ML20100B281

Response to ASLB 841109 Memorandum Re Pipe Supports.None of Hot Functional Testing Results Described by Re Camp Corroborates Case Allegations or Raises Any Safety Question Re Pipe Support Design

ML20100B281
Person / Time
Site:	Comanche Peak
Issue date:	12/03/1984
From:	Horin W BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20100B282	List: ML20100B281 ML20100B288 ML20100B293
References
CON-#484-440 OL, NUDOCS 8412040272
Download: ML20100B281 (6)

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.4-DecembEQEC1984 UNITED' STATES OF AMERICA NUCLEAR REGULATORY. COMMISSION'g4 (yg _4 go gg BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .

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In the Matter of )

TEXAS UTILITIES ELECTRIC

) Docket Nos. 50-445 and 4 j

) 50-446 COMPANY, ET AL. ) -~- .-

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) (Application for (Comanche Peak' Steam Electric ) Operating Licenses)

Station, Units 1 and 2) )

APPLICANTS' RESPONSE TO BOARD MEMORANDUM (OFFICIAL NOTICE CONCERNING PIPE SUPPORTS)

I. INTRODUCTION On November 9, 1984, the Board issued a Memorandum (Official Notice Concerning Pipe Supports). In that Memc_andum the Board quoted a. portion of the transcript from a meeting between Appli-cants and the'NRC Staff Technical Review Team where one of Applicants' employees was discussing the status of hot functional testing. That individual mentioned further testing of " deficient supports found during hot tunctional testing" and "re-tests associated with thermal expansion". The Board stated that the parties could " correct these portions of :he transcript" if they >

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_2-wished.1 - The Board stated that- it appeared that the quoted portions of the transcript 'were relevant to the adequacy of the design of pipe supports, quality assurance for design and Applicants' motion for summary disposition regarding safety factors. (Memorandum at 1.)

Applicants requested clarification of the Board's concern in a letter dated November 14, 1984. The Board offered clarifica-tica on a conference call the following day where it stated it was concerned with whether the " deficient supports" found during hot functional testing mentioned at the meeting corroborate the Intervenor's allegations regarding pipe support design and whether the "re-tests associated with thermal expansion" cor-roborated Intervenor's allegations regarding thermal expansion effects.and local stresses on pipes (Tr. 19,431-32).

II.

APPLICANTS' RESPONSE TO BOARD INQUIRY A.

Consideration Of Hot Functional Testing t.lready Denied By Board The Board will recall that on October 13, 1983, CASE filed a motion for a new contantion based on the hot functional test i

1 Applicants had unt.icipated filing this response on November 30, 1984, as authorized by Dr. McCollom on November 21.  !

However, because of last minute difficulties in contacting one of the affiants - for this response Applicants are filing the requested information today. i here that the Board authorize this shortAccordingly, we request filing the -instant response. additional time for i

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results.2 Following deta,iled examination of CASE's motion 3 the Board denied CASE's motion for'a-new contention and determined that. CASE did not raise any concerns which warranted taking up

'the issue sua sponte.(Special Prehearing Conference Order (Late Contention on Hot Functional Testing), November 23, 1983 at 1-2).

The Board's original consideration of this matter closely tracked the Board's present. inquiry. The Board considered not only whether the HFT results had implications for the Walsh/Doyle allegations,4 including the thermal expansion allegations,5 but also whether the test results raised implications regarding quality assurance for design.6 Upon consideration of each of these matters the Board declined to admit the new contention or 1

l pursue the matter sua sponte.

Applicants note  !

that CASE's motion for a new contention was {

premised on Test Deficiency Reports (TDR's) produced for CASE on  !

discovery in the rate hearings. CASE had a full opportunity then to demonstrate to the Board that this matter should be pursued in the hearings. Indeed, CASE's motion for a new contention was 2

" CASE's (1) Motion to Add a New Contention, (2) Motion for Discovery and (3) Offer of Proof" (October 13, 1983).

3 See Applicants' Answer to CASE's Motions (1) To Add a New Contention and (2) For Discovery (November 3, 1983) and NRC Staff's Answer to CASE's Motion to Add New Contention, Motion for Discovery and Offer of Proof (November 9, 1983);

see also Telephone Conference of November 16, 1983.

4 See e.g., CASE's Motion at 10; Tr. 9171.

5 See e.g.,

CASE's Motion at 26-35; Tr. 9150, 9160, 9164-68; Special Prehearing Conference Order at 6-7.

6 See Special Prehearing Conference Order at 7.

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over 2-l'/2 inches thick, appending numerous TDRs. Further, the Board fully questioned'the parties during the November 16, 1983, prehearing regarding its own concerns.

In sum, the question of the implications of the HFT has already oeen fully pursued and disposed of by the Board. We believe no basis. exists for again pursuing this matter and object to further Board inquiry. Nonetheless, Applicants provide below the information now requested by the Board.

B. Response To Present' Board Inquiry

1. Statements by Mr. Camp The Board's ' first question is whether the statements by Mr.

Camp at the TRT meeting require correction. As explained by Mr.

Camp in the attached affidavit, there is no need to correct - that transcript. The term " deficient supports" concerns supports which did not satisfy test criteria. It was not used to refer to supports which were incorrectly designed. Further, the reference to retests for thermal expansion concern routine test results related to thermal expansion of the piping system. In fact, the type of conditions observed during hot functional testing are the type expected and routinely encountered in such testing. (Camp Affidavit.)

y In sum,JMr. Camp's statements before the TRT are-accurate and.do not require correction. The " support deficiencies" and re-tests for thermal expansion simply concern expected and, routine test results. documented as test deficiencies.

2. Relationship of Test Results to Issues in Proceeding To respond to the Board's questions regarding the relevance of the HFT results to issues in the proceeding (design quality assurance, Walsh/Doyle allegations, safety factors, thermal expansion, local stresses) Dr. Robert C. Iotti and John C.

Finneran, Jr., reviewed each of the TDR's related to pipe supports. As they explain in their, attached affidavit, none of these deficiencies corroborates any of the Intervenor's allegations or raises adverse implicatior.s for the design OA process. Further, the HFT results do not indicate that any of the safety margins addressed by Applicants in their motion for summary disposition regarding safety factors were incorrect.

III. CONCLUSION In sum, none of the HFT results described by Mr. Camp corroborates CASE's allegations or otherwise raise any safety a

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question regarding the design of pipe supports at Comanche Peak.

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Accordingly, there is no need for Applicants to correct these portions of the' transcript.

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Respectfully submitted, i g Nicholas S.E kb 3 nolds William A..Horin BISHOP, LIBERMAN, COOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202) 857-9600 December 3, 1984 '

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