ML20138P555
| ML20138P555 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/14/1985 |
| From: | Doyle J Citizens Association for Sound Energy |
| To: | |
| Shared Package | |
| ML20138P551 | List: |
| References | |
| OL, NUDOCS 8512260164 | |
| Download: ML20138P555 (110) | |
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UNITED STATES OF AMERICA MJCLEAR REGULATORY COM4ISSION BEORE THE AT0i4IC SAFETY AND LICENSING BOARD
- h.[
In the Matter of l
Docket Ng 50-445 TEXAS UTILITIES ELECTRIC COMPANY, et al.
, 7 n.
(Applicatjoniforlan/g",
(Comanche Peak Steam Electric Operating License)
Station, Units 1 and 2) n AFFIDAVIT OF CASE WITNESS JACK D0YLE in Response to Applicants' Changas h Affidavi;s Attached to Their 1984 Motions for Summary Disposition A.
HISTORY OF ALLEGATIONS l '.
General Positions in the Hearings The first point to be made is critical to the understanding of the problems involved in these hearings, and that point is: Unit I was complete and ready for fuel loading in the Spring of 1983 in the opinion of Applicants.
This point was driven home on the last day of the September 1982 hearings by the Applicants, with strong support from the NRC Staff.
See Tr. 5409, where NRC Staff counsel Mr. Mizuno made the point that the testimony was sufficient to address the concerns of Messrs. Doyle and Walsh; Tr. 5410-5411, where Applicants' counsel, Mr. Reynolds, commented that an initial decision could be made on the current record, with Mr. Mizuno concurring at Tr. 5411/11-15; and at Tr. 5412/4-7, Mr. Mizuno added that the Staff planned no further direct testimony on what have come to be called the 8512260164 8512 PDR ADOCK 050 45 1
pg Q
- 2 Walsh/Doyle allegations; finally, at Tr. 5416/11-25, Mr. Reynolds stated again that the ' record was sufficient. Applicants concluded this because they assumed that they had developed a strong position based on two factors:
(1) the allegations submitted were without merit in their opinion out-of-hand; and (2) Applicants, among other factors, had relied on engineering judgement and what they alleged to be standard industry practice.
2.
The NRC Staf f's Position The report of the NRC Staff's Special Inspection Team (SIT) position (Inspection Report 82-26/82-14, NRC Staff Exhibit 207, bound in preceding Tr. 6290), signed in February 1983, concurred in the Applicants' assessment of the plant and particularly. CASE's allegations when, in the first paragraph on page 7 of the S1T Report, it states in general that of 19 areas of concern raised by CASE,12 had no merit, 6 others were at leart partially known to Applicants due to the Applicants' design review process and had been or were (at that time) being rectified. (As we all know, the NRC Staff reversed themselves at a later point on the fact that the six others mentioned above were at least partially known to Applicants due to their design review process.) One allegation relating to the bending of the bolt for Richmond inserts was in part confirmed, but the NRC added the caveat in the last sentence of paragraph 1 "... the Special* Inspection Team considers the stresses involved are unlikely to lead to bolt f ailure."
The NRC Staff at this point (February 1983) and later during the May 1983 hearings argued vigorously in support of Applicants' position, and in fact committed themselves to the premise that CPSES was designed properlyt 2
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"... the Special Inspection Team did not: find any violations of any NRC regulations" (see SIT Report, page 2, at.Results, item 1).
SIT went one step further and' stated that.they had performed an inspection of 100 vendor
- certified supports for 15 design attributes which would be indicative of the problems alleged by Messrs. Walsh and Doyle. The purpose of this review was to determine whether design deficiencies had survived the Applicants' Iterative design review process. The review did not disclose any discrepancies ~which would indicate a failuia of Applicants' design verification progree to-identify and correct supports to assure compliance wih Applicants' design criteria (see SIT Report, page 58).
3.
Overall Positions From the above, there is no doubt regarding the positions of the various parties in these hearings. At that point in time, we had:
(a) The Applicants' position was that the plant was essentially completed with only the review process to be completed, which would result in only minor corrections, most,of which were assumed to be paper corrections.
(b) The Staff's position was that the allegations were insignificant or without merit and the Applicants' design of the plant was in compliance with the intent of the Atomic Energy Act, the Codes, the law, and good engineering practice.
(c) CASE's position was that the facility had many design errors, calculational errors, and code noncompliances.
In fact, the design was effectively indeterminate.
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The status of the licensing hearings
' At that point. in time a controversy existed and that concroversy was:
CASE believed the plant was indeterminate vs. Applicants and NRC Staff assuming the plant was well designed and proceeding effectively. The hearing process would now progress to dstermine which position was correct.
5.
My personal position By the way of. reiterating my position on the controversy as it stood at that point in time as well as as it stands today, the key words are
" compliance" and " Indeterminate." It has always been my position that the design calculations have been grossly deficient, which results in hardware that is indeterminate. That is, we don't know whether or not it will fall and, if so, which ones will fall or not. By failure, I have always meant 1
fall to meet criteria or good engineering practice. For example, see Tr.
pages 154 through 156 of the 3/23/85 meeting with the NRC Staff which was a
' feedback discussion where I stated that I know a structure can be overstressed without falling down; see also page 169 of same meeting; see also my affidavit attached to CASE's 10/6/84 First Motion for Summary Disposition, top of page 62. Beyond that, regardless of what methodology Applicants offer to justify such supports, whether it be exaggerated allowables, industry standards, or what other reduction factors are used, the fact remains that the codes and provisions of 10 CFR have been and are being violated.
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d 6.
Board Order The Board on December 28, 1983, issued a Memorandum and Order (Quality Assurance for Design) which effectively indicated, in part, that the Applicants had failed to support their position that the supports in question were in compliance with 10 CFR and offered the Applicants a second bite at the apple to prove that the supports were designed properly.
7.
The purpose of the Board Order While the Board did make several suggestions, there was no purpose stated in the Board Order that would suggest that Applicants could rewrite standard engineering procedures, the codes, or the law to bend the designs
' into qualifying to criteria which did not previously exist, nor will these new-found aventies of justification apply to future faci.'.ities, nuclear or otherwise.
8.
Applicants' choice for complying with Board Order In answer to the Board's 12/28/83 Memorandus, the Applicants chose three approaches: First, ther retained Cygna Energy Services to perform an independent assessment; secord, the filing of a series of Motions for Summary Disposition; and third, Applicants committed to retain the services of an independent expert f'.on the academic community to review the basic engineering principles to be addressed in the Plan.tnd to provide testimony to the Board. /1/.
ft/ See Applicants' 2/3/84 Plan to Respond to Memorandum and Order (Quality Assurance for Design); 2/24/84 Tr. pages 10,337/14-10,340/9 (with clarification by Judge Bloch regarding 10,340/3); 3/13/84 Supplement to Applicants' Plan to Resp'nd to Memorandum and Order (Quality Assurance for Design); Licensing Board's 6/29/84 Memorandum and Order (Written-Filing Decisions, #1...); etc.
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'9.
The purpose of Applicants' summary disposition motions The purpose of Applicants' Motions for Summary Disposition was two-fold, and was stated by Applicants; for example, at page 10 of the 9/28/84 Applicants' Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Local Displacements and Stresses, the Applicants state "The Board should find... that Applicants' practice is appropriate and based on sound engineering principles." The general concluding statement more often used by Applicants is as follows: "For the foregoing reasons, Applicants' Motion for Summary Disposition should be granted." The inference being again that the foregoing reasons indicate that the practice in the discussion is appropriate and based on sound engineering principles.
Itimust be pointed out that since Applicants originally based qualification on assumptions without calculations, no sound basis existed.
J They are, by use of tests and extravagant mathematical procedures, trying to qualify after the fact while stating that this after-the-fact material was common knowledge all along (by inference), because anyone in their engineering department could write off the problem based on his engineering judgement, which would have required precise knowledge of the results for all of the tests and finite element programs which were forthcoming, including the highly theoretical exercise through academia utillzed to qualify the upper lateral restraint beam that is designed so close to the rasor's edge that the biological shield is jeopardized.
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GEMEAL DISCUSSION OF COMENTS OF APPLICAMS' SUIGIARY DISPOSITIONS
- 10..For this Board to find for Applicants, the evidence by Applicants would have to prove conclusively that under the most, adverse loading conditions regardless of gecnetry of the support, no probability of overstress would exist within the guidance of applicable codes and laws, and indeed, this is what Applicants claim (see Applicants' Motion for Summary Disposition, for instance, Regarding Consideration of Local Displacements and Stresses where, at page 4, they state:
" Applicants' pipe support designs fully satisfy applicable stress allowables even when these effects are included in the design.").
As discussed in detail later herein, in their Summary Dispositions, and most importantly, in their latest affidavit to correct those Summary Dispositions /2,/, Applicants constantly refer to the fact that while an Aten does not conform to the allowable loads, it is of no significance since the ites will still perform its intended function. On this point, Applicants are not only wrong, they are in violation of 10 CFR Part 50, Appendix B, III. Design Control, the first paragraph of which states:
" Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in paragraph 50.2 and as specifiel in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions."
/2/
11/12/85 Af fidavit of John C. Finneran, Jr. and Robert C. Iotti Regarding Corrections and Clarifications to Affidavits Supporting Motions for Summary Disposition of Pipe Support Design Allegations 7
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At-10 CFR 50.2 it states, in part, at (u):
' "' Design bases' means that laformation which identifies the specific function to be performed by a structure, system, or component of a facility, and the specific values or ranges of values chosen for controlling paraseters as reference bounds for design."
In addition, when one wishes to utillae load rating as a means of leproving the posture as relates to allowables, it is permissible to resort'to testing and use the load rating provisions of the ASME code; however, ASME, ASTM and other procedures must be utillsed to determine the range of allowables relative to the loading conditions under consideration.
For example, see ASME Section III, Sub-section NF., paragraph 3260 Design by Load Rating, et seq., wherein the procedures are established for determining allowables based on test loads vs. the load service cases.
It will be noted from the several paragraphs. involved that neither load ratings j
nor indeed any other procedure which has been codified allows the use of I
ultimate results of testing as a caveat for negating the exceeding of i
allowables at the various service conditions.
4 The\\ acts are that under load rating, the test load at termination of f
the test will be subject to factoring as follows:
(1) A reduction of the test load of 10% in the event that the number i
of tests is not statistically significant (see NF 3261).
(2) A further factor is required relative to the tolerance found in standard manufactured elements and that is the ratio of the i
nominal physical dimension of the parts as sold to the actual dimension as tested.
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.(3) The multiplication of these factors times the test load will result in an approved working ultimate load.
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It must be noted that this value is an ultimate, just as vas the guaranteed ultimate by the manufacturer or the alli prior to the test. To determine allowables for the various types of items under the various service loads, this test load (ultimate) must be f actored as noted in NF 3262.2 for plates and shells, NF 3262.3 for linear type supports, and NF 3262.4 for component standard supports. From compliance with these three sections of ASME, one would now have allowable loads for the four cases involved in the design of a nuclear power plant; that is. Case A, normal; Case B, upsett Case C, emergency; and Case D, faulted.
In the case of the U-bolts, for example, if we assume for now that the dimensions of the tested bolts were nominal dimensions, the portion of the test load available for allowable load at Levels A and B is about 20% of the test load. This follows because NT 3262.4 (7) and (8) sets the limits
'for Levels A and B at test load times 5 or Fa/Su where S = 12.6 kol per Table 1-7.1 of ASME Appendix 1 and Su = 58 kel.
Including the 10% reduction for statistically indeterminate samples,. the code allowable would equal.9 (12.6/58) x test ' load or about 20% of what the test load reveals. The fact that a test specimen may still be accepting loads at a stress level of 75 kai has no bearing on what the functional capability of subsequent or in fact prior specimens are capable uf sustaining until the test load is properly factored to arrive at allowable loads. For ASME citations, see Attachments B and C hereto.
Having complied with the above and in possession of the new allowables rationally and correctly obtained, these and only these allowables may be used to qualify the component of concern. What the level of ultimate load 9
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would have been is irrelevant. In short, to quellfy a support, one may only compare the actual stresses at a particular service'1oad to the acceptable allowable for that service load. The Applicants have utilised testing as a means of quellfying questionable supports which were designed without analysis of certain attributes. The Applicants have never developed acceptable allowables for the type of supports and service loads of concern.
Therefore, Applicants cannot use the range of the test load to indicate that while a particular item does not meet the allowable load under normal analytical procedures, it will still perform its intended function.
This criterion, allowables based on load levels, would be required because the Applicants perform no calculations to determine the adequacy relative to the condition alleged, but rather accepted qualification on the basis of engineering judgement and alleged Industry practice.
In this regard, in reference to engineering judgement, Cygna Energy Services' John Ward (the former Chief Executive Officer of Cygna) stated it best at Tr.
9395, when he defined engineering judgement as being limited to "where the effects are minor."
C.
C0lffgifr$ OF APPLICAlffS' NEW AFFIDAVIT
- 11. Pre 1Leinary Statements As to the contents of Applicants' new affidavit, I note a statement on page 3 that I must admit I find it hard to conceive of Applicants making in view of the remainder of the contents of Applicants' affidavit. The statement I refer to is as follows:
"In fact, a large portion of this affidavit consists of material or expansion of material previously 10
u transaltted to CASE and the Staff." The material referred to was, for the main part, the result of the NRC Staff's positions presented at the January, February,-and March 23, 1985' meetings, the draft by Teledyne, and the latest position of Cygna (at that time). The fact that letters were transmitted is of minor significance. The latest position of Applicants in the record prior to the filing of this affidavit was that no problems existed and that any changes being made to suports during the reinspection were being done merely for expediency,-and this f act was made public in the Dallas / Fort Worth metroplex newspapers by Applicants.
12 I next address the statement on page 4 of the affidavit, particularly starting at line 13, which states as follows:
"We remain satisfied that the conclusions and opinions expressed in our affidavits were reasonable, and at most subject to
-differing professional opinions which would be expected in any highly technical field."
When engineering judgement or industry practice are used as a means of quellfying engineering which is for nuclear plant components, there is no margin for dissenting opinion. And by the way, this is also true for engineering of normal commercial buildings. The statement is therefore a contradiction of sound engineering fundamentals.
13, A statement on page 5 deserves comment, starting on line 15:
2 "However, we recognise that other issues regarding the adequacy of the piping systems, and by definition the supports associated therewith, were raised subsequent to the filing of the notions which could have af fected the analyses of the supports presented in the affidavit (e.gg, by changes in loads, or direction and degree of piping movements)."
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6 These facts were raised prior to the filing of the motions, in fact months before the motion of consequence was flied and was partially the result'of the Cygas review insofar as mass participation / mass spacing were f
concerned, and by CASE as far as additlocal masses on the piping from supports themselves. Applicants were well aware of these and other
-questions for many months before the filing of the actions for summary disposition.
The adrent of these questions was no shock to CASE since on many occasions I stated that because of the problems I found in the pipe supports, we had doubts concerning areas other than the pipe supports.
It must also be pointed out that the shortcomings discussed in this affidavit are based on specific allegations alone, not the collective effects which have always been a primary concern of CASE in these hearings.
So, even though some of the supports may survive on a case-by-case basis analysed against a specific allegation, they could still f all under the scrutiny of the collective effects.
'14.
The last. sentence on page 5 deserves at least some consideration.
Applicants' statement is as follows:
"For these reasons the ultimate determination regarding the adequacy of, piping and supports at Comanche Peak is best resolved in the context of the comprehensive Stone and Webster review, where all outstanding issues can be addressed cumulatively."
This statement is misleading because it presupposes that if Stone &
Webster redesigns a support, the controversy over the original support is somehow negated. On the issue of the original allegations, I believe we are entitled to a determination on the merits of the two positions in 12
10 controversy, since Applicants' own CPRT Plan precludes any effective evaluation because the main thrust of Applicants' Plan involves the evaluation for " safety significant deficiencies" and by Applicants'
' thinking, items not conforming to codes, laws, regulations, etc., are not safety significant deficiencies so long as they can perform (in Applicants' opinion) their intended function-(see Section B, pages 90 and 91 of 180, 3.4, VII.b.1, Item 2, of November 22, 1985, letter from Applicants' Mr.
Couns11 to NRC Staff's Mr. Noonan, Re Response to NRC Staff Evaluation of the Comanche Peak Response Team Program Plan). While two questions were asked by the NRC, one in reference to significant design discrepancy and the other in reference to construction items.-Applicants only answered relative to construction deficiencies and we must assume that they both have the same meaning in Applicants' view.
"... Is a deviation in construction of an item which, if uncorrected, would result in the loss of capability of the affected ites, structure, or component to perform its intended function."
However, in reference to CPRT Attachment 3.0, Appendix E, Pages 2 and 3 of 19, the following definition appears at B.1.(e), which defines under DE11GN ADgQUACY:
"' Safety-eignificant', for purposes of the CPRT Prograe [ Footnote omitted), is defined to mean that the identified discrepancy, if uncorrected, would result in the loss of capability to the affected system, structure or component to perform its intended safety function. For purposes of the CPRT Program, credit is not allowed for redundancy at the component, systes, train or structure level."
What Applicants are describing when they make these types of excuses is survivability at the faulted levels.
If this were an acceptable procedure under the codes and the laws, there would be no necessity to check for 13
Levels A, B, or C.
If it would survive faulted conditions (Level D), it obviously would at least survive any lesser condition.
In addition, the importance of the compliance with the codes was best stated by Mr. Terso of the NRC Staff; see quotation at page 4 of CASE's 2/4/85 Motion for Reconsideration of Licensing Board's 6/29/84 Memorandum and Order (Written-Filing Decisions, #1: Some AWS/ASME Issues), where he stated:
"It may be a closed issue from the Cygna standpoint but we are still left with a violation of the code and a violation of the code is important in its own right, because it contributes to the worker's understanding of the extent to which codes are to be followed scrupulously and taken seriously." (Emphases added.)
It must be noted that 10 CFR 50.2,10 CFR Part 50, Appendix B, ASME Section III, the AISC, not'to mentjon Applicants' FSAR, all intended the purpose for any structure is to function within predictable limits depending on the load case under consideration (for example: load cases A/B, normal and upset; C, emergency; and D, faulted).
Therefore, first we must discu.. the original allegations and the interpretation by the Licensing Board as to whether such allegations were with or without merit. Then, as a new phase in the procedure, we may discuss the terits of corrective actions by Stone & Webster.
To avoid a strike-out in these hearings, Applicants have rewritten the rules for the game and in effect have stacked the deck in their f avor. They would now like to put blinders on the Board.
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D.
ANSWERS TO SPECIFIC MOTIONS FOR SUletARY DISPOSITION 15.
Stability of Pipe Supports The first ites discussed by Applicants (affidavit at page 7) is in reference to their motion on stability (see Affidavit of John C. Finneran, Jr. Regarding Stability of Pipe Supports (June 17, 1984)). Before moving forward, I must point out that the original instability problem which I described in my deposition / testimony (CASE Exhibits 669 and 6698 -- see below) and during the September 1982 hearings involved both U-bolt and box structures attached to double pin ended struts (see CASE Exhibit 669 att page 95, line 25, through page 96, line 23; page 97, line 5, through page 101, line 15; page 103, line 15, through page 105; see also CASE Exhibit 669B: items 41, 4J. 4M, 4N, 4P 40, 4S and 4T, among others). The Applicants finally took corrective action on this problem, without ever admitting, however, that the problem existed. So the problems being discussed in Applicants' affidavit are more relative to stability fixes than stability H.E..' *.*
The Applicants, in quoting why the NPC did not accept Mr. Finneran's statement (" Affidavit at page 7" shown on page 8) only references the NRC comments as pages 33-36 and generally as follows: "The Staff stated that piping engineers should assure synten stability by reviewing the piping and support configurations."
