ML20210A755

Requests Appropriate Action Be Taken to Address Case Concern of Potential Misleading Statement by Applicant Re Aws/Asme Weld Design

ML20210A755
Person / Time
Site:	Comanche Peak
Issue date:	03/29/1985
From:	Terao D NRC
To:	Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
Shared Package
ML20210A760	List: ML20210A755 ML20210A763 ML20210A768 ML20210G854
References
FOIA-85-614 NUDOCS 8512310057
Download: ML20210A755 (12)

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UNITED STATES 8

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e MAR 2 91985 NOTE TO: Vincent S. Noonan, Project Director, CPSES FROM:

David Terao, MEB, DE

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SUBJECT:

POTENTIAL MISLEADING STATEMENT BY APPLICANT REGARDING AWS/ASME WELD DESIGN On April 15, 1984, the Applicants filed its " Motion for Sumary Disposition of Certain Case Allegations Regarding AWS and ASME Code Provisions Related to Welding." One of the issues in the motion addressed Case's allegation that the ASME Code did not take into consideration the provision of the AWS Code related to multiplication factors and reduction factors for skewed T-weld joints. The Applicants asserted that there was no genuine issue of material fact because "while the ASME Code does not have explicit requirements governing this area, compensatory requirements have provided assurance of acceptable load carrying capacity."

The Applicant referenced Appendix XVII paragraph 2211 (c) of the 1974 ASME Code Section III as the compensatory requirement. This paragraph required that the T-joint basemetal through-thickness allowable tensile stress be limited to one;-half the normal tensile allowable. The Ap'plicant also provided calculations which demonstrated that the load limitations using the ASME Code requirement in Appendix XVII paragraph 2211(c) was more restrictive than the AWS provision.

The requirements of Appendix XVII-2211(c) are related to lamellar tearing in the base metal. Although the Code intent was to limit the through-thickness allowable tensile strdss of the base metal, the requirement was found to be counter-productive because it resulted in excessively large welds which were susceptible to cracking. As a result, the requirements of Appendix XVII-2211(c) were subsequently deleted in the Winter 1978 Addenda to the ASME code.

In the Winter 1983 Addenda, paragraph NF-4440 was added to address the concerns of lamellar tearing.

In a meeting with the Applicants held on June 8,1984, the staff asked the Applicant whether the Applicant had taken advantage of the later addenda which removed the requirement of Appendix XVII-2211(c) (Transcript page 100/line 11 through p' age 101/line 8). The Applicant stated that they are currently taking advantage of the later edition.

In a meeting between intervenor, Case, and the NRC staff held on March 23, 1985, Case requested that the staff review the Applicant's statement described above for the implications of being a misleading statement.

It is, therefore, requested that appropriate action be taken to address Case's concern. To date, the staff has addressed only the technical issues involved with this motion for summary disposition but has not addressed the potential for the Applicant's submittal being a misleading statement.

xa 3[h Mech n ca Engineering Branch, DE cc: See Page 2.

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I FRON: ENERGY TECHNOLOGY ENGINEERING CENTER, CANOGA PARK CA bl Mu/

PHONE EXTENSION __

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TELEC0 PIER NO.:

(213)700-5118&700-5341 YERIFY: 700-5191 P-WHEN TRANSHITTING TO THE ETEC PLEASE NOTE:

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0UR MACHINES ARE IEROX 410 AUTOMATIC, PLEASE SEND AT YOUR 6 MIN /PAGE SETTING.

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1 Memorandum For:

Vincent 5. Roonan, Ofrector i

Comanche Peak Project From:

W. Paul Chen

Subject:

CPSES - Assessment of 4 parent Omissions in S plictat's Motion for Sunnary 0isposition Aegardiog C1nched Down U-Bolts

[ Peak - Alleged Material False Statements and Q

References:

Vincent 5. noonan to Richard C. DeYoung.

• Comanche 8y Applicants," Aovember 26, 1984.

Spitcant's Mstton for Summary Ofsposition of CASE's Allegations Aegarding Cinching Down'of U-8cits

.kne 29, 1984.

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[ Aegarding Ctaching Down of U-Bolts, ihne Affidavit of Aobert C. Iotti and John C. Finneran Jr.

29, 1984.

