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Category:AFFIDAVITS
MONTHYEARML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20086Q3931991-12-26026 December 1991 Affidavit of Case President J Ellis.* Affidavit of Case President J Ellis Re Motion for Leave to File Response to Portions of Motion of R Micky & Dow to Reopen Record. W/Certificate of Svc ML20154G7841988-09-0909 September 1988 Affidavit of Jj Macktal Re Oppressive Terms of Settlement Agreement for Addl Safety Concerns.Related Info Encl ML20207E6061988-08-12012 August 1988 Affidavit of B Brink.* Discusses Concern Re Operation of Plant.W/Supporting Documentation & Certificate of Svc ML20207E5941988-08-0505 August 1988 Affidavit of K Mccook.* Discusses Concerns Re Operations of Plant.Unexecuted Affidavit of P Reznikoff Encl ML19325D6431988-07-12012 July 1988 Affidavit of B Brink.* Expresses Concern That Operation of Plant Will Cause Loss of Health to Author & Family & Safety Problems at Plant Will Jeopardize Life & Property ML19325D6461988-07-12012 July 1988 Affidavit of L Burnam.* Expresses Concern That Operation of Plant Will Cause Loss of Health to Author & Family & Safety Problems at Plant Will Jeopardize Life & Property.W/ Certificate of Svc ML19325D6401988-07-12012 July 1988 Affidavit of P Reznikoff.* Expresses Concern Re Danger to Health & Safety Posed by Normal Operations of Plant & by Possible Accidents ML20197E3011988-05-23023 May 1988 Affidavit of JW Muffett.* Encl Review Issues Lists (Rils) on Pipe Stress & Pipe Supports Document That All Issues Closed by Cygna.Job Responsibilities of JW Muffett Stated. W/O Rils.W/Certificate of Svc ML20154E5391988-05-13013 May 1988 Affidavit of Ha Levin.* Related Documentation Encl ML20154E5281988-05-0606 May 1988 Affidavit of RP Klause.* Discusses Design Validation & for Large & Small Bore Piping Supports at Plant During Preparation of Project Status Repts.Author Statement of Training & Experience Encl ML20196B0751988-02-0101 February 1988 Affidavit of Rd Pollard Re Environ Qualification of RG-59 Coaxial Cable ML20236X2501987-12-0202 December 1987 Affidavit of Dn Chapman.* Discusses Mgt Analysis Co Audit Rept ML20236E0481987-10-23023 October 1987 Affidavit of Bp Garde in Support of Motion for Reconsideration.* ML20236E7501987-07-23023 July 1987 Affidavit of Jt Merritt.* Affidavit Discusses Mgt Analysis Co Audit Repts.Related Correspondence ML20236E7411987-07-22022 July 1987 Affidavit of JB George.* Affidavit Discusses Mgt Analysis Co Audit Repts.Related Correspondence ML20236E7551987-07-22022 July 1987 Affidavit of Eg Gibson.* Affidavit Discusses Mgt Analysis Co Audit Rept.Related Correspondence ML20211D0591987-02-11011 February 1987 Affidavit of Eh Johnson.* Responds to Statements in Case Motion Re Trend Analyses or Trend Repts.Trend Analyses & Repts Incorporated Into SALP Repts in 1980.Certificate of Svc Encl ML20212E8631986-12-26026 December 1986 Affidavit of Case Witness J Doyle Re Case 861230 Partial Response to Applicants 861201 Response to Board Concerns.* Certificate of Svc Encl ML20211J4721986-11-0101 November 1986 Affidavit of J Doyle Re Scope of Cygna Role.Supporting Documentation Encl ML20211J4141986-10-28028 October 1986 Affidavit of DC Garlington Re Irregularities in Plant Const or Operations Noticed During Site Visits.Emergency Lights Not Aimed & Locked & Trash in Diesel Room Noted in Monitoring Repts.W/Certificate of Svc ML20211J3551986-10-0303 October 1986 Affidavit of MD Nozette Re Events Concerning Participation as co-owner of Plant Between Nov 1984 & Feb 1985.Discusses Util Failure to Answer Questions Posed in Re Participation in Project ML20214L6911986-08-18018 August 1986 Affidavit of Tg Tyler Supporting Applicant Response to a Palmer Affidavit Re Case 860731 Response to Applicant 860716 Motion for Protective Order & Motion to Compel.W/ Certificate of Svc ML20214M4271986-08-0505 August 1986 Joint Affidavit of D Lurie & E Marinos Clarifying 860404 Joint Affidavit on Statistical Inferences from Comanche Peak Review Team Sampling ML20207E3071986-07-16016 July 1986 Affidavit of Le Powell on 860716 Re Estimate