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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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I l
i Attachment 1 l
June 22, 1984 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l 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) )
i AFFIDAVIT OF R.C. IOTTI AND J.C. FINNERAN, JR.
REGARDING DIFFERENTIAL DISPLACEMENT ,
OF LARGE FRAME PIPE SUPPORTS We, John C. Finneran, Jr., and Robert C. Iotti, being first duly sworn hereby depose and state, as followsl: ,
(Finneran) 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 state-ment of my professional and educational qualifications was received into evidence as Applicants' Exhibit 142B.
(Iotti) I am the Chief Engineer, Applied Physics for Ebasco Services, Inc. I have been retained by Texas Utilities 1 Except as otherwise indicated, each Affiant attests to all parts of this affidavit.
8406260298 840622 PDR ADOCK 05000445 O PDR
. Electric Company to oversee the assessment of allegations regarding the design of piping and supports at Comanche Peak Steam Electric Station. A statement of my educational and professional qualifications is attached to Applicants' ,
letter of May 16, 1984, to the Licensing Board.
Q. What is the purpose of this affidavit?
A. This affidavit addresses the Licensing Board's questions regarding " Differential Seismic Displacement" set forth in the Board's February 8, 1984, Memorandum and Order at p. 30, i.e., "how it came about that PSE violated its own design guidelines [regarding design of wall-to-wall or floor-to-ceiling pipe supports], how this event came to be reflected in its design quality assurance system, and whether this problem was resolved promptly . . . ." In addition, this affidavit addresses CASE's recommendation regarding this issue (set forth in its Proposed Findings at p. VI-14) that Applice.nts should be required to reanalyze all wall-to-slab l
(floor or ceiling) pipe supports as it had done for wall-to-wall and floor-to-ceiling pipe supports. Finally, this Affidavit provides a report to the Board on all floor-to-ceiling and wall-to-wall pipe supports. Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design) at p. 7 (February 3, 1984).
~
Q. Are you familiar with CASE's allegations regarding the adequacy of floor-to-ceiling and wall-to-wall pipe supports?
A. Yes. As set forth in the Board's Memorandum and Order of December 28, 1983 at pp. 57-58, CASE has alleged that there ;
should be slip-joints in all large frame supports which span f rom wall-to-wall or floor-to-ceiling. PSE guidelines provided general guidance to this effect. Memorandum and f Order of December 28, 1983 at pp. 57-8. In CASE Exhibit 669B at pp. 7c and d, CASE had identified two supports on ;
the service water system that were designed inconsistent with these guidelines. Id.
Q. Discuss the background and disposition of these large frame supports on the service water system identified by CASE.
A. As indicated in Applicants' Exhibit 142 at p. 25, prior to this issue being raised by the NRC or CASE, in late 1981 Applicants identified large-frame, floor-to-ceiling supports designed by PSE as being inconsistent with PSE guidelines.
(The PSE guidelines state that such large-frame supports should have slip-joints; the purpose was to negate the need to consider differential seismic displacement for such supports between floor and ceiling or between walls.)
t Actually, there were four identical PSE supports in the service water yard tunnel which extended from floor-to-l l ceiling without slip-joints, thus falling outside these
~
guidelines. It should be noted that there were not neces-
- sarily any design deficiencies with these supports, they
[
just'didn't follow PSE guidelines. The supports were very
. conservatively designed, and it was believed that they were. ,
adequate. ,
In the process of awaiting completion of construction of' structures associated with the four supports, and obtain-ing as-built loads by which to fully assess the adequacy of the designs, the NRC Special Investigation Team (" SIT")
inquired about the adequacy of these supports. While Appli-cants believed that a detailed analysis of the supports would demonstrate their adequacy, calculations reflected that the floor-to-ceiling columns could simply be cut off and the supports would still be adequate. This was by far the easier course of action. Accordingly, Applicants cut the columns in half to eliminate any suspected problems of a support extending from floor-to-ceiling.