4plicants' Statement of Material Facts As To Witch There Is As Genuine Issue Aegarding Consideration of Cfnching U-8olts, ihne 29, 1984

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CASE's Motions and CASE's Answer to App 1fcant's Response to Soard Atquest for Information Aegarding

, Cfaching Coun U-Golts. Aovember 5.'1984.

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CASE's haswer to Applicants' Response to Soard Aequest l

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for Information Aegarding Cinching Opun U-8cits in the Form of Affidavit of CASE Witness Jack Doyle, Aovember 5.1984.

App 11 cants

• Response to Soard AeWest for Information Regarding Cinching Down U-8cits. October 23, 1984 App 1feant's Response to Board Aequest for Aan Data Regarding Cfnching Down U-Bolts November 9, 1984.

i Affidavit of John C. Finneran Jr. Regarding Information Relatad to Cinching Down of U-Bolts, November 9,1984.

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ASL5MemorandusandOrder(InformationConcerning Torques in U-Bolts). October 16, 1984.

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ASLBMenorandumandOrder(AawDataonU-Solts).

October 24, 1984 Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design), February,3.1984.

Supplement to Applicants' Plan to Respond to Memorandum, and Order (Quality Assurance for Destyi), March 13, 1964.

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ASL8 Memorandum and Order (Quality Assurance for i

Design). December 28, 1983.

i 15.

ASLB Memorandum and Order (Reopening Discovery,' Mis-leadfag Statement) A5L8P no.79-430

• OL, December 18.

1 1964.

16.

TUEC Motion for Reconsideration of Licensing Boards' Memorandum (Reopening Discovery; Misleading Statement).

January 7,1985 (mis dated January 7,1964).

17.

Affidavit of Robert C. Iotti and Jahrt C. Finnerap*Jr.

Regarding the Licenshg Board's December 18, 1984 Manorandian, January 7,1985.

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.18.

App 1tcants' Aeply to CASE's Motion Concerning Informa-1 tion Regarding Cinching Down U-8alts, movember 19, 1984.

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Affidavit of John C. Finneran Jr. engarding CASE's i

htton Concerning Sampling of Cinched Opun U-8olts, hvassber 19,1984.

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0IE was requested in Reference I to consider whether an apparent significant omissian of material information in Applicants' notion for sminary disposition and associated affidavit and statement of material facts regarding cinched U-bolts in pipe supports (References 2, 3, and 4) constituted a "materfa1 false F

statement *. The apparent caission related to Applicants' failure to disclose the fact that the

• randomly selected representative sample of cinched down U-i i

t bolt supports' utilized in Applicants' determination of *the range of torques yin U-bolts) which exists in the field' was Ifsited to thit 2 U-bolt supports.

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(t See CASE's motions and answer (Referenes 5 and 6) to Applicants' responses a

References 7, 8, and 9) to the CPSES ASLB ammoranda regarding U-bolt torque data (References 10 and 11)). ' Subsequently, you requested that an assessment be made of the tapact of the apparent omission on Appfcants' representations in their untion'for summary disposition. Results of the assessment are rep yted below.

Applicants' etion.for sumary disposition was subettted as part of their plan (References 12 and 13) to respond to the ASL5 desfyl QA memorandtas (Reference

14) regarding the adequacy of the design of the CPSES plant. Specifically, Applicants' motion for sumsary disposition was intended to provide evidence e

that their design and constructfon practice for snubber or strut type pipe

'suppo t which incorporated a cinched down U-bolt in its design were adequate r

I u address CASL's concerns expressed during the CPSES ASL8 OL l

ICASE witnesses Messrs. M. A. Walsh 'and J. Doyle were concerned that:

I (1) stresses induced in U-bolts in the type of supports of concern and the I

supported piping due to U-bolt cinching were not included in the U-bolt and pipe stress analysts, respectively; and (2) loosening of cinched down U bolts due to nonrecoverable plastic deformations resulting from thermal cycifng L

would render the pipe supports unstable (the U-bolt assembly would rotate O

around the pipe) thereby invalfdating the pipe stress analysis.

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l 3-l hearings (Reference 2, p. 4). Evidence was to be obtained by Applicants testing and analysis programs regarding which Applicants state that "to assure that the tests and analyses accurately represent plant conditions, # plicants conducted a sarvey of the torque on a representative sample of cinched down U-bolts * (Reference 2, p. 5). Results of the survey were stammarized in Table 2 of Applicants' affidavit which listed

• torque ranges' for 160 U-botts in supportsfor17pipesizesvaryingbetween3/4inchand40 inches (Reference 3, Table 2).

