ML20095G658

Answer to Applicant Statement of Matl Facts as to Which There Is No Genuine Issue Re Case Allegations Regarding U-bolts Acting as two-way Restraints.Statement in Form of Affidavit of M Walsh.Certificate of Svc Encl

ML20095G658
Person / Time
Site:	Comanche Peak
Issue date:	08/19/1984
From:	Mary Walsh Citizens Association for Sound Energy
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20095G633	List: ML20095G630 ML20095G646 ML20095G658
References
OL, NUDOCS 8408280146
Download: ML20095G658 (35)

Text

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' UNITED STATES OF AMERICA NUCLEAR REG'JLATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of-i I

TEXAS UTILITIES GENERATING l

Docket Nos. 50-445-1 COMPANY, ~ et al.-

l and 50-446-1 i

(Comanche Peak Steam Electric Station i

Station, Units 1 and 2) 1 CASE'S ANSWER TO APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE REGARDING CASE'S ALLEGATIONS REGARDING U-BOLTS ACTING AS TWO-WAY RESTRAINTS in the form of-AFFIDAVIT OF CASE WITNESS MARK WALSH 1.

Applicants state:

"A 1/16 inch gap was designed into each U-bolt Testraint on a rigid frame.

"As a first support design effort, it was viewed that.this gap would accommodate the thermal and seismic movement of piping.

"(The movement due to'a seismic event was preliminar11y calculated to be very small, i.e.,

less than 1/32 inch, for almost all piping.)

"Accordingly, in the initial pipe support design (prior to as-built conditions), all such U-bolts g/ had been considered as only one-way

. restraints (because the lateral gap was present). Affidavit at 3."

I challenge Applicants' first and second sentences. During the 6/11/84 Applicants / Staff / CASE telephone conference call, I asked ~on i

discovery for documentation of Applicants' statements.

I asked specifically for the criteria that would say which U-bolts need to be 1

11/ Regarding the fourth sentence, in the 6/11/84 conference call, Applicants clarified that "all such U-bolts" in this sentence referred j

only to "each U-bolt restraint on a rigid frame" in the first sentence.

(Tr. 23.)

P 8408280146 840820 PDR ADOCK 05000445 G_

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cinched up and which ones need not.be cinched up.and for documentation I-that-therewas'anoriginalintentionthabsomeof.theU-boltsshouldbe#

' cinched up/and some of them shouldn't, and for-documentation to verify how one determined if the U-Bolt was acting as a one-way restraint or a two-way restraint._ (Tr. 8-16 and 23.) It is my understanding that on

7/29/84', Applicants' counsel Mr. Horin advised Mrs. Ellis that there is no such documentation' (see CASE's 8/13/84 letter to Nr. Horin,

Subject:

Open Discovery Items for-Motions for Summary Disposition, page 9-of attachment).:'I further asked for documentation showing why NPSI had allowables for both directions (Tr. 16-21). Applicants' 8/4/84. letter (received by CASE on 8/7/84) stated:

"The question you posed regarding the use of allowables for U-bolts as.two-way restraints was already answered by Dr.. Iotti at pages 21-23 of the June'll conference call."

j However, in that conference call, Dr. Iotti did not really address documentation at Tr. 21-23.

He did state:

"Well, I believe. If you read the affidavit, which you have found is.a sample, which encompasses most of those U-Bolts which were intended to act as one-way, but which could act as two-way restraints.'

O.K.,

the affidavit addresses certainly the ones that I

are most likely to act as two-way restraints, and concludes that the reason was that effect is tolerable.

So that is the best information that we can provide you. We went back, searched for-all.of'the instances which the U-Bolts intended to act as one-way, L

could in fact act as two-way, where we analyze those fresh

_ problems which encompasses some of those U-Bolts, and I say some, because not all were included but most in terms of one's that were most likely to act as a two-way restraint, and presented to you.as a conclusion to those studies. That is the best-evidence that we can provide at this point."

(Tr. 24.)

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Regarding documentation, Dr. Iotti stated;

.~I don't know what other documentation we can provide, other than telling you that these particular U-Bolts were intended tc have a gap, and never intended to be cinched up."

(Tr. 12.)

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w And Mr. Finneran stated

"This information is on--the_ drawing.. What better criteria could you have than the fact that the drawing shows it to be c_nched up or not?" (Tr. 14.)

The fourth sentence is a conclusion based on the previous three sentences, and the previous three are essentially dealing with the original design. There is no indication that Mr. Finneran and Dr.

Iotti worked for the original. design organizations,.or that they were involved in the original design effort,,at the time the original designs occurred, and it is my understanding that they were not so involved at that time.

(The original design was circa 1979.) f2/.

Since Mr. Finneran and Dr. Iotti were not involved in the original design and there is no documentation to support their statements, their conclusion is based on nonfactual information, contrary to Applicants' statements above.

NPSI has allowable values for the U-bolts in the lateral direction, as shown in CASE Exhibit 669B, item 13L f3/; the date on the she,et is 1981, which was prior to the vendor certification process.

Therefore, NPSI was utlizing those U-bolts as two-way restraints, even though a lateral gap was present.

In addition, a lateral gap of 1/16" is generally provided in all directions, including the direction,that would put primarily tension in the U-bolt where the nuts are located (referred to hereafter as the normal direction).

If the U-bolt could f2/ See their resumes (Mr. Finneran, Applicants Exhibit 142B, accepted into evidence at Tr. 4794; Dr. Totti, attached to Applicants 5/16/84 letter

• to the Board attaching Motions for Summary Disposition on Damping Factors for OBE and SSE Loading Conditions, AWS/ASME Code Provisions (Design), and Consideration of Friction Forces).

f3/ Attachment to Doyle Deposition / Testimony, admitted into evidence at Tr.

