ML20113B616
| ML20113B616 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/14/1985 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20113B579 | List: |
| References | |
| OL, NUDOCS 8501220044 | |
| Download: ML20113B616 (13) | |
Text
,
1/14/85
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
~ 'i Er BEFORE THE ATOMIC SAFETY AND LICENSING BOARD E
m, In the Matter of l
Docket Nos. 50-445 /\\ / 3 Al();p I
and 50-446L/C TEXAS UTILITIES ELECTRIC I
COMPANY, et al.
i l
(Application for an (Comanche Peak Steam Electric I
Operating License)
Station, Units 1 and 2) i CASE'S 4TH MOTION FOR
SUMMARY
DISPOSITION:
TO DISOUALIFY THE USE OF SA307 AND SA36 THREADED PARTS Pursuant to 10 CFR 2.749, CASE (Citizens Association for Sound Energy),
.Intervenor herein, files this, its 4th Motion for Summary Disposition: To Disqualify the Use of SA307 and SA36 Threaded Parts.
For the past two and a half years, CASE Witnesses Mark Walsh and Jack Doyle have argued that A307 steel is not to be used for seismic loads (friction joints). Applicants have used A307 material (which is equivalent to, and made from, A36 material) for cinched-down U-bolts and for balts in Richmond connections at Comanche Peak. The use ~of this material has been sufficiently widespread to make it more appealing financially for the Applicants to attempt to litigate the problem away than'to go back and properly correct it.
Applicants have attempted,.by a variety of means (including statements
. deliberately designed to mislead the Board) to prove that their misbegotten design - although clearly contrary to recognized. authorities and applicable codes to which Applicants are committed - is acceptable. "It is becoming more and more obvious, however, that Applicants' efforts have been i
h1h O
._ G L
l, unsuccessful. Two and a half years after we began, the Board's initial impressions as discussed in its 12/28/83 Order are still valid. Applicants' statements (like Alice in Wonderland) get " curiouser and curiouser." They are sinking further and further into a quagmire of contradictory sworn testimony and representations of counsel which have been deliberately misleading, perhaps constituting material false statements and even obstruction of justice. Additional information regarding this aspect will be discussed further in other pleadings.
It appears to CASE, however, that the time is ripe for the Board to make a determination regarding one underlying issue in this regard: whether or not Applicants can properly use A307 material (which is equivalent to, and made from, A36 material) for cinched-down U-bolts and for bolts in Richmond connections in the manner currently utilized at Comanche Peak.
It is this question which is at issue in CASE's 4th Motion for Summary Disposition.
The ASME Code to which Applicants are committed, 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) prohibits the use of this material in this manner (ASNE Section III, Appendix XVII, Table
' XVII 2461.1-1, Note 1 (see CASE Exhibit 752, copy of which is attached; see also attached Affidavit _of CASE Witness Jack Doyle, at page 2).
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.
(See attached Doyle Affidavit, page 2.)
2
The Board stated, in its 12/28/83 Memorandum and Order (Quality Assurance for Design) (pages 27 and 28):
"We agree with CASE that 'the mere fact that a friction on a point of a U-bolt exists does not indicate that the friction is sufficient to prevent rotation under the most adverse design conditions.
.' /72/.
We have no analyses before us that establish the adequacy of the friction forces developed by a cinched-down U-bolt.
Furthermore, the applicant uses SA-307 steel in U-bolts.
This material has nct design allowable under the applicable American Society of Mechanical Engineers Boiler and Presssure Vessel Code (ASME Code) provisions /73/ when it is used in a friction type connection /74. The reason there is no allowable for friction type connections using SA-307 steel is explained in note 1 to the applicable table. The note /75/ states:
"' Friction type connections loaded in shear are not permitted.
The amount of clamping force developed by SA-307 bolts is unpredictable and generally insufficient to prevent complete slippage.'
"This argument did not confuse the Board, differentiating us from applicant /76/. We were persuaded by this rather straightforward argument that SA-307 bolts cannot be relied on in a U-bolt to cinch down a pipe and prevent its rotation by the use of friction /77/. The fact that this material was incorporated into the U-bolts is not surprising, since they were not initially designed to be cinched down and to develop friction forces to hold the pipe. What appears to have I
happened, according to this information, is that applicant's engineers have adopted an impermissible fix for a stability problem that was identified by Mr. Walsh and Mr. Doyle.
"/72/
CASE Findings at III-7.
"/73/
Conformance to the July 1974 and winter 1974 Addenda Editions of the ASME Boiler and Pressure Vessel Code (ASME Code) is mandatory.
See Section 3.2.2 of the applicant's FSAR and paragraph 3.2.2 of the Safety Evaluation Report for Comanche Peak (September 3, 1974).
"/74/
CASE Exhibit 752 contains page 387 of Appendix XVII of the ASME Code. That page contains a table concerning ' Allowable Bolt Tension and Shear Stresses.'
"/75/
- g. at 388.
"/76/
Applicant's Reply at 15 found this argument confusing.
