ML20099G274

Affidavit of Jc Finneran Re Case 841105 Motion Concerning Sampling of Cinched Down U-bolts.Torques Recorded in Unit 2 U-bolts Representative of Torques Recorded in Unit 1 & Common U-bolts.Certificate of Svc Encl

ML20099G274
Person / Time
Site:	Comanche Peak
Issue date:	11/19/1984
From:	Finneran J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20099G259	List: ML20099G255 ML20099G274
References
OL, NUDOCS 8411270196
Download: ML20099G274 (6)

Text

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1 la Attachment UNITED STATES OF AMERICA.

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

.In the Matter of )

) Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC ) 50-446f COMPANY, et al.

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

Station, Units 1 and 2) )

AFFIDAVIT OF JOHN C. FINNERAN, JR.

REGARDING CASE'S MOTION CONCERNING SAMPLING OF CINCHED DOWN U-BOLTS 1, John C. Finneran, Jr., being first duly sworn, hereby ,

depose and state as follows:

I am the Pipe Support Engineer for the Pipe Support Engineering Group at Comanche Peak Steam Electric Station.- In this position, I oversee the design work of all pipe support design organizations for Comanche Peak. I have previously provided testimony in this proceeding. A statement of my professional and educational qualifications was received into evidence as Applicants Exhibit 142B.

The purpose of this Affidavit is to provide information responding to CASE's Motion of November 5, 1984 regarding sampling of torques in cinched down U-bolts at CPSES. At the outset I would like to state that the Unit 2 U-bolts at CPSES are identical in make, manufacture and sizes to, and were torqued

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. u using the:same construction practices as the. Unit 1 and' common

U-bolts. In short, th'e torques recorded in the Unit 2 U-bolts L

werefrepresentative of the torques in'the Unit 1 and common U-bolts. (In-this~ regard, the' October 8, 1982 procedure referenced by CASE in'its motion was written at-the suggestion of the NRC resident inspector at that time (Robert Taylor) to document the construction practice that had been and currently was'being used to torque U-bolts.) It should be noted-that, in any event, Unit 1 had-already been painted and any torque values measured on Unit 1 U-bolts would have been suspect if not altogether meaningless for our purposes- .

Accordingly, we sampled the only-representative population available to us -- the U-bolts 4.n Unit 2.

It never occurred to us that there would even be a concern with the fact that Unit 2 U-bolts were sampled rather than Unit

1. It was certainly obvious to us that due to the circumstances i the sampling of Unit. 2 was representative of Unit 1, .and'the only

! feasible option.

P In our sample, we also used non-safety related U-bolts. In that all cinched down U-bolts at CPSES (safety related and non-safety related) are identical in make and manufacture a.id were torqued using the same :anstruction practice, the torque on non-safety related U-bolts are representative of the torque on safety related U-bolts. Indeed, a comparison of the torque measured on

'non-safety and safety related U-bolts demonstrates this point, and CASE has not, and cannot state otherwise. I would note that, i

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-_3 if anything, use of non-safety-related U-bolts-in the. sample was-conservative in.that workers'may be.less careful'with. torquing-of

, such U-bolts.:

In. response to' CASE's request as.to whether Applicants have utilized;other random-representative samples from Unit 2 rather. ,

. than Unit 1, I am unaware of.any other instance where-a random field sample of. Unit 2 was conducted in lieu:of and as ,

representing a sample in Unit 1. In this regard, however, in

- Affidavit of' Messrs. Iotti and.Finneran.Regarding-Consideration-P of Force Distribution in Axial Restraints (at 10)', attached to Applicants Motion on this issue (July 9, 1984), Applicants

sample consisted of 29 supports employing lugs, 24 of which.are in Unit 1 and common and five of which are in Unit 2.

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p C. Finneran, Jr. [

STA'IE OF TEXAS 01MY OF SOERVELL Subscribed and swm to before me this 19th day of Ncmseber,1984

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• This is a telecopy facsimile. The original will be

. forwarded under separate cover.

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UNITED. STATES OF AMERICA: - A9 :53 1 NUCLEAR. REGULATORY COMMISSION- ..

UI?UE DISECFp m s

BEFORETHEATOMICSAFETYANDLICENSINGBObd'EI JE9vid

'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)~ )

CERTIFICATE'OF SERVICE

'I hereby certify that copies of " Applicants' Reply to CASE's Motion Concerning Information Regarding Cinching Down U-Bolts" in the above-captioned matter were served upon the following persons by deposit in the United States mail, first class, postage prepaid,1this 19th day of November, 1984.

Peter B. Bloch, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety.and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. William L. Clements Dr. Walter H. Jordan Docketing & Service Branch 881 West Outer Drive U.S. Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom Dean, Division of Engineering Architecture and Technology Stuart A. Treby, Esq.

Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Legal Director U.S. Nuclear Regulatory Mr. Robert D. Martin Commission Regional Administrator, Washington, D.C. 20555 Region IV U.S. Nuclear Regulatory Chairman, Atomic Safety and Commission Licensing Board Panel Gil Ryan Plaza. Drive U.S. Nuclear Regulatory Suite 1000 Commission Arlington, Texas 76011 Washington, D.C. 20555 L

in 1 Renea Hicks, Esq. Mrs. Juanita Ellis Assistant Attorney General President, CASE Environmental Protection 1426 South Polk Street Division Dallas, Texas 75224 P.O. Box 12548 Capitol Station Austin, Texas 78711 Elizabeth B. Johnson Oak. Ridge National Laboratory Post Office Box X Lanny A. Sinkin Building 3500 114 W. 7th Street Oak Ridge, Tennessee .37830 Suite 220 Austin, Texas 78701 4

MalboTm H. P K ips, Jr.

cc: John W. Beck Robert Wooldridge, Esq.

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