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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] |
Text
_ _ _ _ _ _ _ _ _ _ - _ _ _
O UNITED STATES OF AMERICA NUCLEAR PEGULATORY COMMISSION Og[
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l '84 SEP -4 I"O M1 1
! TEXAS UTILITIES GENERATING l Occket Nos. 50-445-Db COMPANY, et al.
l and .50-446-fj Q (Comanche Peak Steam Electric Station l Station, Units 1 and 2) {
CASE'S ANSWER TO APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO CENUINE ISSUE REGARDING CONSIDERATION OF LOCAL DISPLACEMENTS AND STRESSES in the form of AFFIDAVIT OF CASE WITNESS JACK D0YLE I. Zero Clearance Box Frames
- 1. Applicants state:
"In the absence of quantitative code guidance, Applicants employed a conservative methodology for selecting allowables for assessing the localized pipe stresses. These allowables are approximately 60% of the allowables uhich normally would be applied, i.e., three times Sm.
(Finneran Affidavit at 4.)"
I disagree with Applicants' statements.
The Applicants have defended the box frame concept for supporting pipes since the time of my deposition in August 1982 d /, at which time I pointed out two problems with this concept
/1/ See CASE Exhibits 669 and 669A, Deposition / Testimony of Jack Doyle, and CASE Exhibit 669B, Attachment to Deposition / Testimony of Jack Doyle.
0409040415 040929 PDR ADOCK 05000445 0 PDR 1
p
- g. .-
r i
( (1) It' restrained thermal growth of the pipe; and I (2) It represented an unstable structure. During the September 1982 hearings, with the aid of models I demonstrated the instability factor. Beyond this, by the use of simplifying equations, I showed that the forces exerted on the box frame were on the order of 28,000 lbs. or 14 tons.
The Applicants and their agents, and in fact, the NRC Staff, have steadfastly stated that this configuration presented no problems. They are not quite sure why this is so, but we must commend thos on their persistence if not their technical competence. I state this because each time they offer.an absolute proof showing the ability of the system to withstand the forces exerted by the pipe, they either get shot down or blow off their own foot. But rather than backing off, t.Sey merely come forward with yet another absolute proof.
A few examples of this proof-of-the-sonth effort are as follows:
(1) There is no thermal problem because the frame does not actually have a zero inch gap g/. The NRC Special Inspection Team (SIT) was quite proud that the Applicants had informed them of this avenue of escape. Beyond this, Applicants had physically measured a number of box beams and announced that they had found that gaps in fact had existed.
However, CASE pointed out that this condition ensured instability.
12f -See NRC Staff Special Inspection Team (SIT) Report, at page 34.
2 1
- u. .
~~ - -=
p g
., Je r. .
V (2) Applicants' agent, Cygna Energy Services, proceeded to prove that there1was no problem with these box frames by utilizing the most sophisticated method of analysis (finite element);
however, their efforts only proved that.there were serious problems with this clamping system /]/. Beyond this, although Cygna was less than satified with some of the r
results of finite element analyses that they had accomplished, they conceded that the excessive forces indicated by the modelling for box beams in this finite model were likely to be more accurate than sose of the others /4/.
However, undaunted by these failures, Applicants have now unveiled their latest final absolute proof. But hold your plaudits, for what we have here is yet another example of the deceit and/or stupidity of those "somewhat knowledgeable" engineers for which Applicants have achieved legendary status in their own time.
For this final absolute beyond-the-shadow-of-a-doubt proof, Applicants of fer Attachments A, B, C, and D to their Motion for Summary Disposition, which are so flawed as to be rendered useless. For examples Referring to Attachment A (1) At page 1 of calculation SI-1-325-002-532R, Applicants state "If air film insulation effect is considered, actual tube temperature will be much higher. Thus, this approach is very conservative."
13/ See Tr. 12,710-12,712, 12,724-11,725.
/4/ See Tr. 13,086.
3 k____mm_____.__________-,_____________.._______-__m_._
'u '
- %'/JAN . _
4 I would have thought that even Applicants' somewhat.
af knowledgeable engineers would not attempt to' reverse'the laws J
of_ thermal transport, for the fact is if the air film is considered, the box beam temperatures would be much lower, not much higher as stated by Applicants. The pipe wall-temperature at the interface between the outer wall of the pipe and the surface of the air film would be higher, 'aut not the tube interface, since there is an additional layer (air film) between the pipe and the box frame.
(2) The above point is relatively minor when compared to the fatal error which appears on page 2 at (2) of the calculation.
While it is a fact that due to contact between the, pipe and the box beam thermal transfer will occur, it is not true that the full length of the tubes making up the box beam will experience the same temperature gradients as was calculated for the tube width resulting from line contact. Any temperature from Applicants' procedure would exist only at a point directly opposite the line of contact.