3630.

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(i not take the lateral load because of a 1/16" gap, it would be reasonable to assume that it could not take the load in the normal direction either. Therefore, Applicants' premise is not logical.

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Applicants state:

"As the as-built design review and corresponding pipe support reanalyses were being conducted, Applicants determined,that the thermal movement of piping associated with some U-bolt supports would exceed the 1/16 inch gap 'provided and some seismic movement may exceed 1/32 inch.

Id."

I disagree with Applicants' statement.

It would appear that NPSI and ITT Grinnell did use the U-bolt as a two-way restraint.

(See Attachment A, 7/16/82 Gibbs & Hill Interoffice Memorandum from H. W.

Mentel to Distribution,

Subject:

U-Bolt Review Procedure; this was received on discovery, as requested during the 6/11/84 conference call, Tr. 27-28.)

This 7/16/82 Memorandum states:

"To date it has become apparent in reviewing the applicable BRH drawings that both NPSI and ITT Grinnell have used U-Bolts in various supporting configurations. Already the following questions have been posed:

"l)

In reviewing the BRH v.s. the BRHL drawing, the BRHL designates a two way support, while the BRH has a U-Bolt with a single design load in the direction of the principle axis.

(In some instances this situation has been reversed). What should be modeled?

"2)

In some instances the BRHL calls for a one way support and-the BRH has a single design load. However the support design consists of the use of a U-Bolt, with the principle axis (U-Bolt in tension) taking the design load. What about the lateral movement indicated in the ADLPIPE analysis? In the past, problems have been issued with the future corrective action sheets requiring the opening up of gaps on the U-Bolt.

However, this procedure is not possible since it would affect the structural characteristics of the U-Bolt."

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l It is apparent from this statement that NPSI and ITT Grinnell.

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-originally designed the U-Bolts as two-way restraints in some instances and in other instances lacked the knowledge of the consequences of a U-bolt acting as a two-way restraint. Applicants' statement that "the thermal movement of piping associated with some U-bolt supports would exceed the 1/16 inch gap..." and that this prompted the Applicants to consider the U-bolt as a two-way restraint is without substance.

~ As indicated by the two items listed above, the thermal movement of the pipe was not the problem as the Applicants have implied in their s tatement.

In addition, the Applicants have not provided the specifications or criteria by which the Applicants instruct the pipe support designer or engineer to consider the two-way restraint of a U-bolt.

The only documentation which the Applicants have been able to provide is the 7/16/82 interoffice memo, which is not binding as a specificatien or pipe support design criteria weuld be.

In addition, there is no indication in the memo as to who is included in " Distribution;" and it is unclear whether or not the engineers who analyze these supports are on the list.

The 7/16/82 Cibbs & Hill Memorandum (bottom.of page 2 and top of page 3) states:

"Our purpose with this procedure is to check the adequacy and af fect (sic) of the existing design not present new design conditions to the support vendors.

"In closing an effort should be made to minimize any changes in U '

Bolt Design hardware.

(Emphases added.)

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'It appearsLto me:that.Gibbs,&' Hill ~never-intended to tell NPSI and

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ITT Grinnel1~ that thby, had to -do it right, and that -their only purpose

.was to justify what-had already erroneously been done -- along with an attempt to keep down costs as amch as possible.

It also appears th'at

.Gibbs &' Hill never' intended to inform the STRUDL Group about this problem,' which was recognized and pointed out by Jack Doyle. ' As discussed in CASE's 8/22/83 Proposed Findings of Fact and

Conclusions:

of Lav (Walsh/Doyle Allegations), at page 11-8:

"The.NRC SpecialLInspection Team (SIT) had the following statements in reference to the allegations by Mr. Doyle (SIT Report, NRC Staff Exhibit 207, page 31):

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"' Relative to the first of Mr. Doyle's concerns, the Special Inspection Team determined that Gibbs & Hill identified the same' concern during the Applicants' As-Built Verification Program. This concern was addressed by review procedures established in a Gibbs.& Hill inter-office memorandum dated July 16, 1982.'"-

(Emphasis added.)

1 This appears to be the isame Gibbs & Hill inter-office memorandum i

discussed previously. Continuing from CASE's Proposed Findings:

j "It is mind-boggling to note the numbers of memos that originated l

as a result of the allegations of Messrs. Doyle and Walsh. This

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particular memo came out about four weeks after Mr. Doyle quit because of this U-bolt problem, other problems with U-bolts, etc.

At the time of his resignation, Gibbs & Hill wanted to hear no 4

more about U-bolts or LOCA.

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"It should also be noted that the SIT was unable to state with certainty exactly when Applicants identified the problem.

(See i

item 66, page 5, CASE Exhibit 848, Stipulations between CASE and NRC Staff, admitted at Tr. 8350-8352).

It is reasonable to assume that Applicants identified this problem as a direct result of Mr.

Doyle's having raised it."

The Gibbs'& Hill memorandum adds further credibility to CASE's statement that it is reasonable to assume that Applicants identified this problem as a direct result of Mr. Doyle's having raised it.

And b

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it appears that Applicants were not going to inform the appropriate groups (i.e., NPSI, ITT Grinnell, or the STRUDL group) of how they were going to resolve this problem. 'This is contrary to ANSI N45.2.11, 5.1.4 (to which Applicants are committed; see Applicants' Exhibit 148).

3.

Applicants state:

"As part of the as-built review program Gibbs & Hill reran the thermal piping analyses at all locations where U-bolts were' initially considered as one-way restraints and where the piping thermal movement was equal to or exceeded 1/16 inch.

"Those reanalyses indicated that even assuming the U-bolt acted as a two-way restraint, the piping stresses would remain well within allowable values.

Id. at 4."