Of more consequence than an NRC desire is what was stated by the NRC Staff's Mr. Termo during the 3/23/85 meeting at Tr. page 25, lines 17-22, which wast "The Applicant referenced the ASME code, Subsection NF, Appendix l
XVII, Paragraph XVII-2221(a) which states, quote, 15 i
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"' General stability shall be provided for the structure as a whole and for each compression element.'
"end. quote."
This section of the code states that not only must a system be stable, each support must also be stable (not necessarily by itself but when considered as a compression element of the system). The main objection of the PRC Staff to the Applicants' stance involves the following statement which appears on page 31, line 24 through page 32, line 4, of the 3/23/85 meeting where Mr. Terso stated:
"The Staf f's concerns stem from the f act that many of the pipe support designs at Comanche Peak represent either an unconventional application of the component standard supports which have not previously been proven to be acceptable, or the use of unconventional support designs."
In addition, the following statement offers some insight into why the c
NRC Staff has adopted its position (see pages 35 and 36 of 3/23/85 meeting):
"The Staff finds that unstable pipe support designs at Comanche peak do not conform to standard industry practice; that is, the unstable designs are unconventional designs."
Then at lines 22-25 (same source):
"Thus, the Staff finds the Applicants' discussion of industry practice for stability and piping and pipe support designs is irrelevlant."
This statement is also not included in Applicants' affidavit.
From page 44, lines 15-18, Mr. Terso continues:
"In fact, that was one of our conclusions, is that the design review required under ANSI N45.2.11 was really not suf ficient to catch those kind (sic) of unstable characteristics."
Another quote by Mr. Termo which was overlooked by Applicants is from page 44, lines 19-23:
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"It is very unique to Com.anche Peak, and it's very difficult in
'p this nuclear industry to have someone look at a support characteristic that no one else has ever looked at before. So it is a very difficult thing to catch."
0n page 9 of the affidavit, Applicants again state that my concerns about stability have somehow been minlaised because I didn't bring it to the attention of the specific members of Applicants' staff.
I will say again, I brought my concerns up with my lamediate supervisor (in fact, two of my j
lamediate supervisors when you include his successor), another person who i
-had at least some type of authority (a Mr. Kerlin, who if he was not i
responsible for individuals had at least some type of responsibility in the reviewing process). Beyond this, I brought it up with my supervisor's manager. With all the negative responses. I could see no use pursuing the natter all the way to the office of Mr. Spence, since normal protocol dictates that you do not go over your bosses' heads.
Moving on to the conclusion (affidavit at page 12), Applicants states l
" Applicants agree with the NRC Staff's assessment that there is j
not necessarily a safety concern regarding the stability of the j
verlous' supports discussed in the affidavit."
i What the NRC states is that only if the position of the clamp can be-l assured can they accept the analysis for the support; see t.ffidavic at 7, last paragraph, where Applicants quote Mr. Terso l
"... we are saying that if the support does not have a positive l
controlled clasping mechanism to assure that the support cannot slide _or rotate along the pipes, then we have difficulty accepting l
the analysis for that support because of the uncertainties Involved in that design."
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It is not a carte blanche blessing of this unique design, which is, by its unapproved introduction, In violation of 10 CFR 50.34 (a)(2) and (8).
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The stability allegation as originally structured, when considered in the light of the Cygna, NRC Staff,.Teledyne, and CASE positions,-was not in compliance with 10 CFR 50.34 (a)(2) or (8) which states, respectively, that Applicants' Preliminary Safety Analysis Report'was to have contained:
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"A summary description and discussion of the facility, with special attention to desian and operating characteristics, unusual or novel desian features, and principal safety considerations." (Esphases added.)
"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... "
Beyond this, the above provisions of 10 CFR 50.34 would obviously apply to any fix proposed for such novel, unique or unusual structure. This point will become more obvious below. While Applicants have never seen fit to concede that there was a problem with the original configuration for these supports, such lack of responsible action does not preclude the fact that the original design falls within the NRC classification of unconventional designs. In addition, I doubt if any person now involved in these hearings would suggest that the supports regarding which there were allegations in the 1982 hearings were anything other than non-supports.
- 16. U-bolts Acting as Two-Way Constraints Applicants correct the statement in reference to gaps for U-bolts (page 12 of affidavit). This is a simple catalog item which required first grade 18
O arithmetic to determine the proper dimensions.
I as therefore amazed that p took the Applicants so long to detect their obvious error.
I also note that Applicants-fall to cite from the 3/23/85 meeting;
. however, I shall make up for their lack of attention to small facts. At page 97,-lines 3-6, of the 3/23/85 transcript NRC Staff's Mr. Fair statest
'The bottom line concluilon that I had out of this at this point-is that the Applicants originally had no basis for making the assumption that these U-bolts provided no lateral support."
.On page 13, lines 6-17, Applicants discuss thermal movement as the criteria for further consideration of the potential for lateral constraint.
This factor was never considered by the engineer who designed the original
. support nor would this have been possible without knowing the potential tolerance due to installation which could result in as little as no clearance. For exemple, see NRC Staff's Mr. Fair at page 96, lines 7-13 of the 3/23/85 trancript where he concluded that Applicant is incorrect in assuming a gap existed, based on his personal measurements in the field.
Proceeding on this premise that it has been proven that a zero gap was probable, all U-bolts of this type required evaluation by the analyst since two-way constraint has now been shown to have been a definite probable condition.
As a final thought on thermal movement, Applicants would have the Board believe that if the computer lists a thermal movement of 1/16", the movement is set in granite and will be no more or no less. The fact is the only time the thermal movement can be stated with any degree of accuracy is after start-up under the various combinations of thermal loadings by physically
- measuring the thermal movement. And even then ten years later you may not get the same readings under the same thermal conditions.
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The fact that actual movements are an unknown quantity may be noted in Applicants' own affidavit at page 5, lines 18 through 23, where they state:
"... which could have affected the analyses of the supports presented in the affidavits (e.g.., by changes in loads, or direction and degree of piping movements).
(See draft Staff letter presented in the February 26, 1985, meeting, regarding need to include assessment of mass participation and mass point spacing effects.)"
Here we have Applicants admitting that the thermal movements and direction are dependent on the input and I am quite sure that Applicants would concede that all factors which affect thermal movement are not included in the computer input (building thermal movement, for example), and therefore one would be foolish to stake his life on either the direction or magnitude of thermal movements which are the result of the computer output.
The computer merely indicates the expected movement relative to tne parameters and geometry which are input, and in the case of CPSES (as mentioned above) does not compensate for building thermal movements.
In other words, there is no thermal differential (building / pipe) movement considered.
Unfortunately, to complete my analysis of Applicants on stability, it is required to study Applicants' new position on cinched-up U-bolts which will be covered later when I discuss Applicants' position in the chronology established in their Affidavit.
On pages 14 and 15 of the AffJdavit, Applicants found that with 1/32" gap for pipe sizes 3" and 4",
the number of supports requiring further evaluation was raised from 8 to 22, which translates into 29% of the total number, which is 76 supports. And this number is using allowables established by Applicants' rules (with which I do not agree).
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.r On page 16, second paragraph, Applicants discuss the fact that they learned of at least one U-bolt with no clearance, but claim that it doesn't L
matter since the analysis for that support assumed zero-inch clearance and therefore at worst the analysis was nonconservative.
i Bowever,~ Applicants forget that they only considered for reevaluation those supports which have a thermal plus seismic movement in excess of the theoretical gap.
If there is no gap, then any thermal plus seismic movement affects'tha support. Additionally, the engineer originally assumed no load in the lateral direction with no concept.of the magnitude of such load if sero-inch gap existed. This can only be determined by complex and time-consuming methodology of computer analysis, as Applicants have proven in their motion for summary disposition. It must be noted that for the support
. movements such determination has been made by computer.
For another maneuver by Applicants, see Applicants' affidavit at page 13, lines 13 through 16, where they stated:
"Further, consistent with our original commitment, U-bolts in 3 sad 4-inch lines where the thermal movement exceeded 1/32" should also have been candidates for removal."
I don't know how Applicants can explain how they determined that all U-bolts had a 1/16" clearance unless they are so set on justification that once they think they have the answer, no further investigation is attempted.
On page 17 of their affidavit, last paragraph, Applicants stated:
"It is evident from the results obtained in the analyses presented in the affidavit that some lateral loads are not auch smaller than the rated load. They are, nevertheless, small enough that
. the safety factor as adequate margins of safety exist.
determined by ITT Grinnell vould range from 2.78 (emergency) to 3.70 (normal / upset). Further, even if allowance is made for the fact that actual material properties employed in the ITTG tests are higher than minimum material properties, the safety factors would still be in excess of 3.0 for normal / upset and 2.2 for acergency."
f 21
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m.
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m
~m-2 Applicants are not being explicit in this statement. The support is overloaded to the 1982 and indeed the current (a year after testing) manufacturer's advertised allowable.
s The fact that these are much higher allowables than are standardly accepted may be noted in the 3/23/85 meeting, where NRC Staff's Mr. Fair at page 96, lines 2-6, stated:
"Now, in order to make this conclusion, the Applicants had to do some actual physical testing of a couple of U-bolts to come up with a load rated allowable that was higher than the original manufacturer's allowable."
It must be recs 11ed that the original acceptance of these supports was
' assumed to be based on the original lower allowables, not based on a 4
clairvoyant knowledge by each of the designers that new higher allowables were forthcoming.
On page 18 of Applicants' af fidavit, first paragraph, Applicants state as follows:
"It should be noted that the U-bolts in the field had material properties greater than the minimum and comparable to the material used in the tests..."
This statement is beyond belief, since this is a conserical item which is warehoused, and the only justification that the material is above minimum can be based on the mill report which involves the properties of the particular heat. There are two problems with the mill report:
One is that the alli report does not go with each U-bolt throughout its course from initial manufacturing to final installation. The user generally telles on 1
the manuf acturer's load data sheet for qualification of these off-the-shelf items. Therefore, the precise physical properties of the U-bolts which are I
22
o-
.m installed at Comanche Peak can only be stated to have material properties at
~
least to the guaranteed limit. The second problem may be noted in the fact th' t the actual physical properties are not normally reflected in the mill a
report. Another point may be noted in the fact that the yield of the material as reflected in the mill report is not the lower yield value which is of interest to the engineer, but is rather,the upper yield limit which results from high speed testing for production items. See, for example, CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations),Section I, Page.I-10, last full paragraph.
It must be known to Applicants that of the hundreds of thousands of U-bolts made by NPSI and ITT Grinnell, the variation in material properties and also physical properties. covers a wide range and for any individual U-4 bolt precise properties are unknown. All that can be stated with any degree of accuracy. is that the material properties are at least equal to the
' advertised minimums at the upper yield point and the physical properties due
~
to mill tolerance is unknown. The only way to determine both properties precisely is to' test for mechanical properties and determine dimensions by field measurements for each U-bolt in the plant.
The final paragraph on page 18 of Applicants' affidavit is a statement of an error in the strain listed in the original affidavit.
It is appalling to note the errors incorporated in Applicants' original' affidavit material which was submitted to convince the Board that Applicants don't make mistakes.
Applicants' conclusions are a contradiction of facts. The purpose af the affidavit accompanying the motion for summary disposition was to prove 23
to the Board that the use by Applicants' engineering staff of engineering judgement for determining consequences of lateral loads on U-bolts installed as one-way supports was acceptable. Instead, Applicants actually proved F
that-if the original allowable listed by the manufacturer is used, a substantial number. of this type of support would fail. And the only way to qualify these supports was to increase the allowable substantially and in addition neglect the effects of friction caused by pipe axial movement.
And even at this, they couldn't get all of the supports to work.
In addition, the last statement in the conclusion by Applicants would indicate that at least one support will fall to qualify even at Applicants' generous allowables. However, Applicants are not supplying an answer to this question but are deferring to Stone & Webster which will, no doubt, change the support in the name of " expediency." The fact that this support is doomed is preordained, since the U-bolt must constrain an 18" diameter pipe against almost 5/16" (.305) displacement.
As shown above, for engineers to attempt to outguess a computer's
' output based on the same information available to the engineer and the computer is not.only imprudent, it-is outright stupid. To understand the preceding, a computer is essentially a high-speed moron; it can only manipulate the information input. The computer per jgt does not make errors; i
the computer operator may. But as we have seen in the past in these
- hearings, the engineers (particularly at CPSES) are highly susceptible to
- error.
. Applicants, in their summary disposition and specifically in their 4
current affidavit, have proven this by showing that by their own numbers 24
e.
almost 30% of the supports of this type may fall to qualify as functional.
The fact that Applicants identify questionable supports (to say the least) confirms CASE's position that failure to analyze these types of supports for
'this type of loading means that ea'ch support was in fact indeterminate.
17.
Applicants on friction Stsrting on page 19 of Applicants' affidavit, they attempt to justify the statement "... when friction and the normal load are combined the stress ratio actually drops from the.775 calculated for friction alone to.46."
Applicants' main premise for assuming the correctness of their
~
assumption is that the base plate is finished to bear. They base this on (again) what the code does not state (see Applicants' affidavit, page 20 at lines 2 through 15, and footnote 10). Applicants state (item (2) on page 20, lines 15 and 16) that this short member was saw cut leaving it plane.
The question I have in reference to this statement is: plane what? saw cut?
Finally, on page 20 at item (4), Applicants state that weld spatter
-will fill in any gaps. To this, I state that relying on weld spatter which is literally absent in the work of qualified welders is a sad commentary on the limits Applicants will go to to salvage the unsalvagable. The AISC 8th Edition has this to say at 1.5.1.5.1:
. accurately sawed or cut to a true plane by any suitable means." The key word is " accurately," which is defined in the American Standard Dictionary, Second College Edition, Houghton & Mifflin Company of Boston, " accurately, adverb, 1. In exact 25
.v.
j conformity to fact; errorless.
- 2. deviating only slightly or within acceptable limits from a standard."' With this definition, a procedure must
~
be established for those specific supports which require a finished to bear joint.. Such joint cannot be created after the " fact by decree. Also, Applicants do not state what provisions were provided to determine standard mill tolerances, for example, plate flatness, plate camber, etc.
I also note in Applicants' statement that they again overlook the 3/23/85 transcript; however, I shall assist them..For this particular oversight, see NRC Staff's Mr. Fair at Tr._78, lines 11-18:
.~ but the critical point in the specification is that you have to have finished-to-bear item in order to take credit for bearing stresses between the beam anu plate.
"And'that specifically 1s the question I asked in the meeting a
~
couple of meetings ago, whether they have any justification for that assumption and did they specify this joint as a finished
~ bearing joint."
A finished bearing joint is precisely that: finished -- not assumed by
-the fact that a base plate is used, a coluan is saw cut, and a welder does a sloppy job. Finished means both joint preparation and welding are intended to create a flush matching joint.
Since Applicants had no documentation to produce a special joint condition, they cannot use the existence of such condition as justification for taking reductions which are specific only to such joints. Therefore, in this case, Applicants have shown that indeterminancy does in fact exist for friction loads which are not analyzed for supports at CPSES.
26
i F
- 18. Applicants on section properties While Applicants have no comments other than the one statement (pages 21 and:.22 of affidavit) that the NRC Staff has questioned their assessment of flare bevel welds, they make no statement and instead refer the NRC question toLStone & Webster. In addition, this is not new information.
CASE raised the same point years ago (see Tr. 6870, 6873, and 6874).
- 19. - Applicants on AWS/ASME On page 23, lines 11 through 13, of Applicants' affidavit, the following statement occurs:
"As Mr. Terso noted in the June 8 and 20, 1984, meetings, those
' compensatory' requirements were deleted in the 1978 Winter Addenda."
On page 23, starting with the last word on 1.tne 13, Applicants make three statements, apparently related to the above statement, and then draw a conclusion.- I can assess the conclusion only based on the contents of the three statements. In this case, however, there are various apparently Intended meanings involved, depending on who le interpreting the contents.
For example, take the first of the three sentences, which states:
"However, as Applicants indicated at those meetings, the large majority of Applicants' designs were accomplished prior to deletion of the ' compensatory' through thickness requirement from our design criteria."
The second statement is as follows:
"In fact, we incorporated that portion of the 1978 Code Addenda in our design criteria in 1982."
f 4
1 27 g-
- .4 6
The final statement reads:
"As evidenced by Attachment I to Applicants' original affidavit, following deletion of that provision Applicants were assessing skawed fillet welds in a manner that satisfied both ASME and AWS provisions concerning effective throst assessment."
As is apparent, Applicants established three time frames: prior to -
1978, after 1978, and a period in between 1978 and 1982. Now the first statement argues that the majority of Applicants' supports were designed in the period before deletion of the compensatory requirement from their design criteria. The statement could be read as meaning that the majority of the designs were completed prior to 1978; in this way, the NRC would be convinced that the designs were executed during a period when analysis
' included an extra conservatism. But that is not what Applicants have stated. What they have said was "... prior to de?etion of the
' compensatory' through thickness requirement from our design criteria"
-(emphasis added).- Since the only point at which they had "our design criteria" was at some point in 1982 (and there is no indication that this has ever been deleted), the statement could mean that most of the designs were completed prior to December 1985.
The conclusion which is based on all of the material from page 22, last two lines (starting "To clarify the use.
. ") through statement 3 (quoted above) on page 23, is as follows:
"Thus, the ' compensatory' measures were unnecessary."
As will be noted, the conclusion is not related to the contents of statements one or two, and is only vaguely related to the third statement, but only if statement one refers to the period prior to December 1985.
28
.4
>In any event, I can't waste any more time trying to figure out what Applicants':somewhat knowledgeables are attempting to say or avoid saying.
The addition of two law firms apparently hasn't helped them to compose their affidavits..
Aside-from the fact that we will address some of the points made on
.page 23 of the affidavit at a later date /3/ I have the following minimum comments, since we have covered the subject extensively in the past. But in
.particular, one statement made by Applicants cannot be allowed to pass without at least a cursory response. On page 23, last paragraph, through page124, line 5, and footnote.12, Applicants include the following comments:
" Applicants agree that proper consideration should be given to effective throats of skewed fillet welds. We believe we have done-
!so.
Although engineers may not always actually calculate the effective throat of each skewed fillet weld in the weld pattern being evaluated e.gg, a conservative and simplified design l
approach was often used for efficiency, /12/ Applicants' practices were appropriate to satisfy Code weld stress requirements."
Quoting from footnote 12:
"For example, the engineer may ignore the existence of an obtuse fillet weld altogether in calculating weld stresses."
On the one hand, we have Applicants stating that they believe that skewed fillet welds should be properly considered and they believe they have done'so,.but on the other hand they concede that the engineer may not calculate-the weld at each fillet, although by inference he still calculates the weld per se.
If the engineer must calculate the weld anyway, why L
doesn't he do it right? If one calculates an all-around weld with the AWS correction factors, the process is less of a problem than calculating a weld 13/ For example, on page 23 starting with the last word on line 1 and continuing through the rest of the pneagraph, the material contained therein is ar.biguous to such a point that the conclusions as outlined in the final sentence of that paragraph are not possible.