"/77/
We also accept Mr. Doyle's testimony that the thermal expansionlof pipes will cause cinched-up U-bolts to yield so 3
1 that, after many cycles of heating and cooling, the frictional forces generated by the U-bolts will be reduced.
CASE Exhibit 763 at 13-14, citing CASE Exhibit 669B (Doyle) at 318-321."
And the Board further stated, on page 33:
i "We did find a design problem, however, with respect to one aspect of
' instability:
the use of SA-307 Steel in friction connections. We conclude from the evidence that this is a design error, in contradiction to the ASME Code. Applicant has not demonstrated the l
validity of cinching of U-bolts made of SA-307 steel as an adequate
-design correction for the purpose of preventing rotation."
In Applicants' 1/17/84 Motion for Reconsideration of Memorandum at*
Order (Quality Assurance for Design), Applicants stated (page 28):
"... the Board-should reconsider its finding that Applicants use SA-
.307 steel in U-bolts (Memorandum and Order at 27). To the contrary,-
. Applicants do not use that material in U-bolts. Rather, Applicants use SA-36 material for U-bolts. This fact is established (at least with respect to NPSI) by the load data sheets in CASE Exhibit 669B, pages 13K-13R. We bring this to the Board's attention only for the sake of accuracy,'however, in that SA-36 and SA-307 materials have equivalent material properties.
"More important, however, we note that the limitation on the use of this material in bolted conttections in Appendix XVII is~ applicable to
-normal bolted construction, not pipe clamp attachments employing U-bolts, contrary to the Board's conclusion (Memorandum and Order at 27)..
Specifically,-the limitation applies to friction connections using bolts in which the friction forces. developed.betwe.en connected members
- by the preloading of the bolts are intended to' resist the full in-line stress. carried by-the connected members, as,1escribed in ASME Code.
Section XVII-2462.1.'131/.
"/31/
Two examples of the type of bolted connections which are used as friction-type connections sre illustrated in Code' Figure XVII-2330-1; Items 8 and 9.
We note these figures.only for references of the type of connections involved, recognizing that the Code section in which Figure XVII-3230-1 is included is'not applicable-to the questions at issue here."
In itsl2/8/84' Memorandum and Order (Reconsideration Concerning Quality Assurance for De' sign)', the Board stated (page 22):
"We accept Applicant's clarificatio-that it uses SA-36 steel in U-
~
bolts, rather than'the equivalent Sa-307 steel we said it used /34/.
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However, we decline to rule on Applicant's new argument concerning the interpretation of ASME Code Section XVII-2462,1.31.
In particular, we do not know whether the quoted section applies by analogy to the use of SA-36 steel to produce clamping forces that will restraint rotation of a pipe /35/ and we have no evidence either about how great those clamping forces are or how great they need to be.
"/34/
Applicant's Reconsideration at 28.
However, the label attached to this steel does not seem to be significant since the different labels apparently refere to the same material applied to different uses.
See CASES (sic) Answer at Doyle Affidavit, p. 4.
"/35/
Although his statement is not yet in evidence, Mr. Doyle believes that ASME XVII-2462 applies and that Applicant is not in compliance with it.
CASE's Answer at Doyle Affidavit,
- p. 4.
This matter may be litigated."
Recently, Applicants have been arguing that the threaded material being used was A36 steel and therefore not a subject of Note 1 of ASME Table XVII 2462.1-1.
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, where Messrs. Iotti and Finneran state:
"0. -Are SA36 and SA307 steels the same material?
"A.
No.
CASE incorrectly asserts that these materials are the same
/1/. -Although it is true that SA36 and SA307 materials-are similar, there is a major dif ference in the specified mechanical requirements for SA36 and SA307 steels. As Applicants explained in our affidavit in support of Applicants' reply to CASE's answer to Applicants' motion for summary disposition regarding the effects of gaps (October 26, 1984) at 8-9, the material specification for SA36 requires both a test for ultimate tensile strength and a test for minimum yield point, whereas the SA307 specification requires only a tensile test (ultimate tensile strength). Thus, unlike SA36, there is no established basis for determining certain characteristics, including relaxation, of components using SA307 material.
In summary, it is not appropriate, therefore, to interchange the two steels as CASE has done.
(See Memorandum at 1 '... variability in A36 (A307) steel
'.)"
(Emphasis added.)
5
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"/1/ CASE's Answer to Applicants' Statement of Material Facts Relating to Richmond Inserts, Walsh Affidavit (September 10, 1984) at 10.
i The memorandum cited by CASE (CASE Exhibit 834) is not correct in referring to the tested materials as SA307. SA36 and SA307 rods 4
are both used in some structural applications not involving pipe supports.= The individual [who was employed by Applicants) who prepared that memorandum (who commonly works with those other applications) apparently did not focus on the distinction when he prepared the memorandum."
Applicants' principle argument consisted of the fact that the testing of the materials was not the same. They stated 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, copy attached; see also attached Doyle Affidavit at page 3).