Q. Did Applicants perform any analyses of the original designs i to demonstrate adequacy?
A. Yes. After this issue was raised in this case, to demon- r i
strate the adequacy of the initial designs, Applicants determined the seismic differential displacement between the floor and ceiling in the location of the supports and anal-yzed the-columns for the combined design load and differen-tial seismic displacement load. The differential seismic j ' displacement between the floor and the ceiling in this area is .006 inches (less than the thickness of two sheets of ,
paper). Using the computer code STRUDL, one of the four identical supports was analyzed for the combined effect of
. pipe loads and the full seismic differential support motion of the floor and ceiling. This is, of course, conservative since the .006 inches is. the displacement that would occur with no column. The presence of the column assures that the actual displacement would be less. Moreover, the computer code itself models the configurations in an extremely conservative manner. For example, the computer code ideally assumes that (1) all members are hard and fast at all support points with no connection flexibility, and (2) all joints modeled as rigid connections remain rigid without any rotation at all. In the real world, neither of these two assumptions are true, and accordingly, a differential displacement of .006 inches (that is limited and would never exceed .006 inches) would never be a matter of concern for any support. In any event, the resulting stresses in the support based on the computer run were within the code allowable values.
In conclusion, the analysis demonstrates that the supports were capable of supporting the original piping loads as well as differential seismic displacement loads between the floor and ceiling.
Q. Have you conducted a review to determine if there are other floor-to-ceiling or wall-to-wall supports in the plant?
A. Yes. Applicants have reviewed all Unit 1 and common safety related piping supports and determined that there are 26 supports spanning from wall-to-wall or floor-to-ceiling. Of
these 26 supports, 7 have slip-joints, 4 have small spans and negligible movements and are not considered large-framed supports, and the remaining 15 have been evaluated and are acceptable considering the potential for differential seismic displacement. (A listing of these supports is contained in Attachment 1). Significantly, none of these remaining 15 supports were designed by PSE, and they were designed prior to transmittal of the PSE guideline regarding this issue to the other design organizations. Accordingly, the PSE guideline was not applicable to these initial design ,
efforts.
t' O. Please answer the Board's first question, "how it came about that PSE violated its own design guidelines." (Memorandum and Order of February 8, 1984, at p. 30.)
A. It must be remembered that the PSE guideline regarding l
l floor-to-ceiling and wall-to-wall supports was not a code or procedural requirement, but rather guidance for the designer. Indeed, this guideline was not initially applica-ble to the other two design groups (ITT and NPSI). However, as indicated above, their supports were adequately designed for all loads including differential seismic displacements.
Uhile we cannot be certain why the designer and reviewer did not follow the guideline for these four PSE supports (these individuals are no longer employed at CPSES), as previously demonstrated the designs were appropriately conservative and, even if unchanged would have been acceptable.
P Q. Please answer the Board's second question, "how did this event [come] to be reflected in the design quality assurance system?" Id.
A. The failure to follow the PSE guideline for these four supports did not require the generation of any QC non-conformance documentation. If the supports had not been adequately designed in the first instance , - appropria te corrective action would have been required in accordance ;
with site procedures. Of course, because there was a design change of the supports, appropriate design change documenta-tion was generated.
Q. Please answer the Board's third question, "whether this problem received prompt a ttention. " Id.
A. Yes, the problem received prompt attention. In 1981 the four non-complying supports were identified. As previously ,
stated, it was believed that the designs, although not in strict compliance with the PSE guideline, were adequate.
Accordingly, Applicants chose to wait until construction associated with all four of the supports and all piping had been completed to determine the precise as-built loads to assure the adequacy of the designs. In the interim, the SIT raised the issue and the decision was made to modify the supports as opposed to going through a detailed and, because of timing, a prema ture design analysis. That prompt atten-l tion to this problem was taken is evidenced by the fact that only these four supports were in violation of the guideline.