I disagree with the first sentence. The problem here is (in more,

precise terms) when a seismic event occurs, which was not considered by the Applicants (as shown in their Affidavit, page 4, first full paragraph), the combined displacement from seismic motion and thermal movement of the pipe exceeding 1/16" will induce a load into the support. Although at the instant the load from the pipe is restrained and stresses decrease within the pipe at that instant, loads increase in the U-bolt.

If the U-bolt were intended for restraint in one direction (that is, other than lateral), the combined load due to this new restraint from seismic and its intended direction may fail the bolt. Now the U-bolt does not act in its intended direction and there is a lack of a support there, even though the support did not move more

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than 1/16" due to thermal mo'vement. The combined thermal and seismic movement can fail the U-bolt and the stresses now within the pipe will increase.

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l In the Applicants' affidavit at page 4, the Applicants state:

'"-,... piping movements associated with' seismic excitation were e believed to be very small and generally less than -1/32 inch."

Although-the Applicants.may have believed this statement, this statement it not:

realistic.- CASE Exhibit 932 (see pertinent portions attached), the

.page labeled 18 of 18, lists the displacements of support SI-1-075-001-S22R and they are +.619 inches and.043 inches in the X. direction, and

+.202 inches and..026 inches in the Z direction. As can be seen, the seismic movements for these load sheets do, exceed 1/32". Therefore, Applicants' statement above does not have merit and is a nonconservative error on their part. Although this particular support did not have a U-bolt, the seismic movement did exist.

For a support with a U-bolt that has a seismic displacement greater than 1/32", see Table 3, page 6 of Applicants' attachment, where the seismic displacement for-Support CC-1-007-040-A63R is.044 inches, which is greater than 1/32".

In regard to Applicants' second sentence, referencing page 4 of their Affidavit, the stress values'in the reanalyses are not within allowables for only a thermal loading condition, as will be shown in answer 5.

In addition, the Applicants (as has already been alluded to)

.did not. include the stresses due to seismic and did not mention the stresses due to dead load.' If the reanalyses were to be a true model of the actual conditions, this would require analyzing the two-way U-bolt for all possible loading conditions *and consideration would be required for those instances where the U-bolt would have exceeded its S

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yield values and acted no longer as a restraint.in either directio'n-

-(1.e., as if no support were even there).

(See CASE's 8/22/83 Proposed.

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' Findings,Section II, page 3',

last line, through page 7.)

4.

Applicants state:

" Applicants decided to replace,all U-bolts on rigid frames initially considered as one-way restraints where piping thermal movements were computed to equal or exceed 1/16 inch in the original analysis.

Id[. "

Applicants'. statement is correct, but they have not given a reason for not replacing U-bolts when the thermal movements are less than-1/16". If their decision was based on a 1/16" gap between the pipe and the U-bolt, this decision would be an inappropriate one. The construction procedures do not require a 1/16" gap on both sides of the U-bolt. The installation of U-bolts or any frame that requires a 1/16" gap has a tolerance of + or - 1/16". Therefore, one could have a zero inch gap on one side of the pipe and a 1/8" gap on the other side.- If the pipe wishes to mo,ve 1/16" where there is a zero inch gap, this will e

induce a load equal to a 1/16" deflection of the U-bolt.

This load due to a 1/16" deflection must be added to the normal load (as defined by the Applicants).- The PSE Guidelines at Section II, paragraph 2.2, page 2 of 15, Revision 2 (see copy attached) states:

"... Clearances required to allow the pipe to move in the i

unrestrained direction should be 1/2" over the calculated movement or.1", whichever is greater. In certain limited space configurations, where thermal growth is small, lesser clearances may be acceptable."

Although the PSE Guidelines allow a* clearance to be less than the' l-thermal growth of the pipe plus 1/2", there has been no documentation i'

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9 to show that there is a gap bet'.;een the pipe and the U-bolt.

To this extent, the Applicants are not in compliance with this provision of the PSE Guidelines.

5.

Applicants state:

"There are currently seventy Unit 1 and common U-bolts on rigid frames which were originally modeled as one-way restraints.

"While the maximum thermal pipe movement associated with each of the seventy U-bolts would not exceed the 1/16 inch design gap, the maximum thermal plus seismic movement of eight would. Jji. at 6."

The Applicants state that they are currently 70, etc.

(emphasis added.) This is not a clear picture of the number of U-bolts existing at the plant in the ori~ginal design that were assumed to act as one-way restraints. This conclusion.is based on the following: On item 3 above, the Applicants stated that as part of the as-built review, all U-bolts were initially considered as one-way restraints and having thermal movements exceeding 1/16 inch were replaced. There are currently (according 'to Applicants' item 5) njt U-bolts where thermal movements exceed 1/16". The combined movements of seismic and thermal of this remaining 70 supports have been evaluated by the Applicants, and 8 supports exceed 1/16" when thermal and seismic displacements are added. This represents 13% of the supports the Applicants currently have where seismic and thermal displacements exceed the 1/16" displacement. The word " currently" indicates that this may not properly represent the design of Comanche Peak'.

This Motion for Summary Disposition was written May 23, 1984, and that is what is current. On the 22nd, maybe (I don't know) there may have been 700 10

r supports that, had seismic and therral displacements been included, would have. exceeded the 1/16" displacement.

6.

-Applicants state:

"To assess the impact on piping analyses of a U-bolt installed in the plant acting as a two-way restraint, Applicants conservatively reanalyzed stress problems associated with the two worst case U-bolts (i.e., those with the maximum combined thermal and seismic movement, CC-X-013-012-A43R and CC-1-007-040-A63R) and a representative sample of other U-bolts initially considered as providing one-way restraints.

Id. at 6-7.