of Time & Effort Required to Prepare Responses to Questions 4-7 of M Gregory Set One Discovery Requests.Related Correspondence ML20207F7741986-07-16016 July 1986 Affidavit of Le Powell Re Discovery in CP Extension Proceeding.W/Certificate of Svc ML20197C1301986-05-0606 May 1986 Affidavit of M Walsh,Advising That Statistical Sampling Being Performed & Proposed for Facility Inappropriate. Applicant Reliance on Statistical Sample Will Not Identify Problems W/Pipe Supports.Certificate of Svc Encl ML20197C1051986-04-26026 April 1986 Affidavit of J Doyle,Addressing Applicability of Statistical Sampling to Facility ML20155A6851986-04-0404 April 1986 Joint Affidavit of D Lurie & E Marinos Re Board Concerns on Statistical Inferences from Comanche Peak Review Team Sampling.Certificate of Svc Encl ML20138B1711986-03-13013 March 1986 Affidavit of SD Mckay Re Likelihood of Reactor Coolant Pump Restart Due to Operator Error W/No Occurrence of Inadequate Cooling Event.Prof Qualifications & Certificate of Svc Encl ML20138B1071986-03-12012 March 1986 Affidavit of CE Mccracken Re Core Flow Blockage Due to Fine Paint Particles ML20138B1431986-03-12012 March 1986 Affidavit of B Mann Re Treatment of Operator Error in Licensing Process & Likelihood of Reactor Coolant Pump Restart During Inadequate Core Cooling Event.Prof Qualifications Encl ML20215E7171986-01-27027 January 1986 Partially Withheld Affidavit Re Allegations Concerning Drug Use & Distribution ML20138P5551985-12-14014 December 1985 Affidavit of Jj Doyle in Response to Applicant Changes to 1984 Motions for Summary Disposition ML20137X1831985-12-0505 December 1985 Affidavit of R Mcgrane Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits Only Recent Awareness of Rept.Related Correspondence ML20137X0201985-12-0505 December 1985 Affidavit of Dh Wade Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge of Rept Prior to May or June 1985.Related Correspondence ML20137W9971985-12-0404 December 1985 Affidavit of Nh Williams Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge of Rept Prior to 850625.Related Correspondence ML20137X2101985-12-0303 December 1985 Affidavit of R Siever Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits Awareness of Audit & Rept Preparation Through General Onsite Conversation in 1985.Related Correspondence ML20137X0881985-12-0202 December 1985 Affidavit of Rc Iotti Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge Apart from News Publicity & ASLB Documents in mid-1985.Related Correspondence ML20137X1291985-12-0202 December 1985 Affidavit of G Krishnan Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits General Awareness of Discovery Process Re 1980 Licensing Proceedings.Related Correspondence ML20137X0601985-12-0202 December 1985 Affidavit of Jc Finneran Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge Apart from News Publicity & General Onsite Conversations Earlier in 1985.Related Correspondence ML20137X1611985-12-0202 December 1985 Affidavit of P Chang Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge of Rept Prior to mid-1985.Related Correspondence ML20205H4071985-11-12012 November 1985 Affidavit of Rc Iotti & Jc Finneran Re Corrections & Clarifications to Affidavits Supporting Motions for Summary Disposition of Pipe Support Design Allegations. Supporting Documentation Encl.Related Correspondence ML20205H3501985-11-12012 November 1985 Affidavit of Rc Iotti & Jc Finneran in Response to ASLB Request for Info Re Variation of Field Configurations of Pipe Supports Utilizing clinched-down U-bolts.Related Correspondence ML20133F8221985-09-0909 September 1985 Affidavit of Aw Serkiz Providing Explanation Re Sser 9, App L,Per ASLB 850918 Memorandum.Certificate of Svc Encl ML20133F8161985-09-0909 September 1985 Affidavit of CE Mccracken Providing Further Explanation of Background of Sser 9,App L,Per ASLB 850918 Memorandum 1994-09-19
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION C:u;4 c.Cur BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i 85 %
In the Matter of l Docket Nos. 50-445 "
IS A!0 3 i and 50-446 TEXAS UTILITIES ELECTRIC l EFFicr ,.