I l
l l
i In sum, Applicants did promptly respond to the problem when it was identified.
Subsequently, the SIT recommended that the guideline regarding this issue be made applicable to ITT and NPSI.
While Applicants did not believe it was necessary, Appli-cants promptly complied with the request. As previously noted, analysis of similar supports designed by ITT and NPSI reflect that such supports were adequate including consider-ation of differential seismic displacement.
Q. CASE has recommended that Applicants analyze all wall-to-slab (floor or ceiling) supports in the plant which do not contain slip joints. Are stresses on these supports result-ing from seismic differential displacement significant?
A. No. The seismic deflection that could occur on wall-to-slab supports consists of vertical deflection of the slab and horizontal deflection of the wall. In that such supports are near the juncture o'f the slab and wall, the actual deflection realized at the support would be minimal and less than the maximum deflection realized toward the middle of the wall or slab. To determine if differential seismic deflection appeared to be a problem with such supports, we analyzed three representative supports using the STRUDL code (discussed above) (i.e., support numbers CC-1-070-002-A33R, CS-X-004-004-A33R and SW-1-132-703-Y33R). The differential seismic displacement for the three supports ranged from
.00035 to .0045 inches, less than the seismic deflection I.
W -
analyzed above regarding floor-to-ceiling supports. As with those other supports, displacements of this range would f never be a matter of concern for any support. In any event, the results of the analysis (even with its substantial !
conservatisms noted above) reflected that stresses for all j members from pipe loads and dif ferential seismic motion are ,
below allowables.
e
f 4
L- .
- l /
Robert C. Iotti
/ r
p ohn C. Finneran, Jr. /
Subscribed and sworn to before me this' day of June, 1984. i r
lei u= ? rc !? L
' Notary Public ~
- 11 Comunnmos Expires Msg 31,1937 L
5 a
i t
e e
ATTACHMENT 1
SUMMARY
OF WALL TO WALL OR FLOOR TO CEILING SUPPORTS Support Number Remarks PSE 1. AF1-099-712-S33R Support designed with slip joints
- 2. CC1-028-720-S33R Support designed with slip joints
- 3. CC1-028-721-S33R Support designed with slip joints
- 4. FW1-017-714-C52R Support designed with slip joints
- 5. BRX-057-705-A53R Small span (4') and negligible seismic motions
- 6. BRX-057-706-A53R Same remark as #5.
- 7. H-BRX-AB-064-006-3 Small span (3') and negligible seismic motion
- 8. SW1-129-736-A43R Small span (4'-3") and negligible seismic motion ITT 9. CC1-009-016-A43A Analysis including differential seismic motion show all stresses below allowable
- 10. CC1-057-011-A33R Support designed with slip joint
- 11. CC2-019-003-A33R Analysis including differential seismic motion show all stresses below allowable
- 12. CS1-018-001-S52R Analysis including dif ferential seismic motion show all stresses below allowable
- 13. CSI-018-002-S52R Support designed with slip joints
- 14. CSI-018-004-S52R Analysis including differential seismic motion show all stresses below allowable
- 15. CSI-018-009-S52R Analysis including dif ferential seismic motion show all stresses below allowable
- 16. CT1-025-004-S22K Support designed with slip joint
- 17. SW1-011-016-F33R Support has already been assessed for differential seismic motion and is ;
acceptable
- 18. SW1-011-017-F33R Same as #17 '
- 19. SW1-011-018-F33R Same as #17
- 20. SW1-011-019-V33R Same as #17
- 21. SW1-011-020-F33R Same as #17
- 22. SW1-011-021-F33R Same as #17
- 23. SW1-011-022-F33R Same as #17
- 24. SW1-011-029-F33R Same as #17
- 25. SW1-173-063-S42K Attached with flexible angle clips and negligible differential seismic motions NPSI 26. FW1-097-018-C62R Analysis including differential seismic motion show all stresses below allowable
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