"The reanalyses reflected that any effects of the U-bolts acting as two-way restraints on piping stresses and ase)ciated loads (e.g.,

nozzle and anchor loads) would be small or negligible and would not result in exceeding allowable stresses or manufacturers' allowable values.

"Further, the analyses reflected that the effects on other associated piping supports are generally decreases in the loads; where there are increases, they are well within allowables.

Ijd. at 8-10."

In regard to the first sentence, Applicants state what they considered to be " conservative";

i.e., " maximum combined thermal and seismic movement." I disagree with their implication that this would be a conservative analysis.

If they meant to imply that they were conservative by looking at the U-bolts as two-way restraints, that is not necessarily conservative, but a realistic modelling technique to analyze a piping system and the loads it will impart on the supports.

I disagree with Applicants' second and third sentences. The reanalyses indicate that the pipe stresses increase and the loads on the U-bolts vs. the allowables of the U-bolts increase. As a matter of fact, some U-bolts exceed allowables, which is contrary to the Applicants' statement, as will be shown below.

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w Referring to'the attachment to-Applicants' Motion which has a-

- cover page titled,"Index of Tables," Applicants' Table 5a (towards the.

.back of theLattachment), for. Support CC-1-007-035-A63R, the vertical

. load without U-bolts modelle'd as two-way restraints, and due to thermal loads ~only, is'52 lbs. swith the:U-bol't modelled as a two-way

.. restraint, and due to thermal loads only, the vertical load is 65 lbs.

and the lateral. load isLequal to 1,259-lbs. (square ~ root of 2 times 890 lbs.).

According to the PSE Guidelines (Section XII, page 66 of 364, see attached copy), the. allowable laterallload for this U-bolt, which

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' is attached to a 6". diameter pipe, is 210.lbs.. which is far less than the applied load.

On Table 1 'of the same attachment, Support CC-2-126-005-F43R is listed. There is no asterisk by this support where the asterisk

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indicates two-way action.'

Its maximum thermal movement is shown to be J

.008".and maximum seismic movement to be.0261".'

Referring to Table 4 for stress problem AB,-2-63B, on page 3 it lists the support CC2-126-i{ -

005-F43R with an asterisk. The level B load without the U-bolt modelled as a two-way restraint is 2,904 lbs. In the X direction. When the U-bolt is modelled as a two-way restraint, the load in the X

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. direct. ion is 3,434 lbs. The load n$w in the U-bolt in the lateral J

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direction (i.e., the Y direction) is 952 lbs. The allowable lateral load for this U-bolt on a 12" diameter pipe is 300 lbs. (PSE Guidelines,Section XII, page 66 of 364, see attached copy).

It should 1

be mentioned that this support had a seismic displacement or thermal i

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movement of less than 1/32", and the allowables were' exceeded. ' It-should also be' mentioned that in their Table 4, the Applicants neglected to consider the two-way restraint which-exista due to thermal

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movement.'This is demonstrated by observing the Table'for this support, and noting that the tw'o-way restraint loads listed were ' for loadings B and C and not A, and-loading'A would be for dead plus thermal loads only.

Other examples where the U-bolts, when modelled as two-way restraints, exceed allowables (based on Tables 2, 3, and 4 of Applicants' attachment and PSE Cuidelines,Section XII, page 66 of 364, see attached copy) are:

CC-X-013-012-A43R CC-X-025-005-A43R CC-1-007-040-A63R CC-2-126-006-F43R The affidavit of Messrs. Iotti and Finneran at page 8 states that a rerun of the problems with U-bolts input as two-way restraints produced no appreciable change in loads; however, if one studies the tables that,resulted from these reruns, the problems become obvious, as discussed in the following:

' Table 3, problem AB-1-62E, second page, support No. CC-1-007-

.025-A43R, shows that the load increased 29%.'

Page 4 of this Tab,le, for Support No. CC-1-007-039-A43R, shows that the load increased 31%.

Page 5 of Table 3,.for support CC-1-007-704-A43R, shows that j

the load increased 28%.

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Table 4, problem AB-2-63B, at_page 3, support No. CC-2-126-010-F43R, shows the load increased 26,%.

CC-2-126-007-F43R, shows a load increase of 61% (2200 lb.

increase).

-Page 3, CC-2-126-005-F43R, shows a load increase of 21% plus a lateral load not existing before of 952 lbs.

Support CC-2-126-006-F43R, shows a load increase of 25% plus a 318 lb. lateral load not existing before.

CC-2-126-011-F43R shows a load increase of 11% plus a 61 lb.

lateral load not existing before.

On-page 4 of Table'4, support CC-2-164-407-A63K, shows a load increase of 27%.

The increases selected above only included those loads that increased 20% or more or where the increase was 10% and lateral loads were indicated that had not existed previously.

Now, since these U-bolts are no longer acting in a predictable manner, one must consider how this will affect the remaining pipe supports and the piping itself, since this U-bolt is not resisting loads in either direction, in a predictable manner.

The Applicants claim that the associated piping supports may have a decrease in loads, but when the U-bolts become nonfunctional because of exceeding the allowables, the adjacent supports will now receive an increase in loads which need,s to be evaluated, and the Applicants have neglected to do so.

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Applicants state:

"If maximum thermal and seismic movement were assumed to occur simultaneously, there would be a lateral load (in addition to the load in the normal direction)' acting on eight of the 70 U-bolts, noted above.

Ijl. at 10.

- " CASE acknowledges that this lateral load will be small when compared to the load in the normal' direction (CASE Findings of Fact at II-3)."

In the first sentence, Applicants are assuming maximum thermal and seismic' movement will occur simultaneously. It is a requirement of General Design Criteria, 10 CFR Part 50, Appendix ~A, I. Overall Requirements, Criterion 4, Environmental and Missile Design Bases, as well as ASME NF-3231.1.

