ML20083K020

Forwards Responses to Items 1 & 3 of 840222 Brief Summary of Generic Problems & Item 10 to cross-examination Questions Re Independent Assessment Program

ML20083K020
Person / Time
Site:	Comanche Peak
Issue date:	03/02/1984
From:	Williams N CYGNA ENERGY SERVICES
To:	Ellis J Citizens Association for Sound Energy
References
84042.02, NUDOCS 8404160031
Download: ML20083K020 (13)

Text

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as l 415 397 5600 101 caenia street, suite 1000, san rrancisco, cA 941115894 March 2,1984 84042.02

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Mrs. Juonita Ellis, President Citizens Association for Sound Energy l426 South Polk Dallas, Texas 75224

Subject:

Comanche Peak Steam Electric Station Independent Assessment Program -

Response to CASE Questions -

Reference:

(l) Brief Summary of Generic Problems from CASE Witness ATTACH Eb Jack Doyle,2/22/84.

(2) Brief Summary of Cross-excminatica Questions from CASE Witness Mark Walsh,2/22/84.

Dear Mrs. Ellis:

Enclosed please find our responses to reference (1) items I and 3, and reference (2) Item 10.

We are continuing to complete the remaining responses and anticipate sending another partial set next week.

Very truly yours, t ki Nancy H. Williams Project Manager NHW:eem

Enclosures:

Attachment A, Partial Responses to CASE Ouestions cc: See attochment' 0404160031 940002 ,f PDR ADOCK 05000

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March 2,1984 Mrs. J. Ellis Attachment Response to CASE Ouestions Nicholas S. Reynolds, Esq. Mr. John T. Collins Bishop, Libermon, Cook, Purcell & Reynolds U.S. NRC, Region IV 1200 Seventeenth Street, N.W. 6Il Ryan Plaza Drive Washington, D.C. 20036 Suite 1000 '

Arlington, Texas 76011 Robert Wooldridge, Esq.

Worsham, Forsythe & Sampels Mr. Lonny Alan Sinkin 2001 Bryan Tower 114 W. 7th, Suite 220 Dollos, Texas 75201 Austin, Texas 78701 Mr. Homer C. Schmidt B. R. Clements Manager - Nuclear Services Vice President Nuclear .

Texas Utilities Generating Company Texas Utilities Generating Company 2001 Bryan Tower Skyway Tower Dallos, Texas 75201 400 North Olive Street L.B. 81 Mr. H. R. Rock Dallos, Texas 75201 Gibbs & Hill, Inc.

393 Seventh Avenue Peter B. Bloch, Esq.

New York, New York 10001 Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. A. T. Parker Washingten, D.C. 20555 Westinghouse Electric Corporation P.O. Box 355 Dr. Walter H. Jordon Pittsburgh, Pennsylvania 15230 881 W. Outer Drive Ook Ridge, Tennessee 37830 Renea Hicks Assistant Attorney General Dr. Kenneth A. McCollom Environmental Protection Division Dean, Division of Engineering Architecture on P.O. Box 12548, Capitol Station Technology Oklahoma State University l Austin, Texas 7871I Stillwater, Oklahoma 74074 i Mr. James E. Cummins Resident Inspector / Comanche Peak Nuclear Stuart A. Treby, Esq.

i Office of the Executive Legal Director

! Power Station c/o U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission P.O. Box 38 Washington, D.C. 20555 l Glen Rose, Texas 76043 Mr. J. B. George Texas Utilities Generating Company

Mrs. S. Burwell -

Licensing Project Monoger Comonche Peak Steam Electric Station U.S. Nuclear Regulatory Commission Highway FM 201 7920 Norfolk Avenue Glen Rose, Texas 76043 Bethesda, Maryland 20014 Mr. David H. Wode Mr. H. Schmidt Texas Utilities Generating Company c/o Westinghouse 2001 Bryan Tower 4901 Foirmont Avenue Dallos, Texas 75201 Bethesda, Maryland 20814 Mr. David R. Pigott l

Orrick, Herrington, & Sutcliffe 600 Montgomery Street San Francisco, California 94111

Comanche Peak ASLB Hearings Response to CASE Questions Question No. Doyle # I Exhibit No. 891,894,897 1,0 CASE Question Effects of out-of-plane seismic excitation of support hardware not included in calculation. Did Cygno oddress this point?

e Additional foods on support?

e Additional loads on pipe?

2.0 Cypo interpretation Did Cygno evaluate the effects of support self-weight excitation in the off-direction, as related to:

a. support design?

b. pipe design?

3.0 Response

o. In the IAP Draft Report, Cygno noted that self-weight excitation was not included in the support design. Note I to checklist PS-01 states:

" Support Self-Weight Excitation" In general, pipe support vendors have not included support loods due to self-weight excitation in their loading. Texas Utilities has done a generic study in response to Walsh/Doyle allegations which shows the effects are negligble. The NRC Site IAspection Team (SIT) has reviewed and occepted this evoluotion in item 3.h of inspection reports 50-445/82-26 ond S0-446/82-14."

Since the LAP was performed for the NRC Staff, further evaluation of on issue ofready identified and reviewed by the Stoff would have ' been redundent.