Applicants have never before argued (until their 1/7/85 Motion for Reconsideration of Licensing Board's Memorandum (Reopening Discovery; g
Misleading Statement) that there is a chemical difference in the two materials, and there is not. 'In their statements at the last paragraph on page 5 through page18 of the Affidavit of Robert C. Iotti.'and John C.
Finneran, Jr. Regarding the Licensing Board's December 18,-1984 Memorandum, Applicants are again 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
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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 Memorandu'm (Reopening-
,[1/ In Applicants' Affidavit, Messrs. Finneran and Iotti refer to certain-requirements that are necessary for determining relaxation.
See discussion at footnote 1,'page 3, of attached Doyle Affidavit. This will also be discussed in more detail elsewhere.
6
. Discovery; Misleading Statement).
(See attached Doyle Affidavit at pages 3 and 4, Footnote 2.)
In Attachment B to Applicants' pleading (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 to Applicants' pleading (see copy attached), which is the ASME specification SA-307: at section 1.3, the code referenced is almost identical to the 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 tests 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 discussion is 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; set also attached Doyle Affidavit at pages 3 and 4, Footnote 2):
"In summary, it is not appropriate, therefore, to interchange the two steels as CASE has done."
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Applicants' only argument is that the tests for yield are not required to be performed on the A307 steel. The difference in the materials generally 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.
(See attached Doyle Affidavit at pages 3 and 4.)
As tar as Applicants' testing of the bolt material, the testing was performed to show that the bolts could take a certain static load. 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.
(See Doyle Affidavit at pages 4 and 5.)
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 I
)
8 m_
l
other seismically active areas), the AISC in the latest revision of their
- code, effective November 1978, codified their position on bolting materials.
And in this, they have prohibited the 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.
(See attached Doyle Affidavit at pages 5 and 6.)
Although in-the past Applicants were only committed to the 7th Edition of the ASTM Manual of Steel Construction, and the preceding paragraph was in reference to statements from the 8th Edition, 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, Criterioa 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.
(See attached Doyle Affidavit at page 6.)
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-Eloads are based on the response spectra and damping factors, in which case 9
4 L_ _
the predictability of the joint is required. Otherwise, both the response spectra and the damping factors are also unpredictable.
(See attached Doyle Affidavit at page 6.)
Beyond this, Applicants have apparently amended their FSAR to include both the 7th and 8th 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; see also attached Doyle Affidavit at page 6).
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.
(See attached Doyle Affidavit at page 7.)
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.
(See attached Doyle Affidavit at page 7.)
If Applicants cannot use A307 or A36 steel for bolted connections, they have to establish a f riction 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.
(See attached Doyle Affidavit at page 7.)
~
In addition to the preceding, Applicants have introduced a novel design feature, violating the provisions of 10 CFR 50.34(a)(2), identification in 10
/
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.
(See attached Doyle Affidavit at pages 1 and 2.)
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.)
"(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.)
It is also noteworthy that documents introduced by Applicants themselves support CASE's position.
In addition to Attachments B and D (discussed on page 7 preceding), Applicants'also attached one page (268) from a document by Messrs. Rice and Hoffman to their 5/18/84 Motion for Summary Disposition Regarding the Effects of Gaps on Structural Behavior Under Seismic Loading Conditions.
In that very article (pages 264 through 271 of which were included as Attachment A to the Affidavit of CASE Witness Mark Walsh, attached to CASE's 8/13/84 Answer to Applicants' Motion for Summary Disposition Regarding the Effects of Gaps on Structural Behavior Under Seismic Loading Conditions), Messrs. Rice and Hoffman -- whom 11
~.
Applicants apparently consider to be authorities -- indicate that A307 bolts are not permitted in connections subject to vibration, such as those at Comanche Peak.
(See attached pages 2 through 5 of Affidavit of CASE Witness Mark Walsh, and Attachment A thereto, pages 264 through 271 of the Rice /Hoffman text.) (Obviously, CASE does not agree with Applicants' 10/26/84 Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding the Effects of Gaps, pages 5 through 8; the Board will have to decide upon the meaning of the documents question.)
Applicants did not comply with NRC regulations with regard to stating irl advance that they intended to utilize They stated that they would comply with certain codes and standards. Applicants have clearly violated NRC regulations, their own commitments in their specifications and FSAR.
It is not sufficient now for them to attempt to go back and justify
-- after the fact -- what they have already done.
For the preceding reasons, CASE moves that the Board find that Applicants are in violation of:
NRC regulations, including but not limited to 10 CFR 50.34(a)(2) and (8); 10 CFR Part 50, Criteria 1 and II; ASME Code,Section III, Appendix XVII, Table XVII 2461.1-1, Note 1; ASME specification SA-307, section 1.3; ASTM A307 specification, Note 1.3; AISC 8th Edition, Table 1.5.2.1.; and standard industry practice.
12
4 In addition, the Board should rule favorably on each of CASE's attached Statement of Material Facts As To Which There Is No Genuine Issue.
Respectfully submitted, ww,% >
[99.L>
(My'e'.) Juanita Ellis, President
~
,GSE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 Y
k 4
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