ML20087M993

Forwards Doyle Clarifying Comments Re Doyle Contention 16. Case Exhibit 969 (IE Bulletin 79-02) to Be Used in Cygna cross-examination in Case.Certificate of Svc Encl.Related Correspondence

ML20087M993
Person / Time
Site:	Comanche Peak
Issue date:	03/31/1984
From:	Ellis J Citizens Association for Sound Energy
To:	Pigott D ORRICK, HERRINGTON & SUTCLIFFE
References
IEB-79-02, IEB-79-2, NUDOCS 8404020267
Download: ML20087M993 (6)

Text

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.,,L RELATED CCR32SPONDENCE a> Q%i5224 214/946-9446 (CITIZENS ASSN. FOR SOUND ENERGY) 84 I?i!-2 All :03 March 31, 1984 -

David R. Pigott, Esq.

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

Subject:

In the Matter of Texas Utilities Electric Company, et al. (Comanche Peak Steam

' Electric Station, Units 1 and 2)

Docket No. 50-445 and 50-446 Clarification - Doyle #16 We are attaching some clarifying comments from Mr. Doyle regarding Doyle

1. 16, which was discussed in the 3/27/84 conference call between CASE /Cygna.

Also attached is CASE Exhibit 969 (IE Bulletin 79-02), to which Mr. Doyle makes reference in his comments and which will be used in Cygna's cross-examination by CASE.

Sincerely, CASE (C1TIZENS ASSOCIATION FOR SOUND ENERGY)

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(Mrs.) Juanita Ellis President Attachments Service List - see attached 8404020267 840331 (Q PDR ADOCK 05000445 0 PDR g

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Doyle #16 This is to clarify the items which we discussed in the 3/27/84 conference call between CASE /Cygna, regarding the point as to why the equation was not acceptable. Discussion of the equation, however, is really academic since the use of holes more than 1/16" larger than nominal bolt diameter is, in itself, a violation of codes, as was discussed in the

3/27/84 conference call.

While the Cygna mathematical gyrations are academically correct, the equation listed contains a major error and in addition contains a fatal philosophical oversight.

,t The error in the equation involves the cancellation of safety factors.

On the one hand, in compliance with criterion, a 1/5 (a safety factor) of ultimate capacity for the anchor bolt in shear is incorporated in equation

3. But, on the other hand, for the solution shown on page 2, this factor is for all practical purposes negated by the introduction of the inverse of a second safety factor of 4. The result is that the apparent required ductility factor of .232 should in reality be .928. This means that, while

the equation as solved by Cygna would indicate that a stiffer bolt would still perform adequately, the reality is that what is required is a. bolt with a softer spring rate than the 1" diameter bolt as used in the equation. If the equation were properly done, it would show that the 1"

diameter. bolt was too stiff to perform as envisioned by Cygna.

The philosophical constraint to this methodology involves the front-end mechanism as~ opposed to the final mechanism of ultimate failure.

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For example, while such a mathematical procedure (correctly done) may be theoretically correct, it is the real world and IE Bulletin 79-02 (CASE Exhibit 969, copy of which is attached) which is of concern. And in this respect, one must consider that in any bolt group for which two bolts are initially active and the remaining bolts of the pattern are located 1/8" from engagement, it is the first active bolts (two) which take the entire f

shear load during the 1/8" displacement. In viewing the chart (D16-1, 4

sheet 2 of 2, enclosed with the Cygna response), the first two active bolts are subj ected to 11.3 kips of shear before the remaining bolts in the pattern accept any loading.

Following the time frame in which all of the bolts in the system become active, additional load is distributed to each of the bolts relative to its 1

stiffness at a particular point on the excursion through the variable stiffness factors along the curve generated by the X-Y plot. Since there is no yield point on the plot, all bolts will continue to pick up loads until failure.

While there will be some disparity in the distribution of loading to the bolts within this range, the stiffnesses are such that for all

, practical purposes they would be equal for each bolt in the pattern. For a

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four-bolt pattern wit.. maximum shear load (based on four bolts at 6890 lbs.

per bolt), the first active bolts would have loads. of 15 kips each (assuming two active bolts) with a displacement equal to .165 inches. This

j. is versus an allowable per bolt of 6.9 kips and a total support allowable j deflection of 1/16".

l Two of the bolts in this pattern are approximately halfway to L

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catastrophic failure. And this does not consider problems for which there are no test results such as cyclic loading. Since no one can predict the consequences of reversal of loading during multiple zero crossing resulting from' seismic events (particularly for bearing joints), it must be considered imprudent to court disaster by shaving the. safety margin established by IE Bulletin 79-02, item 2, merely to justify a feit accompli.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l I

TEXAS UTILITIES GENERATING  ! Docket Nos. 50-445 and COMPANY, et al. i 50-446 I

(Comanche Peak Steam Electric Station i Station, Units 1 and 2) l CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's 3/31/84 letter to Cygna (David R. Pigott) re: Clarification - Doyle

1. 16 (with CASE Exhibit 969 attached to parties only) have been sent to the names listed below this 31st day of March , 198j4_.

by: Express Mail where indicated by

• and First Class Mail elsewhere.

• Administrative Judge Peter B. Bloch Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Panel 4350 East / West Highway, 4th Floor U. S. Nuclear Regulatory Commission Bethesda, Maryland 20814 Washington, D. C. 20555 Dr. Kenneth A. McCollom, Dean Alan S. Rosenthal, Esq., Chairman Division of Engineering, Atomic Safety and Licensing. Appeal Architecture and Technology Board Oklahoma State University U. S. Nuclear Regulatory Commission Stillwater, Oklahoma 74074 Washington, D. C. 20555 Dr. Walter H. Jordan Dr. W. Reed Johnson, Member 881 W. Outer Drive Atomic Safety and Licensing Appeal Oak Ridge, Tennessee 37830 Board U. S. Nuclear Regulatory Commission Nicholas S. Reynolds, Esq. Washington, D. C. 20555 Bishop, Liberman, Cook, Purcell

& Reynolds Thomas S. Moore, Esq., Member 1200 - 17th St., N. W. Atomic Safety and Licensing Appeal Washington, D. C. 20036 Board U. S. Nuclear Regulatory Commission Geary S. Mizuno, Esq. Washington, D. C. 20555

Office of Executive Legal Director -

U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Maryland National Bank Building Panel 7735 Old Georgetown Road - Room 10105 ' U. S. Nuclear Regulatory Commission Bethesda, Maryland 20814 Washington, D. C.- 20555 l

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.. .o Docketing and Service Section

• Ms. Nancy H. Williams (3 copies) Project Manager Office of the Secretary Cygna Energy Services U. S. Nuclear Regulatory Commission 101 California Street, Suite 1000 Washington, D. C. 20555 San Francisco, California 94111-5894

)

Renea Hicks, Esq.

• David R. Pigott, Esq.  !

Assistant Attorney General Orrick, Herrington, & Sutcliffe Environmental Protection Division 600 Montgomery Street Supreme Court Building San Francisco, California 94111 Austin, Texas 78711

John Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 l Arlington, Texas 76011 l Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Lanny A. Sinkin 114 W. 7th, Suite 220 '

Austin, Texas 78701 Michael D. Spence, President Texas Utilities Generating Company Skyway Tower 400 North Olive St., L.B. 81 Dallas, Texas 75201 ADE fR, Ms.) Juanita Ellis, President TASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 e

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