ML20091K229
| ML20091K229 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/02/1984 |
| From: | Philips M BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20091J674 | List: |
| References | |
| NUDOCS 8406060457 | |
| Download: ML20091K229 (12) | |
Text
"'
REl.ATED CORntsPONDM U s *bune 2, u
19S4 UNITED STATES OF AMERf6A JW-6 A9:31 NUCLEAR REGULATORY COMMISSION
. r c rr rr DEF0FE THE ATOMIC SAFETY AND LICENSING DOARD In Matter of
)
)
Docket No. 50-445 and TEXAS UTILITIES ELECTRIC
)
50-446 COMPANY, et al.
)
~~
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(Application for (Comancho Peak Steam Electric
)
Oporating Licenses)
Station, Units 1 and 2)
)
APPLICANTG' MOTION FOR
SUMMARY
DISPOSITION REGARP:NO DESIGN OF RICl!MOND INSERTS AND Til.CR APPLICATION TO SUPPORT DESIGN Pursuant to 10 C.P.R. $ 2.749, Texas Utilitios Electric Company, at al. (" Applicants") hereby move the Atomic Safety and Licensing Doard for summary dir. position of the Citizens Associa-tion for Sound Energy's (" CASE") allegations rogarding the design of Richmond inserts and their application to support design.
As demonstrated in the accompanying Af fidavit of John C. Finneran, Robert C.
Iotti and R. Peter Deublor Rogarding Design of Rjchmond Insorts and Their Application to Gupport Design (" Affidavit")
(Attachment 1) and Statement of Material Facts (Attachmont 2),
there is no genuine issue of fact to be hoard rogarding this issue.
Applicants urge the Board to no find, to conclude that Applicants are entitled to a favorablo decision an a matter of law, qnd to dismiss thig issue from the proceeding.
W PoM21.
O PDR
(
o-C I.
BACKGROUND In August 1982, intervenor CASE deposed Mr. Jack Doyle, a former employee of Applicants, with respect to certain allegations Mr. Doyle had regarding the design of pipe supports s at Comanche Peak.
Mr. Doyle's deposition was subsequently admitted into the record in this proceeding as his testimony (CASE Exhibit 669; Tr. 3631).
One issue raised by Mr. Doyle concerned the adeqLacy of design practice regarding Richmond inserts.
All parties presented testimony on this issue, e.g.,
CASE Exhibits 659 at 1-2, 4 and 659tl at 3r Applicants' Exhibit 142D at Attachment C; and NRC Staf f Exhibits 207 at 17-22, and 208 at 7.
Following litigation of the pipe support design allegations, each of the parties submitted proposed findings addressing, inter alia, allegations regarding Richmond inserts.
(See Applicants' Proposed Findings of Fact Concerning Pipe Support Design Questions (August 5, 1983) at 28-40; NRC Staff Proposed Findings of Fact (August 30, 1983) at 36-46; CASE's Proposed Findings of Fact and Conclusions of Law (August 22, 1983),Section VIII; and Applicants' Reply to CASE's Proposed Findings of Fact and Conclusions of Law (September 6, 1983) at 28-30. )
In its Memorandum and order of December 28, 1983, at 60-66, concerning design issues, the Board stated that the record was not aucquate to provide reasonable assurance of adequate design practice regarding Richmond inserts.
By Memorandum and order of February 8,- 1984, at 30-31, the Board reaf firmed its earlier decision.
F-e Je
ue 4
3 --
Emis motion addresses CASE's concerns regarding Richmond
- inserts, as set forth inLits Proposed Findings of Fact at Section VIII.
In responding to these concerns, Applicants respond to the Board's December 28, 1983 and February 8, 1984 Orders, and provide the information which they committed to generate as part of-Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for. Design)
(" Applicants' Plan"), ' items 10 and 11 (February 3, 1984).
II.
APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION A.-
General Applicants have previously discussed the legal requirements applicable to motions for summary disposition in their " Motion for Summary Disposition of Certain CASE Allegations Regarding AWS and ASME Code Provisions Related.to Welding," filed April 15, 1984 (at 5-8), incorporated herein by reference.
t B.
