ML20092H852

Motion for Summary Disposition of Case Allegations Re Differential Displacement of large-framed,wall-to-wall & floor-to-ceiling Pipe Supports.No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision

ML20092H852
Person / Time
Site:	Comanche Peak
Issue date:	06/22/1984
From:	Philips M BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20092H838	List: ML20092H835 ML20092H852 ML20092H867 ML20092H872
References
NUDOCS 8406260293
Download: ML20092H852 (10)

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00CKETED 1 09!RC  ;

June 22, ISS4 JW,23 P 3 :22 f

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION [

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD t In the Matter of )

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TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445 and COMPANY, et al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for l S ta t i on , Units 1 and 2) ) Operating Licenses)  ;

Y APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION '

OP CASE ALLEGATIONS REGARDING DIFFERENTIAL DISPLACEMENT OF LARGE-FRAMED, WALL-TO-WALL L AND FLOOR-TO-CEILING PIPE SUPPORTS .

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Pursuant to 10 C.F.R. $2.749, Texas Utilities Generating l Company, et al. (" Applicants") hereby move the Atomic Safety and Licensing Board (" Board") for summary disposition of the Citizens Association for Sound Energy's (" CASE") allegations regarding differential displacement of large-framed, wall-to-wall and floor-to-ceiling pipe supports.

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As demonstrated in the accompanying affidavit (Attachment .)

and statement of material facts (Attachment 2), there is no genu-ine issue of fact to be heard regarding these issues. Applicants urge the Board to so find, to conclude that Applicants are entitled to a favorable decision as a matter of law, and to dismiss these issues in this proceeding.

8406260293 840622 1 PDR ADOCK 05000445 0 PDR v

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s i I. BACKGROUND

-The relevant general background of this issue is set forth in detail'in the Board's' Memorandum and Order of December 28, [

4 1983.at'pp. 7-14.- This issue has been the subject of substantial testimony knr all parties, (see e.g., CASE Exhibit 659, 668, and

! G69; Applicants Exhibit 142; NRC Staff Exhibits 207 and 208; and i g

Tr. 5239, 5253-6, and 7053-5).

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. Following litigation of- the pipe support design allegations, f

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. each of.the parties submitted proposed findings addressing, inter  ;

I alia, these issues (see' Applicants' Proposed Findings of Fact Concerning Pipe Support Design Questions (August 5, 1983) at l

. pp. 40-44; NRC Staff Proposed Findings of Fact (August 30, 1983) {

-at pp. 28-34; CASE Proposed Findings of Fact and Conclusions of Law (August 22,.1983)' at Section VI; and Applicants Reply to f

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CASE's Proposed Findings (September 6, 1983) at pp. 23-24). {

Subsequently, on December 28, 1983 the Board issued a Memo- f randum and Order addressing, inter alia, this issue (at pp. 57-

8). In response to Applicants' January 17, 1984 Motion for {

4- Reconsideration - (at pp. 38-39), the Board issued a February 8, 1984 Memorandum and Order which, inter alia, modified its previ-  !

i ous ruling on this issue . (a t p. 30). In response to the Licens-ing Board's December 28, 1983 Memorandum and Order, Applicants 3

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filed a Plan to Respond to Memorandum and Order (February 3,

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r 1984) which also addresses, inter alia, differential displacement of large-framed supports (a t p . 7. ) . [

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l II. APPLICANTS' MOTION FOR

SUMMARY

DISPOSTION 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 AUS l

and ASME Code Provisions Related to Helding," filed April 15,  !

1984 (a t 5-8), incorporated herein, by reference.

B. CASE's Allegations Regarding Differential Displacement of Large-Framed, Hall-to-Hall and Floor-to-Ceiling Pipe Supports Should Be Summarily Dismissed CASE alleges that Applicants' design of large-framed pipe supports which span from wall-to-wall or floor-to-ceiling and which do not include slip-joints are inadequate. Board Memoran- l dum and Order of December 28, 1983 at p. 57. CASE's allegation is based on a concern that such supports are not adequately designed to withstand loads,from seismic displacement, thermal expansion and creep. CASE's Proposed Findings of Fact and conclusion of Law (Walsh/Doyle Allegations) at p. VI-14 (August 22, 1983). Further, CASE notes that PSE design guidelines reflect that these supports should have slip-joints. Board itemorandum and Order of December 28, 1983 at p. 58.

