it's necessary, there's no need to respond to the . -
. 12 ,
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13 filing; should respond after the supplementation a,nd 14 r sponse to the board's request is made.,
i 15 MR. ROISMAN: Does it mean the time for response S
16 will begin to run at some date in the future?
17 JUDGE BLOCH: When the information is filed.
MR. WATKINS: Mr. Chairman, will it be clear 18 19 from your statement exactly what it is you are requesting 20 Applicants to produce?
JUDGE BLOCH: I sure hope so.
21 22
~
MR. WATKINS: It was all Greek to me.
23 MR. TREBY: Does your statement have any impact 24 on.the timing that was set out in your order, which I 25 believe set February 28th as the ending date of discovery?
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1 JUDGE BLOCH: No. Because there's no stay related to this motion for reconsideration. The 2 .
3 obligation to respond and the opportunity to file 4 discovery is in effect until we should rule on the motion.
5 MR. WATKINS: Mr. Chairman, when would you like 6 Applicants to produce the additional information?
7 JUDGE BLOCH: There is no d'eadline. The only 8 problem for, Applicants is, if they want a ruling before 9 the period for responding to requests runs out, they might t 10 want to do it promptly.
11 MR. WATKINS: I take it this order is the 12 Chairman and Dr. Jordan sitting as a quorum?
13 JUDGE BLOCH: No , it's the Chairman sitting in.
14 under the condition that the other board is not in session.
15 The Chairman acting for the' board. -
16 Dr. Jordan has in fact not conferred with me on this 17 because he hasn't yet received the documents which were 18 sent to him in Florida.
19 MR. WATKINS: Thank you, Mr. Chairman.
20 (Whereupon, at 12:48 p.m., the statement was 21 concluded.)
22 .
23 24 25 - .
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