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Category:AFFIDAVITS
MONTHYEARML20073B6731994-09-19019 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 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 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 ML20207F7741986-07-16016 July 1986 Affidavit of Le Powell Re Discovery in CP Extension Proceeding.W/Certificate of Svc 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 ML20138B1071986-03-12012 March 1986 Affidavit of CE Mccracken Re Core Flow Blockage Due to Fine Paint Particles 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 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 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 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 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 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 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 ML20133F8221985-09-0909 September 1985 Affidavit of Aw Serkiz Providing Explanation Re Sser 9, App L,Per ASLB 850918 Memorandum.Certificate of Svc Encl ML20133F8161985-09-0909 September 1985 Affidavit of CE Mccracken Providing Further Explanation of Background of Sser 9,App L,Per ASLB 850918 Memorandum 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] |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of APPLICATION OF TEXAS UTILITIES I I
Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR and 50-446 AN OPERATING LICENSE FOR COMANCHE PEAK STEAM ELECTRIC ,
STATION UNITS #1 AND #2 (CPSES) g AFFIDAVIT OF MARK A. WALSH 1 Q: Would you like to comment on the Affidavit of Joseph I. Tapia of 2 the NRC Special Inspection Team (SIT) on Open Items Relating to the Walsh/
3 Doyle Concerns?
4 5 A: Yes. First, regarding the Applicants' reassessing the changes 6 in section properties for tube steel resulting from changes between the 7 7th and 8th Edition of the AISC Manual, it is stated that all large bore 8 and Class 1 small bore pipe support designs are being re-examined by the 9 Applicants using the member property values in the 8th Edition of the AISC 10 manual, and that only small bore Class 2 and 3 supports are affected by 11 the variations (NRC Staff Exhibit 207, SIT Report, page 52). However, while 12 it is clear that the PSE group is supposed to be reassessing the changes, 13 it is not clear that NPSI and ITT Grinnell are also making such a reassessment.
14 In fact, CASE Exhibit 781 from NPSI (admitted at Tr. 6862) and CASE Exhibit 829
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15 from ITT Grinnell (also admitted at Tr. 6862) indicate that they use member 16 properties from the 7th Edition.
o!h$dN3 PDR
- 2-1 This is of vital importance, since NPSI and ITT Grinnell are the 2 two groups who provided the majority of the pipe supports (and are therefore 3 our primary concern). There is no documentation in the record to contradict 4 CASE Exhibits 781 an'd 829 (which are from the companies involved themselves);
5 therefore, the record at this time reflects that both NPSI and ITT Grinnell 6 are using the 7th Edition values.
7 I would like to add that the steps used by th'e PSE group (that is, 8 reassessing the supports for the 8th Edition) are proper. Since the PSE group 9 is a recently formed group, the tube steel used in their designs will be 10 the 8th Edition. The other two groups (NPSI and ITT Grinnell) have been using 11 the 7th Edition properties in their analyses, although what actually exists 12 in the -field may have 8th Edition properties.
13 14 Q: What do you mean "may have"?
15 .
16 A: NPSI and ITT Grinnell have been utilizing both the 7th and 8th 17 Edition tube steel in the field, depending on when the tube steel was formed.
18 However, the drawings do not indicate which edition the tube steel conforms 19 to.
l 20 21 Q: Were the NPSI and ITT Grinnell procedures for flare bevel welds 22 addressed in Mr. Tapia's affidavit?
l 23 l
24 A: No, they were not.
25
1
. 1 Q: What is the difference between the 7th and 8th Editions as it relates 2 to the welds?
3 4 A: This can be illustrated by the following example. Consider a 5 6 x 6 x 1/2,in. tube steel member. If the tube steel confonns to the 8th
~
6 Edition properties, using the value of 5/16 R, as referenced by Mr. Tapia, 7 the effective throat would be (5/16)(2)(1/2) = .313 inches. If NPSI and ITT 8 Grinnell are using the PSE procedure to the 7th Edition properties, the 9 effective throat will be (5/16)(3)(1/2) = .469 inches.
10 11 Q: What is the significance of the above calculations?
12 13 14' A: The significance is that using the PSE procedure the use of the 15 7th Edition properties will indicate a weld size which is 1.5 times what the 16 weld size would be using 8th Edition properties. That is to say, a weld using 17 the 7th Edition properties will indicate a capacity of .469 kips, but if an 18 8th Edition member is used, this value would actually be only .313 kips.
19 In this instance, use of the incorrect Edition properties would lead to the 20 erroneous conclusion that the capacity of the weld is greater than what 21 it really is.
22 23 Q: Are you aware of what the standard industry practice is in this 24 regard?