29
. ~..
s
~
l
.which neglects the obtuse weld, thereby calculating a three-sided weld with eccentricity corrections. Beyond this, the failure to consider the welds as
-they actually exist creates. a blind spot in two areas relative to the weld
.itself:
(1) The throat of the obtuse weld may be insufficient to take the shrinkage loeds before cracking could occur due to minimum weld violations which could lead to catastrophic crack propagation.
The fact that minimum weld violations escaped detection et CPSES is not news, as anyone is aware. For example, just examining the ANI documentation will enlighten anyone as to the potential problems in this area; see Attachment E hereto, CASE Exhibit No.
1,035. And.this material is generally in relation to non-skewed welds which are far simpler to detect because factoring of the leg size as is necessary for skewed welds is not required for 90 degree fillet welds.
Applicants' lack of understanding of the serious nature of minimum weld violations is best noted in the exchange that took place during the January 10, 1985, Cygna/ Staff / Applicants meeting (see page 5 of CASE's 2/4/85 Motion for Reconsideration of Licensing Board's 6/29/84 Memorandum and Order (Written-Filing Decisions, #1: Some AWS/ASME Issues), discussing Mr. Bush's statement in reference to wash passes for minimum welds:
"That might make it worse, not better. Because the standard. procedure is often to put a wash pass on and that-doesn't accomplish much of anything, based on practical experience.
I'm not talking, now, about precisely meeting the code."
This is followed by a jewel dropped by Mr. George of TUGCO, 30 c_
. _, -. _. _. _.. _ ~ _ _ _ _ _. _. _ _. _. _ _, _ _.._ _ _ _ _.
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who stated as follows:
' "We have done just that on a lot _ of welds that were supposedly. quarter-inch fillet welds. QC put gauges on them and they come up with findings like those -- in fact.7/32 inctead of one quarter; and the corrective action is we go -In there and do just what you said.
It's been done all over the plant."
To which Mr. Bush added:
"I know it.
At about $1500's weld."
(2) The acute weld may have a depth over face ratio in excess'of the AWS standard-1.4 to 1, thus creating the conditions for internal
' weld cracking which.is not detectable by visual exauxnation. For example, see NRC Staff's Mr. Collins at Tr.12159. This could also lead to crack propagation.
Another point of interest may be noted on page 24 of the' affidavit under " Affidavit at 6".
Here Applicants note that 4 of the' sample of 13 skewed fillet welds used in the original' affidavit contained errors.
How could such obvious errors have gone undetected?
Page 25 contains some interesting "what if's."
But first a correction is required for Applicants' first statement.that:
"It should be 'noted that AWS punching shear analysis requirements were introduced to deal with large tubular structures (e.g.,
offshore platform supports) with relatively large flange width to flan'ge thickness ratios."
The correct origin and purpose of the AWS punching shear requirement may best be learned by going to the source. In this case, the AWS itself at the Commentary, Part A, Section 10.1 (I quote from 1984 edition) stated:
"Section 10 originally evolved from a background of practice and experience with fixed offshore platforms of welded tubular steels
... The requirements of section 10 are intended to be generally applicable to a wide variety of tubular structures."
The' Applicants must concede that the criteria evolved from and was not f
I-31 i
J
~-
~. - -
.n--,.
- -. - ~ --
- developed for the offshore industry. Also, by the wording of the code, the intent of. the usage is for a wide variety of tubular structures, not specifically. offshore structures.
Beyond this,-and still on page 25, Applicants disregarded the fact that the tube structures most often used in offshore platforms are round, and they commence to presume what ratios could exist if they use the full range of square and rectangular tube steel available in the 1978 edition of the i
AISC for their offshore rigs, which Applicants determined was a ratio of 64.
1 (As a side thought, do the Applicants really believe that a tube steel with a-12" width and a 3/16" wall thickness is normally used on offshore drilling platforms?) The number Applicants developed from this premise is then -
compared to a ratio of 16, which is now stated by Applicants to be the largest known ratio to have been used at CPSES (after having originally claimed to the NRC Staff, until challenged by CASE, that 10 was the largest known ratio to have been used at CPSES).
However, Applicants are again in error, since they have made an improper-comparison based on an erroneous ratio equal to 64 A ratio of 64
- for.any tube section in the 7th Edition (or, for that matter, the 8th Edition) is impossible since the maximum width of a member in the 7th Edition is 12".with a thickness of 3/16", resulting in a maximum possible ratio of 32; the maximum width of a member in the 8th Edition is 20" with a thickness of 5/16", still resulting in a maximum possible ratio of 32.
In addition, these are available not only for offshore use, they are available
. for anyone. If one were to utilize Applicants' fallacious reasoning, CASE could then claim that ratios at CPSES have been as high as 32.
For example, in -just a brief examination of CASE Exhibit 669B (Attachment to Doyle 32
-~
A Deposition / Testimony, accepted at Tr. 3630) at Item 11XX, we note a TS 8x8x1/4 is used (the' support which failed at hydro) which has a vidth over thickness ratio of 16; utilizing Applicants' reasoning, the ratio would be
- 32. At 14H, Applicants item No.' 4 is s' 10x6x1/2 which has a width over 4
thickness ratio of 10; utilizing Applicants' reasoning, the ratio would be 20.
At 13AA, Applicants' item No.11 uses a 6x4x3/16 tube which'has a width over thickness ratio of (again) 16; utilizing Applicants' reasoning, the ratio would be 32. This is only t,o mention three supports with width over thickness ratios which would be, utilizing Applicants' fallacious reasoning, greater than 16.
Note 13 on page 25 of Applicants' affidavit would indicate that at least one support failed to qualify to AWS local failure criteria. Here 3
again, we have Applicants confirming CASE's posit 1'on that unanalyzed supports indicate indeterminancy.
20.
Generic Stiffness The statement made by Applicants on page 27, under " Affidavit at 17",
requires review:
"The analyses relied on in.:he affidavit indicate that the original generic stiffness assumptions were adequate. However, subsequent analyses of other piping systems, performed in response to NRC questions after the affidavit was filed, Indicate that some supports could experience, when actual stiffnesses are assumed,
. load increases which could cause the support to exceed allowable loads."
Applicants' sample wasi o prove that the original position of t
Applicants in reference to generic vs. actual stiffnesses was not a conce n, and this sample was to show that since it produced good numbers all the other systems were O.K.
However, Applicants mystically defied the laws of 33
$ 's
- o-
.T statistics by analysing a system favorable to their own position. The purpose of Applicants' Motion for Summary Disposition was to prove that Applicants' use of engineering' judgement was adequate to insure that the U supports at'CPSES were in compliance with the< codes and the law. The purpose _was not to show that in some cases it was indicated that Applicants If Applicants believed the purpose was to show that engineering
~ 1uc ked out..
judgement works'sometimes on a randon basis, they have made their point. If they had anything else in mind, they were sadly mistaken.
The statement by Applicants on page 27, starting on line 17, "This does
~
not mean that those supports _would not be capable of performing their intended functions," is a contradiction in terms, since Applicants admit that a number of supports would exceed allowables. The intended function of the supports is to operate at the various Levels A, B, C, and D conditions within the-allowable deflections and stress levels established for those conditions. It is not the intent of regulations, codes or the Atomic Energy e
l Act to have components operating at Levels A, B, or C conditions to the stress or deflection levels established for Level D.
By Applicants' own L
statement "... which could cause the support to exceed allowable loads,"
J Applicants concur with CASE that failure to consider the stiffness of the support pipe system leads to an indeterminate condition for associated supports.
I wonder if Applicants, having now found the error of their ways, will f
now concede.that the only way to really know what the actual loading of the
_ support would be is by doing it on a case-by-case basis, which has been the 1
i position of CASE all along.
4 34
h'
- 21. Effects of Gaps
_The first reference;1n the material by Applicants on page 28 of the
?
affidavit is to the AISC 8th EditionLdefinition for hole sizes, which limits
-the size of standard holes and confirms that, regardless of the fact that
. such holes have not exceeded the maximum size for oversize holes per code, i
theyfare nonetheless oversized.-
i'Ihe second item noted by Applicants quotes from section 1.23.4.1 of the A1SC code and is stated to be' in reference to what the first item means or refers to.
The affidavit states:
j
"... this section of the AISC Code actually addresses steel to steel connections..'This is apparent-from paragraph 1.23.4.1, which specifically states that for the connections discussed in the affidavit, i.e., holes in baseplates for anchor bolts in
. concrete foundations (' column bases' in AISC terminology), even L
holes larger than those listed in the table may'be used."
i-Applicants' game of: semantics is once again in high gear. First, there is no 'part of AISC which was ever intended to address the tube steel /
Richmond insert method of attachments to structures, since this is a unique design. Applicants are trying to read into the code provisions those requirements which they require to quellfy their structures.
Beyond this, the reference in the code to column bases is not AISC i
terminology for attachments to concrete generally but means precisely what It-says: " column bases," which is a vertical load bearing (generally i.
I-compression element) shape with a plate attached to the lower end to l
transfer structural loads to the foundation and footing. This cannot be f
interpreted to' include beams attached to ceiling and wall.
i To determine the truth of this statement, Applicants need only turn
_to pages'4-125 through 4-131 of the AISC 8th Edition (see Attachment A).
j=
The same information, with the exception of the oversize hole notes at the i
r i
35 i
H bottom of the pages also appears in the 7th Edition of AISC on pages 4-104 through 4-109. This shows the details and the specific hole diameter oversized allowable for the column bases being discussed, and incidentally, on page 4-131 of the AISC 8th Edition shows a beam and alignment member integral with the concrete, and indicates the hole type required for adjustment as being slotted; and slotted holes are controlled as normal to the load, as shown in Attachment A, Sections 1.23.4.4 and.5.
And incidentally,' at Section 1.23.4.3 of the same citation, the following statement.ls made: " Oversized holes may be used in any or all plies of friction type connections, but they shall not be used in bearing type connections. And hardened washers shall be installed over oversized holes in an outer ply."
(Emphasis added.) The same paragraph for the 7th-Edition, located at 5-193 (3), Bolted Parts (1), Oversize Holes, states:
"... they may be used in any or all plies of friction type connectiens.
Hardened washers... " By omission from the above, oversize holes were not permitted in bearing type connections, even in the 7th Edition, since this sectJon tells one where they may be used. Obviously, the connection in question is not in compliance with the code and all discussicn relative to the size of the oversized hole is irrelevant, as indicated by this new code clarification.
On this particular problem, I gave a copy of J. Fisher's paper on shear keys and oversized hole situations for column base plates (which is the same information used by the code committee for AISC, of which Mr. Fisher is a member) to Mr. Bachman and Mr. Tereo of the NRC Staff over a year ago.
The code is referring to a totally different animal than exists with the Richmond / tube steel arrangement utilized at CPSES. The code is making 36
E i.1 r-allowance for holes in column bases for specific reasons as follows:
(1) Shear transfer between column bases and foundations occurs through two mechanisest first, there are normally huge vertical dead loads in columns, and thus friction will allow for a discrete
- horizontal shear to be transferred prior to engagement of the bolts; second, for larger shear loads which exceed the friction
~
capacity of the. joint, shear keys are employed.
(2) If the code referred to any steel member in contact with concrete, they would have so stated and not used the word " column." I am sure that even Applicants' experts have never seen a horizontal column, the key word being " column."
The Richmond / tube steel arrangement has many supports, perhaps most cases where there is no compression between the steel and the concrete, and
- 1n fact tension may be the usual condition. Therefore, Applicants' word games are worse than incorrect; they are ridiculous to say the least.
22.
OBE v. SSE Conditions In reference to page 30 of the affidavit, OBE vs. SSE conditions, I have several comments. First, Applicants state two facts as follows:
First, that there was "Information received subsequent to filing the affidavit"whichnecessitatedtheirclarifyingtheiraffidavitf4/.
f4/
It is hard to understand what Applicants would have us believe in reference to this statement, since Westinghouse was working on changes to their procedures for the use of damping factors. In f act, as may be seen in Applicants' affidavit at page 34, item (2), in May 1984 Westinghouse was making corrections of errors relative to damping factors at the same time that Applicants were preparing their affidavit. All Applicants had to do was check with Westinghouse to have known about such errors and thus avoid the problem of "Information received subsequent to filing... "
37
And then at page 31, Applicants state, starting with the first full paragraphs.
"Regarding the different damping values employed by Westinghouse,
.at Applicants' request Westinghouse conducted a~ historical review of the stress problems within their scope 'of work."
Apparently Applicants went about formulating their motion for summary
' disposition without checking all the material they were using and without discussion with their vendors.
On page 34 of the affidavit, Applicants at (2) are discussing nine stress problems on 24" and 30" lines which used the wrong damping factors, and they state "This was identified and corrected in May of 1984..." on this. point, I would like to comment in two areas. First, Applicants were anticipating fuel. loading in the spring of 1983 at the time of the September 1982 hearings (see above), and yet incorrect stress problems were still in place at least until May of 1984. Second, the problem of incorrect damping factors was brought to Applicants' attention long before this time frame; see CASE's 8/22/83 Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations),Section XXII. Obviously, Applicants failed to
^
monitor the problem.
At page 35, Applicants for at least the second time in the discussion i
on OBE vs. SSE offer the excuse that they have no problem since the material which was incorrect was (to quote Applicants) "not in final record analysis."
(
At page 30, Applicants aske the following comments:
l "Information received subsequent to filing the affidavit indicates i
that in some initial and intermediate stress problem calculations, j
1.e., calculations performed prior to final record calculations, Applicants.did not employ Regulatory Guide 1.61 damping values.
The affidavit could be read to suggest that even for these
' analyses Applicants used Regulatory Guide 1.61 values."
38
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=a 11 a.ns n
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a x
a Two points that I find curious: what part of codes or regulations allows you to produce less than somewhat correct calculations for non-record analyses? Second, were Applicants trying to suggest that this type of material could be offered to prove that there were no design problems?
In reference to the above, the Board has already told Applicants to use due
. caution in the preparation of documents offered in these hearings in support of a specific point (see Board's 12/28/83 Memorandum and Order (Quality Assurance for Design), from page 52, line 3, through page 53, line 10). In rereading Applicants' original affidavit, I find no mention of " Interim" or
" Intermediate."
At page' 36, Applicants make the following comment:
"While this is not necessarily incorrect, depending on the piping 1
. problem it may result in a response which is not appropriate, or at least less conservative than using the other approaches
[ footnote omitted]."
I love this statement. It shows imagination, if not the results of adding new legal staff assistance. Applicants' statement offers a mirror argument which I add because Applicants probably forgot to, and it would read thus:
"While this methodology is incorrect, depending on the piping problem it may result in a response which is not appropriate, or at least less conservative than using the other approaches." This reminds se of the old ellehet.12 the glass half full or half empty? In this case, one might say that the Applicants are being optimistic, but not necessarily candid.
Additionally, how can Applicants devise such clever sentence structure that within 20 words they can cancel the statement they just made that ".
this is not necessarily incorrect... [but] It may result in a response which is not appropriate.
"?
39
...... -. ~.
f n
At the time CASE filed Proposed Findings of Fact on this matter, and indeed until the time Applicants filed their Motion for Summary Disposition, CASE stated that the damping factors were incorrect, and now apparently we J
' have no argument from the Applicants, since they agree with CASE's position as shown above.
i
- 23. Differential Displacement of Large Frame Supports Since Applicants have nothing of consequence to offer in this affidavit, I shall stand mute at this time and rely on our answers to their Motion.
24.
Upper Lateral Restraint On page 39 of their Affidavit, Applicants stated:
".... I note, however, that the conclusion is correct for those analyses performed specifically to address CASE's concern with thermal expansion - the two analyses performed to assess long -
tern LOCA and MSLB effects, i.e., when the maximum thermal loa 1 on the beam and concrete walls occur."
Applicants are at least premature with this declaration, and this is borne out by the NRC Staff's "BNL Review of Texas Utilities Generating Company Comanche Peak Steam Electric Station Upper Lateral Restraint Beam -
- Steam Generator" (FOIA-85-59, C/364, Attachment D hereto); in the BNL Review of the calculations, it is stated (page 9, Conclusions, item 3):
"BNL has investigated the effects of the ULRB axial loads developed during MSLB and it was found that significant shear and moment cracking will develop in the concrete compartment walls.
It is reasonable to expect that significant cracking will occur both to the interal (sic) (i.e., reactor cavity walls as well as A
40
_ _. _ _, _. _. _ _.,... _ _ _ ~ _ _ _ _
F 1;
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+:
I I
at the outer wall-of the 4th. compartment. Some cracking is also expected on the outside compartment walls of the other three compartments."
l Therefore, to make the upper 'interal restraint beam qualify, Applicants have extended the capability of the beam and concrete to the extent that severe cracking takes place through the biological shield. So Applicants' excitement over the fact that they haye beaten CASE may be shortlived, since the proof may be merely academic unless they can now prove that the damaged biological shield will not - present a hazard to the public health and safety.
See page 10 of the BNL Report, item 6, which states:
"No assessment was made with respect to the effect of the cracks on radiological shielding."
Beginning on page 38 of their affidavit, Applicants expend 7 pages of doubletalk to evade a major point. Applicants on several occasions referred to questionable procedures as relate to tension on the upper lateral restraint anchor bolts. On almost every occasion that Applicants mention this concern, they cite as an intervening factor that this problem was related to tension on the bolts and not the problems related to compression as noted by CASE. This insertion of caveats each time Applicants must cite an error is absurd. Applicants would do well to address the errors as they find them and refrain from qualifying their answers. In this way, Applicants will not wind up again compromising their credibility and CASE will not have to resort to vast expenditures (based on available resources) of time and personnel pointing out Applicants' errors and deceptions.
The main reason the Board offered Applicants a second bite at the apple was to prove that the supports were adequate to the codes and the law, not 41 4m
V f
to devise schemes to cover CASE's allegations while neglecting the fact that 1
the structure suffers from other diseases.
j Applicants' caveats notwithstanding, the above recently detected potentially ~ severe error is notable for several reasons, none of which are covered in Applicants' response.
(1) Aa shown in the beginning of this affidavit, Applicants were certain that Unit 1 of the plant was' completed and were demanding a license in September 1982 (In fact, earlier than this).
(2) The upper and lower lateral restraints are the main structural components which constrain the steam generators horizontally.
Prevention of catastrophic failure of these members is critical to the safety of the plant and the public. The unique nature of the support system for the steam generator is such that the loss of the horizontal constraint results in vertical instability.
(3) Since the plant was (in the opinion of the Applicants) complete and the covering of this problem with the restraint anchorages would not have occurred if CASE had not proved that:
(a) The originsi calculation did not address certain phenomena (LOCA, for example), and (b) _ When Applicants attempted to qualify this support for the hearings, they utillzed 11 alt analysis (plastic design) but their procedure was in error (see Tr. 6043 where Applicants' Mr. Vivirito conceded the error was 5%). At Tr. 6068, Mr.
Vivirito'adultted the error amounted to 600 kips (which is 300 tons of force). At Tr.'6191, NRC Staff's Dr. Chen agreed 42
% g;t:
e that CASE-allegations of error were correctly assessed. In using the correct numbers in Applicants' equations, the support exceeds the yield strength of the material.
a (4) 'As.part of the proof requested by the Board in the December 28, 1983, Memorandum, Applicants flied a Motion for Summary Disposition which addressed the upper lateral restraint. As a result, we now come to the third and most sophisticated attempt to qualify the upper-lateral restraint. First Applicants produced a time history to reduce the loading used in the calculations and then Applicants resorted to a NASTRAN analysis to take advantage 9
of the energy dissipation through a large portion of the containment.