(3) Because of the temperature gradient between the inner and outer surface of the box frame, the box frame will not expand 0.01359 inches as assumed by Applicants but will in fact expand in an indeterminate manner to a f ar less degree.
Additionally, as a result of the differential expansion of 4
i: c .
[.
the two surfaces of the tubes making up the box beam, there will be new internal thermal stresses generated which were not considered by Applicants.
(4) The fact is that the thermal gradient is not linear as indicated by Applicants. See CASE Exhibit 669B, Attachment to Deposition / Testimony of Jack Doyle, graphs generated through tests by ITT Grinnell, items 13E through 13J. This would result in actual box frame stresses that are somewhat higher than assumed by Applicants' considering direct bending only as a result of thermal constraint.
(5) Another point associated with Applicants' attempt to supplant logic wih the appearance of logic may also be found on page 2 (2). Young's Modulus is stated to be: 6.387 times 10 to the
-6, whereas the AISC states at 6-11 that Young's Modulus is approximately (6.1 + .0019 times the temperature) times 10 to the -6, or 6.486 times 10 to the -6, and this would be.the value used in the analysis of a warehouse, not the lesser value used by the Applicants.
Collectively, these deviations from engineering fundamentals listed above become frightening when one finds that the wide band of reliability which existed prior to the inclusion of thermal expansion effects has been dangerously erroded. For example, Applicants at page 8 of 11 indicate that the stress levels for equation 11 are 39169 divided by 44000 = about 90%. However, the reality is that when 5 ,
i 1
-._--___---__--__----__--___j
~
-properly' analyzed, the pipe. falls to meet the codes.
-When considering_this single problem, one must be aware that there are other contributors. to this problem which have not been addressed.
For example, the mass of' supports supported by the pipe, the stiffness effects, etc., all could' result in higher mechanical loads, and are being independently. addressed elsewhere.
This manicuring of standard procedures will always occur when somewhat krawledgeable engineers are allowed to justify multiple problems on a point-by-point basis with each justification being offered independent of all other concurrent problems. If the principle of uncoupling of problems were acceptable procedure, it would have been accepted years ago as a means of reducing the cost of all types of construction. ,
I have come to the conclusion, after almost two years of shooting at moving targets thrown up by the Applicants, their agents, and in fact the NRC Staff, that the American system of jurisprudence is not the proper- forum for determining the reliability of nuclear power plants. Should the Board accept the procedures utilized by Applicants to justify construction which was initiated by somewhat knowledgeable engineers based on their judgement in lieu of technical expertise, then the Board must be prepared for the consequences. Acceptance of these concepts offered by the Applicants will establish precedent legalizing the approach of constructing facilities without attention to fundamentals and codes and then at a later time justifying this fait l accompli. And this will apply on a national basis, not strictly to Comanche Peak.
6
1 l
l l
I didn't waste my time dissecting all of the material accompaying
. Applicants' Motion for Summary Disposition on this subject, since I believe that the points made on Attachment A are sufficient to show the methodology that Applicants have used throughout these hearings. Beyond this, it is appalling that for almost two years it has been Mark Walsh and I that have rooted out the fallacies of Applicants' offerings, while the NRC Staff not only have f ailed to perform their mission to protect. the public health and safety, but have in fact been joint participants in these devious games played by Applicants.
- 2. Applicants state:
"There are 51 zero clearance box frame supports at Comanche Peak.
(Finneran Affidavit at 4.)"
See answer 1 preceding.
- 3. Applicants state:
"Only one zero clearance box frame is located on a piping run with a maximum water camperature greater than 200 degrees F. This is support SI-325-002-S32R. The maximum temperature of the pipe in this case is 350 degrees F. (Finneran Affidavit at 4.)"
See answer 1 preceding.
- 4. Applicants state:
"Even when including the local stress induced in the frame from the thermal expansion of the pipe with other loads, all stresses in the frame on support SI-325-002-S32R are less than Code allowables. The 7
t d-iloads and stresses 'in this support would be greater than those.
~
E encountered in'the:other supports of this type because of the higher temperature of this pipe and the fact that the pipe is stainless steel ;
(resulting in greater pipe expansion), and the greater thickness of .the pipe (affording less flexibility and, thus, imparting greater loads).
.(Finneran Affidavit at 4-5.)"
See answer 1 preceding.
- 5. ~ Applicants' state "All stresses in the' pipe are also less than the con,servative ,
allowables Applicants employ for assessing localized pipe stresses.
(Finneran Affidavit at 5.)"
See answer 1 preceding.
t 1 i !
-t
- 6. Applicants states
! "Cygna also peformed an' analysis (finite element) of the frame on this support. Their analysis demonstrated that the stresses in both the
> pipe and the box frame remained well below allowables even when both
- thermal and mechanical loads were combined. (Finneran Affidavit at 5-6.)"
i See answer 1. preceding.