In its allegation, CASE identified two supports on the l

service water system which are large-framed and span from floor-to-ceiling, yet did not have slip joints. Id. at pp. 57-8.

While these two supports had been modified to bring thom into compliance with PSE guidelines, the Licensing Board requested I

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additional evidence regarding "how it came about that PSE violat-ed its own design guidelines, how this event came to be reflected in the design quality assurance system, and whether this problem

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was resolved promptly, as required by 10 C.P.R. Appendix B, Criterion XVI." Board Memorandum and Order of February 8, 1984 at p. 30. In additions, Applicants committed to report to the Board on all floor-to-ceiling and wall-to-wall supports in the e - J plant, and where slip-joints are not used, to perform an analysis demonstrating that the design is adequate. Applicants' Plan to Respond to f1emorandum and Order (Quality Assurance for Design) at

p. 7 (Feburary 3, 1984). Further, CASE / recommended that Appli-cants nhould be required to reanalyze all wall-to-slab (floor or r

ceiling)/ supports as it had done for wall-to-wall and floor-to-ceiling pipe supports. CASE's Proposed Findings at p. VI-14.

I The ina/ cant motion addresses the Board's outstanding ques-r l

tions, provides additional information on other simihar supports, and responds to CASE's recommendation that a reanalysis of all vall-to-slab supports is necessary. In this Motion, Applicants

rely on tcetimony in,the record which reflects that creep and e' thermal expansion need not be '

considered. See e.g., Applicants' l f j'

{ Propo, sed rindings at pp. 40-44 ( August, 5,1983) .

Indeed, by

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Board %=moran,.dum and ,peder (Thermal Stress in Pipe Supports) of July 6, 1983, the Doard ruled that there was no requirement to s a consider thermal streeses in pipe supports. The position that 1

['therelevantconcernisnotcreeportherNa1 expansion,but

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u: n seismic loading, is further supported by the Licensing Board's characterization of the issue in its December 28, 1983 and i N "

~Eebruary 8, 1984 Memoranda and Orders as " Differential Seismic Displacement."

As set forth more fully below, responses to the outstanding .

qdest' ions raised by the Licensing Board and the analyses of the rernaining large-framed, floor-to-ceiling and wall-to-wall i

J.J ., 1 supports, coupled with testimony previously presented do not reflect that there has been a breakdown in the QA program or that

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these supports present a safety concern. Accordingly, no genuine issue,.of material fact exists with respect to these issues, and

, the Board'should find that the Applicants are entitled to judge-ment as a matter of law.

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1. General As indicated in Applicants' Exhibit 142 'at p. 25, prior to

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this. issue being raised by the NRC or CASE, in late 1981 Appli-s . , cants'" identified four large-frame, floor-to-ceiling supports designed by PSE without slip joints as being inconsistent with l PSE guidblines. Affidavit at p. 3. (The PSE guidelines state ,

that such large-frame' supports should have slip-joints; the purpose being to negate the need to analyze differential displacement of supports isetween floor and ceiling or between l walls. Id.) However, the supports were very conservatively 1

designed, and it was generally felt that they were adequate. Id.

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In the process of awaiting completion of construction of structures associated with the four supports, and obtaining 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. Id. at pp. 3-4. While Applicants believed that a detailed analysis of the supports would demon-strate their adequacy, calculations reflected that the floor-to-ceiling columns could simply be cut off and the supports would still be adequate. Id. at p. 4. This was by far the easier course of action. Id. Accordingly, Applicants cut the columns in half to eliminate any suspected problems of a support extend-ing from floor-to-ceiling. Id.

After this issue was raised in this case, to demonstrate the adequacy of the initial designs, Applicants determined the seis-mic differential displacement between the floor and ceiling where the supports were located and, using the; computer code STRUDL, analyzed one of the four identical supports for the combined design load and differential seismic displacement load. Id. at pp. 4-5. Significantly, the seismic differential displacement was calculated to be .006 inches, less than the thickness of two l

sheets of paper. Id. While as a practical reality, limited displacement on the order of .006 inches would never be a matter

[ of concern for any support, the computer run was made and the resulting stresses in the support were below allowable stresses.

l l Id. at pp. 4-5.