In addition, through a vast effort in theoretical engineering, Applicants have produced perhaps the world's first variable joint fixity condition; see BNL Review, Attachment D hereto, page 10, item 6, where they state the following:
"The effects of the wall cracks will be to change the end fixity of the ULRB to that of simply supported."
Applicants have done this type of analysis for a simple beam and in all probability have set a world's record for sophistication in analysis of simple beams, because the stress for s
this type beam is always determined by the simple equation Mc/I plus or minus F/A. But this is the least of Applicants' problems, since in attempting to prove to the Board that the upper lateral restraint was qualified to codes, regulations, and FSAR, the Applicants found that there are questionable areas in the 43
i analytical methodology. This type of problem never occurs using Mc/I plus or minus P/A for fixed-ended simple besas. Beyond this, i
'what is the probability of survival for the ULRB as currently designed by Applicants vs. the same beam and loading conditions designed by conventional methods?
(5)' Having noted the questionable areas of analysis which could affect i
the statements made by Applicants in their affidavit, we are not told what the effects will be, but are rather told that CPRT is looking into the problems and ramifications. My basic conclusion as relates to this problem is how.can a simple beam be erroneously analyzed wrong not once, not twice, but on three separate occasions?
CASE originally stated that problems existed with the upper lateral f
' restraint. While it is true that our reference basically was related to l
4 compression, it was the tenacity of CASE's efforts on the first calculation, i
the second calculation, and in fact the third calculation which ultimately
. led the applicants to find that the NRC also questioned the third e
calculation. Now Applicants concur that their calculation may be incorrect for the problems related to tension in the upper lateral restraint anchor bolts. Although Applicants fall to mention it, In addition to the problems discussed new problems related to the radiological protection have been f
induced. Therefore, the CASE allegation that the upper lateral restraint l
was indeterminate is in fact accurate (which certainly has been proved in i
i the area of tension).
l l
4 1
i I
4' I
I 1
- 25. Cinched-Up U-bolta, On page 47 of the affidavit, Applicants state as followa:
"In light of the definition of stability employed by the NRC Staff, i.e., motion of support into a position not analyzed or analysable, and Applicants' decision to apply that standard in subsequent analyses, the conclusion 'thus behaving stably'- would no longer be consistent with the use of the Staff's definition."
For an organisation to employ at a minimum four major legal firms,
' Applicants seem to have a problem expressing themselves. Beyond this, from the way I read their statement, it appears that Applicants are saying that
'while they disagree with the NRC definition of stability, they will do as the NRC requires.
Beyond this, by inference, Applicants seem to state that they have or do not have a stability problem based solely on the definition of the word
" stability," which is obviously absurd since stability in engineering requires no definition to exist de, facto nor to be recognizable by competent engineers. The definition was required for the hearings merely to explain for the record why a concern existed in the first place, not to indicate that the NRC Staff Teledyne, and Cygna had simultaneously uncovered a new physical phenomenon. The phenomenon has always existed, but was rarely if ever institutionalised as it has been at CPSES. Therefore, a definition was not normally required in the past. However, since Applicants installed the unique design at CPSES, a method of describing it became a necessity. This is yet another exemple of Applicants' somewhat knowledgeable staff off on another tangent designed to confuse the issue. The above becomes apparent when one reads the statement by Mr. Tarso of the NRC Staff at page 44 of the l
March 23, 1985, meeting in Texas:
l-45
... It's very difficult in this nuclear industry to have someone look at a suppo:t characteristic that no one else has ever looked at before."
Obviously, from the above statement, definition was required.
No'one wishes Applicants to do anything other than qualify the suppor't s..'If the Applicants can show that the NRC, Cygna, Teledyne, and CASE are all incorrect, let them do so, because to disagree and have facts
- to back up this disagreement and proceed to rework the plant is somewhat less than prudent and in fact can only be seen as complete irresponsibility.
On page 49, Applicants make the following statement:
"In summary, we conclude that in general torque applications to the U-bolt pipe assemblies can potentially result in high but accoptable local pipe stresses and can further result in high stresses on the U-bolt. In some instances pipe stresses,
-calculated on an elastic bases (sic), may be unacceptably high even.for torque values comparable to those required for stability.
In such instances, the supports would be candidates for modification."
In addition, Applicants continue as follows:
" Applicants make these revisions because the analysis of individual supports performed subsequent to filing and in accordance with the commitment in the Affidavit, indicated that for a small number of supports (on large pipes with relatively thin schedule walls) the pipe stresses may exceed Applicants' acceptance criteria (footnote omitted] at torques predicted to be necessary for stability. This condition will be further addressed in the context of the Stone & Webster review."
On the above,- I have a number of comments, but first I would like to comment on the structure of the above quote. It appears from the statement made by Applicants that in their original affidavit they had committed to an analysis of all of the individual supports, whereas in fact they had only committed to a program of retorquing.
46
~
?,
. It was the Applicants' purpose in filing their Motion for Summary Disposition to prove to the Board that consideration of the effects of cinching were not required, since no combinu::Jon of geometry, piping, or loading conditions would result in any problems (see Applicants' Statement of Material Facts As to Which There Is No Genuine Issue Regarding Consideration of Cinching U-Bolts, page-7, 11nes 8 through 11 where Applicants state "(3) Stresses in piping due to preload values expected in i
the field in conjunction with other loa $ds imposed will not result in any adverse impact." Further, at lines 23, continued to page 8,.11nes 1 and 2:
j.
"To provide further assurance of acceptable preload values, Applicants have committed to an inspection program to assure that every cinched-down U-bolt.
on a single strut or snubber (a tot.al of 380) is torqued to a level at' which' 4
the assembly will be stable in the absolute truest sense, i.e., no rotation and axial movement, if any, is towards the strut.")
In Attachment 3 to Applicants' Motion for Summary Disposition at page 5, last three lines, the following statement -is contained:
"The pipe will not have stresses that exceed acceptable limits if preload torquing is restricted to the recommended values." On page 63, last three lines (same source), it states as follows: "From the above discussion, it can be concluded that the pipe stresses induced in the pipe due to cinching of the U-bolc will not exceed acceptable limits." From Applicants' Motion for i
Summary Disposition, pages 4 and 5, the Applicants provide the following comments on the purpose of the Motion for Summary Disposition:
provide evidence of the acceptability of stresses on pipes caused by thermal 47 i
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l' 1 expansion in local areas around cinchid U-bolts." And on page 5, lines 3-6 f
".-.. no genuine issue of material fact exists in respect to the allegations and the Board should find that the Applicants are entitled to a judgement as.a matter of law."
At lines 11-13, Applicants state " Applicants g
. conducted's survey of a torque on a respresentative sample of cinched-down j
U-bolts. From the data Applicants established that to bound field conditions..." From the Affidavit of Messrs. Finneran and Iotti, the following comes to light: from their answer on page 2, the purpose of the Affidavit is outlined, and at page 3, item 4 "The local (and global if any) stresses induced in the piping by the cinching down practice..." The Applicants' answer to this question appears on page 3 at 3:
" Provide evidence that the ~use of U-bolt cinching is appropriate to eliminate potential local instability without introducing adverse effects in the piping and U-bolt itself."
The evidence was complied from tests and finite element analyses in 1
reference to the tests from the original affidavit of Messrs. Finneran and Iotti; page 35, lines 16-18 contains this statement: "The test results indicate no unacceptable stresses in the pipes for the preload condition."
The key statement in the affidavit in reference to the evidence complied to support Applicants' position that no problems existed with the pipe supports or piping may be noted on page 51 of their original affidavit, lines 16 through the end of the page, which is as follows:
"The bottom line, however, is that the testing program and finite element analysis have demonstrated that cinching of U-bolts as 4
done at CPSES and generally by the industry produce no adverse i
effects on piping and supports for the range of pretorque values
)
which are either representative of the worst conditions encountered at the plant or required to ensure stable behavior' of the U-bolt assembly."
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But on page 76, Applicants state: "However, as previously noted, Applicants will inspect every U-bolt on a single strut or snubber (a total of 380) and ensure that each U-bolt is torqued to the torque value set forth in Table
- P."
Finally, at page 77, ites 2, Response, App'licants state:
" Stress results obtained from the finite element analysis of the U-bolt support piping assembly associated with the anticipated support and piping loads Las well. as recommended preload values are within acceptable limits. The supports as well as the pipe will not experience any gross distor*.lon or loss of function."
From the above, several points are perfectly clear:
(a) Applicants had no reservations that the support type under discussion (cinched U-bolts) did not cause an overstressed condition la either the pipe or the U-bolt.
(b) The only commaltment made by Applicants was in relation to an inspection (not an analysis) program to ensure that the torque values recommended by Applicants were in fact' existing in the field or the U-bolt would be retoruqed.
.(c) 'All of Applicants' statements in all of their original Motions for Summary Disposition are now suspect as a result of the gross s
erIors found in those Motions for Summary Disposition covered in-t, i
this affidavit.
Applicants' November 12, 1985, affidavit contains several other points th'at deserve mention, as discussed below.
On page 50, last two lines and continued on page 51, Applicants make the following statements:
"Theie changes are prompted by the fact the (sic) during the initial preparation of Table I, outside surface secondary circumferential stresses were subtracted inadvertently from the inside surface total circumferential stresses."
49 4
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l Are we to assume that the use of the word " initial" means that the summary disposition process is also an iterative procedure, or was this yet another case of failure to check once the initial result proves acceptable to Applicants?' I have said it before and I wiil say it again:
Is it mere coincidence that the' vast. majority of errors comaltted by Applicants favor their position?-
'At the bottom of page 51, in the Conclusion, Applicants state:
"The conclusions set forth in the [ original] affidavit remain valid." In view of all of the above, I shall refrain from comment on this point.
In reference to the material covered under cinched-up U-bolts, it must
'be noted that two of CASE's allegations are confirmed by the revelation in these corrections'to Applicants' Motion for Summary Disposition: the cinched-up U-bolt problem being one, and the fact that in a number of cases, as pointed out by Applicants themselves, stability cannot be achieved without exceeding allowables. While we still disagree with the ludicrous allowables derived by Applicants, it must be borne in mind that the problems noted by Applicants are based on these super allowables.
- 26. -Axial Restraints First, let me state again that the purpose of Applicants' Motion for Summary Disposition was to prove to the Board that for all potential loading conditions and geometries there would be no supports of this specific type
.which would exceed allowables for each of the Motions for Summary
- Disposition as shown above.
50
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?
cv fl y t
,n 3 q
f Ion psge ~53 of tihe affidavit, Applicants have the following statements h
W
, u,-
y [ ' starting on line'5:-
1 i
'"Accordingly, we no. longer consider' application of the ASME code
(
'provisidas concerning self-limiting. loads, as was done in the Affidavit, to be appropriate. Therefore, we have assessed the implications of not applying Code provisions applicable to self-limiting' loads, i.e., use o$ stress allowables equal to three timesLthe'normalallowhble,\\intheanalysesoftheserestraints.
We now conclude thatialthough modelling the restraints in question.-
m, as purely axial restraints ~(1.e., no rotational constraint) is
' adequate'for assessing pipe global stresses, such modelling may I
' '2 not be. adequate to assess thexadequacy.of the support itself or-V g
the local strdis conditio & 1n'the trunnions at their interface
!*=
with the pipe (i.e., weld to pfpe and trunnion stresses) (footnote
.omitted]."
A Jf
~,
l, It must be mentioned in-any event that Applicants' flagrant use of 3Sm
.t j7
'to triplk allowables is generally in error, as was noted by a recent code
- V
.. 4 g
Y clarification. See Cygna's 11/26/85 latter 84056.095, attaching their L
't y
.~
lafestrevisionstoopenitems,addattachedpages18and19(AttachmentF hereto) on friction, regarding change by ASME re: 3Sm'(1983 Edition, NF-n.
3 i
~
3121.2). This is not a change in the definitionjof primary stress, it's a a
clarification. 'In practice,' restraint of the thermal growth of the pipe has
- N always been considered to be a primary stress industry-wide. And thermal e
loadd inducing pipe expans.lon have always been part of load condition A.
7 As relates'to the' above statement, Applicants have more caveats than candor, but,-regard 1,ess, Applicants now find that the allowables they were
- h.
{
s
.using to qualify [these.suports are incorrect. CASE has always contested the use of SSm.
,y
/;
y,,,
'y At the bottom of page 53 and continued to page 54, the following is
.y.
p i
notedbykpplicants:
"When normal Code allowables are applied, 12 out of N. ',
114 double trunnion supports exceed allowables." It must be observed that f
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this equals 10% of this type of support installed at CPSES which are Inadequate.
.In the middle of page 54, Applicants explain how, by performing an elastohlasticanalysis,theyshowedthattheductilityofther'apport
. redistributed loading and the support accepted the load. This whole 4
dissertation is irrelevant, since the code does not ' allow one to venture into areas of esoteria to prove that structures that have failed'by normal code criteria may still hang on by a thread. Beyond this, the majority of those who are involved in these hearings have always been aware that there is a reserve between the allowables and the ultimate; however, this reserve
~is a no man's land. This is simple to understand when one realizes that the design of nuclear ~ power plants and their components are quellfled to at least two load conditions:.A/B and C; and for some supports, a third case, Level D.-
Therefore, if a support can be proven to qualify at Level D, it obviously will not fall at the lower load levels.
Here we have in yet another area Applicants concurring with CASE's position that this type of support which is not analyzed for rotation or otherwise addressing the rotational problem becomes indeterminate. In fact, as Applicants point out, 12 out of 14 axial restraints are overstressed.
CASE never predicted the numbers of supports which would fall, but have
.always indicated that the possibility for failure existed. We are happy that Applicants now concur.
One must keep in mind that Applicants are using allowables which they created in their own image. Now, to understand the problem, one will find
'when examining the numbers develored to prove an existing item is safe, one 52
- g.
need only examine the fudge factor which results from bias. Aside from
- this, the code'has already clarified the status of constraint of free-end displacement;(see Cygna's~11/26/85 letter 84056.095, page 19, line 4, et
. seq.,' Attachment F hereto).. The new code clarl'fles.the interpretation of
~
constraint' of free-end displacement (Cygna says " change the definition;" we disagree:on this point, since generally constraint of the pipe per se has always-been Econsidered ' to induce a primary stress). This clarification also applies to items:15 and'16 of this affidavit.
I find ~1t difficult'to understand how, during the 1983 hearings, Mr.
Reedy was stating that a' code revision was coming out with an editorial
- change to. state that-thermal stress.In supports would not need consideration. But Mr. Reedy failed to mention that an editorial change would also clarify the fact that constraint of free-end displacement would
. be considered to be a primary stress.
27.
Richmond Inserts One statement I can make regarding Applicants' comments beginning on page 57 is that here again App 11 cants are revising their allowables from the U
original affidavit which accompanied their Motion for Summary Disposition
. downward!from an Interact'lon of 1.75 to 1.33.
l One other minor point I might make is that it seems rather senseless to discuss the particulars of a problem when the concept is erroneous from the beginning. - In the case of the Richmond insert / tube steel issue, the AISC clearly dictated the restrictions for oversized and slotted holes, as is 53
_.~ ~
1 o
shown in Section 5-193 (3) of the 7th Edition. But the clarification of the 8th Edition is more to the point (see Attachment A, Section 1.24.4.3),
which. states: " Oversized holes... but they shall not be used in bearing
-type connections." Beyond that, Table 1.5.2.1, Note 1, limits the use of A307 bolts and A36 threaded material to static loads only (see Attachment A).
Also see NF 4721, Attachment C, which limits oversized holes to friction joints only at (d)(1), but only restricts the slots in the bearing connections relative to direction, which must be normal to the load. Beyond that, I can only say that this issue remains open for the time being.
28.
In reference to the box beams covered on page 61 This issue also remains open and CASE will have much to say on this at a later date, even though we could have commented on the fact that the Applicants admit that some of the stresses are higher (although they don't say how much higher) than assumed when they flied their original affidavit.
This issue they also defer to Stone & Webster.
29.
Overall Perception As a final statement on the revelations contained in Applicants' affidavit, I would like to comment on the overall perception which is conveyed. With over 35 years of experience within the engineering discipline, I find it impossible to accept the possibility that all of the errors and oversights which effectively negate at least 8 of Applicants' 54
_ -.. ~. _ _ _. _ _.. _..
- 9,-
,f:
Motions for Summary Disposition are the result of massive incompetence. One has to keep in mind that in Applicants' efforts to provide the proof for the Board of the adequacy of the various supports, Applicants utilized the k
staffs of no less than 6 major corporations f5/, in addition to their own rather formidable staff. Beyond this, Applicants had the legal staffs of at least two major law firms f 6/ to guide them as relates to the legalities and the wording of the contents of the motions for summary disposition, again, 1
in addition to their own substantisi in-house legal staff. The only conclusion available to me at this point in time is that Applicants were aware that at least some of their arguments rested on "somewhat" shaky
+ - -
ground to say the least.
In considering the above, I must state that it is not in the interest of plant safety or in fact public safety to allow those involved in the motions for summary disposition to exercise any control over decisions being made in relation to the Stone & Webster /CPRT corrective action program, considering the fact that they were involved in past decisions that proved to be either results of gross incompetence or otherwise.
f 5,/ Gibbs and Hill, ITT Grinnell, NPSI, Ebssco, Westinghouse Corporation, and Cygna Energy Services indirectly.
f6/ Bishop, Liberman, Cook, Purcell & Reynolds; and Worsham, Forsythe, Sampels & Wooldridge.
55
j.
Attachments:
.A -- AISC Eighth Edition, pages 4-125 through 4-131, Table 1.5.2.1, Sections 1.23.4.1, 1.23.4.3, 1.23.4.4, 1.23.4.5 -- (pages 35, 36, and 54 of this affidavit)
B -- ASME Section III, Subsection NF, Appendix I, Table 1-7.1 -- (page 9 of this affidavit)
C -- ASME Section III', Subsection NF, paragraphs 3260, 3261, 3262.2, 3262.3, 3262.4, 4721, etc. -- (pages 8, 9, and 54 of this
. affidavit) 1 D -- BNL.Raylew of Texas Utilities Generating Company Comanche Peak Steam Electric Station Upper Lateral Restraint Beam - Steam Generator, FOIA-85-59, C/364 -- (pages 40, 41, and 43 of this affidavit)
.E - CASE Exhibit No.1,035, SIS Report G-044, Hartford Steam Boller Inspection and Insurance Company (ANI), 5/26/83 -- (page 30 of this affidavit)
F -- Cygna Energy Services November 26, 1985 Intter 84056.095, cover letter and pages 18 and 19 of 11/20/85 Revision 2 of Pipe Supports Review Issues List -- (pages 51 and 53 of this affidavit) 56
p*
-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.
do f I,
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,I f
Date:
I2~Ik -Y STATE OF Massachusetts COUNTY OF Worcester On this, the 14th day of December
,198 5, personally appeared Jack Doyle known to me to be the person whose name is subscribed to the foregoing instrument, and acknowledged to me that he/she executed the same for the purposes therein expressed.
Subscribed and sworn before me on the 14th day of December 198 5,
~
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~
Notary Public in and for the Stite of~
Massachusetts W Commission EFPIfM My Commission Expires:
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5 ea pin hole o
g E
'Olddl Nesn e 6 6 a.-
.-s for.mactior botts ase riosrn.sfiv l
Cl V
+,Lo Fuwsh bear og plate
+4 w... 4 sate to facsistate ese:ction as loslows i
a.
an accordance with t<.. :. i., s -
- oversize
\\*
AISC Spec. Sect.1.213.
14.43, e s.. r.