Since the Applicants are stating that they must make an assumption, apparently Messrs. Finneran and Iotti are not awara that they are require _d_to perform the simultaneous load combination analysis.

In regard to Applicants' second sentence, Messrs. Finneran and Iotti have again taken CASE's statements out of context. As stated in CASE's Proposed Findings, page II - 3:

"The SIT concluded that the forces in the lateral direction of the U-bolt is considered negligible (page 31, second paragraph, Staff Exhibit 207). CASE agrees that the forces in the lateral direction are small when compared to the intended vertical direction. But the allowables for U-bolts in the lateral direction are'also negligible compared to the intended vertical direction. For a comparison (referring to CASE Exhibit 669B, Attachment to Doyle Deposition / Testimony, page 13N and 13-0), the allowable in the intended vertical direction for a 18" diameter pipe under Level B is 9920 lbs., as shown on page,13N. The allowable in the lateral direction for the same pipe and loading B is 320 lbs., as shown on page 13-0."

(Emphasis in the original.)

Although CASE agreed with the SIT at the time CASE's findings were written (based on the information we had at that time), I now disagree e

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-that the loads will be small in the lateral direction when compared to.

the normal (intended vertical) direction, based on the Applicants' reanalysis.

By observing Table'5a of' Applicants' attachment, for Support CC - 007-035-A63R, the lateral load is 24 times larger than the original

' intended vertical load. From the same' table, Support CC-1-007-040-A63R, the lateral load is 7 times larger than the original intended vertical load. This is just a sample; other supports had lateral loads that were a considerable percentage (rather than a small percentage) of the original intended vertical loads.

8.

Applicants state:

" Applicants commissioned ITT Grinnell to carry out a series of tests on U-bolt capability.to carry both normal and lateral loads.

"The tests reflected that even for lateral displacements exceeding the maximum that could occur, the lateral load would not impair the capability of the U-bolt to carry its load in the normal direction.

For example, the tests reflect that even if the maximum seismic plus thermal lateral displ'acement were to induce a lateral load equal to fifty percent of the rated normal load, the U-bolt would still have more than a factor of 2.5 margin of safety in its normal direction.

Id. at 10-11."

l Regarding the first sentence,-it should be noted that ITT Grinnell has a vested interest in the outcome, and thus can not be considered to be impartial or independent. Also, during the 6/11/84 telephone conference call between Applicants /NRC Staff / CASE, when asked what criteria was used to have ITT Grinnell do the testing rather than an Independent outside laboratory, Dr. Iotti stated (Tr. 32/2-8):

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"I guess the prime criterion is expediency in the sense that we have to have this done in a short time; secondly is that the devices employed to test for ultimate capability are essential, universal.(sic) and, you know,' there is no way you can hide the

,results of the test, so it's really immaterial who conducts them."

(Emphasis'added.)

Regarding the second : sentence, I do not agree with their method of testing and the conclusions they have drawn. - The test results are

. based on two particular rods where the yield and ultimate tensile l

strengths exceed the minimum. required. This is an advantage to the Applicants because their rod is already known to be stronger than the minimum specified and used at Comanche Peak.

Therefore, for those rods that are utilized from those particular test'results, the results are accurate; however, for all remaining U-bolts which come from a different batch of steel, the results obtained in this testing is not reflective of the test.

If the Applicants were to utilize the test values, the Applicants would have to require the supplier of these U-bolts to have a minimum yield o'f 51.6 ksi and not 36 ksi, and a minimum 7

tensile strength of 73.4 kai and not 58 ksi. Since this is not being done, the conclusions which the Applicants have drawn are immaterial and misleading. If the test was properly done, the U-bolts tested would have a yield strength equal to or less than 36 ksi, and a tensile strength equal to or less than 58 ksi.

i The test results which the Applicants provided indicate that they are not in compliance with their own stiffness criteria, but-this will be discussed in an affidavit in response to Applicants' Motion for Summary Disposition on generic stiffnesses. However, there is one 17

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_ point which I need to bring to the Board's attention (as well as the

-Applicants').

It is on page 16 of the Affidavit of Messrs. Finneran and Iotti where they state:

"The test program has' confirmed that deflections in the normal directions, even when'the U-bolts are loaded to their full rated loads, would be small..One can see this from the charts on pages 54-56 of Attachment 1.

At the normal loadings the stresses are small and deflections are less than.02 inches for the 1/2 inch bolt, and less than.03 inches for the 1 inch bolt."

A review of the test results on pages 54-56 of Attachment 1, indicates that displacements are not measured but strain is measured (strain is change in length over original length).

In Figure A-13 on page 54, there is, however, an indication that possibly displacements were measured. If the values shown (i.e.,

.5, 1.0, and 1.5 inches) are the displacements (which is difficult to determine from the Figure),

the loadlat 1/16" deflection would equal 1,200*1bs.

According to the PSE Cuidelines (page 65 of 364,Section XII, see copy attached), the allowable load listed is 2,260 lbs. This load of 2,260 lbs. exceeds 4

the 1/16" (.0625") de'flection criteria. Therefore, the statement which the Applicants make in their affidavit indicated above is contrary to the test results. It is also noteworthy that the Applicants provide the load vs. displacement for the axial'and lateral tests, but not for the load normal to the U-bolt.

This is particularly unfortunate since the load vs. displacement in the normal loading direction of a U-bol't is also one of CASE's allegations.

In_ regard to Applicants' third sentence where they state that they have a factor-of 2.5 margin of safety in its normal direction, is i

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r ea contrary to standard industry practice. Standard industry practice has k.

'u a factor of safety.of 4 in regards to the allowables for standard component supports.

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9. ' Applicants state:

"Using conservative assumptions, it was determined 'that all of the U-bolts at issue.here were well within the manufacturer's interaction formula limits.

Id. at 12-15."