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Subsequently, Applicants have reviewed all Unit 1 and common safety related piping supports and deter' mined that there are 26 supports spanning from wall-to-wall or floor-to-ceiling. Id. at pp. 5-6. Of these 26 supports, seven have slip-joints, 4 have small spans, negligible seismic movements and are not considered large-framed supports, and the remaining 15 have been evaluated and were found to be acceptable considering the potential for differential seismic displacement. Id. Significantly, none of these remaining 13 supports were designed by PSE, and all were designed prior to the time that the PSE guideline was made appli-cable to the other design organizations. Id. Accordingly, these supports were not originally designed in conflict with the PSE guideline, i.e., the guideline was not applicable to those organ-iza t ions . -Id. at p. 6.

2. Response to the Board's First Ouestion, "how it came about that PSE violated its own design guidelines."

It must be remembered that the PSE guideline-regarding l floor-to-ceiling and wall-to-wall supports was not a code or i

l procedural requiremen t, but rather guidance for the designer.

l l Id. at pp. 6-7. Indeed, this guideline was not initially appli-l cable to the other two design groups (ITT and NPSI), although their supports were adequate for piping loads and differential displacements. Id. While we cannot be certain why the designer l

and reviewer did not follow the guideline for these four supports (these individuals are no longer employed at CPSES), as previous-i

ly stated, the designs were appropriately conservative and, even if unchanged would have been acceptable. Id. f i

3. Response to the Board's Second Question, "how did this event (come] to be reflected in the design quality ,

assurance system?"

The failure to follow the PSE guideline for these four supports did not require the generation of any QC non-Conformance  ;

documentation. Id. at p. 7. If the supports had not been adequately designed in the first instance, corrective action l would have been required. Id. at p. 7. Of course, because there was a design change of the supports, appropriate design change documentation was issued. Id. at p. 7.

4. Response to the Board's Third Question, "whether this problem received prompt attention." ,

Applicants maintain that the problem received prompt atten-tion. In 1981 the four supports in question were identified.- As previously stated, it was believed that the designs, although not i in strict compliance with the PSE guideline, were adequate. Id.

at pp. 7-8. Accordingly, Applicants chose to wait until construction associated with all four of the supports and all l

piping had been completed to determine the precise as-built loads to assure the adequacy of the designs. Id. In the interim, the SIT raised the issue and the decision was made to modify the  ;

l support as opposed to going through a detailed and, because of timing, a premature design analysis. Id. That prompt attention to this problem was taken is evidenced by the fact that only Id.

these four supports were in violation of the guideline.

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Subsequently, the SIT recommended that the guideline regard- ,

ing this issue be made applicable to ITT and NPSI. Id. While Applicants did not believe it was necessary, Applicants promptly complied with the request. Id. As previously noted, analysis of similar. supports designed by ITT and NPSI reflect that such supports were adequate considering piping loads and differential displacement. Id.

In sum, Applicants did promptly respond to the problem when it was identified.

5. Analysis of tiall-to-Slab Supports l c

CASE has recommended that Applicants analyze all wall-to-slab (floor or ceiling) supports in the plant which do not contain slip-joints. CASE's Proposed Findings at p. VI-14. For the following reasons, Applicants maintain that such additional reanalysis is not necessary.

The seismic deflection that could occur on wall-to-slab ,

supports consists of vertical deflection of the slab and hori-zontal deflection of the wall. Affidavit at pp. 8-9. In that such supports are near the juncture of the slab and wall, the r i actual deflection realized at the support would be minimal and less than the maximum deflection realized toward the middle of the wall or slab. Id.

To determine if differential seismic deflection appeared to be a problem with such supports, Applicants analyzed three repre-sentative supports to determine the resultant stresses. Id.

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From the analysis, the seismic deflection for the supports ranged .

l from .00035 to .0045 inches,.less than the seismic differential deflection noted above regarding floor-to-ceiling supports. Id.

While as a practical reality limited deflections on this order would never be a matter of concern for any support, a conserva- ,

t tive analysis of the three supports using the STRUDL computer code reflects that resultant stresses are within allowables. Id. i Accordingly, Applicants maintain that CASE's concerns i

regarding wall-to-slab supports are without merit.

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i III. CONCLUSION l For the reasons set forth abo've, Applicants request that the Board grant Applicants' motion for summary disposition.

Respectfully submitted, i

Nicholas S.#Reynolds l William A. Horin Malcolm H. Philips, Jr. >

BISHOP, LIBERMAN, COOK, PURCELL & REYNOLDS i

1200 Seventeenth Street, N.W.

i Washington, D.C. 20036 l (202)857-9817 l

! Counsel for Applicants l

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June 22, 1984 l

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