25
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1 A: I do know that at Bechtel, they took an even more conservative 2 approach. There, we disregarded the flare bevel weld completely and always 3 designed for the capacity of the fillet weld alone. The reasoning behind 4 the disregard for the flare bevel weld is that QC inspectors do not nonnally 5 inspect if full penetration is achieved.
6 7 Q: So they would be unable to tell from looking just what might be 8 underneath?
9 10 A: _That's correct.
11 12 Q: Is there anything else you would like to add?
13 14 A: Yes, I would like to address the items that were left open during 15 the hearing and those items left open in the SIT Report (NRC Staff Exhibit 16 207) which were not addressed by either Mr. Tapia or Dr. Chen.
17 18 (1) The first item is the releasing of the moment in the tube steel 19 menber at a Richmond insert. This is addressed in Section VII of CASE's 20 Proposed Findings of Fact (Walsh/Doyle Allegations), pages 5 through 10.
21 (2) Another item not addressed is the moment restraint and local pipe 22 stresses due to welded stanchions on pipes. This was addressed in the SIT 23 Report on pages 38 through 40 and in CASE's Proposed Findings, pages XVII 24 - 1 through 8. This is of particular importance since (1) the SIT stated 25 that they would review the Main ateam 1ine; (2) I stated that Mr. Krishnan S
- _ . _ _ . _ _ _ - _ . = . - - - - - - . --
. - 5-1 told me that they would not be evaluating the stanchions (or trunnions) 2 on the containment spray and feedwater lines; and (3) it is my under-l 3 standing that many of the supports for the Main Steam line are now being 4 torn out and apparently are being completely redesigned and rebuilt. This 5 rebuilding of supports would have required the Applicants to report this 6 problem to the NRC under 10 CFR 50.55e when they learned of this problem 7 in March of 1982 (which they did not). (See CASE Exhibit 300, which has 8 been accepted into evidence NRC Guidance - 10 CFR 50.55(e), Construction 9 Deficiency Reporting, 4/1/80; and discussion in CASE's Proposed Findings, 10 pages XXIX - 9 through 14.)
11 (3) On pages 27 through 29 of the SIT Report, the Staff discusses 12 stability. On page 20 (at the bottom) the Staff. states that they will 13 " verify that these modifications are completed in a follow-on inspection 14 as part of its construction inspection program (0 pen Item Nos. 50-445/8226-4 15 and 50-446/8214-3)." These itens have not been close.d. Further, one of 16 the proposed modifications is cinching up of U-bolts, which is addressed 17 in CASE's 11/4/83 Assessment of Applicability of Board Notification 82-105A 18 to Comanche Peak Steam Electric Station, which I understand will be sent at 19 the same time as this pleading.
20 (4) In regard to cinching-up of the U-bolts, I would like to bring 21 to the Board's attention one specific reference from Board Notification 22 82-105A. This concerns the terminology for thennal stress (which has been 23 discussed at length in these proceedings). On page IV-3, third paragraph,
! 24 it states:
25 "The thermal stresses resulting from differential thermal expansion
..,__.,w.,,mr._-_,, . , _ . - _ , ,-----,,.._.-...-,,_._,-,-~vr-._ .,-% %.
1 of the pipe and clamp should be ca'tegorized as a secondary (medrane 2 and/orbending) stress" 3 It is obvious from this statement that thermal stresses are not 4 considered to be secondary stresses ordinarily (oth'erwise, it would not 5 have been necessary to make this s'tatement).
6 CASE, in its Findings of Fact and related pleadings has argued 7 that stresses due to ' constraint of free end displacement must be considered.
8 Also CASE has argued that thermal stresses are not secondary stresses. It 9 would appear from BN 82-105A that the stresses imposed on a pipe support 10 due to environmental conditions are secondary stresses and are not thennal 11 stresses as the term is generally used. CASE believes that this BN 82-105A 12 clearly supports CASE's position in regards to the terminology of thermal 13 stress, that is, a thermal stress is additive to the secondary stresses 14 (due to a LOCA) and primary stresses.
15 The classifying of thermal stress as being independent of a secondary 16 stress is critical, since the Applicants have repeatedly claimed they do 17 not consider secondary stresses. Secondary stresses are required to be 18 considered for normal / upset conditions for pipe supports as well as for 19 the building structures.
20 Further hearings are needed to clarify these matters for the Board.
21 22 23 24 25 I
. i I have read the foregoing 6-page Affidavit, which was prepared under my personal direction, and it is true and correct to the best of my knowledge and belief.
Mark A. Walsh DATE: // 83
/
STATE OF TEXAS On this, the # day of November,1983, personally appeared Mark A.
Walsh, known to me to be the person whose name is subscribed to the foregoing instrtment, and acknowledged to me that he executed the same for the purposes therein expressed.
Subscribed and sworn before me on theO# day of November,1983.
- nw Abm Notary Public in and for the State of Texas My Commission Expires: /Ms//p/
t
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