- overs 2 e (4
8 is so..~.
T.
s oversa2e 9
DEPTH Dri NOMINALLY
..,.v os a rosumn..tts.ts soa.s.no sim As be l
te o.e i.t 2
e stages os c ns.o..
=s.ts base 2 IN. LESS THAN Dr.
BUTT PLATE i
... e-
.aum.s.es y soe anchors ar= twa. plate s
i i
N..te. Erecten clearance = % in.
3
--...... ~
c.... c...
en, cwmm en_ganuni~.n rarrn
.~...
i la e
4 129
~
SUGGESTED DETAILS l
SUGGESTED DETAILS Column splices Column splices i
f Welded Welded Jr i A _. _
nn.d I,
/
R isamuig I'
lYf f }' ]', y% Note A
~
$r<"~ ^
h
- +
I s
9 a s s tem taAb g..
- s. e se E
E g
p
'f l.,
i,; j.
l
. v= :
u 3
k,),
3
\\
1,3 I
I k"
Q,nage a
/
.a
.. v-g s-is
).
[
n e-iu.
__ _ n..
. i.
g
.c:
w g-is 7
- ~
4 =' 'a dr 88 n
5
_y
+.
y
. ouus.
It g
g g
qj
,4 '.
- l c
' ~
BUTT PLATE DEPIH OF D AND Dr.
DEPTH Der NOMINALLY ERECil0N A1D AND Ig,,***""8 NOMINALLY IHE SAME 2 IN. LESS THAN Dt STABILITY DEVICE acco dance.ith AISC Spec. SECT.
[t Flii of D, AND De 1213.
r:af.lif4A1LT IHE SAME BUTI PLAIE g
a
,a
'j
~
Note A [
6 l
W
,3..
7
,_./ column il l
i, 8
- s. ~
g-Weld to develop l
S t
i j
3 8
3
'E Note A y{
ty 4;,
__qg
'8 s.n piates m
i i
t.ato.
i 9
Ik
'sII.O*'
dL} I-
}
$ l l
}
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l t,-
,4, n' w<tiot* A a
p., ese t,
,t, g' #
t et.gitaosulp
,l 6
BUTT PLATE y
DEPTH OF D,. AND Dt DEPTH Du NOMINALLY NOMINALLY THE SAME 2 IN. LESS THAN Dt DEPIH Dr. NOMINALLY i
2 IN LESS IHAN Dt Note A: Use idtet welds or partial penetration
{
weld whenever possible.
Ries E se t-m*. h
+..
- si e...
.aly one saim.mul unn smusen se<iume it simp may attach Friesh bearing plates in accordance with AISC Spec. Sect. I 21.3.
whe-ee is,
..e-:. e u.
@e; pt.ase L.. 4.g= e mInne. soul provide lackl a let.as.aen e ovet lowtr8 barctauri.
$140 4 8y of upp.-s 94.stt. math als loadang. Should be consadered untd the isnal *e 4.lder) es completed-jg
.;e
- e. Ive s siete ese See e e e. we. s en o6 in we Anst gescape leastiltsit Of STEEL. COcesTRUCTIOps
iW j
4 IJI l
SUGGESTED DLTAILS SUGGESTED DETAILS 1
Miscellaneous Miscellaneous sIRUCitIRAL TUBWG AND PtFE M AW 10-COLUMN t,0WtCilNIS SHELF ANGLES WITH ADJUSTMENT I
{,.
[
'I[ l
- * ' " ~
3 l
OC.* M f*G:
4 14.y,* t..
.,,. j q,
- f. v. i. 4...
p" g
cino ance
-(
ur
-i'{1,y.**s thp angte p
f..,<
[...o. t 4. 1* *"
- 1*
k Islot both legs cnp 3
, /p i
lor ad ustments angle
, f ///
i 31
' y' /
N DETAIL OF SHIM
],j s*
~~
f Bolt heads-.
g sats -
sai neads this sa
\\
it=s se 3
,3.,,,,,,,,,
ice I sheitansiesconbnuousa d r=
m sia lo, hontontal Base it. r
<[, j i
Note Detaas w. t.* 8 a save asut tubing
'[*
Notes Horizontal adgustment is made by slotted holes; vertacal adjustment may be made by stoned holes or by shans.
An viwie A
For tolerance allowance in ahgnment, see AISC Code of Standard Practice.
Chp S'"'"'
gg k at oa o8 TIE RODS AND ANCHORS
[I l _ b--m l
B'e
- 'e emt= was' l
a l.
i sett - tapping
- &-- 7 2% to 1% % to gg Cl3 Cl3 C53 Cl3 Hen. nut
- g. q g a
_3 a
~~
l r
lC E. to c. of beams n
i er g
)
[
i Erection seat.
a E
i h,
!. &\\
B I
.l nwumum shop weld El m
I g
8** ""8 ,. g]
f seemowe aftererection l l l'
h se necessary 3' 4 3,
--I
[ Plate j l O T;T
~
)
r,a s,a Nose. Connecson *.uwe tubes and pape may be foote: 1ength of rod o to a.
o,thcuts or nniessade to esect should be shed in Note: Dimension d should CIRT CONNECil0NS
""*nsp8es 3 in be based on design req't for uphtt PtlRtits t'Or.M Cll0NS l#l _
Tae hs h Botts Swedge Bolts l' '
l
. tColumn channes tepe r_
i g,.
t 5
%...h..
j, A
i e
o a.g,
/~
,.e.d.r,at
,e,n
.l (4
7F 4'45%'3 kh I g
16 P.E
" b"**
~
f E
-. MN
/
p r
x i.
4
<g '.. 3
,M; 9
4 J
e o
,e l
a,...t -s to
~a
- i i.4 i
s-a avoed blocksng girls i
when posssble.
Angle Wall Anchors Government Anchor
$ - 24 e AISC Specs /scatoon fEffectwe iIII/w a
Q 1.5.2.2 shall be in accordance with Appendix B, Sect. B3. Design fo g,
}ll.
i L
! e.
t ase -
TABLE 1.5.2.1 M
ALLOWABLE STRESS ON FASTENERS. KS1 u
g, Allowable Shears (fa y{
y Allow-Friction. type Connectionso able Descripuon of Fastener' B**ms -
j,
~
Tensions
- " 8'd g
tyTw 4gg Standard and Short Long-Connec-s4:e slotted slotted uons' 1
-- 1 Holes Holes Holes A502. Grade l. hot-driven rivets I 23 0=
~t A502. Grades 2 and 3. hot. driven ITS
{
rivets 29.0=
A307 bolta 22 o' 20.0=
l 8
Threaded parts meetmg the 10 0*1 j
requirements of Secta 1.4.1 and 1.4 4, and A449 botta msetmg the requirements of
- ')
Sect.14 4, when threads are I
4 not escluded from shear planes 0.33 f, " " l l
0 lif, a Threaded perta meetmg the i
I g
requirements of Sects 141 I
and 1.4 4. and A449 bolts
,;~
meetmg the requirements of
}
Sect. l.4.4. when threads are [
i j
~
j 1-escluded from shear plane *
' 0 !?f,**
y A325 bents. s hen threads are not !
0 22f,
- i
!U escluded from shear planes l 44 08
[r.
l A325 bulta. s hen threads are i
17 5 15 0 12.5 3
21 Of j'
escluded from sheer planes 44 Od 17.5 15 0 A490 holts. mhen threads are not
- 12.5 10 08 3
f escluded from shear planes i
54 08 22 0 19 0 A490 bolts. e hen threads are l
16 o 2d O' excluded from shear planes 54 Od f
22.0 19 0 i its 0 400' I f
- Static loadmg onl>
{
'
- Threads permitted m theer planes
!h, -
- The tensde capacity of the threaded porten of an upwt rod. based upon the crian sectiona area at its maeor thread diameter. As. shall tw larger than the nominal bodv area of the L
3 rod before upsetting times 0 60f, l
- For A325 and A490 botta subject to tensile fatigue heding.see Appendia h Sect B3
[
' When spectfeed bv the desymer. the allowable shear strm. f,. for inctum nT* connections having special faving surf ace conditions mas be increased to the apphcabie value give in Appendis E
' When bearmg type connections used to spisce tension members have a fastener patt whose length, measured parallel to tr e hne of force esceeda Vi inches tabulated values shall be reduced hv 20 percent 8 See Sect 15 6
" See Appendis A. Table 2. for values for rpecific ASTM steel specifuatu ns
- For hmstatuma on u e of oversized and slotted holes. see Sect i 23 4
.r 5 $$ AISC Specs /scatson (Effectwe IItIlini E
TABLE 1.2: 4 M A AIMi1M 84'.>>* OF F AATF.NFH H ol,FA iNCHFa
/
W Standard Overnaredh Short Slotted" I
Long Slotted'-
Hole Hole Hole Hole Diameter Dimension.
Dimennion-b Diameter l idi p
7M 5 %
d + '/i.
d + h.,
a d + .,1 x ( d + '.. e 4 d + ' r i x 2 ' di l
y i
I l ','r l
l '!
l ',i x i ',,,
l 'a x 2 ',
{
4 i
-fd+b l d + 'h.
a d + ',,,,i x i d + i i a + ' o. i x l' 4 t
} Z l'/
l
- Sere
- are nominal i
I, l h Ngg p,7m,gggg ggygn gepf g ggy,g,,gg i
-I gouges greater than Winch that remam from cutting shall be removed hs grinding All re-entrant corners shall be shaped notch tree to a radius of at lea t j
%-inch 3
l 1.23.3 Planing of Edges l
Planing or finishing of sheated or thermally cut edges of plates or shape-w ill l
not be required unless specifically called for on the drawings or included in a i
4, stipulated edge preparation for weldmg t-l 23.4 Riveted and Bolted Construction-floles i
1.23.4.1 The maximum sizes of holes lor rivets and bolts shall be as stipu-2.i lated in Table 1.23 4. except that larger holes. required f or tolerance on location of anchor bolts in concrete foundations. may be used m column base details r;
l
'g. e 1.23.4.2 Standard holes shall be provided m member-to member connec-
- I
~
tions, unless oversized, short slotted, or long slotted holes m bolted conneco ns o
i are approved by the designer. Oversized and slotted holes shall not be used m N
riveted connections.
L f
If the thickness of the material is not greater than the nominal diameter of h
the rivet or bolt plus /e inch, the holes may be punched if the thickness of the 5d materialis greater than the nominal diameter of the rivet c' bolt plus Linch the holes shall be either drilled from the solid, or sub punched and reamed The die
-h for all sub punched holes, and the drill for all sub drilled holes, shall be at least b inch smaller than the nommal diameter of the rivet or holt. Holes m A514 r
M steel plates over % inch thick shall be drilled E.h D
1.23.4.3 Oversized holes may be used m any or all plies of friction type f,0 connections, but they shall not be used in bearing type connections. Hardened G
washers shall Le installed over oversized holes m an outer ply
- {
Short-slotted holes may be used in any or all plies of friction type f
1.23.4.4
}
or hearing type connections. The slota may be used without regard to direction of loading in friction type connections, but the length shall be normal to the di-I rk rection of the load in bearing-type connections Washers shall be installed over b
short slotted holes in an outer ply; when high strength bolts are used such I
washers shall be hardened.
l
)
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- w StructuralSteelfor Buildine e 5~%
TABLE I 2:1.5 l
l MINIMt'M Hol.T TMNstoN. istf%*
t.F.n. INCHFr Bidt Seze. Inche.
A:15 Hola, A49u B.Jts
.uedh long Slotted'*
12 15 I
Hole ions Ihmenskmn 19 24
=
s 4
~
~
u a...,
a... m si o
s m
is.
n,ms t,s
. m.s...
g
=
u.u 1,..i 14e 3g i
a Euualin n. n at specified minimum ten.ile atreninh.e4 Im.h.. rmmded uff tu nearent kip.
i 1
1.23.4.5 Long slotted holes may be used in only one of the connected parts cutting shall be removed hv etch Iree to a radius of at leait of either a friction type or bearing tpe connection at an individual faving surface.
i Long slotted holes may be used without regard to direction ofloading in fric.
f tion type connections, but shall be normal to the direction of the load in bear.
i ing type connections. Where long slotted holes are used on an outer ply, plate; l
washers or a continuous bar with standard holes, having a size sufficient to com.
it edges of plates or shapenill pletely cover the slot after installation. shall be provided. In high strength bolted the drawing or included in a connections, such plate washers or centinum bare shall he not less than b.in.
l thick and shall be of structural grade material but need not be hardetned. If hardened washers are required to satisfy Specification provisions for use of i
high strength bolts, the hardened washers shall be placed over the outer surface
.l **
eta cnd botta shall be as stipu.
of the plate washer or bar.
uirsd for tolerance on location issd in column base details.
Riveted and High Strength Bolted Construction-Assembling 1.23.5 All parts of riveted members shall be well pinned or bolted and rigidly held n member to member connec.
tad holesin bolted connections together while riveting. Use of a drift pin in rivet or bolt holes during assembling shall not distort the metal or enlarge the holes. Holes that must be enlarged to ittsd holes shall not be used in admit the riveta or bolts shall be teamed. Poor matching of hoies shall be cause r th:n the nominaldiameter of for rejection.
Rivets shall be driven by power riveters, of either compression or manually.
mehed, if the thicknessof the operated type, employing pneumatie, hydraulic.or electric power. After driving, h3 rivst or bolt plus Sinch,the they shall be tight and their heads shall be in full contact with the surface.
Riveta shall ordinarily be hot driven. in which case their finished heads shall punched and teamed. The die b-drilitd holes. shall be at least be of approximately hemispherical shape and shall be of unitorm size throughout g
u rivst or holt. Holesin A514 the work for the same size rivet, full, neatly finished.and concentric with the holes.
. N Hot driven riveta shall be heated uniformly to a temperature not exceeding 1950' F; they anall not be driven after their temperature has fallen below 1000* F.
my or all plies of friction type Surfaces of high strength bolted parts in contact with the bolt head and nut g typeconnections. Hardened shall not have a slope of more than 1:20 with respect tu a plane normal to the bolt i en outer ply.
axis. Where the surface of a high strength bolted part has a slope of more than 1:20, a beveled washer shall be used to compensate for the lack of parallelism.
s eny or allplies of friction type High strength. bolted parts shall fit solidly together when assemblei and shall, i
1 sed without regard to direction not be separuted by gaskets or any other interpmed compressible materials. When assembled, all joint surfaces. including those adiacent to the washers, shall be free l ength shall be normal to the di.
Washsrs shall beinstalled over of scale,except tight millscale. They shallbe free of dirt, loose scale, burrs,and Contact surfaces n str ngth botta are used, such other defects that would prevent solid testing of the parts.
P
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g-SECTION
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1977 EDITION i
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ASME BOILER AND PRESSURE VESSEL CODE AN AMERICAN NATIONAL STANDARD ANSI /ASME BPV.III.l.A SECTION III Rules for Construction of Nuclear Power Plant Components DIVISION 1 APPENDICES 1977 EDITION JULY 1.1977 t
ASME BOILER AND PRESSURE VESSEL COMMITTEE SUBCOMMITTEE ON NUCLEAR POWER THE A M E RIC A N SOCIETY OF MECH ANIC AL ENGINEERS United Ensincenns Center 343 East 47th Street New York. N.Y.10017
.t.
t it I
L t
1 a
APPENDIX I 2
Design Stress Intensity Values, Allowable Stresses, j
Material Properties, and Design Fatigue Curves
!ti Dense Stress lassaulty Values. S., for Clas I Campeesmas r
Tables I.I.0 Table 1 1.1 Design Stress Intensity Values.S., for Ferritic Steels for Class I 6
Co mpone n ts.........................................................
f Table 1 1.2 Design Stress intensity Values. S.. for Austemtic Steels. Hirh Nickel.
18 and Copper Nickel Alloys for Class 1 Components....... :...............
Table 1.l.3 Design Stress Intensity Values.S., for Bolting Materials for Class 1 Co mpone n ts........................................................ 30 Tables 12.0 Yleid Strength Values.S, 34 Table 12.1 Yield Strength. 5,. for Ferritic Steels.....................................
Table I.2.2 Yield Strength Values.S, for Austenitic Steels. High Nickel, 44 and Copper Nickel Alloys...........................................
12 Table 12.4 Permanent Stram Liraiting Factors...................................
Tables I.3.0 Tensile Strength Values.S.
Table 13.1 Tensile Strength Values. S.. for Ferritic Steels........................... 53 Table 13.2 Tensile Strength Values.S., for Austeniue Steels. High Nickel.
and Copper. Nickel Alloys............................................ 19 Table 14.0 Coemclents of Dermal Conduethity and nermal Dimeshity................ 57 68 Table 15.0 Coemclents of Dermal Espaassoa.......................................
69 Table 14.0 Modull of Elassicity of Materials for Given Temperatures....................
Tables 17.0 Allowable Stress Valees.S. for Class 2 and 3 Ca-ra==ets Table 17.1 Allowable Stress Values.S. for Ferritic Steels for Class 2 70 and 3 Compon e nts....................................................
Table 17.2 Allowable Stress Values.S. for Austenitic Steels and High Nickel and 84 Copper Alloys for Class 2 and 3 Components...........................
Table 17.3 Allowable Strest Values.S. for Bolting Materials for Class 2 98 and 3 Components....................................................
I Tables 14.0 Allowable Strees Values.S. for Class 3 Componeses Allowable Stress Values.S. for Femtic Steels for Class 3 Components..... 103 Table 18.1 Table 14.2 Allowable Stress Values.S. for Austenit c Steels for Class 3 Components... 107 3
4 Tame I-7.1 SECTION III, DIVISION I - APPENDICES I
TABLE I.7.1 ALLOWABLE STRESS VALUES,S, FOR FERRITic STEELS FOR CLASS 2 AND 3 COMPONENTS arede Nemwiel P-Gr.
Prodnet' Sees.
er Composit6en No.
No.
Perm No.
Type Close Neees Carten Steels C
1 1
(311131 C
1 1
Plate SA 285 A
(13)
C 1
l Wid. Pipe SA472 A45 (3)tgi C
1 1
Smts. Pipe SA 106 A
I131 C
1 1
Wid. Poe SA 155 C50 1
(311535 C
1 1
Plate SA 285 8
1131 C
t 1
Wid. Pipe SA472 A50 13Hty C
1 1
Wid. Pipe SA 155 C56 1
(3111T C-Si 1
1 Wid. Poe SA 155 KC55 1
(3)(13)
C Si 1
I Wid. Poe SA 155 KCF55 1
(3H13)
C 1
1 Plate SA 285 C
113)
C Mn 1
I Wid.& Smts Poe SA.333 1
(3H13)
C-Mn i
1 wid. & Smis. Tube SA 334 1
(3H13)
C 1
1 Piste SA414 C
(13)
C-Mn.Si 1
1 Plate SA442 55 (13)
CSi 1
1 Plate 5A 515 55 I131 C Si 1
1 Plate SA 516 u5 (131 C
1 1
WId. Pee SA471 CASS (3Hg3)
C Mn Si 1
1 Wid. Pee SA471 CE55 (3H13)
C 8
I W'd P*e SA472 ASS 13 113)
C Si 1
1 Wid. Pee SA472 855 (3it:33 C Si i
1 Wid. Pee SA472 CSS 13Hg3 C Mn Si 1
1 Wid. Poe SA472 E55 (3Hg C M n Si 1
1 Shape. Piete & ser SA 36 16H13)
CSi 1
1 F org.
SA 181 I
.7 C Si 1
1 Castmg SA 216 WCA (4)
C Si 1
1 Forg.
SA 266 1
(131 C Mn 1
1 F org.
SA 350 LP1 C-54 1
1 Castmg SA 352 LCA (4)
C-54 I
I CastPee SA460 WCA 14L C S4 1
1 WId. Pepe SA 155 KC60 1
13Ht3I C Si 1
1 Wid. Pepe SA 155 KCF60 1
13H13)
C Mn Si 1
1 Plate SA442 60 I13)
C-54 1
1 Plate SA 515 60 1131 C Si 1
1 Plate SA 516 60 (131 l
C Si 1
1 Wid. Pipe SA 471 C860 (3H131 i
C 54 1
1 Wid. Pee SA 471 CC60 (31113l l
C Mn Si 1
1 Wid Pee SA 471 CE60 131113)
C Si 1
I Wid. Pee SA 672 860 (3H13)
C SI 1
1 Wid. P oe SA 472 Cc3 131113)
C Mn-Se 1
1 Wid. Pee SA472 E60 13H1]
C Mn i
1 Smis. Pee SA106 8
1937 C Mn-Se 1
1 wid. & Smas. P pe SA 333 6
13H131 C Mn Si 1
1 Wid. & Smis. Tube SA 334 6
(3)(13) 1 I
B ae SA 495 835 1
1 Bar SA496 8
C 1
1 wid. Tube SA 178 C
(177 C
1 1
Smis. Tube SA 210 A1 (13 C 56 1
1 Wed. Pepe SA155 KC65 1
(3Hi'35 C Mn S.