Accordingly, Cygno noted the potential deficiency

on the appropriate checklist and deferred to the Staff evoluoti%

b. The response to item b. v ,1) M t r ded later.

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l Cornanche Peak ASLB Hearings Response to CASE Ouestions Question No. Doyle // 3 exhibit No. 891,897 I.0 CASE Question Dead weight of structure not included in calculation.

2.0 Cygno interpretation Did Cygno consider the effect of gravity loods on the design of pipe supports?

3.0 Response Cygno considers self-weight excitation to include all oceferation lood effects within the support, including gravity. Therefore, this matter is addressed by note i on checklist PS-01.

For further discussion of the evoluotion process regarding self-weight excitation, see the response to Doyle Question //l.

Comanche Peak ASLB Hearings Response to CASE Questions Question No. Walsh # 10 Exhibit No. N/A 1.0 CASE Question WD-07-02 What document did Cygno see that showed the temperature indicator would be installed at a later dote?

2.0 Cygna interpretation What was the basis for closing Cygno Observation WD-07-02? What documentation was reviewed?

3.0 Response Based on a conversation with Texas Utilities personnel, Cygno learned that temperature elements are normally installed offer all other work in on area is completed. This is done in order to avoid domoge to the instrument during construction. When Cygno performed

-the Spent Fuel Pool Cooling System walkdown, pointing octivities were still underway.

Further review o!so showed that local indicators, such as this one, are not safety related devices.

The key documents reviewed by Cygno relevant to closing Observation WD-07-02 are discussed below:

l.. Instrument Installation Checklist (Form No. 2-81)

Form 2-81 is required to be completed by CP procedure 35-1195-ICP4.

In this cose, it indicated that the device was not installed and that the

" discrepancy" was " turned over to Brown & Root completion and TUGCO".

2. The Q-list was checked to ensure that the device was non-sofety.

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-From CASE Witness Jack 'Doyle to CYG?tA 2/22/84

• Summary of Crass-Examination Questions

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BRIEF

SUMMARY

OF GENERIC PROBLEMS Omitted from Calculations and Omitted from Checklists

1. Cinched up U-bolts:

-o.Not in compliance with Cygna criteria o Not in compliance with NRC criteria

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o Stresses of unknown quantity due to pre-stress, thennal and design loads o Effects on pipe not shown on calculations o Not in compliance with Board Notification.

2. Local effects on tube walls:

o Punching shear

.o-Effect on welds o Resultant effect due to wall flexibility on moment at tube weld.

3. Dead weight-of structure not included in calculations.

4.: Weight of support masses as they affect pipe stress.

5. Inaccurate conclusionsLas relate to KL/R for pinned columns:

o If a column fixed at its base and free at'the top has an effective

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K of 2.0Ecutting at some point up from the~ base and adding a pin does not address the problem.

6.16-inch ~ pipe with about 20 kip load along 31/2-inch length induces e

high bearing: stresses which require pads. This is not- addressed,

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o ASME Code against-flattening. .

7. Clip angle 14x4x1/2 which supports.U-bolt not addressed (critical to

maintaining-stability):-

. t o Section-modul'usi .04 in cube'

.olomant; arm at least 2; inches.

~ o 3100131oadie~xceeds' Code allowables'.-

'oPre-tensioningtoobtainaclamping[forcerequiredcould; exceed

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,o Page 2 this (not including thermal constraint and design loads) o Clamping force with no margin of safety for single degree system

(not point contact or line contact) is force / coefficient of friction or; about 4 times what is required for clam' ping force.

~ 8. There Lis no-documentation in calculations to support the conclusion

. that: flair weld is stronger than fillet weld--no calculations, there-iforeshy did Cygna accept this statement?

.o Flair wel_d.. strength depends on radius of flair (depth).

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9. The reduction:of._ weld. capacity in the calcuation is based on 135 . Actual  :

Therefore, an error exists. Did Cygna take

<tangental angle is 150.30 inote'of.this?--

o More stress' in weld. than stated.

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o-Wide / thin ratio induces cracking as well as the 1:4:1' ratio width to-k W

(depth.

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11. Effeci.s of out-of-plane seismiciexcitation of support handware_ not included

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in the document in detail). Why didn't Cygna consult with their experts--

for example, Eric von Strijgeren (who was the editor on a paper by T.Y.

Chow, C.H. Chen and O. Bilgen)--in reference to deviations from generic stiffnesses in pipe supports and the effects on piping systems.

o Third paragraph introduction et, seq. (C456 64. 99//)

14. In Note 1, same source, did Cygna consider the additive effects of self weight excitation if the stiffness is considered from node point to hard point as opposed to the stiffness of the frame independent of hardware, local effects, base plate and anchor bolts?

o Spring rate of base plate / anchor l'olts (particularly bearing-type joints) can be considerable (observation of base plate II finite analysis).