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/tdisagreewilh,thisstatementbytheApplicants. First of all, I e

J have not seen w'ere conservative assumptions were employed.

In h

addition, it had been shown above that five of the supports exceeded e-L,

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established code allowables.

In addition,'it was shown above that the 4

i' U-bolts,do not comply with the Applicants' generic stiffness.

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. 8

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x,:

Attachments:

?

Attachment A 7/16/82 Gibbs & Hill Interoffice Memorandum from H. W. Mentel to Distribution,

Subject:

U-Bolt Review Procedure (see answer 2, page 4)

Attachment B CASE Exhibit 932 (pertinent portions, Drawing SI-1-075-001-S22R and page 18 of 18) (see answer 3, page 8)

,/

Attachment C PSE Cuide1Ln6,Section II, paragraph 2.2, page 2 of 15,

^

Revision '? (see answer 4, page 9)

/

Attachment D PSE Guidelinas,Section XII, pages 65 and 66'of 364 (see

answers 6 and 8, p' ages 12,13, and 18,)'

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__-______________1-_.

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The preceding CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue was pre' pared under the personal direction of the undersigned, CASE Witness Mark Walsh.

I can be contacted through CASE President, Mrs. Juanita Ellis, 1426 S. Polk, Dallas, Texas 75224, 214/946-9446.

My qualifications and background are already a part of the record in these proceedings.

(See CASE Exhibit 841, Revision to Resume of Mark Walsh',

accepted into evidence at Tr. 7278; see also Board's 12/28/83 Memorandum and Order (Quality Assurance for Design), pages 14-16.)

I have read the statements therein, and they are true and correct to the best of my' knowledge and belief.

I do not consider that Applicants have, in their Motion for Summary Disposition, adequately responded to the issues raised by CASE Witness Jack Doyle and me; however, I have attempted to comply with the Licensing Board's directive to a6swer only the specific statements made by Applicants.

~(Signed) Mark Walsh s

STATE OF TEXAS On this, the

/[

day of M

, 1984, personally appearedMarkWalsh,kn'owntometobethepepsonwhosenameissubscribed to the foregoing instrument, and acknowledged to me that he executed the same for the purposes therein expressed.

Subscribed and sworn befero me on the

//

day of %

1984.

(

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'A O,k M Notary Pub'lic in and for'the

~

i SAMUEL W. StalGR of Texas My Commission Empires IE

,My Commission Expirest

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ATTACHMENT A'-'

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G/DDS S Hfff,Inc. W Jntero m ce Memorandum

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Julv 16, 1982 Distribution DATE:

TO:

2323 H.W. Mentel JOB NO:

F80M:

U-Bolt Review Procedure REF. NO:

SUBJECT:

i ble BRH To date it has become apparent in reviewing the ap in Already the following various supporting' configurations.

questions' have been posed:

In' reviewing the BRH v.s. the BRHL drawing, the BRH 1) i iple with a single design load in the direction of the pr nc designates axis.

What should be modeled?

[

d In some instances the BRHL calls for atone way support an However the support the BRH has a single design load.

2) design consists of the use of a U-Bolt, with the principle What taking the design load.

E analysis?

axis (U-Bolt in tension) about the lateral

• movement indicated in the ADLPIP In the past, problems have been issued with the future on corrective action sheets requiring the opening up of g

~

h U-Bolt.

it would affect the structural characteristics of t e the U-Bolt.

0,which may arise In response to these questions and any cG ;:et m statements on U-Bolts)

(also to c._ ear past future ~ corrective the following procedure is presente.

i STE7 ' I s

For those Review the applicable BRH and BRHL drawi.

s.

i l design loads, supports utilizing 'U-Bolts, check the orig na

~'

in particular their directions.

(ie BRH In those instances where the BRHL and BRB disagrec ide) design load is Fy only; BRHL indicates a two direct'enal i

The report the disciepancy to the GHABCii for clarificat on.

lied rupport stiffness values to be used are the G&H app r

^

mechanics standard values.

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= - -,.

f P

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-t STEP'II for those supports which have a Once an initial run is made, U-Bolt but only one design load the piping movements in theFor example in t perpendicular direction must be reviewed. load was Fy. The piping is figure below the.U-Bolt Desigp'Y essentially f ree to move in Jg y the Z direction.

However, the

.y'*fh*

b 3,g U-Bolt of f ers resistance in the

, 49h X Direction.

-M a m umm s

Only the thermal It is the X movements which must be reviewed.the reasoning being that th

. movements need be checked,

. existence of the lateral stiffness.of the U-Bolt is an aid of the over-improving on the rigidityis the thermal condition in the seismic analysis, It all system in a seismic event.

which is in question since the lateral stif fness jeopardizes the flexibility that may be needed to reduce thermal stresses,

If the lateral thermal move-and equipment nozzle loadings.

ment is not greater than 1/16 inch then it will be deemed that For those cases where the 1/16 inch a problem does not exist. criteria is violated further analysis is requir STEP III-For lateral thermal movements' greater than 1/16 inch anThis run should additional ADLPIPE run should be made. consist of only stiffness imposed at the U-Bolt.from the attached tables,_ extrac First In this study run two things must be checked.Second the re 550-1-6.

the affect'on thermal stresses.If the imposed stiffness creates an'over-d load on the U-Bolt.

stressed condition or the lateral load on the U-Bolt excee s the vendor's allowable than a modification to the supportIf n Note: That there will be requested.

U-Bolt will be deemed not to be a problem.is no concern o The U-Bolt will since if it exceeds the vendor's allowable.

yield and the resulting displacements are accounted for in th piping analysis since seismically the piping is f ree to move.

dld Also note that the reason the lateral stif fness is not mo e will automatically result in a lateral load not pre Our purpose identified in the previous designed analysis.

f '~

with this procedure is to check the adequacy and af f ect o the the existing design not present new design conditions to

/

support vendors.