1 I
Wid Pee SA 155 KCP65 1
13H13)
C Se 1
1 Casemg SA 352 LC8 141 C Se 1
1 Plate SA 515 65 t13)
C Mn Se 1
1 Plate SA516 65 t131 C Si 1
1 Md Pipe SA 671 C865 (3H131 70
N u
7.
APPENDIX 1 TaWe I 7.1
- i TASLE 17.1 tis ALLOWASLE STRESS VALUES,S, FOR FERRITIC STEELS FOR CLASS 2 AND 3 COMPONENTS k
W.
Allowebte Stress, hel (Muttiply by 1000 to Ottown pas),
Mme.
4At.
F: i 14essl Temperaturne. F, Not to E saeed
-?
Vised Teande
'9 Serenc s Swengde 100 200 300 400 900 000 000 700 790 000 e
i Carbon Steels
]
r:
24 4 45 0 11.2 11.2 11.2 11.2 11.2 11.2 11.2 10A
.4
=
30 0 48.0 12.0 12.0 12.0 12.0 12D 12.0 12.0 11.6 27.0 50.0 12.5 12.5 12.5 123 12.5 123 12.5 12.1 i
30.0 55.0 13.7 13.7 13.7 13.7 13.7 13.7 13.7 13.2 36 0
$8.0 12 6 12.6 12.6 12.6 12.6 12.6 12 6 12 6 30 0 60 0 IS O IS O 15 0 IS O 15 0 15.0 15.0 14.3 320 60 0 15 0 15 0 15 0 15 0 IS O IS O 15 0 14.3 36 0 60 0 IS O 15 0 15 0 15 0 15 0 IS O 15 0 14 3 37 0 60 0 15 0 15 0 15 0 15 0 IS O 15 0 15 0 14 3 00 65 0 14, 2 16 2 16 2 16 2 16 2 16 2 16 2 IS 2 71
O s
APPENDIX I TaWe 17.I TABLE 17.1 (CONT'D)
ALLOWASLE STREM VALUES,S, FOft FERRITic STEELS FOR CLASS 2 ANO 3 COMPONENTS h
au Seren, kei IMuisspey by 1930 se Otseaws pad.
IAt-Per Messe Tomparetores, P. Net se Esosed Yiesd Yonede Serengsg Serengsh top 200 3m 400 900 000 000 700 790 See High Alloy Steels (Cont'd)
Precipitation Herdened Steels (Cont'd) 115 0 I40 0 35 0 34 35.0 34.9 33.3 328 32.4 32.2 t 25 0 145 0 34 2 36 2 34.2 36 2 34 5 34 0 33.7 33.4 Mernest at Eenmenetron Quaker facter fel Viewei 0 80 Ibl Magnetie Particle 0 86 ist Leewid Penetrent 0.86 fdl Modeogroony 1.00 tel Ultreeon.e 1 00 ifl Meene'ie Particle or Laswas Penetrant oeve uttresonie or Med.ogroony 1.00
($1 Not for veoided construction, tel The use of enees materiets snell be temeted to ensteriods for swooorts and hengers and for tennis covered en Subesctions NC and NO The ettomente strees in one enort trenoverse e.VTl o.rection for otstes snell be d. meted to one.nelf of the f.sied weaves.
179 3 volves and P.Numeees for essel feet.nge sneal ne the some se tnoes essegned to the meteries from wenien the fattings are made.
Festings enesi tie enese only from motorisse lessed en thes fonte Housever, the meterials tooverements of the referenced meteries sesofiestion need be met only se reewered bv ene 8sttmg specification.
O These ettoss ve#wes soo6y ta meterist that not Deen eve nordened at 1160 P.
O f nees stress weevee secey Io meterial that mes eeen ege meroened et i100 F IIJ These stress veswes ecos, eo matersee inst nas noen age nereened et 10 PS P.
I111 Orsoe S. C, or O of SA.302 mov ee noecifieo i12) Any geode of sne piste inecif wereon may oe em8 ed.
1931 For E aternet Pressure Chart reference, see Teo6e 814 0.
9 8)
CASE ATTACHMENT C ASME BOILER AND PRESSURE VESSEL CODE AN AMERICAN NATIONAL STANDARD ANSI /ASME BPV-IU-1-NF SECTION III Rules for Construction of l
Nuclear Power Plant Comp.onents DIVISION 1 - SUBSECTION NF l
Component Supports t
1977 EDITION JULY 1,1977 ASME BOILER AND PRESSURE VESSEL COMMITTEE SUBCOMMITTEE ON NUCLEAR POWEA eq THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS Ussted Engineering Center 345 East 47th Street New York. N.Y.10017 L.
NF.3346-NF.3362.2 SECTION 111. DIVISION I - SUBSECTION NF NF.3240 DESIGN OF COMPO.STNF STANDARD SUPPORTS BY ANALYSIS
/
The requirements of NF.3220 or NF.3230 apply as applicable.
04 0.S Sm aaLh;L d d si JLsi NF.3250 EXPERIMFNFAL STRESS ANALYSIS l
x Component supports of all types may be designed j
by experimental stress analysis in accordance with Appendix II.
NF.3244 DESIGN BY LOAD RATING NF.3261 Pmcedure for lead Rating ne procedure for load rating shall consist of l
imposing a total load on one or more duplicate full t.:
size samples of a component support equal to or less
/
/
than the load under which the component support fails to perform its required function. A single test sample is permitted but. in that case. the load ratings 8""'#m shall be derated by 10'"c. Otherwise. tests shall be run dad d aJL on a statistically significant number of samples.
4 NF.3262 Land Ratless la Relation to Senin f
[
f
'8' De load ratings for Service Loadings for which Level A. Level B or Level C Lirmts have been designated shall be determined by means of the equations in the following subparagraphs. For Level D Limits.see Appendix F.
NF.3262.1 Noemesclatwe. De symbols used in this C
paragraph are denned as follows:
T.L. = support test load equal to or less than the load under which the component support s, = 0.en nem ine.ne.io.a.e fails to perform its speciAed support function o = m.mem e ne.ie nem sn in. inreven tnenm e.,wi.on f.,,= allowable value for the type of stress in et cem one ei.m.nie.# v..w en w.
so.w ei ine XYll ll00of Appendix XVil at i et in id eru in ene ei. ment eu,#we S= allowable stress value at the design tempera.
ture (NF.J il2.2) from the applicable table of Appendis i FIG. Nr.3226.51 lLLUSTRATl0NS OF S.=specined minimum tensile strength of the MAXIMUM DESIGN STRESS IN THROUGH.
matenal used in the support as given in the THICKNESS DIRECTION OF PLATES applicable table of Append s l AND ELEMENTS OF ROLLED SHAPES NF.3 W W
l De load.
ratings for slate and shell supports for the Service Loadings saall be deternuned by the following equations:
40
,- v g
Level A Limits 13.3 of Appendix I muhiplied by the cpplicable design f:ctors of Table XVil 2461.1 1.
ioad ratirg =T.L x 1.0f (1) vel B Umits b
NF 3290 DESIGN OF WELDED JOLVTS f c,
r u
s load rating =T.L X 1.0g (2)
NF 3291 Permissible Types of Welded Joints 1
- d. M Plate and Shell Type Welded l M$*)F LevelC Limits Supports i
load rating = T.L X l.2 f" (3)
(a) All welded joints in plate and shell type supports shall be continuous and shall be one of the NF 3262.3 I h==e Type Suppoets. He load ratings types shown in Fig. NF 3291(a)-l and described in for linear type supporu for the Service Loadings shall (1) through(4 below:
be determined by the followmg equations:
(1) full penetration butt welded groove joint, sketch (a) w,,ve.
Level A Limits (2) double %fter welded oint, sketch (b) 7 load rating = T.L X 1.0 p,"
(4)
(J) full penetration groove welded tee joint.
sketch (c)
Level B Limits N) full penetration groove welded corner b
load rating = T.L x 1.0 (5) joint. sketch (d)
Mi figet welded eye joip'ts, sk Su (J) fillet w elded jom,'et'ch (f)
~i,(',".,
gle nts.p Level C Limits t between a surface,and a '
F (7) load rating = T.L X 1.13.n
.(6) closed tubular section or a closed section, sketchesF' 3"
(g) and (hl NF 3262.4 C-x;=nt Standard Supports. He (3) fillet weldec joint between the edge of a i
load ratings for component standard supports for the plate and the end surface of a closed tubular section Service Loadings shall be determined by the follow-or a closed formed section. sketch (i) v'.
ing equations:
When angle jomis are used for connecting a tranu Level A Lirn>ts ition in diameter to a cylmder. the angle, a. of Fig. 6 S : i F.n NF 3291(a) 1 skeich(fi shall not exceed 30deg.
i load rating = T.L x 1.0 (7)
(b) A tapered transinon having a length not leu than three times the offset between the adjacent Lesel B Limits S or F.n surfaces of abuttmg sections. as shown m Fig. NF.
load ratmg = f.L x 1.0 16' 3291(bbl. shall be provided at jomts between sec.
tions that differ in thickness bs more than one fourth plate and shell of the thickness of the thinn'er section or by more LevelC Limits than h in. (3.2 mm). whichever is less.The transition may be formed by any process that will provide a load rating = T.L X 1 ' 5, (9ai uniform taper. De weld may be partly or entirely in linear type the tapered section or adjacent to it. This paragraph LevelC Limits also apphes when there is a reduction in thickness F
within a sphencal shell or cylindrical course or plate.
load rating = T.L x 1.33 pn i
(9b)
(c) When the use of backing rmgs will result in undesirable conditions such as severe stress, corro-sion, or erosion. the requirements of NF 4240 shall be NF 3280 DESIGN OF BOLTS met.
NF 3281 Imel A and leel B Senice Umits NF 3291.1 Design Stren Intensity and Allowable
.i The number and cross sectional area of bolts Stren Units for Welded Joints. De limits of design required for the design loadings of NF 3112 shall be stress intensity for welded joints for plate and shell e.
Q,. determined in accordance with the procedures of type supports shall not exceed the appheable design
' hr ( '
Appendia XVil. The allowable bolt design stress stress intensity value or allowable stress value for the values shall be the yield strength values of Table I-base metal bemgjoined or the electrode bemg used.
il 41 e
NF 3000 - DESIGN NF 3291.1-NF=3311 e
- ~^
~
/33y. whereles required length of taper and y es b
the of fset between the
(
odiacent wrfaces of abutting sections y
I NOTE: Length of required taper,/, may include the j
wndth of the weld.
l l
I Weld h
tal in ail cases / shall be not less than 3y.
tDI FIG. NF 3291(b) 1 BUTT WELDING OF PLATES OF UNEQUAL THICKNESS Temperature differences between the component and support and, where applicable, expansion or contrac-its support and, where applicable, expansion or tion of a component produced by internal or external contraction of a vessel produced by internal or pressure.shall be considered.
caternal pressure shall be considered.
NF.3292 Periniulble Tges of Welded Joints in NF 3300 DESIGN OF CLASS 2 Unear Type Welded Supports COMPONENT SUPPO"tTS The pernussible types of welded joints used in NT 3310 GENERAL REQtl1REMENTS hnear type supports shall be as stipulated in XVil-2450.
ST 3311 Acceptability ST 3292.1 Allowable Stress Units. ne allowable The requirements for acceptability of Class 2 stress hmits for welds in linear type supporu shall be component support design are given in (a) through as sei forth in Table NF 3292.1 1.
(d) below.
(a) ne design shall be such that the design stresses will not exceed the limits given in this NF 3293 Perniluable Types of Welded Joints in Subarticle. Table NF 3132.l(b) l indicates the rules Cx;not Standard Sepurts to be used for the various classes and types of design ne permissible types of welded joints used in Procedures. De applicable table of allowable stresses for a given material to be used with a specific design component standard supports and connections shall pr cedure is stipulated in Table NF 2121 1.
be as supulated in NF 3291(a) and NF 3292.
(b) ne design procedure shall be one of those NT 3293.1 Deelen Strem latensity and Allowable referenced in TaHe NF 3132.l(b) l applicable to Strees Wadu for Welded Jonats. De limit of design Class 2 component supports.
stress intensity or of allowable stress for welded joints (c) De design details shallconform to the rules of for component standard supports shall not exceed the this Subarticle.
applicable design stress intensity value or allowable (4 For configurations where compressive stresses stress value for the base metal beingjoined. Tempera-occur, the potential for crincal buckhng shall be ture differences between the component and its considered.
43 ess e
p:
I
- l. i SECTION III. DIVISION I - SUBSECTION NF
{
j NF.3326-N F.3321.2 TABLE NF.3292.11
~
l ALLOWABLE STRESS LIMITS FOR e'
LINEAR COMPONENT SUPPORT WELDS-ALL CLASSES o
Base Metal d
Stress Umits, T.S. Range.
ksi ksi Kjnd of Stress l
l Tension and compression parallel to amis of any Same as for base metal complete penetration groove weld I
Same as allowable tensile i
Tension normal to effectrve throat of complete stress for base metal I
penetration groove weld Same as allowable compressive Compression normal to effectrve throat stress for base metal of complete or pa.tlai penetration groove weld Same as allowable shear stress Shear on effective throat of complete penetration for case metal groove weld and partial penetration groove weld l
45 60 Shear stress on effectrve throat of fillet weld 18 regardless of direction of application of load; 61 70 21 tension normal to the amis on the effective throat of a partia penetration groove weld 71 80 24 and snear stress on effectrve area of a plug or slot weid. The given stresses shall also apply 81 90 to such weids made with the specified e'ectrode 27 on steet naving a yield stress greater tnan that 91 100 30 of the matchmg base metal. The ailowable stress, regardiets of electrode classification 101 120 l
used. shall not onceed that given in the table 33 for the weaker matchmg case metal being l
121 135 i
36 j
Jomed-h NF.3320 DESIGN OF PLATE AND SIIELL oi = maximum tensile stress at the contact surface TYPE SUPPORTS BY ANALYSIS of a wc!d producing a tensile load in a direction through the thickness of plate and NF.3321 Stress Limits rolled shape elements, as shown in Fig. NF.
332I IIC)*I S = allowable stress valuejf'ro/m the appli
~
N F.3321.1 Design leadings.The ress3 linuts are satis 6ed for the Desian Loadings (N 2142.1) stated Table of Appendix I as referenced in Table
. [
in the Design Speedications if the requirements of NF 2121(a).1
'.i, Eqs.(l),(2). and (M are met.
, ( {,,[
I on $ l.0S (1)
NF.3321.2 Service Loadings (2) lxvel A Service Limas. Level A Semce Lim
**3h]S (a) t 2t'hl are satis 6ed for the Service Conditions [N4 s
-a 2142.2tMl for which these limits are des i
where Design Speci6 cations if the requirements of Eqs. (1).
oi = membrane stress $hich is the average stress 3'
across the solid section under consideration.
(2). auf(3) of NF.3321.1 are met.
It includes the effects of discontinuities but (b) I_nel B Service Limits. Level B Servise Limits are satisfied for the Service Conditions (RA.2142.2 notlocal stress concentrations, os = bending stresthhich is the linear varying (bhfor which these limits are designated in the Design portion of the stress across the solid section Speci6 cations if the requirements of Eqs.(l) (2).afw6 under consideration, it excludes the etiects (h of NF.3321.1 ate met.
'l of discontinuities and concentrations.
(c) t.nc/ C Scruce Lemus. Level C Service Li s
u]
are sate ed for the Service Conditions [i <.
n 2142.2M] for which these Imuts are designated in the 8: m means the mammum normal stem.
g ',.L 44 f
NF-3321.2-NF 3360
. f$
NF-3000 - DESIGN
. 4/;,-
g r, Design Specifications if the requirements o
,.. r" and (2) of NF-3321.1 are not exceeded by more than 20L...J Z J.,.ym a of Q.p)of NF032M is t
M f
(d) Lavel D Service LJmits. Level D Service
'ts are satisfied for the Service Conditions 0'058 2142.2(M for which these limits are designated in the ahAnaA h h h d
Design Specifications if the requirements of QJi'%
NF 3321.1, and Eqs. g and g below, are met.
6 a,4 lesser of 1.5S or 0.4S, h),
6 ai + a < lesser of 2.25S or 0.65,
)
f where u
S,=specified minimum ultimate tensile strength k's of material. Table-Met /.J.O
-g Other terms are as dermedin NF 3321.1.
s.
l s
3rp NF 3330 DESIGN OF LINEAR TYPE SUPPOR'I3 BY ANALYSIS J
The design rules and stress limits which must be l
satisfied for the Design and Service 1.o2 dings are as oc o3, AAA AAA givenin NF 3230.
I 8
V NF 3340 DESIGN OF COStPONENT STANDARD SL'PPORTS BY ANALYSIS The design of component standard supports shall
' T-be in accordance with NF 3320 or NF 3330.
1rr NF.3350 DESIGN BY EXPERIMENTAL (bl o - us.imum ionii. iiresi n ine inrove inickness directica STRESS ANALYSIS of plates end elements of rolled sneces. evaluated at ine Component supports may be designed by experi-coniset oo ni of ine weio eres wiin ene eiement sudecementti stress analysis in accordance with Appendix 7 - Apow lood 11.
FIG. NF 3321.1(c) 11Lt.USTRATIONS OF MAXI.
MUM DESIGN STRESS IN THROUGH THICK-NESS DIRECTION OF PLATES AND ELEMENTS 0F ROLLE0 SHAPES NF 3360 DESIGN BY LOAD RATING Component supports may be designed by. load rating in accordance with the requirements of NF-3260.
45
NF 4000-FA RICATION AND INSTALL ATION NF 4646-NF 4721 2, '
NF-4640 HEAT TREATMENT AFIIR be used unless the load bearing surfaces are REPAIR BY WELDING machined or ground smooth. De die for all sub-punched holes shall be at least ' lie in. (1.6 mm)
P
/
r NF 4641 Rules Governing Heat Trenament smaller than the nominal diameter of the bolt.