15. Was themal lockup considered for anchors which restrain pipe radial growth?

o Induces frame moments

.16 . The base plate analysis is based on distribution of shear relative to Did Cygna address load path / stiffness for all bolts in the pattern.

this problem?

o With oversized holes and the inability to eliminate construction tolerances (location of the bolts combined with localtion of the bolt '

holes), it is not possible for all of the bolts in the-system to be active'. (See CASE Exhibit 906).

o The stiffness'of the bolts is such that deflection cannot be counte o'n as a means to achieve full pattern participation o Even if deflection could result in full activity, the first bolts deflecting would receive the larger portion of the load in an ideal .

symetrical and systens.

..- Jack Doyle to Cygna .

. 2/22184

. Page 4 0 For non-symmetrical system and systems of variable stiffness, the inactivity of a number of the bolts will alter the accuracy of the computerized analysis.

17. Has Cygna verified the statement: "No 2-inch topping"?

o This affects the calculations for Hiltis relative to embedment, since a non-monolithic shear plane has been established.

18. The base plate analysis performed without including stiffeners alters the stiffness matrix of the base plate and consequently the distribution of moments and tension to the bolts. Beyond this point, stiffeners remain unqualified. Has Cygna addressed this?

The preceeding questions are the primary areas in which I will be cross-examining Cygna witnesses. (Additional questions may be triggered by

.-Cygna witnesses' answers.)

In addition, CASE has not yet received all of the documents which it requested from Applicants' on the Cygna report. Therefore, additional questions may be triggered from these documents (_if and when they are supplied).

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- -From CASE witness Jack Doyle SurnTrary of Cross-Examination Questions 2/22/84

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. 3 MATRIX OF EXHIBITS AND DOCUMENTS S' J CASE ~ Exhibit Concerns 891 1, 3, 4, 5, 6, 7, 11, 13, 14, 15, 16 892 9, minor question relative to pad width diameter + (Rt)h 893' 8, 10, 14 894' 1, 4, 5, 11, 14 895 14, 16

• 896 12, 14 897 1, 2, 3, 4, 5, 11, 14, l'6 898' 14, 15, 16, 18 899 14,.15,16,18 900 14, 15, 16 1901 Has minimum weld violation (walk-down)

9021 Has support completely rebuilt on CMC and then calculated lhis matrix has- been compiled' to the best of our ability due to time

= constraints. :(ItLis from notes etc.) .

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- BY? CASE" WITNESS-MARK WALSH TO CYGNA Appendix E of Cygna Report

% LSection DC-2.4.4. What was the yield point used for A500 Grade B tube steel?

Observation Record PS-02-01: The Applicants did not consider shear cone interaction of' adjacent bolts.

PI-01-01.. There ~ has been no detailed computer analysis performed to consider the concentrated-' loads (valves, etc.)'and their effect an dead weight' and seismic.

_ LAlso,' the seismic analysis will-not be linerally proportional.

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PI-02. -Is there'an error in the table:shown?

CTS-00-03i: 'See ' CASE ~ Exhibit: 889, sheet 129.

bx;= should be 21.2, not 23.2 -

.or; 22. f The'-length i is' 6' not 5.'5'.

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See: CASE: Exhibit 890:.1)Whywasonly 1/2 SEE. considered?

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2)Why_was4% damping.used;notconsistentwithFSAR?.. 3)? Assumed cable tray' .

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,.7effect'slof the cable tray..itself'to the' support;.did not includeEeffect;on welds.

'[' $4)[The. validity that the cable trays have' the capacity tor. transfer a loa'd larou'nd a corner when c'ne run of catfis; tray has no axiallr_estraint, as shown io drawing 2323]EI-06bl-01.; (NOTEi :he only!- have a 36"x48" .' drawing;; please - -

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f kletius(know when. you want toi1ook'atlit.)., :5) What ~ documentation 'did Cygna-

, f  :.?seef thSt i jusItifiidjthe hangers' receiving a lateralLload aroundjoeners. that i *

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how did Cygna evaluate it? It appears the axial load has not been taken into account. 6) CASE Exhibit 902. Did not consider base plate flexibility.

CTS-00-05: In the description, it discusses a channel bent about its weak axis. The resolution does not consider this problem nor does the document C SE requested on discovery; see CASE Exhibit 907. On CMC 88306, are the originator and approver the same person?

CTS-00-06. What is the "significant design margin" as shown in the resolution?

CTS-00-07: The analysis that included the beam element did not consider prying action and the flexibility of the base plate to determine the center of compression.

WD-03-01: What documentation was there that " accept as is" was valid? Were there calculations to support this?

WD-07-02: What documentation did Cygna see that showed the temperature indicator would be installed at a later date?

- Pipe stress checklist, note 3, item a: 1) What is the basis for considering that the effects were negligible?' 2) What pipe stress run'did Cygna look at,

.since the inclined load was used in the design of support RH-1-010-003-522R?

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A Cable Tray Check List: CTS-II , Item 6, probl em 4. This was not. discussed in CTS-00-07.

The preceeding questions are the primary areas in which I will be cross-examining Cygna witnesses. (Additional questions may be triggered by Cygna witnesses' answers.)

In additi_on, CASE has not yet received all of the documents which it requested from Applicants' on the Cygna report. Therefore, additional questions may be triggered from these documents (if and when they are supplied).

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