COMPANY, et al. i 'S M , JE'
. 1 (Application for an W*'
(Comanche Peak Steam Electric 1 Operating License)
Station, Units 1 and 2) {
CASE'S 4TH MOTION FOR
SUMMARY
DISPOSITION TO DIS 0UALIFY THE USE OF SA307 AND SA36 THREADED PARTS AFFIDAVIT OF CASE WITNESS JACK D0YLE Q: Do you have any concern over the use of SA36 steel as bolting material?
.A: I certainly do.
Q: What is your major concern in this regard?
A: Applicants have introduced a novel design feature, violating the provisions'of 10 CFR 50.34(a)(2), identification in the PSAR of unusual or novel design features and (8) identification of those structures requiring research and development to confirm the adequacy of their design.
10 CFR 50.34(a)(2) and (8) state:
"(a) Preliminary safety analysis report. Each application for a
-construction permit shall include a preliminary safety analysis report. The minimum information-to be included shall consist of the following:
"(2)'A summary description and discussion of the facility, with special attention to design and operating characteristics, unusual or novel design features, and principal safety considerations." (Emphases added.)
O h 0
a
"(8) An identification of those structures, systems, or components of the facility, if any, which require research and development to confirm the adequacy of their design; and identification and description of the research and development program which will be conducted to resolve any safety questions associated with such structures, systems or components; and a schedule of the research and development program showing that such safety questions will be resolved at or before the latest date stated in the application for completion of construction of the facility." (Emphases added.)
Q: What points would you like to make?
A: First, a little background is necessary. For two and a half years, Mark Walsh and I have been pointing out that A307 steel is not to be used for seismic loads (friction joints). In this argument we were backed up by, among other sources, the ASME Code. This code, at section III, Appendix XVII, Table XVII 2461.1-1, Note 1 (see CASE Exhibit 752, copy of which is attached) states, regarding friction type connections loaded in shear, as used by Applicants for cinched-up U-bolts and to a minor degree for bolts in Richmond connections:
" Friction type connections loaded in shear are not permitted."
The reason for this is the unpredictability of this material for-dynamic loads, and the prohibition for'use of this material by ASME is
-in compliance with the requirements of 10 CFR Part 50, Criterion II.
Applicants, on'the other hand, have been arguing that the threaded material being used was A36 steel and therefore not a subject of Note 1
- of the above table (see, for example, Affidavit of Robert C. Iotti and John C. Finneran, Jr. Regarding Board' Request for Information Concerning A36 and A307 Steel, attached to Applicants' 12/5/84 Response to Board Memorandum "Information on Composition of A36 and A307 Steel,"
at pages 2~and 3, copy attached).
2 1
4 Applicants' principle argument consisted of the fact that the
-testing of the materials was not the same. They state that SA36 steel required both a test for minimum yield point and a test for ultimate tensile strength, while SA307 required only a test for ultimate tensile strength /1/. According to Applicants, the bolting material used at CPSES also has no defined yield point, as was proved by their test program (see Vivirito at Tr. page 6556, cop; attached.)
Applicants have never argued that there is a chemical difference in the two materials, and there is not /2/. Their only argument is fl/ In Applicants' Affidavit, Messrs. Finneran and Iotti refer to certain requirements that are necessary for determining relaxation. In the CMTR (Certified Mill Test Report), no reference is ever made to
~
relaxation for A36 or A307 or A50 or any of the other common mild steels used in construction.