~
'd After Repair by Welding (c) Bolt holes in material over % in. (13 mm) thick having a spectned mammum vield strength greater
,y-Component supports, parts and materials that than 80.0 ksi(552 MPa). shall be drilled.
have been repaired by welding shall be postweld heat
/
(d) Oversized. short slotted. and long slotted bolt q
es ed in accoruance with the requirements of NF-holes may be used with high strength bolts % in. (13 s
mm) in diameter and larger except as restricted in (I),
6 (2), and (3) below, i
(1) Oversized holes shall not exceed hin. (4.8 mm) larger than bolts % in. (22 mm) and less in N 00 REQUIREMENTS FOR 5"
diameter, % in. (6 mm) larger than bolts I in. (25 mm)
BOLTED CONSTRUCrlON in diameter. and W in. (8 mm) larger than bolts 1%
NF-4710 BOLTING AND 'IIIREADING in. (28 mm) and greater in diameter. Rey may be used in any or all plies of friction type connections.
NF-4711 Dread Engagement Hardened washers shall be installed over exposed
/
ne threads of all bolts or studs shall be engaged slotted holes shall not exceed in.
for the full length of thread in the nut.
(1.6 mm) wider than the bolt diameter and shall not have a length exceeding the overstre diameter al-a
/
NF-4712 Dread bbricants lowed in (1) above by more than 1/16 in. (1.6 mm).
'5ny lubncant or compound used in threaded joints ney may be used in an,s or all plies of fnetion type or bearing-type connections. The slots may be used shall be suitable for the service conditions and shall without recard to direcuon orloadmg in friction type not react unfavorably with.any support element connection $ but shall be normal to the direction of matenal. Contact surfaces within fncuon type jomts the load in bearing-type connections. Hardened shall be free of oil, pamt. lacquer or galvamzmg.
washers shall be installed over exposed short-slotted holes.
NF 4713 Removal of Dread Lmbricants
(.1) kng slotted holes shall not exceed in.
TI.6 mm) wider than the bolt diameter and shall not All threading lubricants or compounds shall be have a lensth which exceeds 2% times the bolt
.~
remond from surfaces which are to be welded.
diameter. In' friction type connections, the long slot-ted holes may be used without regard to direction of loading provided the stress on the bolts does not
, NF 4720 BOLTING exceed 75% of the allowable working stress given in NF 3000. In bearing type connections. the long g4F-4721 Bolt Holes diameter of the slot shall be normal to the direction of Bolt holes shall meet the requirements of (a) loading. Long-slotted holes may be used in only one through(e)below.
of the connected parts of either a friction type or (a) Holes for nonfttted bolts shall be b in. (1.6 bearing type connection at an individual raying mm) larger than the nominal diameter of the bolt for surface. Structural plate washers or a continuous bar t
bolt sizes up to and including i in. (25 mm) and % in.
not less than k in. (8 mm) tn thickness shall be used
' (3.2 ram) larger than the nominal diameter of the bolt to cover long slou that are in the outer plies ofjoints.
foriazeslagter than l in.(25 mm).
These washers or bars shall have a size sufficient to (b) Ezcept as specined in (c) below, holes may be completely cover the slot after installation and shall punchid provided the thickness of the materialis not meet the requirements of NF 3000.
greater than the nominal diameter of the bolt plus %
(e) For bolts not subjected to shear, the limits for in. (3.2 mm). Holes shall be subpunched and reamed.
oversized and slotted holes in (d) above may be
- drilled or thermally cut when the thickness of the increased if structural plate washers or continuous
- matetial is greater than the nominal diameter of the bars which meet the requirements of NF 3000 are bolt plus 4 in. (3.2 mm). Hermal cutting shall not provided..
65 4
I j
. g S
l
\\
\\
NF.4723. NF-#F25 SECTION lit, DIVISION I - SUBSECTION NF i
NF-4722 Behad Mh
@tions. Tightening,shall be done by the turn 0
(a) Surfaces of boltedparts in contact with the of nut method or with properly calibrated wrenches.
bolt head and nut shall net have a slope of more than Bolts tightened by means of a calibrated wrench shall k Wh& a M washa & se nut w 1:20 with respect to a plane normal to the bolt axas, Where the surface d high strenge bolted part has a bolt head, whicheveris the element ttwned in tighten-slope of mm &an 1:20, a W washer sW k ing. Hardened washers are not required when bolts used to cornpensate fw & clack ofgh are tightened by the turn of nut method, except that (b) Bolts loaded m pure shear shall not have hardened washers are required under the nut and bolt head when the bolts are used to connect material threads located in se load hg part dee M unless permitted by the Design Wh ions.
having a.W yield point less than 40.0 ksi (276 t
MPa).
NF-4723 PW Before Boldng All parts assembled for bolting shall have contact surfaces free from scale, chips, or other deleterious NF4725 WW material. Surfaces and edges to be joined shall be smooth, uniform md free from fins, tears, cracks.
All threaded fasteners, except high strength bolts, and other defects which would degrade the strength shall be provided with locking devices to prevent loosemag during service. Elastic stop nuts (when of thejoint.
compatible with service temperature), lock nuts jam NF M M 'TW nuts, and drilled and wired nuts are all acceptable locking devices. Disk and helical springlock washers All high strength structural halts shall be tightened shall not be used as locking devices. Upset threads to a bolt torque not less than tnat given in the Design may serve aslockmg devices.
4 ja a
f
,\\
a e.
)
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66
.--w,
.-.-..a-.
'N CASE ATTACHMENT D
- s..
.j N.
.QNL Review of Texas Utilities Generating Company Comanche Peak Steam Electric Station Upper Lateral Restraint Beam - Steam Generator Contributors M. Reich, C.J. Costantino, S. Sharma, C. Miller and A.J. Philippacopoulos 9
4 i
(.
j
~s i
I' e
' ~~.
\\
INTRODUCTION On August 14 and 15, 1984, an audit was conducted by NRC and BNL at the offices of Gibbs and Hill, Inc. (G & H), New. York, on the subject of the upper lateral support beams (see Figures 1 and 2) for t'he steam generator compartment. At this meeting, various aspects of the structural analysis and design of the steel beam and concrete compartment were investigated. At the conclusion of the meeting, G & H was asked to provide additional information which was needed to complete the review. This material was received during
. the final week of August. Additional material and clarifications were required during the review process. These were obtained via telephone converstations and meetings held at BNL in Upton, NY, at NRC in Bethesda, MD and Gibbs and Hill in New York City. Specific dates for these meetings are November 5, 1984, November 13, 1984 and December 5, 1984 The BNL evaluations have now been completed and the specific findings are sumarized below.
LOAD COMBINATIONS Three separate load conditions were considered in the structural analysis, two LOCA loadings (at 0.5 and 216 seconds) and a Main Steam Break at 324 seconds. These load conditions were composed of combinations of pressure,
. temperature, dead, live, mechanical loads including primary system seismic loads, and seismic loadings from compartment motions. The last of these, seismic from compartment motions,.were obtained from the peak acceleration output determined from the dynamic analysis of the stick model of the RCB.
The other loadings, having been previously investigated by the MEB of NRC, and thus were not considered as part of this audit. All load components for each load condition are summarized or pages 2 and 3 of the Letter Report GTN-69363 from G & H to Texas Utilities, dated August 21, 1984.
NONLINEAR FINITE ELEMENT STUDY A detailed nonlinear finite element model (FEM) analysis of the upper lateral beam and concrete compartment walls was performed using the EBASCO version of the NASTRAN computer program. The nonlinearity in the problem was introduced by allowing concrete cracking to occur as the load combination was l
applied to the structure. Since the problem contains nonlinearities, all u
.. !~... q.........
... _ ; _ q...
.___.._...p.
i
, applied loads, including seismic loads, must be applied at the same time to properly assess the extent of cracking. This was done by G & H.
Seismic loads were applied to the G & H model in three coordinate directions, two horizontal and one vertical and were scaled such that 100% of the seismic load was applied in the MS direction,'40% N the EW direction and 40% in the vertical direction. Normally, seismic analyses are performed by applying the dynamic loads independently in opposite directions. For this nonlinear analysis, such an approach leads to the requirement of performing nine separate analyses. G & H parformed two such analyses for the seismic loadings.
The FEM used by G & H was developed for one-half of the concrete compartment, since the compartment is symmetric ab6u~t the NS direct P j e model extends from an elevation of about 81g' at the bottom to 88Mt the top.. Boundary conditions app 1;ed to the top and bottom nodes of the FEM are considered reasonable in view of the actual construction of the compartment.
Along the centerline, however, the node points were restrained in the EW direction (by using roller supports in the NS direction). The use of this boundary condition leads to the result that the EW seismic loading conditrion' cannot be correctly treated, since the model is artificially restrained. For the other loading types, namely pressure and temperature, this boundary condition-is reasonable, since both the applied loadings are synamtric for these cases.
Thus, considering all the loads applied to FEM, two questions remain on the adequacy of the calculations associated with the seismic loads; namely, only two seismic load combinations were considered, and the boundary conditions used invalidate one component calculation. To evaluate the impact of these two restrictions on the nonlinear analysis, the results of previously, obtained linear finite element seismic analyses were investigated. These analyses were performed by G & H using STARDYNE and hence did not suffer from the two restrictions mentioned above.
Concrete cracking effects were not considered in these runs, however. The results of these runs indicate that I
,==
. the stresses developed by the seismic loads are very small as compared to the stresses developed by pressure and thermal loadings. Therefore, it is our judgement that the deficiency in the analyses associated with the seismic loadings are not significant.
It should be noted that BNL arrived at this conclusion using the results of G & H's TARDYNE output together with a mesh diagram.used for that run.
Another aspect of the numerical studies of interest to the audit team has to do with the verification of the modifications inserted into the NASTRAN Computer Code inserted to perform the nonlinear cracking analysis of con-crete. The analytic formulation of the model was ascertained and based on
.BNL's experience with concrete crack modeling it was found to be reasonable.
In addition. ESASCO was asked to perform two other computer model studies to further verify the applicability of the code to this particular type of load-ing problem. These had to do with the probles of bending behavior of members with significant axial loads.
NASTRAM VERIFICATION RUNS After the audit of kugust 14 and 15,1984 EBASCO performed the evalua-tion of several check problems. The results of these were sent to BNL early
)
in September. After studying the output and after consultation with istC
(
staff, it was decided to further investigate one of these problems in greater detall. The specif1e problem (identified as CA29 in the EBASCO subaittal),
and involves the prediction of load / deflection / cracking behavior and failure conditions for a RC beam rigidly held at both ends and centrally loaded.
A detailed finite element grid was developed by ESASCO, consisting of 200 elements,10 layers through the thickness and 20 divisions along the half length. BNL used the same mesh and boundary conditions, and ran a comparable s
s
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- - = - - - - -
c
. analysis using the NFAP program (developed at BNL). The results d these two runs can be described as follows:
1.
At low loads of (about 15 kips in the linear region, before the de-velopment of substantial concrete element cracking), the two runs yield comparable load-deflection output.
- 2. : At higher loads (about 22 to 24 kips), the BNL/NFAP results pre-dict diagonal tension cracking failure occurring near the supports for the beam. This result is very close to the value of ultimate capacity predicted by ZSUTTY'S equation, which is based on statis-tical evaluation of extensive experimentally determined data points.
(Bazant & Kim, paper 81-38, ACI Journal September - October 1984).
It should be noted that this failure load could also be deduced from the ACI Code.
3.
The failure pattern predicted by NFAP. indicates that multiple cracking will develop in some of the elements of the mesh, prior to failure of the, beam.,
4.
The results from NASTRAN indicate no failure even at.a load of 32 kips where the run was terminated.
5.
The predicted crack pattern for this NASTRAN run (Sept. 84) did not Indicate any multiple cracking. In fact, the brief review of the output from all four sample problems presented by EBASCO did not show any mulitple crack patterns.
At this stage, a second meeting was held between BNL and EBASCO to discuss these comparisons. This meeting was attended by R. Iotti and H. Chang who represented EBASCO/G&H and S. Sharma and M. Reich from BNL. The outcome of this meeting was that EBASCO would check the NASTRAN results and screen the problem to validate the EBASCO predicted results. At a subsequent meeting
~
,==
~~.
l
. 1 (November 5,1984) at BNL, the results of the new computer runs for (EBASCO CA29) were presented by H. Chang. The written report given to BNL is attached to Appendix 1 of this paper. These results can be summarized as follows:
1.'
EBASCO was able to show a failure load of 24 kips (comparable to test data) only by assuming a tensile strength of 120 psi, which is four times lower than the strength that would be nonna11y assumed for the concrete. (It should be noted that in the.,Jeptember run, the concrete tensile strength used in NASTRAN was 546 psi.)
/
2.
The.EBASCO results show that failure is associated with shear failure accompanied by very large displacements. This is contrary to the results of other studies, including the BNL/NFAP results, as well as experiments.
Diagonal tension failure in concrete is typically a brittle failure at normal displacements.
3.
The results of the E8ASCO runs indicate that the assumed value of the shear retention factor has no impact on the computed failure loads (this factor was varied from 0.2 to 0.4).
This is not supported from studies reoorted in the literature, nor from the BNL/NFAP results. An O
ease in of shear retentIoibfactor from 0.1 to 0.4 should lead to an increase in ultimateMy of the beam of about 20%.
\\
4.
The multiple crack pattern shown by ESASCO for this new run indicates
~
cracks orthogonal to each other. This result would not nonna11y be i
expected and needs further explanation.
{
l On the basis of these results, BNL concludes that the ESASCO formulation of j
the concrete cracking model as implemented in their NASTRAN version leads to l'
incorrect results for this verfication problem. Therefore, the adequacy of l
the results from the code for the steam generator compartment cracking prediction are considered questionable.
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EVALUATION U UPPER LATERAL SUPPORT BEAMS (ULRB)
.& Q 4W.
q,d The four upper lateral restraint beams in the steam generator compartments are subjected to high thermal loads especially for the Main Steam Line Break (MSLB) case. G & H was requested to provide calculations showing that an upper bound estimate of the. axial and bending stresses in the ULRB would still comply wiy#I5f-1.6-lalequirements. These computations were included in the G & H 1.otte omrt GTN-69363 mentioned previously. A review of the data.however, shows that the stresses were calculated for a peak temperature of 282*F which corresponds to a LOCA temperature loading. For the MSL8,'the peak temperature reaches a value of 355'F according to G & H and ESASCO. For this latter case BNL carried out computations assuming rigid walls and found that the upper bound estimate (for the cas'e when the beam is assumed -f4xed at both ends) of stresses would not be in compliance with AISC-lj.6-a. It should however be noted, that this assumption is unreartstically conservative and if reasonable if co rvative assumptions are made concerning the concrete wall flexibility, e stresses in the beam will be reduced significantly and they then satisfy AISC-1.5-la. A sample calculation is provided in Appendix 2.
These calculations show, that even if only through thickness compressive flexibility of the wall is considered, the beam stresses would reduce to allowable levels.- In reality the walls are even more flexible because of bending and shear deformations, and thus, the beam stresses will be substantially lower.
In all of the discussed calculations above, the assumptions were that the i
beam is rigidly held by the concrete walls, i.e., no end rotations are possible. This condition would change if sne walls crack around the beam end supports. The beams could then be considered as simply supported instead of fixed. -The net effect of this condition would be a further reduction in the t-thermal stresses. However, for the case of seismic loads this change of and
[.
fixity.would increase the bending stresses by approximately a factor of two.
This is due to the fact that the maximum bending moment in a centrally loaded beam with simply-supported ends is twice that of a beam with fixed ends.
BNL, therefore, evaluated the adequacy of the ULR8 under seismic laods
~
assuming simply supported conditions. Both, the deflections as well as the stresses in the beam were found to be much below tne a\\1.owable limits.
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. should be noted. however, that in carrying out this latter evaluation, BNL utilized the loads provided by G & H who obtained them from Westinghouse.
The modeling assumptions used by Westinghouse especially with regards to 1
gap-impact phenomena between the steam generator and the ULSB were not evaluated.
EVALUATION OF CONCRETE WALLS G & H and EBASCO used the modified NASTRAN results to establish the adequacy of the reinforced concrete walls for the four steam generator compartments. In particular G & H,provided calculations to show that the concrete walls of the steam generator compartments satisfied ACI shear strength criteria. These calculations are however based on stresses obtained 4
from the NASTRAN runs. Since BNL had questions pertaining to the adequacy of the modified NASTRAN code, especially with regards to the shear failure mode, it was decided to evaluate the walls using simplified engineering concepts.
In performing these evaluations, flexibility calculation for the walls were made assuming that the walls deformed as plates fixed along the intersection lines with supporting, floors or walls. The reactor' cavity walls were found to be much more flexible than the outer compartment walls which are stiffened by vc.-ious intersecting floors. Because of this flexibility the interior wall will deflect and substantially reduce the axial thermal thrust induced by the ULSS. Based on the reduced thrust it was however still found that the reactor cavity walls undergo substantial flexural and shear (punching type) cracking. This type of failure is not likely to occur at the outer walls of compartments 1, 2 and 3, because of the intersecting floors (although some cracking of the concrete will probably also occur there).
In compartment 4, the intersecting floors are outside of the punching shear, zone, and hence,
[
cracking cannot be precluded there. It should be noted that thermal stresses l
are self limiting and consequently once this failure occurs, the beam expands axially, 'and the total thrust is corresponding reduced. Actually, the beam only has to expand approximately 1/3 of an inch to completely relieve its stresses. It is therefore judged that the cracking will be of a localized nature and will not significantly affect the overall structural integrity of 4
the compartment walls.
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~..
. Because of the localized stress and deformation condition around the beam supports, the structural response away from the supports should not be affected. Thus, with respect to the question pertaining to missing rebars at a much lower elevation, it is BNL judgement that the missing rebars will have negligible effect on the evaluations carried out for this report.
ANCILLARY INVESTIGATIONS 9
In addition to the above items, several other questions were raised during the audit to which G & H was asked to respond..These had to do with what are considered to be relatively minor problems and those which, based upon engineering judgement and experience, could be relatively easily quantified.
1.
G & H was asked to provide calculations to show that in fact the con-crete walls of the compartment are stiff enough such that the pres-sure rise time of LOCA loading is slow enough to eliminate dynamic effects. Such was in fact the case, with a dynamic load factor calcula-ted to,be about 1.0.
2.
Calculations were requested to show that local buckling and torsional loading effects on the upper lateral restraint beam do not lead to a reduction in ' stress allowables. They do not. It should be noted that the stress resultants used for these calculations were taken from the EBASCO/NASTRAN nonlinear output and as such may be in error. The moment resultants shown to us were small (on the order of at of the allowable for the MSLB case). Thus, even if they are in error, they e
should not influence the overall conclusions.
3.
Additional calculations were requested to show that stresses in the anchor bolts and adjacent reinforcing rods at the beam-wall support junction are of no concern. These calculations are included in the referenced G & H document (sheets 64-69) and are satisfactory.
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9 4.
The same peak temperatures were used in the upper and lower re-straint beams in the FEM analyses of the. compartment. G & H was asked to estimate the magnitude of stresses that could. be developed in the walls from the small diffarences in temperatures of the two beams that could develop during LOCA and Main Steam Break loadings.
The approximate analyses performed are felt to be reasonable, and the results indicate that the effects of the differential temperatures are small.
CONCLUSIONS Based on the discussions above BNL has arrived at the following conclusions:
1.
The ULRS can satisfactorily support the hig*: thermal loads developed the LOCA and MSLB. Since the other load components are small, the ULR8 is considered satisfactory.
2.