4 i
I e
- 7. Applicants states
,! - " Applicants conservatively calculated the loads between the frsee and i the pipe for the support cited by CASE in its Proposed Findings (page l IV-17) on this topic. That analysis demonstrates that the resulting -
- j. force between the pipe and the frame will be 454 lbs. CASE had
., estimated, using a very simplified calculational technique (CASE
! Froposed Findings at IV-17), that the laod created between the pipe and
- the box frame was 27,280 lbs. (Finneran Affidavit at 6.)"
! i See anewer 1. preceding.
l 8
I
0; II. Anchors
'8. Applicants state:
" Applicants performed a conservative analysis of the anchor supports referenced in Section 14 of CASE Exhibit 6698 for which CASE claimed the ' radial' thermal expansion of the pipe should have been calculated.
Inclusion of the thermal expansion effects of the pipe with other loads in the assessment.of the anchors led'to no overstressed conditions.
(Finneran Affidavit at 8.)"
See answer 1 preceding.-
- 9. Applicants. state:
"Cygna analyzed a similar support for these same effects in their response.to Doyle Question 15 (see Testimony of Nancy H. Williams, Board April 1984 Ex.1 at 33.) These results demonstrate that all stresses in the frame and baseplate were far below the allowables used by Cygna. (Finneran Affidavit at 7-8.)"
See answer 1 preceding.
III. Tube Steel Walls
- 10. Applicants state:
" Applicants' practice regarding the assessment of local stresses in tube steel walls is for each support design organization to assess the effects on a case-by-case basis, when deemed appropriate by the engineer. The NRC Staff reviewed Applicants' practices in this regard and had no concern regarding the adequacy of Applicants' approach. The l
Staff reviewed a random sample of 100 vendor certified supports
- selected by the Staff and found Applicants had considered these local
! effects. (Finneran Affidavit at 9.)"
i See answer 1 preceding.
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- 11. Applicants state:
" CASE performed no calculations to substantiate its assertions on this issue. Rather, CASE premises its position on certain factors it believed indicated that analyses should be performed. First, CASE incorrectly implies that the minimum width ratio of tube steel to tube steel connections that Applicants used (until September of 1982) was 0.8. Next, with respect to CASE's assessment of the local stresses in the support referenced in its Proposed Findings, CASE claims that the-tube to tube ratio was less than .4. The connection ratio is actually
.5625. Finally, the actual stress for this connection is 2261 psi, or 57% of the applicable allowable. Thus, contrary to CASE's assertion the design of this connection is clearly adequate. (Finneran Affidavit at 10-11.)"
See answer 1 preceding.
- 12. Applicants state:
" Applicants selected several worst case supports from CASE Exhibit 669B with tube steel connection ratios less than 1.0., and included three additional supports claimed by CASE to have been inadequately designed with respect to local effects of welded attachments to tube steel, for detailed local failure analysis. In all cases the local stresses were less than allowables. (Finneran Affidavit at 11-12.)"
See answer 1 preceding.
IV. Local Deflections and Deformations
- 13. Applicants state:
" Applicants' practice regarding consideration of local deflections and deformations is standard industry practice which is premised on sound engineering principles that result in adequate support designs.
Applicants' practice is to consider the deflections of the structural portions of each support in calculating deflections for comparison to the'1/16" deflection guideline. (Finneran Affidavit at 13.)"
See answer 1 preceding.
10
- 14. Applicants state:
"To assess these effects, Applicants selected the 15 supports from CASE Exhibit 6695 which present worst case conditions, and a support used by CASE in the cross-examination of the Staff on this subject.
Applicants' analyses demonstrate that even when local and component effects are accounted for in deflection calculations, their deflection criterion is still satisfied in the vast majority of cases. In those casas where the deflection does exceed 1/16" (and none greatly exceeded the criterion), the support stiffnesses remained in the acceptable range. Thus, although these local effects may result in potential deflections slightly greater than 1/16" there is no safety significance to this fact. (Finneran Affidavit at 13-16)."
See answer 1 preceding.
- 15. Applicants stato:
" CASE incorrectly alleges that Applicants' support designs will have
'large deformations' and, thus, Applicants have not satisfied the guidance contained in the Regulatory Guide 1.124. However, Applicants' practice regarding Class 1 supports (to which the Regulatory Guide applies) is to perform complete stiffness calculations, including consideration of local effects. (Finneran Affidavit at 16.)"
See answer 1 preceding.
- 16. Applicants state:
" Irrespective of the support classification, the discussion in Regulatory Guide 1.124 regarding large deformations is related to the use of plastic analysis methods. With respect to support design using elastic analysis, as Applicants use, Regulatory Guide 1.124 recognizes that deformations will, in fact, be small. (Finneran Affidavit at 17.)"
See answer 1 preceding.
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