Subsequently, It was determined that the " torque ranges' were based on the average of the torques in the two legs of the U-bolts provided by Applicants in Reference 7.

(The raw data on which the average torques were based were submitted by Applicants to the ASL8 in Reference 8.)

6fith respect to Applicants' characterfzation that their U-bolt pipe support j

t s aple was " randomly selected" and " representative", a review the data t

provided by Applicants in Reference 7 confirmed CASE's observations in References 5 and 6 that: (1) all the U-bolt supports in Applicants' sample I,

were imit 2 supports; (2) of the 160 supports in the sample, 52 were non-safety related;.and (3) of the 160 supports in the sample 36 were for pipe sizes 3 inches and under.

The review also found in agrement with ASLB memorandum regarding reopening discovery and misleading statment (Reference

15) that there was "no method of drawing a randos or representative sample".

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Applicants stated in their raw data affidavit (Reference 9, pp. 2 3) that:

The field inspections during which the data were collected were conducted by 3 pSE engineers, m ile no fonmal proce-dures for the inspection were written, the three engineers were given verbal instructions as to what they were to do.

The instructions were to measure and record the torque of both nuts on any cinched down U-bolts that could be found in Unit (2) that were unpainted...Each leg of the U-bolt was checked where accessible.

Applicants further stated in their motion for reconsideration of ASLB Reference 15 memorandum (Reference 16, p. 8) that:

f Wile Applicants did provide detaf fef verbal instructions to i

the individuals collecting the data on the approximately 160 U-bolts checked...... Applicants did not perform a detailed statistical evaluation and analysis.

Based on the preceding CASE observations and Applicants' statments, it was concluded that Applicants' U-bolt pipe support sample was neigher randomly selected nor representative in a statistically sagling sense.

2 Applicants argue in their reconsideratfon motion (Reference 16, Page 9) that:

Given the purpose of the sampling...(to obtain an indication of the range of torques in the field in order to reasonthly i

set some parameters for the U-bolt test program), such detailed (statistical) evaluations were not wided or warranted.

However, I would offer that if the torgse values obtained in App 11 cants' survey were to their favor. Applicants would have attempted a statistical i

evaluation.

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4-Additionally, since Appitcants' action for suusary disposition was intended to provide evidence that their design and construction practice for cinched down U-bolts in pipe supports was adequate to address CASE's concerns related to the ability of these supports to perform satisfactorily in service, the i

question of the appitcability of the requirements of criterion XI to Applicants' sampling of U-bolt torque arises. This question should be--

referred to OELO for resolution.

i With~ respect to the ASL5 ruf fng (Reference 15, pp.1-2) that Applicants' testimony was sisleading. reflected adversely on Applicants' expert witnesses and was cause for reopening discovery, the following apparent inconsistencies were observed during the assessment:

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First. Applicants' state in their ution for sumary disposition (Reference 2,

p. 5) that:.

None of CASE's four concerns raises an issue that reflects a i

l breakdown in Applicants' Quality Assurance (*QA") Progras or a safety concern in the plant.

i However. Applicants' statement in their motion for suusary disposition (Reference 2.p.11)that:

To provide further assurance of acceptable preload values.

Applicants' will conduct a 100 percent inspection of all cinched down U-bolts on struts or sawbbers (a total of 380)...At the ttee of the inspections, to remove questions regarding stability, Appifcant's will assure that each such U-bolt is torqued to a level at d ich the assembly will be stable in the absolute truest sense, i.e.. no rotation, and l

axial action, if any, is toward the strut.

suggests that Appifcants' 100 percent reinspection program was an acknowledge-2 ment of the validity of CASE's concern regarding stability.

Furthennore, Applicants' statements in their reconsideration motion (Aefer-ences16p.7)that:

From the wide range of torque valves obtained and reported in our Ane 29;1984 motion for summary judgment, it (was) obvious that the torqueing practice had not resulted in a narrow range of values.

and that:

l In short, the torque sample...was not reported to demon-strate that work in the field ru acceptable or that no addf-tional work needed to be done.

j and th'at:

The results of the testing program and finite element analyses were ultimately used to detemine and provide assurance of the acceptabfif ty of the torque values to be used in retorque-i ing.