The calculations presented for th,e nonlinear concrete cracking of the Steam Generator Compartment are considered unverified, due to questions arising from the sample problem CA29 output from the modi.
l fied E8ASCO/NASTRAN Code.
3.
8NL has investigated the effects of the ULR8 axial loads developed during MSL8 and it was found that significant shear and moment cracking
!~
will develop in the concrete compartment walls. It is reasonable to expect that significant cracking will occur both to the interal (i.e.,
reactor cavity walls as well as at the outer wall of the 4th compartment.
Some cracking is also expected on the outside compartment walls of the other three compartments.
4 -
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4.
It is our engineering judgement that cracking will be localized around the beam supports and shoula not significantly impair the structural performance of the walls and of the URLB.
'5.
The effects of the wall cracks will be to change the end fixity of of the ULRB to that of simply supported. Based on seismic loads provided by the applicant, the modification-in end conditions will have little impact on the seismic response.
6.
No assessment was made with respect to the effect of the cracks on radiological shielding.
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APPENDIX 1 VERIFICATION PROBLEM CA29 CONCRETE SHEAR FAILURE MODE STUDY Submitted by EBASC0"- November 5,1984 INTRODUCTION This is a continuation of verification probles CA29.
Verifica-tion problem CA29 is a reinforced concrete beam fixed at both ends.
Due to
- symmetry, half of the beam is modelled by two hundred CQDCA elements and forty CROD elements, the latter simu-4 lating the two layer reinforcements (Fig 1).
f The beam is loaded at its center with a series of concentrated loads of 8, 16, 24, and 32 kips.
The dimensions of the beam are a inches wide, 10 inches thick, and 78 inches long.
The follow-ing properties of steel and concrete are used in performing the
~
analysis.
e Concrete te'aile strength = 546 pai Concrete elastic modulus
= 3,800,000 pai Concrete poisson's ratio
= 0.15 Steel elastic modulue
= 30,000,000 pai Brookhaven indicates that this beam should have's ahear failure when the concentrated load is approximately 22 kips.
The ahear failure la exhibited by opening up two'eracks in some of the concrete elements and the vertical beam displacements become very i
large.
- Nowever, from our results. of the analysis performed by the EBS/NASTRAM
- program, this phenomenon la not observed even with concentrated load at 32 kips, e.i.,
no concrete element has two cracks and the beam vertical displacements are still reasonable.
This raises the question of whether the EBS/NASTRAN can c,orrectly predict the sheer failure mode by opening up the second crack in the concrete elements.
By reviewing the theory implemated in the programI, it la deter-mined that tho theory allows the opening of the second crack and can thus predict the sheer failure mode.
Brookhaven concure the correctnese of the theory.
The program has been verified against many experimental data and manually computed
- data, hence the possibility of a coding error in the program is very ame11.
Our review of the coding has indicated no error.
Thus the difference between our results and Brookhaven's may be due to differences in parameters used.
There are three parameters in the program which will affect the ahear failure mode.
The first is the angle limitation on the
- This strength is varied as one of the parps tars in this study.
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1 opening of the second crack.. The,second is the ahear-interlock- '
And the third is the tensile strenk h of the t
con-ing factor.
crete used in the analysia.,
These three parameter are discussed 7
in detail in the followings.
i ANGLE LIMITATION CN THE OPENING OF THE SECOND CRACX In I
The program as developed is intended to be a designhng tool.
dealgning a concrete structure, it is usually assumed that the In order to prevent tensile strength of the concrete la zero.
apurious opening of a second crack and render the nonlinear iteration scheme stable, the progara adopted a criterion that the angle between the first crack and the second crack should be than 31.7 degree.
Otherwise, only one crack is assumed.
. larger This criterion is derived from the rule that the stress parallel stress the first crack is in compression'and the compressive to' the first la assumed tua be larger than the shese stress along crack Case attached notes).
to see whether this criterion will ' affect the ahear In order CA2S was re-ran with the angle limitation criterion failure mode, The results of this run together with the run for which removed.
It is seen criterion is not removed are shown in Table 1.
this limitation that the resulta have no difference whether the anage criterion la removed or not.
e e
SHEAR INTERLOCKING FACTOR
..n th. coner.t. h.s.n. cr.ek, t,e ah.a. stiffn... across the the but does not completely vanish because of crack is reduced, The reduced shear stiffness is interlocking effect of concrete.
stiffness obtained by multiplying the original uncracked sheer The by a constant which is called the shear interlocking factor.
ahear interlocking factor is usually taken to very between 0.2 to The progers has adopted a default sheer interlocking factor 0.4.
of 0.2.
4 has any to see whether the sheer interlocking factor In order effect on the ahear failure mode, CA29 was re-ran with a sheer The results are tabulated in Table factor of 0.4.
interlocking It is seen that the shear interlocking constant of 0.2 givea very close results to those given by the ahear interlocking 1.
constant of 0.4.
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CONCRETE TENSILE STRENGTH The concrete tensile strength originally used in CA29 is 546 pai.
l The opening of the second crack is very much dependent on the concrete tensile strength used in the analysia.
The second crack will open if the diagonal tension obtained from the combined
- effect of the strema parallel to the fira,t crack and the ahear atrams across the first crack is larger than the concrete tensile strength.
~
- In order to see the effect of the concrete tensile strength on the ahear failure mode, three runs have been performed.
The i
first run uses a concrete tensile,strenth of 60 pai and four i
loading cases:
10, 12, 14, and 16 kips..
The beam fails at the i
concentrated load equal to 12 kips.
The failure is e
ahear i-failure mode which is exhibited by very large vertice3 displace-monta.
Most of the concrete elements save two cracks.
The second run uses a concrete tensile strength of 120 pai and four loading cases:
22, 24, 26, and 28 kips.
This time, the beam j
fails at the concentrated load equal to 24 kips.
The third run.
uses a
concrete tensile strength of 180 pai and *four loading cases:
30, 32, 34, and 36 kips.
For this run, the beam fails at the concentrated load equal to 34 kips.
The results of these three run are tabulated in Table 2.
As an e,xample, the crack angles of the ten concrete elements near the fixed and are shown in figure 2.
please note that these crack, angles occur with very large displacements.
Thus the l
example serves only as an indication of how many cracks in the l
l element and their approximate orientation.
I CONCLUSION From above dimeussion, it is seen that the effect of the angle limitation criterion and the value of the shear interlocking constant on the opening of the second crack and the ahear failure is negligible.
The most important parameter in the opening of the second crack
[
is the concrete tensile strength used in the analysia.
Once the l
second crack
- opena, sheer failure follows immediately.
The program pridicts the sheer failure by analyzing the condition in each element.
From a macroscopic point of view, we can ask the question:
what is the ratio of the been nominal sheer streme to the concrete tensile strength which will cause the been to fail in ahear.
The program predicts a value from 1.18 to 1.25 (see l
Table 2),
with the lower value at higher axial streassa.
The*
theoretical value for the simplest case of pure shear la 1.0.
Therefore, the prediction of the program is,in consistant with the conventional beam analyale method.
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From.above discussion, we conclude that the progra=
correctly pridicts the shear failure mode by opening up the second crack in the concrete.
The reason we did not observe the ahear failure in concrete for CA29 is that the concrete tensile strength of 546 pai used in the analysis is higher than the value of,182 mai which will cause the beam to fail at a loading of approximately 34.0 kips.
4
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, TABLE 1.
TNK EFFECT OF ANGLE LIMITATION CRIT'ERION AND SHEAR INTERLOCKING CONSTANT I
RUN LOAD TENSIL ANGLE SHEAR MAXIMUN MAXIHUN NO.
STRENGTN. LIMITATION INTERLOCK.
DISPLACEMENT REINF. STRESS kipa pai CRITERION FACTOR inches kai 3
~
1 32.0 546.0 yes 0.2 0.231 28.57
'.2, 2
32.0 546.0 no.
O 0.231 2a.57 3
32.0 546.0 no 0.4 0.225 28.98 Angle limitation criterions yee means the angle between the first crack and the seccond crack must be larger than 31.7 degree.
No means this angle cien be any value.
TABLE 2
. THE EFFECT OF CONCRETE TENSILE STRENGTN ON SNEAR FAILURE been crose-sectional eroe A = 80 square inches RUM TENSILE FAILURE NOMINAL RATIO NO.
STRENGTN LOAD SNEAR STRESS TAU / FT FT, pai P, kipe TAU =P/A, pai 1
6O.0 12.0 75.0 1.25 2
120.0 24.0 150.0 1.25 3
180.0 3410 212.5 1.18 4
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.o APPENDIX 2 For the case involving the main steam break the maximum compressive load with ends restraint would be i
P = Am (At)E
= 357 x 6.632 x 10-6 X (340 70) x 28,000
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= 17912 kips.
i If the all were perfectly rigid, this would amount to an axial stress fa = P/A =
= 50.17 ksi.
The alloele (Fa) for this beam has been calcualted (See sheet No. 56 attachment to GIM-69363, August 21,1984) to be 45 ksi. Thus, under this assumption the upper lateral beam would not satisfy AISC 1.6-la requirement..
The assumption of completely rigid well is, however, unrealistically conservative. The alls in reality are flexible members and thus will move due to the axial thrust.
In order the assess the safety of the upper lateral support under conservative estimates but without going through a detailed complex model, BNL has performed the following calculations based on the assumptions given below:
(1) Walls at outer surfaces are fixed and are 6 feet thick.
This thickness assianption is based on the fact that only the area adjacent to the beam support is modeled for the analysis.
(2) The axial force due to thermal expansion acts perpen-dicular to the well.
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Page 2 (3) No in-plane displacment is allowed in the walls. This f urther increases their stiffness by a factor "$ "
equal to 1.2 which is caused by the Poisson effect.
The specific calculation are performed in an interative manner as foll ows:
Initial Axial Force P = 17912 kips Assuming conservatively that this force is distributed uniformly at the base plate (area 65" x 66") - well intersection, the compressive stress in the concrete is s=
= 4.175 ksi o
The compressive strength fe' for the concrete is 5.0 ksi. Then, 'e corresponds to (see Fig.1) a uniaxial strain e = 0.00125. Thus the concrete strain (including the Poisson stiffening effect se is.
-n.
1 5 ".001 8e=
c is assumed to be distributed linearly through the walls thickness.
s Tnerefore, the well will yield by an amount 4, given by 4 =.001 x h = 0.036 in.
This will reduce the axial force in the beam by an amount R = 2 4 x A x E L
357
= 0.72 x
[
163
= 4410 kips t
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1 Page 3 Modified Upper Lateral Support Loads The new beam axial force P' = P - R = 17912 - 4410
= 13502 kips, c' = h =3.147 ksi.
and the compressive stress in the concrete o This correspords to a compressive strain e ' = 0.00085/1.2 = 0.00071.
c The wall will thus yield, s' =.00071 x h = 0.0255 in.
357 x Axial force reduction R' = 2 x 0.0255 x 800') = 3124 kips.
Repeating the foove iterative procedure, we finally arrive at a upper 1ateral beae axial force = 14000 kips.
The final axial stress fa is P/A =
= 39.2 ksi. From CL 1.6 - la of AISC manual m by fa/Fa +
+
< 1.0 Y
Y bx by Fa/F = h *1le the other two factor in the above equation are given in sheet No. 60 (attachment to GIN-69363, August 21,1984) as 0.015 and 0.033 respectively. Thus the left hand sum is.918 <1.
i Since the above is obtained by conservative assumptions, it is the BNL opinion that upper lateral restraint beam will satisfy the AISC code require-ments.
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e CASE ATTACHMENT E n
- SIS' REPORT L)-
- CASE EXHIBIT NO.1,035 THE HARTFORD STEAM BOtLER INSPECTION and 1."
'RANCE COMPANY nAmrieomo.coxw ru:t.resa C-044 Tn DATE SHEET OF I^ -Gordon Purdy Q. A. Manager 5/26/83 1
2-i
" Nan;
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H.O./SRANCH OFFICE Marvin Coats. Lead ANI Houston (RGANIZATION Brown & Root. Inc.
LOCATION STREET CITY COUNTY STATE ZIP CODE, CPSES Glen Rose Somervell Texas 76043 PERSON CONTACTED (GIVE NAME AND OFFICIAL TITLE)
CONTRACT /P.O. Nos BS 042007 REASON FOR VISIT 1
Full time contract
- COPIES SENT 70:
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' 1 initiation of NCR's and better as. re that_Q C vill perform final i
inspections on acceptable fabrication. This policy is understandable
'but is not supported by the content of Section 16 of the Q. A. Manual.
'(2) Repair Process Sheets generated to build up' undersize welds are being transmitted to craft with an information copy of the vendor 4
certified drawing.- Even though the RPS virtually stands alone and the drawing serves only to provide location & material information Section 7 of the Q. A. M. specifically precludes use of an uncontrolled drawing for fabrication and installation activities.
(3) Full. fillet'on Class 1 support primary members should be identified in process and not left to be identified during the final walkdown.
'Your proposed action of the above is as follows:
(1) Prepara a Q. A. M. revision for submittal.to the ANIS to provide for policy outlined in item 1 above.
(2)'
R.P.S.'s will be issued with controlled drawing attached.
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(3) Q C I identification of full fillet velds will be proceduralized
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to assure i=plementation.
Your assistance in resolving the above is appreciated.
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CASE ATTACHMENT F
,~llo.
/c4. ///.2 7/W 415 3c -5600 10* Camonut. Strare:. Sune 100C. San Francisco. CA 44111-58N p
November 26,1935 1
84056.095 L
'A Mr. W.G. Counsil Executive Vice President Texas Utilities Generating Company Skyway Tower 400 North Olive Street, L.B. 81 i
Dallos, Texas 75201
Subject:
- Review issues List (RIL)
Texas Utilities Generating Company Comanche Peak Steam Electric Station Independent Assessment Program - All Phases
References:
See Attachment A
Dear Mr. Council:
(
^
, Enclosed are revisions to the mechanical systems, electrical /l&C, cable troy supports, conduit" supports, pipe supports, and design ' control Review issues Lists (RILs).
All significer.1' changes are noted by a revision bor in the right margin. Most of the revisions were mode to provide changes'in accordcyce with information requests made in the open items letters (References 2, 3, 5, and 6) and questions or comments on the CPRT pion (References I and 4). The cable troy supports RIL was also revised to provide clarification and expansion of existing issues. A similar revision is in progress for the pipe stress RlL.
The current revisions to ec* discipline RIL are os follows:
Discipline Revisions Cveno letter reference l
Pipe Stress I
84056.093 Pipe Supports 2
84056.092 Mechonical Systems 3
84056.088 Electrical /l&C 3
84056.090 Cable Troy Supports 12
'84056.094 Conduit Supports 3
84056.094 Design Control 2
84056.085 San Francisco Boston San Diego Chicago Richland
9
=-
Mr. W.G. Counsil November 26,1985 Page 2 If there are any questions please call at your convenience.
Very truly yours, N.H. Williams Project Monoger Attachments cc: Mr. V. Noonan (USNRC) w/ottochments Ms. A. Vietti-Cook (USNRC) w/ottachments Mr. S. Treby (USNRC) w/ottochments Mr. W. Horin (Bishop, Liberman, et al.) w/ottochments Mr. J. Redding (TUGCO) w/ottochments Mr. J. Finneron (T_UGCO) w/ottochments I r[D3igott (Orrick, HerringTol "Sutcliffe) w/ottochments Mr. F. Dougherty (TENERA) w/ottochments Mr. R. Ballard (Gibbs & Hill) w/ottochments Mr. R. Kissinger (TUGCO) w/ottachments Mr. J. Beck (TUGCO) w/ottochments
4 O
11/20/85 Revision 2 Page 18 PIPE SUPPORTS Review Issues List In performing the pipe support design review for Phases 2, 3 Summary:
and 4, Cygna utilized certain engineering standards from.!TT -
Grinnell, NPSI, and PSE when they were referenced in a par-ticular calculation. Cygna did not review all the guide-lines or standards from each organization and has returned those that were used.
i Status:
In order to complete our design process reviews, Cygna requests a controlled copy of the pipe ' support engineering guidelines / standards from ITT Grinnel, NPSI, and PSE.
- 28. Use of A563 Grade A' Nuts With High Strength Bolting
References:
1.
Comunication Report between Rencher (TUGCO) and Minichiello (Cygna) dated 3/16/84, Item _1.
2.
L. M. Poppelwell (TUGCO). letter to N. H. Williams (Cygna) dated 4/19/84, Item 1.
E ASTM specification A563 recomends that Grade A nuts be used l
Summary:
with A307 (low strength) bolting. However, as noted by TUGCO, their' designers, when not using high strength nuts, will specify double nuts, with both nuts snugged. Cygna's scope of review confirmed this statement.
I Status:
This issue'is closed.
b
- 29. Friction Loads
References:
1.
Cygna Phase 3 Final Report, TR-84042-01, Revision 1, Appendix G., Pipe Support Observation PS-08.
f 2.
Juanita Ellis (CASE) letter to Administrative Judge P.B.
l Bloch (ASLB) dated 6/13/85. "Further Clarification of CASE's Position Regarding Applicants' Use of 3 Sm".
Loads due to friction were not included in the support Sunnary:-
design of pipe supports at CPSES when the piping thermal movement was 1/16" or less.
l Open, further TUGC0 response is required. The observation l
. Status:
on the omission of f,-iction loads in pipe support design Texas Utilities Generating Company y
Comanche Peak Steam Electric Station Independent Assessment Program - All Phases
,,.,,,ggggg Job No. 84056 23PS-ISSUE
1 f
~
11/20/85 Revision 2.
Page 19 PIPE SUPPORTS Review Issues List (PS-08) with small thermal movements was previously con-cluded as invalid based on the considerations of industry practice, the TUGC0 sample reanalysis, and the factors of safety available for normal conditions. This conclusion was 4
reached with the due consideration of the 1974 Edition of the ASME Code as the Code of Record. However, the latest edition of the ASME Code--namely, the 1983 Edition, para-graph NF-3121.2--significantly changed the definition of g
primary stress due to constrained free end displacement and appropriate allowable stresses.
(See Table NF-3523 (b)-1.)
The code change has significantly altered some of the tech-nical points upon which Cygna relied to invalidate the observation. Consequently, Cygna requests further response from TUGC0 and considers this issue open.
However, it should be noted that Cygna did review fifteen (15) pipe support calculations within Cygna's Phase 3 and 4 scope, which had negleted the effect of friction load.
Cygna found that all the supports are acceptable with the inclusion of friction loads in combination with the original design loads. However, load changes due to the consideration of Mass Participation effects (Review Issue 5) may affect those conclusions.
- 30. MS-1-003-007-C72K. Revision '10
Reference:
1.
N.H Williams (Cygna) letter to J.B. George (TUGCO),
84056-013 dated 7/31/84. " Pipe Support Review Questions", Question No.10.
2.
L.M. Popplewell (TUGCO) letter to N.H. Williams (Cygna),
dated 8/30/84.
3.
L.M. Popplewell (TUGCO) letter to N.H. Williams (Cygna),
dated 9/17/84 4.
Communications Report between Van Amerogen/Rencher/
l Ker11n (TUGCO) and Minichiello (Cygna) dated 9/11/84.
Item No. 1.
Sunnary:
Due to insufficient dimensioning in the subject drawing (Section J-J), Cygna has concerns about the design of the connection and particularly about the plate stresses of Texas Utilities Generating Company Comanche Peak Steam Electric Station g
[
Independent Assessment Program - All Phases l
, giggisiig Job No. 84056 23PS-ISSUE L