'The studies on relaxation are aside from mill tests and have in_the.
past been performed, to the best of my knowledge, only for steels 'used in bolting friction joints (for example, A325 and A490 high-strength steels, etc.). In these cases, studies have shown that pre-torqued bolts which are torqued to 70% of ultimate will relax to approximately 1/2 of the proof. load, which is the principle involved in satisfying the predictability of these joints for dynamic applications. The CMTR inclusion of the yield strength (approximate) is not required for-determining bolt relaxation, since this is-determined by tests and the application of safety factors.
The' Applicants are well awareLof this, as may be noted from their statement in answer to questions by the NRC Staff of the meetings of 8/8/84 and.8/9/84 on page I where they state:
Section A, U-Bolt Cinching, (see attached copy), page 1:
"a. There is scant, if any, data available on' strain relaxation
- n properties of SA36 material."'
f2/ Again the Applicants are. attempting to misrepresent the facts.
Applicants are well' aware that for the material being discussed (for example . U-bolts which are bent unheaded threaded rods and unheaded.
anchor bolts), the material referred to as SA-307 is in fact SA-36_
material, as may be noted from the following documents supplied by Applicants (attached to Applicants' 1/7/84 Motion for Reconsideration of . Licensing; Board's Memorandum (Reopening Discovery; Misleading Statement): .(continued on next page) 3 N w
r-
'that the tests for yield are not required to be performed on the A307 steel. The difference in the materials generally (threaded materials notwithstanding) involves only one fact and that is, for A36 the
-approximate yield is known (when you have mill testing) and for A307 it is not. The fact that both have a yield point is not in question. ,
1 As far as Applicants' testing of the bolt material, the testing was performed to show that the bolts could take a certain static load.
. f2/ (continued from preceding page):
In Attachment B (see copy _ attached), which is in reference to ASTM A307 at Note 1.3, the following code statement is made:
"Nonheaded anchor bolts, either straight or bent,.to be used for structural anchorage purposes, shall conform to the requirements of Specification A 36 with tension tests to be made on the bolt body or on the bar stock used for making the anchor bolts."
(Underscored on the copy-supplied by Applicants.)
Attachment D (see copy attached), which is the ASME specification SA-307: at section 1.3, the code referenced is almost identical to the s ASTM 307' specification quoted above:
"Nonheaded anchor bolts, either straight or bent, to be used for structural-anchorage purposes, shall conform to the requirements
" of ASTM Specification A 36, for Structural Steel, with tension teste to'be made on the bolt body or on the bar stock used for making the anchor bolts."
'From the above-quoted code provisions from both the ASTM for commercial use or the ASME for nuclear power plants, there is no doubt that SA-307 and A-36 are' identical, since the SA-307 for the bolts under discussionuis made-from A-36. Therefore, the following statement
-by Applicants is a gross misrepresentation of the facts (page 3 of the Affidavit of Robert C. Iotti and John C. Finneran, Jr. Regarding Board
^
Request for Information Concerning A36 and A307 Steel, attached to Applicants' 12/5/84 Response to Board Memorandum (Information on Composition of A36_and~A307 Steel); see attached copy):
"In summary, it is not appropriate, therefore, to interchange the two steels as CASE has done."
~(NOTE BY' CASE:
'The preceding footnote 2 was added at the request of Mr. Doyle by telephone after he had received a copy of the Applicants' 1/7/84 (sic; should be 1/7/85) Motion for Reconsideration of Licensing-Board's Memorandum (Reopening Discovery; Misleading Statement).)
4 7
L
m b
The test did not show whether the joints could sustain seismic loads nor what effect the non-friction joint would have on the dynamics of the system itself (see, for instance, NRC Staff Witness Dr. Chen at Tr. page 6546 (copy attached), where he states that tests for one-time loads are not applicable to cyclic loading.) Therefore, without accurate dynamic tests for both the bolt material and the infrastructural effects (pipe stress analysis, for example),
Applicants are using a bolting material which is only qualified for static loads. These joints present an unknown quantity as relates to the dynamics of the total system and are therefore not in compliance with 10 CFR Part 50, Appendix A, Criteria I and II.