CASE's Allegations Regarding Richmond Inserts Should be Summarily Dismiesed In Section VIII of its Proposed Findings, CASE makes allegations regarding Applicants use of Richmond inserts that may be categorised into six basic areas, viz., (1) the factor of safety used for Richmond-inserts, (2) testing of Richmond
. inserts, (3) ability to resist axial torsion,-(4) methods used to analyse connections, (5) bending moments in the bolts, and (6) sharing of shear loads.
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- In responding to these concerns, Applicants committed to the following analytical and testing program (see Applicants' Plan at Litems.10 and 11):1
"(10). Provide evidence of the capability of Richmond inserts to accept-the maximum loads to which they will be subjected in tension, shear, and combined tension and shear, with ample margins of safety.
This evidence will be generated by a combination of tests and analy-ses.
(ll). Provide evidence of the tension in the bolt employed by
-Richmond inserts and the correct lo'ad distribution in the concrete, washer, tube steel, and bolt occurring when a torque is applied to the tube steel.
This evidence will be generated through the performance of finite element analyses."
The results. of this analytical and testing program and associated evaluations are set forth in the attached Affidavit.
As set forth more fully below, none of CASE's six concerns raise an issue that reflects a breakdown in Applicants' Quality Assurance ("QA") Program or a safety concern in the plant.
Accordingly, no genuine issue of material fact exists with respect-to these allegations, and the Board should find that the Applicants are entitled to judgment as a matter of law.
.l.
Factors of Safety Used for Richmond Inserts and Tests This issue raises the concern that Applicants had employed a safety factor of. 2' for Richmond inserts 'instead of the manufacturer's recommended value of 3.
(See the Staff's Proposed Findings of Fact and. Conclusions. of Law ( August 30, 1984) at 37-39 adopted in the Board's December'28, 1983 Memorandum and Order 1
In addition,: Applicants have addressed CASE's tangential concern that Applicants failed to consider the A-307 bolt in a :
(their' calculations submitted as Applicants' Exhibit 142D.
Affidavit at'43-46.
1
at 60-62).
The two key aspects of this concern are (1) the appropriateness of-Applicants' use of a safety factor which could be viewed as lower-than that recommended by the manufacturer, and (2) the lack of certain test data regarding Richmond inserts.
Affidavit at 3.
Based on testing, the manufacturer of the Richmond inserts specified the ultimate loads associated with the various sized inserts.
Idl. at 4.
In addition, the manufacturer selected a factor of safety and back-calculated the corresponding allowable
- loads, i'.e.,
the ultimate load divided by the safety factor is equal to the allowable load.
Id.
It should be noted that this factor of safety and corresponding recommended allowable loads specified by the manufacturer applies only to the Richmond insert itself and not to the threaded rod (sometimes used interchangeably with bolt) which may be procured separately.
Id.
Allowables for the threaded rod are those set forth in appropriate Codes,.e.g., for A-36 threaded rod the allowed load in shear is 17.7 kips.
Idl.
In its design calculations, Applicants used higher allowable loads for the inserts than specified by the manufacturer.
Id.
Accordingly, if the ultimate loads listed by the manufacturer were applicable to Applica..ts' use of the inserts, it could be viewed that Applicants had~ reduced the factor of safety recommended by the manufacturer.
Id. -However, this is not the case.' Taking into consideration relevant factors (e.g.,
the differences between the conditions.of the tests from which the Richmond insert manufacturer obtained its recommended ultimate
. loads and the; conditions known by Applicants to exist in the
.actualIapplications of the Richmond inserts at CPSES), the
- ultimate loads-for the inserts used at CPSES are much higher than those specified by the manufacturer, and the actual safety margin
-for Richmond' inserts in CPSES is essentially equivalent to that recommended by the manufacturer.
If. at 4-11.
Two sets of tests have been conducted that verify
[
Applicants' position.
Id. at 11-17.
First, at the request of
?
'the NRC Staff, shear tests were conducted at CPSES on 1-1/2 inch 1
Richmond ' inserts 'in March 1983.
Id. at 11.
The results of these I
tests demonstrate that the performance capabilities of the Richmond inserts in shear exceed the design allowables by a ratio in-excess ~of 3.3 to 1.
Id. at 12.