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together with the prev fously quoted objective of the 100 percent inspection program also suggests that Spifcants' were acknowledging a deficiency in their design and construction process related to a safety concern.

Second Spiteants state in their action for samary disposition (Reference 2,

p. 5) that:

In that the tests (and corresponding finite element analysis)--

rely on assmations regarding the torque appifed to U-bolts in the plant, to assure that the tests and analyses accurately i

represent plant conditions, Appifcants conducted a survey of the torque on a representative sample of cinched down U-bolts.

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However, a comparison of the observed range of torque values in U-bolts in the plant reported in Table 2 of App 1tcants' U bolt affidavit (Refere with the range of' torque values utilized in the test and analysis programs s that the range of torque values in the test and analysis program did not se reflect the range of torque values observed in the plant. Contrary to i

i Applicants' stated purpose for conducting the survey, the range of torque values utilized in the test and analysis program were utilized to determine a range of torque values which would be acceptable from a stability and U-bolt Ioad and pipe stress point of view.

In addition to the above apparent inconsistencies the folleming additional concerns were raised durfng the review of the range of torque values in U-bolts in the plant.

i, 3

First, in ~ view of the substantiation of CASE's concern regarding uncinched i

r down U-bolts in safety related pipe supports and Splicants' statement in theirReference18replytoCASE'snotionandanswer(Reference 18,p.6) that:

i All cinched down U-bolts at CPSES (safety related and non-safety related) are identical in make and manufacture and were torque using the same construction practice, the torque on non-safety related U-bolts are representative of the torque on safety-related U-bolts.

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would tely that CASE's concern would also extend to cinched down U-bolts in non-safety related pipe supports.

Second, the range of torques reported by 4 pifcants.In Table 2 of their Reference 3 affidayit in small-bore piping (less than 4 inches in diameter) together with tiie preceding concern raises concern regarding etnched down U-bolts in both safety related and non-safety related pipe supports.

Third, the num6er of pipe supports affected by 4p11 cants' action for summary disposition is much larger than the 380 supports referenced in their motion (Reference 2 p.11).

related supports designed with a single snubber or strut.The 380 supports rtfere i

i The concerns relating to cinched down U-bolts relate to all type of pipe support incorporating such bolts in their design (e.g., trapeze type supports with two snubbers or struts).

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6 The above inconsistencies and concerns notwithstanding, the raw data for the torques in the U. bolts (References 8 and j) served to identify the inadequacy of Applicants' U-bolt torqueing procedure. The data indicated that: (1) for each pipe size, the torques in the U bolts in the plant varied over a wide range, (2) some torques were below the torque values Applicants' claimed were necessary to assure stability of the supports in the " truest sense" and (3) in most cases, the torques in the legs of the U-bolts were unequal, hwever, as stated previously. Applicants' have consitted to a 100 mercent inspection program of U-bolts installed in the plant during which Applicants " wit! assume that each U-bolt is torqued to a level at sich the U bolt (support) will be stable in the absolute truest sense" (Reference 2 -p.11 and Reference 3, pp.

34-35).

Applicants' claim that torque values for such assurance were to be determined by their test and analysis program (Reference 3, p. 73). In view of Splicants' 100 percent inspection program, the question of whether or not Applicants' W. bolt sample was

• randomly selected" and

• representative" is of no technical consequence. Staff review and acceptance of App 1tcants' proposed 100 percent inspection torque values is contingent on final resolution cf outstanding technical issues related to Appitcants' notion of summary disposition and related submittals (References 2, 3 and 4),

W. P. Chen E

6 i

r 3CASE and the Board have raised a question regarding possible differences in torques in U-bolts (Raference 5, p.6, Reference 6, p. 4 and Reference 15 pp.3-

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4) was a result of Applicants' adoption of their October 8,1982 U bolt torqueing procedure (See Reference 3. pp. 9-10). bwever, Applicants' saintain that their October 8,1982 torqueing procedure did not affect the torques in l

U-bolts.

Applicants' clate that their October 8,1982 procedure documented their construction practice (Reference 18 pp. 7 4, Reference 19, pp.12, i

f Reference 16, pp.11-12 and Reference 17, pp. 3 4.

Applicants' claim has not Y

been verified but is not pertinent to the discussion.

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