,r

. i In closing an effort should be made to minimize any changes in In each instance where it is necessary U-Bolt Design hardware.

to proceed to Step-III above, both the job engineer and group

.This procedure is effective supervisor should be consulted.Past future ccrrective items will be closed out immediately.

the job engineer in his-review.

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UPSET (B)

+3:is

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EMERGE? ICY (C) / -FAULTED (D)

+ 3co90_ _

"l:0R"Al OPERAT11;G MODE" DISPLACEMENTS AX= f,s7p AY= -, gik A Z= f, i

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%. 2, ATTACfEENT C TEXAS UTILITIES l-s.

SERVICES INC.

REv.

Issu,_E DATc PAGE ENGNEERING GUIDELNE TITLE COVER SHEET !

[emvlco.Hf-82.l l OF 0

("

FOR Section II GUIDELINE General Engineering REVIS!ONS

[.

Criteria For Pipe Stepport Design PSE PROJ. ENGR.

f I. INSTRUCTIONS FOR FILING GUIDELINE PAGES 1.

Remove Section II in its entirety and replace with the enclosed revised Section 11, pages 1 through 15.

2.

Place this cover sheet in front of page 1, Rev. 2 of Section II.

(

II. STATUS OF GUIDELINE PAGES PAGE REV DAGE REV PAGE REV PAGE REV PAGE REV PAGE REV 1

2 15 0

2 2

3 2

4 2

5 2

6 2

7 2

8 2

9 2

10 2

l 11 2

12 2

13 2

s.'

14 2

t s

31

= - -

Page 2 of 15 Rev. 2 SECTION II

(-

2.2 (Continued)

Clearances-required to allow the pipe to move in the unrestrained direction should be 1/2" over the calculated movement or 1",

whichever is greater.

In certain limited space configurations, where thermal growth is small, lesser clearances may be acceptable.

2.3 DEFLECTION Effective at the issue date of' this Section, the maximum allowable support deflection, at the point and in the direction of load application is 1/16" (0.063".) with level "B" loads. See Section XVIII for Class I.

There is no deflection criteria for unrestrained (friction) loads.

2.4 DESIGN TEMPERATURE See Section III for allowable material properties at different Q.

design temperatures.

2.5 BASE PLATES Refer to Section IV for base plate design criteria. Random bolt patterns may be qualified using the ITT Grinnell base plate program or by sending off-site for finite element analysis.

Hand calculations incorporating plate flexibility, bi-axial stress and prying action considerations may also be used. However, this is not recommended due to the complexity and time required to perform a hand analysis.

Base plate material is available in SA'-36 or SA-515, GR.65.

SA-36 is more abundant and should be the first choice.

2.6 HILTI CONCRETE ANCHOR BOLTS Refer to Section V for available sizes, and allowable loads.

s

i i

ATTACHMENT D

.I TEXAS UTILITIES SERVICES INC.

R EV-issg SAGE CAh ENGWEERING GU10ELNE TITLE COVER SHEET 1

(f.J.f&

1 OF 7 FOR APPROVED

• I sEcTION III GUIDELINE g', U y' NPSI and Irr-Grinnell Load REVISIONS

+^ / N Capacity Data Sheets /

g Certified Design Report PSE PROJ. ENGR.

Summaries I. INSTRUCTIONS FOR FILING GUIDELINE PAGES

_'i." "id_d'__H.__e.'e._n~clbsed 'pigh' 68 f,' Rev. ' l.

~ "

~~ ^ ~ ' ' ' ~ ~

=

2.~ 'Remise~tWexis't'iHfcoiieF sheets, page 1"thrT2 7.-'Rev. O and

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replace ultft 'thiiiEcI6seTeiver sheets, pages T thrd' 7, Rev.1.

~~iOTE: diiTievisio'n' addid page58' AZ.- Vi~ dor jiage numbers have

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-not been changed ~a~nd consequently 'tiop~ age numbers usually

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i IE. STATUS OF GUIDELINE PAGES PAGE REV PAGE REV PAGE REV PAGE REV PAGE REV PAGE REV 1

2 11 B

21 N/A 31 0

41 0

51 0

2 N/A 12 B

22 0

32 0

42 0

52 0

3 N/A 13 B

23 0

33 0

43 0

53 "O

4 0

14 B

24 0

34 0

44 0

54 0

5 0

15 N/A 25.

0 35 0

45 0

55 0

6 0

16 N/A 26 0

36.

'O 46 0

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7 0

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9 N/A 19 N/A 29 0

39 0

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1 10 N/A 20 N/A 30 0

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i-Produe: Na=e/?ar Code Material Lead Capaci / a. 6500 ? (1bs..;

5pec-Type Des:.p Level 0 l

Size Code ifica-Grade Level A Level C

(?tr Ap-l U-Belt Standard / PUS tic =

Class Level 3 cendix Tl 1/2 004 SA36(1) 485 645 906 3/4 l 006 l l

l 485 l 645 l

906 l

1 l 010 l l

l 485 l 645 l

906 l 1220 l 1620 l

2220 l

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1 1/2 j 015 l l

l 1220 l 1620 l

2230 l

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2 l020 l l

l 1220 l 1620 l

2230 l

"B l 2260 l 3000 l

a225 l

l 21/2 l 025 l l

l 2260 l 3000 l

A225 l

3 l030 l l

l 2260 l 2000 l

4799 l

31/2l035 l l

l ??60 l 3000 l

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l l 2260 l 3000 l

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5 050 l l

l 3620 l 4815 6770 l

6 060 l

l 3620 l 4815 l

6770 I

8 l080 l 5420 l 7200 l

10100 l

10 100 l

l 7540 l 10030

.l 14100 12 120 l 7540 l 10030 l

14100 Y

14 C 140 l l

Dil2?C.T:cN CP 16 160 l l 7540 l 10030 l

14100 l

l VG7~ / ' ' #

18 l180 l l 9920 l 13200 l

18500 l

l l 9920 l 13200 l

18500 l

20 200 l

(Nola:eraiload) l 9920 l13200 l

18500 I

24 240 l 99?O I13200 l

18500 l

30 1 300 l

l1enn0 le oon I se:en I

16 360 l w-(1) Nu s: 5A-307 GR B or A-307 Gr. A (per cede cases 16L4-5, 164A-6, N71-7, N71-8, N71-9, N-249-0)