Because the tests were
[
terminated before failure, the actual ratio is higher, and the
.results are conservative..
Id.2 In addition, a second series of tests were conducted in
[
March and April 1984.
Id. at 13.
These tests were performed to I
determine the load-carrying characteristics of 1 and 1-1/2 inch Richmond inserts (inserts of concern here) when subjected to 4
tension'only, shear only and combined shear and. tension loadings.
Id. - The test results confirm the judgment of Applicants that-the i
actual factors of-safety'for the, Richmond inserts used at CPSES it It should be noted that the test results for the specimens with and without l' inch-washers installed were comparable, indicating that the presence of the washer has little effect
-oni he performance of the: threaded connection / bolt or the t
Richmond: insert.'
Id.
- If any bending' stress is introduced l
in'the bolt'as'a risult of the 1 inch thick washer, the test results show that it is not'significant.
& at 12-13..
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.are in" excess of 3.'0 for shear, tension and combined shaar-l tension [ loadings.. Id.Jat 13-14.
In. sum,.'from thejforegoing, Applicants conclude that the j g
! margins'of safety for. Richmond inserts for loading in shear, i
itension'and combined shear-tension for the conditions at CPSES g_
n f
' are in excess - of a - factor of 3.0.3 l
2.'
Ability to Resist Axial Torsion i
Thisiissue refers to a' concern by CASE regarding the ability i
Lof the' Richmond assembly (including the threaded rod) to resist l
" axial" torsion.- The Board concurred with CASE's view that the i
Applicants'. manner of' computing the tension. force in the bolt of l
fthe Richmond insert assembly, resulting from torsion in the tube
.: steel,.was incorrect.
Id., at 18.
In computing the torsion force in the bolt of a Richmond
-insert, Applicants used. formula T.= Fd; where T = torsion applied
~to the' steel tube,'F = tension in the bolt, and d = the distance from the' bolt to the force acting on the washer.
Id.
The Board
! believed that Applicants were using an incorrect" calculation to determine the distance "d,":1.e., 2/3 of the' one half of the iwidth.of-the washer.
See December 28, 1983 Memorandum and Order at, 62-66. -. Affidavit at 19.-
3 As-toiCASE's concern'that the concreteJused in the tests has Jmore;rebar than that found'at CPSES, Applicants have conducted a review of a representative sample of test reports
'of: concrete-used at CPSES:to assure,that'such concrete is
~
essentially-the same.as1that usedlin the tests.
Id. at 16-L17 1 In' addition, Applicants have reviewod~NCRs reg'arding fs concrete'at.CPSES;to provide additional assurancefthat the i
v:
fu
, concrete ~used'in these' tests was; representative of that used 4
.at CPSES. ' Id. - at117. =
In short, with regard to' concrete, the-g 4
V test JconditTons;arel representative of, and Leven more:
Tconservative!than,1the conditions at CPSES.
Id.
7
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- +>
- s
- While Applicants, in general, did not use this calculation to determine the value of "d," Applicants conducted an evaluation
'of the methodology used in calculating "d" to determine whether it accurately reflected the appropriate load distribution.
Id.
at_19.
As a L result of -the evaluation, Applicants conclude that
-while the method used to calculate "d"
is valid if the problem were truly two-dimensional, and is generally employed for solving
. problems of this kind, the distribution of strains within the assembly is a tri-dimensional complex pattern and without further analyses the' issue could not be resolved with certainty.
Id. at 20-21.
To study this problem further, Applicants performed detailed finite element analyses utilizing the STARDYNE computer program.
Id. at 21.
The results of the analyses indicated that the methods used.by Applicants, as described above, did not precisely model'the resulting forces.
Id.
Further, the formulas used by
. Applicants resulted in a calculated force that was low for virtually all supports by as much as 18 percent (for six specific 44 x 4 x 1/2 inch tube _ steel sections, the calculated force was low by a factor of 334).
Id,. at 21.
However, because of conservatisms in the methodology and process used by Applicants in the initial calculations, the finite element analyses and confirmatory _ testing reflected that in all cases allowables would -
not have'been exceeded.
Id,. at 21-24 and Attachment F.