Q: For these reasons, therefore, do you believe that the bolting materials used at CPSES are in noncompliance with the law?
A: For the above reasons, yes. However, these arguments are really academic when one looks to the codes.
. Q: What do you mean by this?
A: To all but somewhat knowledgeable persons involved in engineering, it was obvious.that to cope with dynamic loads, the joints must be predictable; that is, slippage must be a controlled criteria. With the
'introduction of dynamic analysis by Structural Engineers and Architects of California (SEAOC) for structures in California (which is often used as a guide in other seismically active areas), the-AISC in the latest revision of their code, effective November 1978, codified their position on bolting uaterials. And in this, they have prohibited the e
5
r-use of bolts and threaded materials made of SA307 and A36 steels (among other materials) subjected to other than static loads. See Table 1.5.2.1, Threaded Parts, AISC 8th Edition, page 5-24 (copy of which is attached). The only bolting materials commonly used for dynamic loading conditions are A325 and A490.
0: But isn't it true that Applicants are only committed to the 7th Edition, and the statements being made are from the 8th Edition?
A: That is true, but the logic which required the change existed even prior to the 7th Edition if you were doing dynamic analysis.
Therefore, the exclusion of these materials for nuclear power plants dynamically analyzed is required under the provisions of 10 CFR Part 50, Appendix A,-Criterion I. Additionally, the provisions of ASME,Section III, Appendix XVII, Table XVII-2461.1-1, Note 1, still apply (see Board's 12/28/83 Memorandum and Order (Quality Assurance for Design), at pages 27 and 28).
During the time prior to the 8th Edition, the AISC Code addresses
' loading in terms of static application; that is, even for structures which included earthquake considerations, the earthquake load was assumed to be an equivalent static horizontal load based on KCZW (dynamic derivation of loads was not utilized). In the case of nuclear power plants, the earthquake loads are based on the response spectra and damping factors, in which case the predictability of the joint is required. Otherwise, both the response spectra and the damping factors are also-unpredictable.
6
Beyond this, Applicants have apparently amended their FSAR to include both the 7th and 6th Editions of the AISC Code (see Transcript of meeting between Cygna Energy Services and the NRC Technical Review Team, 12/20/84, page 80: lines 6 through 9, copy attached.)
0: Is that all that you have to say on this matter?
A: No,'I would like to make one final point. If you build the perfect nuclear structure, perfect piping systems, and perfect pipe supports, and then you connect these items with unpredictable bolting materials, you have a total system which is no longer perfect as independent components and which is now, as a system, unpredictable; and all of the semantics, all of the legal loopholes, or all of the deceptive verbage will not alter this fact.
CPSES is less qualified for dynamic events than a California factory designed under SEAOC and, as a result, the health and safety of the public is in jeopardy.
Q: What must Applicants do if they cannot use A307 or A36 steel for bolted connections?
A: They have to establish a friction joint, to start with, with materials which are acceptable under dynamic loading conditions, to at least-bring the plant up to the same level of quality as a California pig sty.
< 7 b
r ,
- s I have read the foregoing affidavit, which was prepared under my personal direction, and it is true and correct to the best of my knowledge and belief.
[ & _- AMh Dat R / / , ,rr y STATE OF SM tt 0 COUNTY OF 40b On this, the 3 / day of M2/haba ,198_k, personally appeared lh('l( 7 DO\/LE
, known to me to be the person
( l' (
whose name is subscr)ibed to the foregoing instrument, and acknowledged to iue that'he/she executed the same for the purposes therein expressed.
Subscribed and sworn before me on theb day of famdu ,
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VNotaryVI((lkJ Publif D-4 ip ay(d LU M for4E, the State of
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l_ My Commission Expires: ( /fLf S / #ldb
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