(2) This is a non-welded item

1. "" "'"*a..,

This Cer.1fied Desi p Reper: Sc==ary has been ;repared by NFS f *8,t k..").hl' y,4* ;j^/ k.\\k*.,' Q and MC C...:penen: suppcrts designed by analysis in c=:11ance " th

1. k Industries, in ac: rdance with ASMI See:1= I-, Subparag-aph NCA-YCluE 3551.1, code Case N-247 and is applica 1e ter Code Classes 1,2,3

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P Secticn Pr.~2ucts ccvered by this Cert:.fied Desip Repert Su=.ar/ are included in of N?S Industries' Cataleg Product Name/Part Code Material Lead capacity at 6500T (its.)

Spec-Type Desip Level D Size Code ifica-Grade Level A Level C

( Fer Ap-U-Bolt Standards / PUS tien Class Level B cendix F) 205 1/2 004 SA36(1) 1to

, en l

85 l

115 l

160 3/4 006 l

l 95 l

130 1

1 010 vn l 185 l

250 l

3a:

1 1/c l 012 U

l 215 l

300' l Mn 1 1/2 l 015 l l 130 l

175 245 2

020 l

g l 250 l.335 470 l

, -NECIWd 2 1/9 n,c 4

I ene l

275 l

385 it.7524.:.-

3 010 180 240 340 L8MT 3 1/2 035 160 215 l

300 4

040 130 l

175 l

245 5

050 1

(No Vertical load) l 210 l

200 l

395 6

060 l 165 l

220 l

31n 8

080 225 l

100 aen 10 100 U

~~~

12 120 300 A00 275 365 l

14 l 140 i

l 240 l

320 450 16 160 l

l 320 l

425 l

600 18 180 1

l 255 l

380 1

35 20 l 200 l

l 210 l

320 I

350 24 l 240 l l

l 190 l

255 l

255 30 300 l l 310 l

415 l

550 l

36 l 360 l v

l (1) Nuts: SA-307 GR.B or A-307 GR.A (per Code Case 1644-5, 1644-6, N71-7, N71-8, N71-9, N-249-0) l (2) This is a non welded item.

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This Certified Desip Repcrt Su:=ary has been prepared by NFS

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A Industries, in accordance with ASF.. Secticn I;;, Su:parag a;n NCA-

/kd* Cfd.b"'*g'+E/ k'Q i

2551.1, code case N-267 and is applicable fer Code Classes 1,2,3

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and MC Compenent supper:s desiped by analysis in compliance with

• W *.% 1-i Subsection NF, Article 3000, 1976 Editien anc aise all accenca

$M thru 1980 Edi-'-7, 5* ' 80 Adcenca.

ne A;;11ca::,e Desig:f Spec:.fi '

a 5* ;A.* !..!..L*..***,.. T-g.,Cien j5d ca:icn (N?SS 5H76 and Desip 3e;:r: (N?S-R PUS are na.n.ained

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'h Err UNITED STATES OF AMERICA O"IC NUCLEAR REGULATORY COMMISSION 24 Al :07 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

}{

.l E '. 5 !

4 "1

}{

TEXAS UTILITIES ELECTRIC

}{

Docket Nos. 50-445-1 COMPANY, et al.

}{

and 50-446-1 (Comanche Peak Steam Electric

}{

Station, Units 1 and 2)

}{

CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Answer to Applicants' Motion for Summary Disposition of CASE's Allegations Regarding U-Bolts Acting As Two-Way Restraints have been sent to the names listed below this 20th day of August 198_4,

by:- Express Mail where indicated by

• and First. Class Mail elsewhere.

• Administrative Judge Peter B. Bloch

• Nicholas S. Reynolds, Esq.

U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor

& Reynolds Bethesda, Maryland 20R14 1200 - 17th St., N. W.

Washington, D.C.

20036

• Ms. Ellen Ginsberg, Law Clerk U. S. Nuclear Regulatory Commission

• Geary S. Mizuno, Esq.

4350 East / West Highwsy, 4th Floor Office of Executive Legal Bethesda, Maryland 20814 Director U. S. Nuclear Regulatory

• Dr. Kenneth A. McCollom, Dean Commission Division of Engineering, Maryland National Bank Bldg.

Architecture and Technology

- Room 10105 Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland 20814

• Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board panel Oak Ridge, Tennessee 37830.

U..S. Nuclear Regulatory Commission Washington, D. C.

20555 i

1 e

e

c dho Chairman

.Renea Ricks, Esq.

Atomic Safety and Licensing Appeal; Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C.

20555 Austin, Texas 78711 John Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Lanny A. Sinkin 114 W. 7th, Suite 220 Austin, Texas 78701 Dr. David H. Boltz 2012' S. Polk Dallas, Texas 75224 Michael D. Spence, President Texas Utilities Generating Company Skyway Tower 400 North Olive St., L.B. 81 Dallas, Texas 75201 Docketing and Service Section (3 copies)

Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C.

20555 L t.A-1 *. s g(s.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 p

2

_____ _ _ _ _.. _ _ _ - - - -.