In the process of' performing.the finite element analyses, Applicants noted that when it was assumed that no clearance existed between the tube steel and the bott, a shear couple fr-t I
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s
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U created which places the bolt in bending.
Jd. at 24-5.
The 1
effect becomes pronounced when the bolt holes are offset to their
. largest values.
Jd. at 25.
To investigate the possible adverse effects on the connections of this condition, Applicants developed a screening criterion which was based on very conservative assumptions.
Id. Testing revealed that the assumptions were exceedingly conservative and contained factors of safety in excess of 10.
Id. at 25-8.
Based on Applicants' l
evaluations, only 12 supports exceeded the conservative criterion.
Jd. at 24-30.
Subsequent testing revealed that with regard to the 12 supports, there is no safety concern, and an l
adequate margin of safety exists.
Jd. at 28-30.
In sum, from the foregoing Applicants conclude that the Richmond inserts have adequate capacity to withstand the offects of axial torsion with adequate margins of safety and without any l
adverse impacts.
l 3.
Method Used to Analyze Connection
[
i CASE criticized the method used by Applicants to analyse the l
connections of the bolts, tube steel and Richmond inserts in that i
L Applicants assumed the release of all moments except the torsional moment (M,).
,Id. at 31.
While CASE agrees that the moment in the tube about the axis of the bolt (M ) cannot y
develop, it contends that the moment (M,), which would tend to produce a prying action, should either be considered (i.e.,
" coupled out") whenever the torsional moment (M,) is considered, or both M, and M, should be released.
CASE Proposed Findings at VIII-6.
o !
I Applicants performed a finite element analysis in response to these concerns.
The results of the analysis reflect that Applicants' method of calculation (i.e., the release of all moments except the torsional moment (M,)) is appropriate, and no increase in bolt tension is experienced. M. at 32-40.
In addition, a parainetric study was used to analyse if any prying action would occur from a bending moment (M,) produced due
[
to a torsional load.
M. at 33.
The results of this study l
indicate that there is no prying action.
M. at 33-37, n. 12.
l Applicants also reanalysed several support configurations selected at random to *.est the effect of assuming the release of all moments, as CASE recommended.
M. at 39.
The results of this analysis indicate that adequate margine exist even considering fully released moments.
M.
l l
In sum, from the foregoing Applicants conclude that with regard to this issue, the method used to analyse connections is correct and assures adequate margins of safety.
4.
Send L nti Momente l
CASE has also expressed concern with allegedly high bending moments caused by shear forces on a bolt that is offeet from the concrete surface by the use of a one-inch washer between the concrete and the support steel Qej,the discussion in Apptjeants' Proposed Findings at 35-37).
Applicants have utilised a finite element analysis to evaluate the effected supports which are highly loaded in shear.
Affidavit at 40.
The results of this analysis reflect ths.t such bending momente do not present a safety concern (M. at 40-42).
(
a,
These results were reinforced by testing which demonstrated that deflection of the supports at the design loads are very small regardless of whether the load is applied torsionally or as a
)
shear load, and that ample margin against failure exists.
Id.
5.
Sharing of shear Load CASE has also raised a concern with the sharing of a shear load by all the bolts in a particular support.
CASE's Proposed Findings at VIII-10.
More specifically, CASE allegen that because of the presence of oversized bolt holes, only half or fejer of the bolts would accept the shear, and these would exceed allowable vatuoc before the remainder of the bolts could take up the load.
M. at 42.
Since this issue is common to all connections, not just Richmond inserts, Applicants have elected to address it in a separate Affidavit and Motion for Summary Disposition Regarding the Effects of caps on Structural nehavior Under Seismic Loading conditions, filed in this proceeding on May 18, 1904, and, as appropriate, incorporated herein by reference.
A
- o III.
CONCLUSION For the foregoing reasons, Applicants request that the Board grant Applicants' motion for summary disposition.
Respectfully submitted, b
Nichola( F.
Reynolds William A. Horin Malcolm H. Philips, Jr.
t BISHOP, LIBERMAN, COOK, PURCELL & REYNOLDS
[
1200 Seventeenth Street, N.W.
Washington, D.C.
20036 l
(202) 857-9817 Counsel for Applicants June 2,1984 i
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